Complaint Review: City of San Antonio, Texas
- City of San Antonio, Texas
P O Box 839966
San Antonio, Texas
United States of America
- Phone: 210 207 7080
- Category: Government Services
City of San Antonio, Texas Report of Aggrevated/Subornation of Perjury by CIO Varn and City Attorney Klein San Antonio, Texas
FRAUD UPON THE COURT
A REPORT CONCERNING THE AGGREVATED PERJURY/SUBORNATION OF PERJURY BY CITY OF SAN ANTONIOS CHIEF INFORMATION OFFICER RICHARD J. H. VARN, CITY ATTORNEY DEBORAH KLEIN AND OTHERS
ADDITIONAL REPORTS: BOGUS TIME REPORT SCHEME / THEFT OF $200,000 city IT Manager and vendor
ENTITY: THE CITY OF
ITSD - (INFORMATION TECHNOLOGY SERVICES DEPARTMENT)
Chief Information Officer Richard J. H. Varn IT Director Hugh Miller
LOCATION: CITY OF SAN ANTONIO, TEXAS
FACT: CIO RICHARD VARN, CITY ATTORNEY DEBORAH KLEIN AND OTHERS CONSPIRED TO PRESENT A FRAUD UPON THE COURT WHEN THEY OFFERED FALSE/ FABRICATED TESTIMONY UNDER OATH IN AN EFFORT TO HIDE CRIMINAL ACTIVITY BY CITY EMPLOYEES INCLUDING THEFT, FRAUD, GRANT FRAUD, RETALIATION AND FALSIFICATION OF OFFICIAL DOCUMENTS.
IMPACT: THE ILLEGAL SCHEME TO PRESENT A TOTAL FABRICATION TO THE COURT CAUSED THE COURT TO BE DEFRAUDED. THE FALSE TESTIMONY HID FROM THE COURT AND FROM OUR CITIZENS THE FACT THAT PUBLIC AND GRANT FUNDS HAD BEEN STOLEN, MISUSED AND MISAPPROPRIATED FOR DECADES. THE FALSE TESTIMONY LAID THE FOUNDATION FOR OTHER CITY WITNESSES TO PRESENT THEIR FRAUDULANT TESTIMONY IN SUPPORT OF THE FABRICATED WORK OF FICTION OFFERED TO THE COURT BY CITY ATTORNEY KLEIN AND CHIEF INFORMATION OFFICER VARN TO HIDE THE CRIMINAL ACTIVITY.
This is one of many reports that will be published detailing the numerous illegal schemes devised by corrupt city employees/officials to embezzle public/grant funds and to hide the criminal activity. The City Attorneys Office has conspired with corrupt city officials/employees and law enforcement officers to cover up decades of theft, fraud, falsification of government records, retaliation, etc. This report proving aggravated perjury, subornation of perjury and obstruction is but a single example of the many instances of criminal behavior undertaken to hide the crimes against our government and our citizens.
Citizens Against Public Corruption, Waste, Fraud and Abuse
9650 Limestone Pond
City of San Antonio, Texas Chief Information Officer Richard J. H. Varn testified under oath in a court of law that in 2005 he understood the internal billing account commonly referred to as the telephone variable, investigated the use of the account, found that the variable was created to help balance the budget / make requests for additional funds/pay for pop-up expenses/make adjustments to the budget, contacted Washington and found that there was no grant fraud and found nothing illegal concerning the use of the variable.
Page 23 line # 10 Varn states They had to have some way of balancing their budget and serving their needs. They had something calledsome kind of variable in the telephone system.
Page 25 lines 22-25 Varn states Well, I want to be very specific, and theres nothing illegal about it. It does not violate any city policies, rules, or ordinance. It doesnt violate Texas law.
Page # 41 line # 17 Varn replies I understood the telecom variable cause thats the one that seemed to be the largest one that was used to adjust the budgets.
Page #45 line # 14 Varn again broke in replying- I have actually visited with a number of federal officials in Washington asking them about
With his fabricated testimony and false statements CIO Richard J. H. Varn of Des Moines, Iowa ( yes, he resides in Iowa) set the stage to facilitate the presentation of a fraud upon the court inside the Bexar County Courthouse in the case of Foddrill v City of San Antonio -2006 CI 06702- in February 2009. Varn told the critical lies used to hide decades of criminal activity including but not limited to theft of public funds, State and Federal grant fraud, falsification of government documents, threats to keep quiet, retaliation and aggravated perjury inside the Citys IT Department and with the assistance of City Attorney Deborah Klein and other city witnesses presented a work of fiction- a total fabrication- to the court- and to our citizens.
I. INTRODUCTION - Chief Information Officer Richard Varns fabricated testimony was created in an effort to conceal decades of fraud, theft of public funds, grant fraud, falsification of documents, fraudulent audits, fake reports, doctored financial books, threats to keep quiet and many other crimes. The criminal activity centered on the illegal manipulation of an internal telephone billing account the variable- created on January 4, 1982 with the publication of Administrative Directive 6.12 signed by Purchasing Director Brooks and City Manager Huebner. Corrupt City officials, Municipal Integrity officials/investigators, City attorneys including Deborah Klein, IT officials including CIO Varn/IT Director Miller/Fiscal Manager Segovia, the SAPD and others would have us believe that AD 6.12 and other publications regulating the use of public and grant funds do not exist and no illegal acts were ever committed by city employees and others. Their lies are exposed in this report.
II. CHRONOLOGY OF THE SCHEME TO HIDE THE CRIMINAL ACTIVITY - In the summer and fall of 2005 City officials, City employees, the Office of Municipal Integrity, the San Antonio Police Department, the IT Department, the City Attorneys Office, etc. began efforts to cover up the criminal activity almost immediately after the crimes were exposed. These efforts continue to the present day. Corrupt city officials, attorneys, witnesses and employees violate the law in their efforts to hide decades of criminal activity inside the Citys IT Department. Law enforcement officials, State/Federal auditors/investigators and many elected officials turn a blind eye to the decades of criminal activity and the ongoing illegal cover-up.
III. THE VARIABLE - METHODOLOGY EMPLOYED TO GAIN ILLEGAL ACCESS TO PUBLIC/GRANT FUNDS - For decades corrupt City employees manipulated an internal billing account the telephone variable to illegally and secretly gain access to over $ 3 million a year in funds set aside by law in the form of grant rules, OMB regulations, budgets, local government code, ordinances, bonds, etc. for telecommunications support and used the money for other than its intended purpose and in many instances to support illegal schemes in an effort to funnel the ill-gotten funds to accomplices and co-conspirators.
IV. FRAUD UPON THE COURT - As early as 2005 the City Attorneys Office and others embarked upon a scheme to conceal documents, falsify audits/reports, suborn false testimony. etc. in an effort to defraud citizens, grantors and the courts. CIO Richard Varn lied under oath in a court of law fulfilling his part in the deliberate scheme to defraud the judicial process while all the attorneys present in the courtroom (Klein, Gaul and most probably Kosanovich.) had intimate knowledge of Varns 2007 sworn deposition, documents including AD 6.12 and other publications that directly contradicted his entire testimony and proved beyond a doubt that he was lying under oath in a court of law. The fraud perpetrated upon our courts by Varns coached, false testimony coupled with the criminal acts of the attorneys presenting the case rose the level of fraud upon the court.
V. CITY PERSONNEL CONSPIRED TO COVER UP THE CRIMINAL ACTIVITY AND THE COMMISSION OF AGGREVATED PERJURY, SUBORNATION OF PERJURY AND OBSTRUCTION OF JUSTICE Every effort has been made to cover up the decades of criminal activity. The Office of Municipal Integrity, the City Attorneys Office, District Attorney Reeds Office, SAPD, the Bexar County Sheriffs Office, Mayor Castro, City Manager Sculley, City Council members and others have either taken steps to hide the crimes or deliberately look away allowing the criminal cover-up to continue. DPS Texas Ranger Captain Hank Whitman lied under oath in support of Varns fabricated testimony and FBI Special Agent Brown of the local San Antonio field office of the Federal Bureau of Investigation published a fraudulent document stating that three separate meetings had taken place and the violations of law had been investigated. Everyone involved in the illegal cover-up makes a mockery of Freedom of Information laws via the constant denial of access to public documents that prove their involvement in the illegal cover-up of numerous violations of law.
VI. CITY, STATE, FEDERAL AND LAW ENFORCEMENT OFFICIALS WERE ALERTED TO THE FRAUD AND ASSULT UPON THE INTEGRITY OF OUR JUSTICE SYSTEM City officials, the San Antonio Police department, the Bexar County Sheriffs Department, the Bexar County District Attorney, the Texas Rangers, the FBI, State Auditor Keel, Attorney General Abbott, Governor Perry, numerous elected officials, HUD OIG officials/agents especially Agent Victoria ( I dont care, I dont care, I dont care) Marquez and others were made aware of the criminal activity including the theft of public/grant funds and of the fraud upon the court. HUD OIG case # 10-0465 was opened and closed while HUD OIG officials REFUSED to interview the Telecommunications Manager who along with another citizen convinced Congressman Lamar Smith to open the investigation into the fraud and the theft of our money.
VII. STATUTES APPLICABLE TO THE COMMISSION OF THE CRIMES- Penal Code- Title 8- Offenses against Public Administration Chapter 37 Perjury and other Falsifications
Federal statutes may apply as Varn, several attorneys and others conspired to hide violations of federal law
VIII. STATUTE OF LIMITATIONS Code of Criminal Procedure- Chapter 12 Limitation. Aggravated Perjury/Subornation of Perjury - three years from the date of the commission of the offense. Chief Information Officer Varn is also an accomplice/co-conspirator in the commission of other crimes as he has conspired to assist offenders avoid apprehension and prosecution. Some of these crimes can be prosecuted up to ten years after the fact.
IX. CONCLUSION - The testimony that Chief Information Officer Richard Varn presented in the Bexar County Courthouse on February 10, 2009 was a fabrication concocted by City Attorney Deborah Klein and others. Klein coached Varn during his presentation of known false testimony while the opposing attorney Malinda Gaul sat idly by. Gaul knew the testimony was entirely false but raised no objections and refused to enter Varns 2007 deposition, Administrative Directives 6.12, 1.6, 2.1, 2.2 and other documents into evidence. Attorneys Klein and Gaul were present at Varns 2007 deposition when he stated I dont know what that is when asked about the variable and they also had knowledge of City documents proving Varn and others to be lying under oath about the legal use of the variable (especially AD 6.12) but allowed the fraud to continue. The court was never allowed to know of Varns 2007 deposition or the City, State and Federal documents that directly contradicted his fraudulent/fabricated courtroom testimony. The attorneys, Varn and others presented a fraud upon the court. After presenting a fraud upon the court to win the Whistleblower lawsuit city attorney Deborah Klein stated to the press- I think the city is interested in fixing things when things arent right and I think we showed that. The City is indeed interested in fixing things. They are interested in fixing trials, police reports, Municipal Integrity investigations, etc. to hide the decades of criminal activity inside the City. If fixing things means violating the law, committing aggravated perjury/ official oppression, etc. - so be it.
X. APPENDIX detailed list follows
REPORT IN FULL
Chief Information Officer Richard Varns fabricated testimony was created in an effort to conceal decades of fraud, theft of public funds, grant fraud, falsification of documents, fraudulent audits, fake reports, doctored financial books, threats to keep quiet and many other crimes. The criminal activity centered on the illegal manipulation of an internal telephone billing account the variable.
When deposed in 2007 Chief Information Officer Richard Varn admitted that he didnt even recognize the term variable, had no knowledge of any such account, didnt know how departments obtained funding when their money ran out and handed over all responsibility as CIO by July 11, 2005 to incoming CIO Armstrong. The City has stated that there are no documents in existence concerning Varns review/investigation of the variable in 2005. There is no mention of Varns ever looking into the variable by any witness testifying in the 2005 Municipal Integrity investigation. Incoming CIO Mickey Armstrong states in an email of November 29, 2005 that the existence of variable accounts came as a surprise to him.
In court under oath in 2009 Chief Information Officer Varn presents a fabricated fairytale concocted by corrupt city attorneys and IT employees to hide decades of criminal activity. In 2009 under oath in court Varn now falsely states that in 2005 he understood the variable, investigated the billing account, contacted Washington, discovered that the account was created to help balance the budget and pay for pop up costs, found that nothing illegal had transpired, etc. He lied and all the attorneys were aware that he was lying as they were present at his 2007 deposition and were aware of numerous binders of documents proving the existence of City, State and Federal regulations, rules and laws governing the use of the telecommunications funds. The court never saw the 2007 deposition or the binders. With the assistance of city attorney Deborah Klein and with attorney Malinda Gaul looking away CIO Richard Varn presented a fraud upon the court.
II. CHRONOLOGY OF THE SCHEME TO HIDE THE CRIMINAL ACTIVITY
In the summer of 2005 City officials, attorneys and employees began efforts to cover up the criminal activity almost immediately after the crimes were exposed. By October 2005 Municipal Integrity investigator Steve Harrison and Manager Virginia Quinn prematurely halted an internal investigation, published a fraudulent investigation report declaring that no wrongdoing was found, no rules or laws were broken and that there were no rules or laws regulating the variable-a lie. This lie implying that AD 6.12, AD 2.1, AD 2.2, Local Government Codes, OMB regulations, budgets, etc. do not exist formed the central theme of every effort by corrupt city officials/employees to hide the criminal activity for the past five years and is the basis for Varns fabricated, fraudulent testimony. In November 2005 the City Attorneys Office illegally denied FOIA access to the MI report and an internal contract audit performed by the now defunct Contract Services Department so as to hide the crimes. The Telecommunications Manager who refused to go along with the criminal cover-up of the criminal activity was illegally terminated in February 2006. His Whistleblower trial took place in February 2009 in the Bexar County Courthouse. The City Attorneys Office continued to violate the law in an effort to hide decades of criminal activity. City Attorney Deborah Klein with the assistance of hired help Mark Kosanovich suborned perjury from numerous city witnesses including CIO Richard Varn who told the critical lies central to the fraud upon the court. Each witness was provided with a false, fabricated testimony that they were to present to the court. The jury found for the City answering NO to the first question Did the Telecom Manager make a good faith report basing their decision on fabricated, false testimony concocted by the City attorney and presented to the court and our citizens by CIO Richard Varn and other corrupt city employees with the assistance of city attorney Deborah Klein and others.
III. THE VARIABLE - METHODOLOGY EMPLOYED TO GAIN ILLEGAL ACCESS TO PUBLIC/GRANT FUNDS
For decades corrupt City employees manipulated an internal billing account the telephone variable to gain
access to over $ 3 million a year of funds set aside by law for telecommunications support and used the money for other than its intended purpose and in many instances to support illegal schemes to funnel the funds to accomplices and co-conspirators.
Numerous schemes to defraud the government centered on the corrupt employees abilities to gain access to millions of dollars a year behind the backs of City Council, auditors, grantors, citizens, etc. The Telephone
Variable Billing Account created by City Administrative Directive 6.12 was clandestinely and illegally used to pilfer tens of millions of dollars from telecommunications budgets of every city department and every grant awarded the City of San Antonio, Texas since 1982. The annual cost of City Centrex services is less than $ 2 million. Official transfer requests for the Finance Dept. to move funds from department and grant telephone budgets to ITSD were clandestinely and illegally inflated by $ 3 million a year or more and consequently the telephone variable account swelled to an annual cost to grantors and citizens of over $5.2 MILLION more than twice the real cost of Centrex services described in AD 6.12. If a grant or department had a telecommunications budget it was drained of funding via fraudulent monthly bills totaling well over $ 3 MILLION a year for decades. The illegal manipulation of this monthly telephone billing account commonly referred to as the Variable provided corrupt city employees with the funds to use as they wished as if they were given a blank check to run the IT department or any other scheme they could envision. Internal City documents describe this slush fund they created as a bottomless pit of money. The billing account that over the years grew to $ 5.2 million was fraudulently described in audits, billing statements, etc. as Telephone Centrex costs when in fact the funding was used for whatever the IT Managers and their cronies wished to use the money for. The funding never ran out and had no limits set via city ordinance. Corrupt IT Managers ran the Information Technology - Communications Department like a private fiefdom or family-owned business rather than as a publicly funded municipal division of the City of San Antonio. They and their friends operated under the radar for decades with no accountability or overview by City Council, auditors, regulators, grantors, etc. They operated outside of the law as if there were no annual budgets, Administrative Directives, City Charter provisions, City ordinances, State Local Government Codes, State Uniform Grant management Regulations, Federal OMB regulations, State/Federal penal Codes, etc. They ignored City Administrative Directives (especially AD 6.12), Local Government Codes, City ordinances, City budgets, OMG regulations, etc. IT managers including Jose Medina, Mike Mitchell and Victor Perez and their accomplices altered invoices, caused to be created false and fraudulent statements in the books and records of the City, concealed the true and accurate disposition of department and grant resources and used funding set aside by city ordinance and state/federal grants as they wished and not for their intended purposes. They misused, misappropriated, embezzled, etc. funding set aside by law for telecommunications support. They violated open-bidding regulations as they never followed the law and requested the funding via city council approval/ordinances but simply purchased goods and services and dumped the bill into the telecommunications variable account to be paid with telephone funds from city and grant phone budgets. They stole money from every city department/program including Fire, SAPD, Library, Aviation, Health, WIC, Public Works, Community Initiatives, Housing and Community Development, Parks, etc. and every grant awarded each of these departments that contained provisions for telephone support. Their illegal slush fund created as is described by an internal city document a means for ITSD (Citys Information Technology Services Department) to balance its own books internally. The slush fund was used to tap a bottomless pit of money totaling in the millions of dollars. The internal contract billing process is compromised to the extent that departments were billed for an untold amount of goods and services from which their department received no benefit. State/Federal grants administered by every city department were billed for goods and services from which they received no benefit as well due to the fact that this illegal scheme plundered city department telephone budgets and grant telephone budgets alike.
IV. FRAUD UPON THE COURT
Chief Information Officer Richard J H Varn presented the critical lies to the court and with the assistance of
City Attorney Deborah Klein constructed the fraudulent foundation upon which the other city liars could place their blocks of false testimony in an effort to build a house of fraud, falsehoods, fabricated testimony and outright lies. Varns courtroom testimony centers on his tenure as the Citys Interim CIO in the summer of 2005.
A. Varns testimony focused on his investigation of the variable and budget issues in 2005. His statements under oath conveyed the message that in 2005 Varn investigated the variable billing account and other billing problems, contacted Washington DC concerning the issue of grant fraud, found everything legal and turned over the billing problems to the incoming CIO Mickey Armstrong.
On February 10, 2009 under oath in a court of law the Citys current Chief Information Officer Richard Varn declared that there was nothing illegal about the telephone variable. In the trial transcripts on page 25 lines 22-25 he states Well, I want to be very specific, and theres nothing illegal about it. It does not violate any city policies, rules, or ordinance. It doesnt violate Texas law.
On pages 22 24 Varn describes how cost/budget overruns are addressed and presented the court with his knowledge of how the city budget process operated in 2005. He falsely testifies that the variable was created
to help balance the budget and pay for pop up costs.
On page 23 line # 10 Varn states They had to have some way of balancing their budget and serving their needs. They had something calledsome kind of variable in the telephone system. They were using the the allegation was that was being illegally used, which Im very sensitive to. If anybodys illegally using money or inappropriately using money, were going to stop now and were going to figure out a way to fix it. So I went in and looked at that. What I found was it was an accounting mess. Varn went on to state on page 25 line # 7 We needed to be direct and honest with the departments about how we were billing them and exactly what the money was being used for.
Varn goes on to explain how he investigated the variable, called people in Washington, etc.
Page # 41 line # 4 Question- in talking to Mr. Foddrill, you learned about this variable account; is that correct?
Page # 41 line # 7 Varn replies- Thats correct.
Page # 41 line # 11 Varn states I just knew they had some things they used to adjust charges.
Page # 41 line # 17 Varn replies- I understood the telecom variable cause thats the one that seemed to be the largest one that was used to adjust the budgets.
Page # 41 line # 22 Question- Now, you said that you looked into the issues that Mr. Foddrill brought to you; is that correct?
Page # 41 line # 24 Varn replies- I did the best to my ability, Maam, yes.
Page # 43 line # 6-12 Varn explains- As long as you have a fair way doing it, its done uniformly, you can charge everybody the same way, then its okay to do that method.
Page #43 line # 20 Question- Okay. So did you look into that to make sure this variable was not violating those federal---
Page # 43 line # 22 Varn cuts in and replies- Yeah, I did, and I didnt think it wasyou know, it did get done the same way for everybody, so it was a commonly confusing way of doing it, you know.
Page #44 line # 1 Varn explains everyone had equal access to come in and make a plea to the department director to say, I have a problem this year, or I have an issue with this financing, or the department director would say this ended up being more expensive than we thought. We would have to figure out how to cover the costs. Allocating it by any common way probably would fallwould get accepted by federal auditors. Theyre really looking for somebody whos dumping bunches of costs onto Medicaid and other contracts to try to solve their budget problems. Thats not what the City was doing. The City was trying to allocate costs that it
really did have.
Page # 45 line # 7 - Varn states that it is acceptable and legal to use grant funds to purchase the IT trophy case If its legal to spend the moneyeven if its a dumb thing to spend money on, if its legal to spend money on, its not to my knowledge violating the federal audit rules.
Page #45 line # 11 Question- Did you ask the feds about whether they thought it was okay to buy trophy cases and remodel the ITSD
Page #45 line # 14 - Varn again broke in replying- I have actually visited with a number of federal officials in Washington asking them about
Page #45 line # 25 and page 46 line # 1 Question- Did you stop the process of the variable when you found out about it in 05?
Page # 46 line # 2 Varn replies- No. There was no alternative. I did ask them to start developing an alternative billing process, and I left it on my list, you know. It was like handing off the bible over to Michael Armstrong saying, heres a big list of things. Im sorry. You have to fix your billing system.
Varns testimony provides a systematic, clear outline of his actions in 2005 after he was informed during a meeting of June 16, 2005 by the Telecommunications Manger of billing issues and threats to keep quiet or provide auditors with bogus information. His testimony provides a detailed accounting of how as the Citys senior Information Technology Guru he responded to serious allegations of violence in the workplace and fraud. This internationally recognized expert and leader in information technology, privacy, identity security, public policy, and digital government, former State of Iowa Representative, former State of Iowa Senator, Senior Fellow with the Center for Digital Government, Technology Policy Advisor to the National Retail Federation, Director of the Coalition for Sensible Public Records Access, Board of Trustees member for the Educational Testing Service, holder of a juris doctorate law degree and self- proclaimed author of Whistleblower law testified under oath in a court of law that in 2005 he immediately addressed the serious allegations, investigated the variable and budget irregularities, contacted Washington DC concerning the issue of grant fraud, found no wrongdoing or violations of law and turned over the whole accounting mess to his successor- incoming CIO Mickey Armstrong ( current CIO for Corpus Christi, Texas).
Chief Information Officer Richard J H Varns courtroom testimony presents a very powerful narrative, a white-paper like review of exactly what type of actions are to be taken to address serious allegations of fraud, workplace violence and the theft of public and grant funds by corrupt public employees. One could easily be just as impressed as the jury and judge were in 2009 when they listened to IT Guru Varns words of wisdom and City Attorney Kleins descriptive, informative and supportive statements to the court.
Anyone, just as in the case of the judge and jury, could easily be impressed not knowing that Varns sworn testimony was a cleverly crafted lie, a fable, a fairy tale, a fabrication, a work of fiction, a typical South-Texas novella-a soap opera, a totally untrue account that was intentionally represented as true by Varn, Klein and the other conspirators in the fraud upon our court. Anyone would be impressed until they heard the truth- the truth that the judge and jury were prohibited from hearing by the attorneys in the courtroom and others behind the scenes at the City Attorneys Office and City Hall.
B. In direct contradiction to Varns fabricated testimony under oath in court his sworn deposition of August 15, 2007 (that was intentionally concealed from the court), official city documents, sworn statements and other evidence prove that Varn, Klein and others conspired to present a fraud upon the court in an effort to hide violations of law committed by city employees and others. The subornation of perjury by an attorney and/or the intentional concealment of documents by an attorney are actions which constitute extrinsic fraud and directly contributed to a "grave miscarriage of justice inside the Bexar County Courtroom of Judge Antonia Arteaga.
Excerpts from Varns August 15, 2007 deposition follow:
When questioned about how city departments obtained more money if they ran out of funds Varn responded that he didnt know how that worked as follows.
Page # 12 line # 9 - Question During the 2005 time period that you were employed by the City, if a department was allocated money under the budget and ran out of money, what was the process for obtaining more money during the budget year ?
Page # 12 line # 13 Varn replies Gosh, Im not really sure how that worked. I dont really know how a department requested something to be changed about their allocation for money in their budget.
When questioned about the telephone variable billing account he admitted that he didnt even recognize the term and knew nothing of any such account as follows.
Page # 38 line # 17 Question have you ever heard of an account in that telecommunications department that was called the variable account?
Page # 38 line # 20 Varn asks Variable
Page # 38 line # 21 Attorney Gaul reiterates- Variable
Page # 38 line # 22 Varn replies- No. Were there any other names for it?
Page # 23 Line # 23 Gaul states- No. Thats the only one weve had it called so far.
Page # 38 line # 25 Varn states I DONT KNOW WHAT THAT IS.
Page # 39 line # 8 Varn goes on to say IF THERES AN ACOUNT THAT GOES TO COVER THAT, IM NOTI DONT KNOW THAT THERES A SEPARATE ACCOUNT. I DONT HAVE KNOWLEDGE OF THAT.
Page # 39 line # 20 Varn again states IF THERES AN ACCOUNT FOR THAT, I JUST DONT KNOW.
When deposed in August 2007 Chief Information Officer Richard Varn admitted that he knew nothing of the telephone variable account, didnt recognize the term variable and did not know how city departments received funding if their money ran out. City responses to FOIA requests, the 2005 Municipal Integrity investigation, sworn statements and city documents support this fact. Varn knew nothing of the variable.
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