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STATE
OF Harry
R. Welty, Dean
Davidson, Robert D. Sershon,
Court File No. 69DU-CV-09-758 and
Art Johnston, Plaintiffs, v.
Defendants. ANSWERS TO DEFENDANT JOHNSON CONTROLS,
INC.’S INTERROGATORIES TO PLAINTIFF HARRY R. WELTY (SET I)
The
plaintiff Harry R. Welty answers set I of Defendant Johnson Controls, Inc.’s
interrogatories as follows: Interrogatory No. 1:
Identify all Persons you believe have knowledge of any fact that is
relevant to the claims or defenses in this litigation, and for each such person,
describe in detail the knowledge you believe such person has. Answer: It is my belief that a great many people have some knowledge of at
least a few facts relevant to this litigation. They would include any of a dozen
or more Duluth School District administrators and employees and probably at
least the same number, if not more, employees of Johnson Controls Inc. employed
at the time of the consummation of, or subsequent to, the contract in question.
As I know a great many of the District’s employees from my eight year service
on the School Board I am aware of the role they play in District operations
which might give them access to this knowledge. In addition some members of the Duluth School Board should have been
privy to details of the negotiations between The most knowledgeable District employees would include Supt. Keith
Dixon, Bill Hanson and Kerry Leider followed by Patrick Devlin in Purchasing,
and Jody LeBlanc who currently oversees District finances. Two School principals
who were drawing their salary from a federal grant for healthy schools while
working in cooperation with Johnson Controls and who, I’ve been led to
believe, subsequently went to work for Among other administrators and secretarial staff that might have had
an inside view of the contract’s development would be Bill Westholm, formerly
the Assistant Superintendent in charge of school operations and his successor
Joe Hill who succeeded Mr. Westholm after the contract’s development. Ron
Soberg, the District’s lobbyist would likely have been consulted relative to
the statutory authority permitting the contract’s initiation. The
Superintendent’s Secretary’s Judy Maki and Bill Hanson’s secretary Melinda
Thibault would have some knowledge of the negotiations as they would have kept
track of the scheduling and perhaps the agendas of meetings. The District’s
Public Relations director Katie Kaufman who has an office adjacent to the
Superintendent and who has taken a leading role in defending the District’s
actions and criticism of the LTFP. To do this effectively she would need to have
some knowledge of the process that brought it about in order to answer questions
addressed to the Superintendent by the public and the press. Mr. Leider’s facilities management staff likely learned details of the contract negotiations as they would have been consulted about the condition of the District’s many facilities. These would include Dave Spooner and possibly John. Hoban who is in charge of district-wide maintenance. While a similar number of Johnson Controls employees may also have
played some part in the development of the contract I have only met one of them
to my knowledge, Jeff Schiltz, but only to exchange pleasantries. Additionally, a number of attorneys were consulted during this
process and one of them Mark Knudson (spelling) was in charge of drafting the
contract on behalf of the I have been asked to detail the particular knowledge that each
person has and for this I must confess that common sense and speculation are my
guide. The District has not been forthcoming in providing background information
which would make the contract negotiation process more transparent but I presume
that each of the people I’ve mentioned, by virtue of their position within Interrogatory No. 2:
Identify all Persons you believe have knowledge of Answer: To answer this question I would refer the court to my answer to the
first interrogatory as the list of Persons and the knowledge they might be privy
to would be virtually identical.. Interrogatory No. 3:
Identify and describe in detail any and all Communications and Meetings
you have had with any School Board member (including but not limited to Gary
Glass), Answer: The last one-on-one meeting I recall having with any school board
member other than Gary Glass would probably have taken place over two years ago.
I recall driving home from Gary Glass’s home with Tim Grover about the time
Mr. Glass was elected to the Board and that is the last such meeting I recall. I
also met with Mary Cameron, and Nancy Nilsen and explain the circumstances of
those meetings in my answer to Interogatory No 25. I
do not recall speaking with them specifically
about any issues relating to our current litigation on those occasions. I attended many meetings with Tim Grover for about a year in
connection with Let Duluth Vote. Because Mr. Grover made it clear that he was
strongly opposed to any litigation related to the development of the Red Plan
the issues listed in this interrogatory were rarely part of our discussions. I do recall teasing Tim about a comment he had made to Gary Glass
when Mr. Glass showed Tim the contract between I have not sent an email to a Board member other than Gary Glass for
over a year and rarely did so before that time. None of these emails to Board
members, other than Mr. Glass, ever covered details listed in this
interrogatory. I have never met with any school district employee to discuss any of
these issues for fear of putting their jobs at risk. Neither have I sent any of
them any email that I can recall. I have written unflattering things about Kerry
Leider in my blog related to the Red Plan some of them based on affidavits found
in our pleadings. A short time after posting my criticisms I talked with Mr.
Leider at a School Board meeting and told him I did not hold him responsible for
the Red Plan’s defects but regarded him merely as its “messenger.” He
seemed grateful to hear me say this. This was one of a number of School Board meetings I have attended
with School Board members and on some occasions I’ve addressed the school
board in the public comment portion of their meetings but these were not
“meetings” in the sense implied by this question. I’ve not met with any Other than the unofficial meetings of Let Duluth Vote I’ve often
met with Gary Glass to discuss the Red Plan. These one-on-one meetings have
rarely been scheduled far in advance and so rarely appear on my calendar thus
unless I mentioned them in my blog it would be difficult to reconstruct their
timing or specific subject matter. I was aware in the summer or fall of 2007 that Mr. Glass had
acquired the actual contract between the District and At some point I believe Mr. Glass showed me a copy of contract and
perhaps he even gave me a copy. I do not recall if I read it in full. If I did I
certainly did not fully comprehend it. I do recall a long conversation with Mr.
Glass about a provision in the contract that gave I am aware of at least three requests to the District for some of
this data each of which the District denied. Our request for discovery in this
suit seems be a fourth such instance of the difficulty common citizens have in
reviewing this data.
Interrogatory No. 4:
Identify and describe in detail
any and all Statements in your possession or that you are aware of referring to
or related to the RFP; the Response; the Agreement; the Resolution; or any
issues related to the subject matter of this litigation. Answer: Most of the primary statements you wish me to identify can be found
in the pleadings we have presented to the Sixth District Court. A few other
related documents that I consider significant I’ve uploaded to the website www.letduluthvote.com.
These documents include portions of the Review and Comment on the
Red Plan presented to the Minnesota Department of Education. They include a
document given to the District by its financial advisor Northern Securities
showing the timing and cost of bonds needed to finance the Red Plan.
To the best of my knowledge I have never removed any of these documents
from the www.letduluthvote website after
uploading them and they are all available for viewing by anyone who is able to
connect to the Internet. They could also be printed out. I also have copies of two letters I obtained from the taxpayer’s
attorney, Craig Hunter, at least one of which was written by Kerry Leider. I
believe both of them were composed in 2007 and discuss the District’s work
with There may be other such documents in my possession but I do not
presently recall what they might be. If I have not already posted them to the
Internet its probably because I did not consider them to be of central
importance. Interrogatory No. 5:
Identify all Persons you
believe have knowledge of the Answer: All school board members are responsible for enforcing school policy
as they and their predecessors are the guardians and authors of the policy. Whether they understand or follow these policies or not all District
employees are expected to adhere to the policies and failure to do so is grounds
for termination. The responsibility for procurement falls primarily on the
business office and its purchasing department. The District’s chief purchasing
agent is Patrick Devlin. Mr. Devlin’s name is currently being listed on all
the District’s advertisements for bids on all Red Plan construction. The adds
direct venders to send their bids to his office. I believe, however, that this
is simply a matter of protocol and that Mr. Devlin is only tangentially involved
with drawing up or evaluating these bids. I base this assumption on a discussion
he had with a school board member about the RFP on When I served on the School Board there were two purchasing agents
who drew up the I deduce from this long ago conversation that the extremely
demanding work of drawing up detailed construction bids for the Red Plan would
be more than Mr. Devlin could handle. Additionally, I do not believe any Until a few years ago the Interrogatory No. 6:
Identify all Persons you
believe have knowledge of the Answer: The principle Persons would include Supt. Keith Dixon, Bill Hanson,
Kerry Leider and those individuals who served on the committee to select a
company to develop the Long Term Facilities Plan. Interrogatory No. 7:
Identify all Persons you
believe had knowledge of Answer: Certainly the two Interrogatory No. 8:
Identify all Persons you
believe had knowledge of the negotiation and execution of the Agreement, and for
each such person, describe in detail the knowledge you believe such person has. Answer: I have listed these individuals previously. They would include Supt.
Keith Dixon, Bill Hanson, Kerry Leider and possibly Patrick Devlin the
purchasing agent who had many years of experience drawing up RFP’s for the
District. It would also include employees of As for the “execution” of the agreement I’m uncertain if this refers to the adoption of the agreement by the School Board or the use made of the agreement in the implementation of the Red Plan. In either case I believe I’ve outlined the likely Persons who played a part. Interrogatory No. 9:
Identify all Persons you
believe have knowledge of the School Board’s adoption of the Resolution, and
for each such person, describe in detail the knowledge you believe such person
has. Answer: I would ordinarily list the School Board members themselves as
Persons who would have had knowledge of the adoption of this contract because in
my experience as a school board member all contracts were presented in their
entirety to the School board at official school board meetings prior to approval
by the Board. This was not the process followed in adopting the When Board members Tim Grover and Laura Condon were shown the
contract by Gary Glass they both expressed some surprise. Tim explained to Based on correspondence sent to the Board by Supt. Dixon and
Facilities Management Director Kerry Leider I presume they were familiar with
the contract’s language if not all the implications of the language. Indeed, the vehemence of the District in denying Johnson Controls’
future earnings suggests either that some District administrators did not fully
understand the contract’s language or worse that they lied to conceal it. I have been told by Sarah Horner, the education
reporter of the Duluth News Tribune that Kerry Leider told her that he
never told Mr. Glass that It is not simply Kerry Leider who has denied the compensation
spelled out in the Contract. Many people that I’ve talked to have told me that
Supt. Keith Dixon repeatedly assured the public at school district presentations
that If these stories are true it strongly suggests either a lack of
knowledge about contract’s details or an unwillingness to admit the truth. I
do not know which explanation is more likely. There is a simple alternative explanation. Gary Glass may be
mistaken or could be telling a lie. As I’ve considered this I could never
think of a reason why Mr. Glass would invent such story and to spread on the
front page of the local newspaper only to suffer the abuse which was heaped upon
him afterward. Any doubts I may have had regarding Mr. Glass’s veracity were
laid to rest the moment I myself reviewed the documents that we have now
presented as affidavits to the Sixth District Court. Interrogatory No. 10:
Describe in detail the factual
basis of your assertion in Paragraph 14 of your Complaint that “the amount yet
to be spent on the red plan is hundreds of millions of dollars.” Answer: Our complaint simply restates the information provided to the public
by the A succession of news stories in the Duluth News Tribune with
accompanying graphs have confirmed this information. It was recently presented
by the Chamber of Commerce when they released the results of an economic study
they commissioned to show the multiplier effect anticipated from the Red Plan
construction spending. Without reviewing the report’s figures I recall them to have shown
approximately $10 million in spending for 2008; $58 million for 2009 and $100
million to $128 million for the two succeeding years. The Red Plan has been
estimated to cost $293 million thus $220 million in Red Plan spending lies ahead
in future years. The word “two” in twohundredtwentyeight justifies the use
of the plural “millions” in describing future Red Plan spending. Interrogatory No. 11:
Describe in detail the factual
basis of your assertion in Paragraph 14 of you Complaint that “the fees yet to
be generated to Johnson Controls for professional services related to the “red
plan”, may run to tens of millions of dollars.” Answer: The affidavits presented to the Interrogatory No. 12:
Identify and describe in detail
any and all Documents or Statements in your possess or that you are aware of
related to the RFP; the School District’s selection process and criteria with
respect to the RFP; the School District’s selection of Answer: In addition to the documents mentioned in my answer to Interrogatory
No. 4, I have a number of documents about the Red Plan printed for public
consumption by the Interrogatory No. 13:
Identify any and all Documents,
Communications, and Statements dated January 1, 2005 to present, in which
you have expressed your opinions regarding the School District, the
School Board; individual School Board members, the RFP; Answer: I have written these opinions in several venues since Another source of my writing on these subjects is the website: www.letduluthvote.com.
This is a site of my creation and organization – such as it is. I have
uploaded documents to this website that I am not the author of but most of the
presentations and writing in this site are mine. While I occasionally update the
information in this website most of the pages I’ve put on it have undergone
few changes from the time I first uploaded them. The main page does change
frequently mostly by the addition of new items near the top of the page and
removing items which are out date. Rather than completely erase these obsolete
items I frequently put them on pages that are described as “archives.” My blog is roughly analogous to a diary. While each separate post
could be considered a document in and of itself, like a daily entry in a diary,
the blog as a whole could be viewed as something akin to a diary, making it a
single document as well as a collection of separate documents. I have also been a regular contributor to a column in a local
tabloid called the Reader Weekly where I’ve often written a column every other
week. I would guess that over the past two years I’ve written about 15 columns
on these subjects including a series I described as a history of the development
of the Red Plan. That history, however, did not dwell on the issues referred to
in these interrogatories but rather on the situation leading up to the hiring of
Dr. Dixon by the Duluth School Board. I believe that I have posted all of these columns on a much older
website of mine, whose creation dates back to 1999. The website is: www.snowbizz.com
and can be found in a section called “Diogenes.” I have also exchanged a multitude of emails relating to these issues
over the course of two years. Because my home computer has had some technical
problems most of the emails prior to about a year ago have been lost. Some
emails this age or older do remain on a remote server. I recently did a rough estimate of the number of words I’ve
expended to write about these and other Red Plan related issues and concluded
that my public writings alone could exceed three quarters of a million words. In
the single month of July of this year I “published” over 30,000 words on my
blog alone. Interrogatory No. 14:
Identify and describe all
activities in which you have participated in addition to this lawsuit to oppose
to the RFP; the Agreement; the Resolution; or the “red plan.” Answer: I began my “activities” two years ago when I was embarrassed by
Bob Boone, the publisher of a local tabloid the Reader Weekly, into writing a
column about the Red Plan. Although I had no interest in returning my gaze to
the School District Mr. Boone told me that as a former eight year member of the
School Board I had an obligation to the community to share my thoughts. I began
that first column by saying that the Red Plan might be the best plan in the
world but without a public vote it was wrong. That column led to my meeting with other people who wanted a
referendum and people who opposed the Red Plan and people who resented the
process by which the Plan was brought to life. In addition to the writing and publishing I’ve done to insure a
public vote I took the lead in forming the organization called, “Let Duluth
Vote.” I helped circulate two petitions the first of which asked the School
Board to hold a referendum. When the Board rejected that petition I lobbied the Minnesota
Department of Education to reject the District’s Review and Comment on the Red
Plan. When I learned from the MDE that a new school board had the right to
set aside all contracts signed to construct the Red Plan for a one year period I
ran for the School Board hoping to give it a new majority which would assure a
public referendum. When I failed to win election I helped draft a second petition which
the Minnesota Department of Education assured me would require the After many months passed I concluded that the District had no
intention of allowing the Plan B alternative to be put on the ballot. I then
began raising money for a legal challenge of the Red Plan. I helped disseminate
requests for proposals to law firms asking them if they could present a sound
legal theory that would, should it prevail, put an end to the Red Plan. While I
had in mind a challenge on the loss of our voting rights I made clear in the Let
Duluth Vote RFP that any legal theory that had a serious chance of derailing the
Red Plan would be considered. To my surprise such a theory was presented
challenging the lawfulness of the contract. I have also had some presence with other groups who have challenged
the Red Plan. They include some laison work between Let Duluth Vote and
attorneys who were working with homeowners in the Lester Park neighborhood who
feared being evicted from their homes by eminent domain. At one point I wrote a
personal check to one of these attorneys for his work when I could not persuade
Let Duluth Vote to expend the money. I have also offered advice to homeowners in the Ordean neighborhood
who object to the construction of a high school on the small property where the
current I became one of the taxpayers in this suit brought before the Sixth
Judicial District and when the Court set a $100,000 bond I contributed $20,000
myself to the bond and worked to raise the other $80,000 to protect the
taxpayers from the theoretical costs a construction delay would cause. I have also contacted potential candidates for the next school board
campaign and I intend to help them win election this November in order to change
the majority on the School Board and so guarantee a referendum on the Red Plan
or a suitable and less expensive alternative. In addition I intend to write a book about the politics and fight
against the Red Plan so that future generations will not forget what has
happened here in This seems to be a relatively complete list of my actions over the
past two years but it is probably not absolutely complete. Interrogatory No. 15:
Describe in detail the “Let
Duluth Vote” campaign, including but not limited to the date the campaign was
established; the Persons who established the campaign; any and all Persons who
have held positions within the campaign; any and all Persons who currently hold
positions within the campaign; the date the website www.letduluthvote.com
was established; any and all Persons who update material on the website www.letduluthvote.com;
any and all activities in which the campaign participates; and any and all
efforts and activities in which the “Let Duluth Vote campaign has participated
in opposition to the RFP; the Agreement; or the Resolution. Answer: As this court knows Let Duluth Vote has no legal standing. It is not
incorporated and consists of whoever wishes to participate in it at any given
time. Let Duluth Vote has no “official” officers but it does have
someone who acts a treasurer, by virtue of her handling the organization’s
bank account. Her name is Shirley Evensen. To date over 2,000 The organization’s actions closely mirror my own. It has at my
insistence refrained from taking any stands on candidates or ballot questions
because this would require it to file campaign finance reports. Its sole purpose
is to return the right to vote to citizens of the The first meetings were held in the summer or fall of 2007. Let
Duluth Vote has generally held weekly meetings attended typically by 20 to 25
people over the past year. There is one other significant activity that I did not mention in
interrogatory 14, the development of an alternative to the Red Plan called Plan
B. I did not list it in that interrogatory because I’ve only played a small
role in its creation. This was first proposed by Tim Grover in January of 2008.
I favored a different proposal, one that would give the public a chance to vote
on something very similar to the Red Plan, but financed completely by bonds
rather than lease levy purchase agreements. Tim and I debated the merits of our
two proposals at a Let Duluth Vote meeting and Tim’s petition language
narrowly won. It’s the basis of the current Plan B that is being roundly
criticized by Mr. Grover and other Board members now. In Fall or December of 2008 a small group of people, architects,
engineers and Let Duluth Vote leaders got together to flesh out the spare 75
words of the Plan B petition in preparation to developing a Review and Comment.
I attended a few of these meetings but was primarily interested and responsible
for some of the other activities I described in Interrogatory 14.
This activity foundered when, for the following year, it became evident
that the District had no intention of allowing the petition language to be drawn
up into a review and comment document for presentation to the Minnesota
Department of Education. When the District changed course in the late spring of
2009 and indicated a willingness, even an eagerness, to draw up a review and
comment document by hiring an Architectural firm to do the work several leaders
of Let Duluth Vote actively worked with the Architectural firm Let Duluth Vote has also taken the lead in raising the money to hire
an attorney to challenge the Red Plan and in raising the $100,000 bond to
protect the five taxpayer/plaintiffs financially should their suit fail. I would be unable to list all the people who have attended meetings
of Let Duluth Vote over the past two years. The closest to a title might be the
honorific “spokesman” or “spokeswoman.” The two chief spokesmen for LDV
would include Harry Welty one of the group’s founders and Brenda Anderson who
also runs the group’s meetings and draws up is agendas. Art Johnston, an engineer, has worked long and hard to develop the
Plan B alternative. Larry Burda, Dan (Robert) Sershon, Art Johnston along with Harry
Welty are four of the five taxpayers in the current suit against the District
and Gary Glass is a school board member and since his election to the
Board does not consider himself a member of Let Duluth Vote but has done his
best to keep the group appraised of the actions of the School Board. I consider this list to be something of an honor roll and am
embarrassed to leave anyone’s name out but unless ordered to do so by the
court I’ll stop here with a very incomplete list of our supporters. Many of
the people who regularly attend Let Duluth Vote meetings can be identified
because they have written letters to the editor at one time or another. I am the sole owner/manager of www.letdulthvote.com.
I am its principal author/organizer and the only person with access to the site
for uploading new material. I occasionally upload information written by others
to the site and generally attribute authorship of said material. All of the material on both of these sites is easily available,
printable and downloadable. According to the web registration website, whois.com.,
www.letduluthvote.com was
created and or first registered on Interrogatory No. 16:
Identify all Persons whom you
believe have knowledge or information regarding the profits Answer: It seems obvious to me that only I also believe that anyone who has read the documents presented to
the Sixth Judicial District by the plaintiffs in this case would be able to draw
reasonably accurate conclusions about the income The documents presented, however, do not reflect the additional
earnings and or profits Interrogatory No. 17:
Describe in detail when you
first received any information regarding the RFP including what information you
received; the source of that information; how you received the information; and
when you received the information. Answer: I do not recall the date I first learned any details about the RFP.
It would have been sometime after the spring 2007 and probably before 2008. The
source of the information would most likely have been Maureen Booth or Gary
Glass. This public information would have come from the Interrogatory No. 18:
Describe in detail when you
first received any information regarding the Response, including what
information you received; the source of that information; how you received the
information; and when you received the information. Answer: I do not recall the date I first learned any details about the Interrogatory No. 19:
Describe in detail when you
first received any information regarding the School Board’s selection of Answer: I most likely received information about the School Board’s
selection of Interrogatory No. 20:
Describe in detail when you
first received any information regarding the Agreement, including what
information you received; the source of that information; how you received the
information; and when you received the information. Answer: I received the first information about the Agreement from Gary Glass
in the spring or summer of 2007. I know that he acquired this document from the
School District’s business office shortly before he revealed that Johnson
Controls would likely earn 13% of the over all cost of construction of the Red
Plan. I believe I read some of the contract language at that time and know that The first expert analysis I encountered of the earnings Interrogatory No. 21:
Describe in detail when you
first received any information regarding the Resolution, including what
information you received; the source of that information; how you received the
information; and when you received the information. Answer: I received the first information regarding the June 19th
resolution from Gary Glass in the summer of fall of 2007 and specifically
remember being appalled to learn the School Board had approved the Resolution
approving a contract sight unseen just as the Red Plan’s Review and Comment
document had been approved sight unseen before it was sent on to the Minnesota
Department of Education. It was at this time I learned it had been signed by Chair Ann Wasson
on an undated document. Interrogatory No. 22:
Describe in detail the letter
referenced in a posting by Plaintiff Harry R. Welty on www.lincolndemocrat.com
on May 20, 2008 which “outlined a possible case of bid rigging by Johnson
Controls” including but not limited to the letter’s author; the party to
whom the letter is addressed; the letter’s date; how you came into possession
of the letter; and the letter’s contents. Answer: This was a letter of complaint sent to the Duluth School Board by
ABE Systems of Duluth outlining the uncompetitive circumstances surrounding the
awarding of a construction contract and the unfair and improper influence
brought to bear by Interrogatory No. 23:
Identify all Persons you
believe have knowledge or information with respect to the veracity of the
allegations asserted on www.lincolndemocrat.com,
www.snowbizzs.com and www.letduluthvote.com
that Answer: This Interrogatory states that I have alleged that It is only in the past few weeks that I’ve learned that I had also heard word-of-mouth stories that Influence by its nature is not illegal but it can confer an
advantage. Since the Board was already working with Once again it was Dr.Dixon, Bill Hanson, Kerry Lieder and the School
Board members who had this preexisting relationship with Interrogatory No. 24:
Identify any and all documents,
Communications and Statements relating to, referring to or evidencing the
veracity of the allegations asserted on www.lincolndemocrat.com,
www.snowbizz.com and www.letduluthvote.com
that Answer: Let There are no documents to my knowledge that suggest anything other
than that I would add that this harm is being aggravated by the Interrogatory No. 25:
Describe in detail your
relationship with each of the current School Board members, including Gary
Glass, including but not limited to any Communications referring or relating to
the issues in this lawsuit; the RFP; the Response; the Agreement; or the “red
plan.” Answer: I have only addressed most of the Duluth School Board members
irregularly at the allotted time for public comment at their monthly school
board meetings. The time allotted for my comments is three minutes a month. *** The first time I met Ann Wasson may have been seven or eight years
ago when, as a School Board member, I sat in a dunk tank for the elementary
school carnival that her children attended. We have never spoken to each other
about the Red Plan or anything else that I can recall. *** I met Nancy Nilsen in 2003 when she became the de facto leader of A short time after this a vacancy on the School Board opened up with
the death of a school board member. I met with Ms. Nilsen once in 2007 in a coffee shop near her place
of work to encourage her support a referendum on the Red Plan. She told me she
would not support one. *** I first met Laura Condon when we both taught in the Proctor Schools
in 1976. I do not recall her well and she had to remind me of our early
acquaintance when I met with her to ask for her support in my quest to be the
School Board Chairman after the 1997 School Board election. Laura
had campaigned in opposition to the previous Board’s decision to bring the
Edison Charter Schools to To the best of my recollection Laura and I never had a hostile
conversation although when I met with her just before retiring from the Board in
2004 and asked her to support Mary Cameron for the School Board’s Chairmanship
Laura reacted to my request with some vehemence and antipathy. I do not recall speaking to her one on one about the Red Plan. *** I encouraged Judy Seliga-Punyko to run for the school board on at
least two occasions and gave her some help in her first run for the office. We
have always had a cordial relationship and I was grateful when Judy sent me a
donation when I pursued a quixotic race for the U.S. Congress in 2006. It was
one of very few I received. At the time she sent me a kind personal note perhaps
in gratitude for my earlier help in her unsuccessful school board campaigns. When Judy filed for the 2nd District School Board in
2007, the seat I had once held, I called her up told her I would be running
against her because I disagreed with her about the Red Plan. It was a somewhat
awkward conversation but it was cordial. That, to my recollection, is the only
conversation I’ve had with Judy regarding the Red Plan. *** I first met Mary Cameron just before filing to run for the School
Board for a fourth time in 1995. Three times before I had run for an at-large
seat and I had always lost. For my fourth attempt I intended to run for the
smaller and more manageable District 2 seat where I would have a greater
likelihood of success. When I learned an African-American woman who lived in the District
was planning to run for the Board I called her up and introduced myself. The
candidate was Mary and I wanted to size her up since she lived in the same
district and was a potential challenger. It was my intention to step aside for
her and run for the at-large seat once again if it turned out she was planning
to file for the District seat. I felt strongly that As it happened Mary had already set her sights on a District-wide
seat so we did not end up challenging each other.
In fact, much to the consternation of my own campaign volunteers, when I
discovered that Mary’s campaign volunteers were inexperienced I put my
campaign on hold to help get Mary’s started. I painted her law signs and sendt
out a fundraising letters to my supporters asking them to donate to Mary. We both won and served on the Board as the newcomers with very
little power or influence with the senior board members. In the process we
became each other’s biggest supporters. I continued to serve as Mary’s unofficial campaign manager for her
two subsequent School Board campaigns in 1999 and 2001. I wrote a candid but
sympathetic column about Mary for the Reader Weekly and created a Website
devoted to her reelection in 2001. Like most of my web creations much of it
remains on the Internet as an archive of my past activities.
Its current web URL is: http://www.snowbizz.com/DuluthSchools%20Page/WildAboutMary/wildaboutmary.htm In 2005 I passed on all of my records of Mary’s past campaigns to
her new campaign manager Bob Brooks along with my advice on how she should
campaign. I was confident that Mary would easily win reelection and she did. Mary was one of two former School Board members that I invited to my
daughter’s wedding. I met with Mary once after filing to run for the School Board in
2007 and told her that I planned to keep To her credit Mary made it clear in that meeting that it was the
health of the entire school system that was her top priority and that old
loyalties would have to be set aside. I have not met with her since to discuss
the Red Plan. *** I first met Tim Grover in 1989 when I circulated a petition hoping
to persuade the School Board to keep Washington Junior High open. We have been
political allies and close friends ever since. Tim is the other former School
Board member I invited to attend my daughter’s wedding. During the time we
served on the School Board we enjoyed each other’s company and had many long,
animated and laughing discussions about School Board personalities and politics.
For the first nine months of Let Duluth Vote’s existence Tim was
once again a close ally. In late winter or early spring of 2008 Tim threw in the
towel and decided that the Red Plan could not be stopped. At that time he bowed
out of Let Duluth Vote. Tim regards himself as a pragmatist and in his opinion
there was no way to convince the Board to put the Red Plan up for a vote or stop
the construction. This had the effect of helping him regain the trust of most of
his fellow school board member’s and has resulted in his election this year to
be the Chairman of the School Board. I can not fault him for his pragmatism but we no longer talk about
the Red Plan or school politics. It’s been over a year since I sent him an
email. *** Mr. Glass and I met again as opponents of the Red Plan coalesced in
2007 and called for a referendum. We were both candidates for the School Board
that year and have continued to work for a referendum ever since. Mr. Glass and I speak regularly about our joint efforts to bring
about a referendum and in the intervening two years have discovered problems
with the Red Plan far beyond the School Board’s refusal to put it to a public
vote. We typically send each other several email messages each week and
talk on the phone fairly often. We’ve met over coffee on occasion and Interrogatory No. 26:
Identify all Persons whom you
believe have knowledge or information with respect to the veracity of your
allegation that Answer: This list would include most of the individuals I’ve mentioned in
my answers to previous interrogatories. I can not think of any additional
material details that I would enhance my previous answers Interrogatory No. 27:
Identify an all personal e-mail
addresses you have used from period beginning Answer: harrywelty@charter.net Interrogatory No. 28:
Identify any and all personal
computers you have used from the period beginning Answer: I have a personal computer at home and I occasionally use my
wife’s laptop computer when I am traveling. I have also posted to my blog from
computers in many public libraries and occasionally from computers in the
business centers of Hotels I’ve stayed
Dated:
_________________________ Harry
R. Welty
Dated:
NORTHLAND LAW __________________________ Craig
S. Hunter (#48264) |