Case: 3:15-cv jdp Document #: 179 Filed: 05/11/16 Page 1 of 24. One Wisconsin Institute Inc. v. Gerald Nichol et al.

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1 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 1 of 2 One Wisconsin Institute Inc. v. Gerald Nichol et al. 15CV32BBC Transcript of the Testimony of: Cassandra Silas April, 16 G ',. GRAMANN REPORTING 800.6,72, MILWAUKEE FAX: North Plankinton Ave, Suite 00, Milwaukee, WI 533 MADISON FAX: West Mifflin Street, Suite 3, Madison, WI 53703

2 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 2 of 2 //16 Cassandra Silas ~-----~ Page IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN ONE WISCONSIN INSTITUTE, INC., CITIZEN ACTION OF WISCONSIN EDUCATION FUND, INC., RENEE M. GAGNER, ANITA JOHNSON, CODY R. NELSON, JENNIFER S. TASSE, SCOTT T. TRINDL, and MICHAEL R. WILDER, Plaintiffs, -vs- Case No. 15 CV 32 JUDGE GERALD C. NICHOL, JUDGE ELSA LAIVIELAS, JUDGE THOMAS BARLAND, JUDGE HAROLD V. FROEHLICH, JUDGE TIMOTHY VOCKE, JUDGE JOHN FRANKE, KEVIN J. KENNEDY, and MICHAL HAAS, all in their official capacities, Defendants Deposition of CASSANDRA SILAS Thursday, April, 16 1:6 p.m. at MILWAUKEE STATE OFFICE BUILDING 8 North 6th Street Milwaukee, Wisconsin 2 25 Reported by Lindsay DeWaide, RMR, CRR (800) 8-72

3 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 3 of 2! //16 Cassandra Silas Page Deposition of CASSANDRA SILAS, a witness in 2 the above-entitled action, taken at the instance of the 3 Defendants, pursuant to the Federal Rules of Civil Procedure, before Lindsay DeWaide, Registered Merit 5 Reporter, Certified Realtime Reporter, and Notary 6 Public in and for the State of Wisconsin, at MILWAUKEE 7 STATE OFFICE BUILDING, 8 North 6th Street, Milwaukee, 8 Wisconsin, on the st day of April, 16, commencing at 1:6 p.m. and concluding at 3:08 p.m. APPEARANCES: PERKINS COIE LLP, by Mr. Joshua L. Kaul 1 East Main Street, Suite 1 Madison, Wisconsin Appeared on behalf of Plaintiffs. 15 WISCONSIN DEPARTMENT OF JUSTICE, by Ms. Jody Schmelzer 16 West Main Street P.O. Box 7857 Madison, Wisconsin Appeared on behalf of Defendants (800) 8-72

4 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 //16 Cassandra Silas Page E X A M I N A T I O N 2 PAGE 3 BY MS. SCHMELZER BY MR. KAUL 52 5 BY MS. SCHMELZER E X H I B I T S 8 NUMBER PAGE IDENTIFIED Exh. 1 Document 30 Exh. 2 Application 30 Exh. 3 6//15 Letter 3 Exh. 3/2/16 Letter 3 (Original exhibits attached to original transcript; copies of exhibits attached to copies of transcript.) (800) 8-72

5 //16 Cassandra Silas Page TRANSCRIPT OF PROCEEDINGS CASSANDRA SILAS, called as a witness herein, having been first duly sworn on oath, was examined and testified as follows: EXAMINATION 6 BY MS. SCHMELZER: 6 7 Good morning, Ms. Silas. Am I saying your name 7 e correctly? A Yes. 1 o I'm Jody Schmelzer. I'm an attorney at the Department of Justice, and I represent the state officials that are defendants in this action. Have you ever had your deposition taken before? 15 A No. Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 5 of 2 1 And did you do anything to prepare just for this 2 deposition after you got notice that you were 3 going to be deposed? A Yes. I signed off on my birth certificate. First 5 I called. First I called downtown to the birth B certificate where I usually get them, and I had them before. So I called there, and they said they was going to check; call back. And I called back in a few days. They said they couldn't find it. I'm going to stop you right there. A Right. I'm sony. So once you got notice that you were coming to this office today to sit here and have your 15 deposition taken a week or so ago, did you review Page Page 6 16 Well, I'm going to talk about some of the ground 16 any documents or papers to, I guess, prepare you rules. And you probably talked about those with for today for the questions I was going to ask your attorney beforehand, but I'll go through 1s you? those again. A No. No. Wait a minute. Can you say it again? This is an opportunity for me to, I 2 o Sure. When you found out -- I'm presuming at some guess, talk to you about your case, find out a point you were told that you were going to have to little bit more about you. come to this office today. Everything that you say is transcribed A Yes. 2 by the court reporter here, so it's iniportant to 2 When you found that out, did you review any 25 verbalize your responses. I know some of us say 25 documents or talk to anyone besides your attorneys f Page 5 "uh-huh" and shake our head. And that's normal to 1 Page7 to kind ofrcfresh your memory on what was going 2 do that, but here we're going to ask that you 2 on in the case? 3 speak your responses clearly. 3 A Yes. A Yes. And what did you do? 5 And make sure that the court reporter can hear you 5 A Well, he asked me would I be a witness -- 6 as well. 6 MR. KAUL: Let me just intem1pt. 7 A 8 15 A Yes. And another important, I guess, ground rule is to try not to talk over each other. Sometimes it's natural to answer a question that you already, ygu know, know that I'm getting at before I'm done talking, and that makes it a hard job for the court reporter to get that all in the transcript. Okay? Yes Anything you did to prepare for just today's deposition -- THE WITNESS: No. MR. KAUL: -- that involved talking to your lawyer, including me, that, you don't have to talk about. So the question is did you do anything outside of talking with me? THE WITNESS: No. 16 And you are sworn in. You are under oath, so 16 MR. KAUL: Just to get ready for today? anything you say here can be used later on in the THE WITNESS: No. case or at trial. Do you understand that? 1s BY MS. SCHMELZER: So you didn't review any documents before you got A Yes. 2 o here today because you knew we were going to have Okay. What did you do to prepare for your this deposition? deposition today besides speaking with your A No. attorney? Okay. I'm going to ask a little bit about you and 2 A Well, I went down to the DMV and tried to get an 2 your background. 25 ID so I can vote ~ 2s A Okay. (800) 8-72

6 //16 Cassandra Silas Page 5 Page 8 Page 1 Did you graduate from high school? 2 A No. 3 What was the highest grade level that you were at in school? s A th grade. th grade. 6 And where did you go to school up to the th 7 grade? 8 A Manley High School in Chicago, Illinois. Before being involved in this lawsuit as a plaintiff, have you ever been involved in any other lawsuits? A No. l3 Have you ever been sued by anyone before? ever file any lawsuit against you? 15 A Like, housing? 16 Sure. Like, when you have to go to court for something. A Yes. Like, housing. Yeah. Like, housing. Tell me about that. A Somebody try to evict you. Eviction cases? A Yes. MR. KAUL: Object on relevance. 2 BYMS. SCHMELZER: 2s And when did you first have a lawsuit filed against you in an eviction case? MR. KAUL: I'll object on relevance. THE WITNESS: I can't remember. MR. KA UL: You can answer. THE WITNESS: I can't remember. 6 BY MS. SCHMELZER: 7 Would it be more than years ago? s A Yes. More than years ago? A A No. More than 15? No. Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 6 of 2 Anyone Page 1 A Yes. Can you explain to me what you mean about 2 that? 3 Sure. Sure. I was wondering if you have ever had 5 6 a case filed against you where you had to come to court because someone was suing you for some reason, and you had mentioned housing or an 7 eviction case. B And then I think I had asked was that just once, or did that happen more than once? A Yes. Well, yes. Yes. More than once. Do you know about how many times? MR. KAUL: And I'm going to object to this line on relevance. THE WITNESS: No. 15 MR. KAUL: But you can go ahead and 16 answer. THE WITNESS: I don't remember how many times. BY MS. SCHMELZER: Was it more than five? MR. KAUL: I'll do a continuing objection for the record. You can answer. 2 THE WITNESS: I don't remember BY MS. SCHMELZER: 2 Okay. Fair enough. Anything besides those Page I] 3 housing actions where you would have been sued by anybody and had to go to court for that? s A No. 6 Have you ever been convicted of a crime? 7 A Convicted of a crime? No. a Were you -- do you recall if you were convicted of criminal damage to property here in Milwaukee? A Oh, yes. Yes. MR. KAUL: I'll object to the line. But you can answer. And do you know how many times you've had cases THE WITNESS: Yes. I'm sorry. Yes. filed against you on eviction issues? BY MS. SCHMELZER: 15 A I don't remember. 1s And was that a 00 case? 16 MR. KA UL: Jody, could we go off the 16 A Yes. record for a minute so we can speak briefly 1 7 And that was here in Milwaukee County? outside the room? 1a A Yes. MS. SCHMELZER: Sure. MR. KAUL: And, again, continuing (Off the record.) objection to this line. BY MS. SCHMELZER: BY MS. SCHMELZER: Ms. Silas, before we took the break, we were 2 2 And was that a misdemeanor, that you recall, or talking about any cases where a case was brought you don't know? 2 against you for some reason. And you mentioned an 2 A I don't know. 2s eviction action, a housing action. 25 And besides that one, do you recall whether or not {800) 8-72

7 //16 Cassandra Silas ~ P-~ge 6 Page Page 1 you've been convicted of a crime? 2 A No. No. 3 How did you first become aware of this lawsuit? And I'm going to clarify that -- being a witness 5 in this lawsuit. I don't want to know about when 6 you actually were a plaintiff or how you got to be 7 a plaintiff with your attorneys. But before that s process. Before you were a plaintiff. A How did I get -- can you -- Yes. When did you first become aware of this lawsuit? MR. KAUL: And I think you've clarified the point, but I'll instruct, just consistent with this, Ms. Silas has been instructed, and I'll instruct her again on the record, that you're 15 welcome to answer any questions about somebody, 16 including a lawyer, who talked to you about being 1 7 a witness in the case, but nothing about you being a plaintiff, who we were representing in the suit. THE WITNESS: Okay. MR. KAUL: Does that make sense? THE WITNESS: Yes. MR. KAUL: So just the stuff before you 2 were a plaintiff or talked about being a 25 plaintiff. Page 1 THE WITNESS: Okay. 2 BY MS. SCHMELZER: 3 Yes. So when did you first find out about this s A 6 7 A 8 A Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 7 of 2 case? When did I find out? When I was contacted. As being a witness in the case? Yes. And do you recall when that was? Was it March? No. Sorry. Yeah. March. In March. I don't remember the date. Sure. Was it March this last year? A TI1is year. Last month? A Yes. 15 So March of16? 16 A Could have been February too. I be forgetting. February or March of 16? A This year. Yes. MR. KAUL: And I'll instmct the witness after that last answer. Ms. Silas, you should answer the questions to the best of your recollection. If you don't remember the answer to something, you're welcome to say that. Or if you 2 do, give the best answer you can, as long as 25 you're answering truthfully. Okay? 1 THE WITNESS: Okay. 2 MR. KAUL: I think Ms. Schmelzer agrees 3 with that, but teel free to correct anything. MS. SCHMELZER: I agree with that. s THE Wl1NESS: Okay. 6 BYMS. SCHMELZER: 7 And who contacted you about being a witness in s this case? A Mr. Martin~ And do you know why they contacted you, how they got to know who you were? A Yes, because I've been trying to get a photo ID and -- to vote. And I was turned down constantly. And he said that he's seen my paperwork, and it - you know, I cannot say it. I guess he saw my paperwork, and he seen all the things 1 had been through trying to get a photo ID, so he called me. 1s And then we met at my home. Did he show you or send you any of that pape1work before you became a plaintiff? A No. Yeah. Heshowedme. Yes,hedid. Hecame 2 2 to my home. MR. KAUL: And let me interpose an 2 objection. Any meetings that you had v.rith 25 Mr. Martin or anybody from my firm that related to Page 15 1 you becoming a plaintiff in this case -- 2 THE WITNESS: No. He didn't show me no 3 paperwork. MR. KAUL: Anything that relates to you s becoming a plaintiff in this case, you don't need 6 to answer that. 7 THE WITNESS: Okay. 8 MR. KAUL: So Ms. Schmelzer's questions are limited to any conversations you had just when you were talking about potentially being a witness. Does that make sense? THE WITNESS: Yeah. MR. KAUL: If you have any questions about that,just let us know. Okay? 1s THE WITNESS: Okay. 16 BY MS. SCHMELZER: And I'll move on from that now. 1a A Okay. Do you understand what your claim is in this case? A Yes. What do you understand that to be? A Trying to get my ID so I can vote. Have you ever had a valid photo ID? 2 A Yes. 25 Since being an adult, let's say adulthood. (BOO) 8-72

8 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 8 of 2 //16 Cassandra Silas Page 7 Page 16 Page 1 A I had a Milwaukee ID. I had a Transit Plus ID. I 1 But by me movmg, thmgs happened. I misplaced 2 never had a state ID. 2 them. So 1 do not have it. 3 The Transit Plus ID, is that for the bus? 3 So somebody else got that from the Cook County A No. That's for, like, driving in a cab, because I Hospital for you? s got severe arthritis and I can't ride. I can't s A On th and Vliet. Our caseworker. 6 walk to the bus stop. 6 What was her name? 7 So that allows you to ride in a cab? 7 A I don't remember her name. It's been years ago. s A Yes. 8 And when was that? And that has your photo on it? A I don't remember. I came here probably 1, so A Yes,ma'am. it would have to be sometime, like, in that -- you How did you get that ID? know. I don't know what month. A I went down to -- first, my doctor had to sign a Sure. form saying, you know, all the sickness I have. A But that's when I came up here. And then I take it down to the bus company, and And what happened to the birth certificate she 15 they go over it, and they decide. 15 gave you? 16 Is that kind of like an accommodation -- a Misplaced. I moved from different houses and got 1 7 disability accommodation for people who would ride the bus or otherwise get a bus ID? A Yes. If I could make it to the bus, they would 2 o let me -- help with bus tickets or something. But since I can't make it to the bus stop, they accommodate me. Ifl don't have a ride, I can ride with the American cab. 2 I think l understand. What is the Milwaukee ID? 25 A I don't have the Milwaukee ID. They stopped doing Page it. It was like a W2 ID. Back before W2 came out, it was a welfare ID and -- Sorry. Go ahead. A s A 15 A So I had that ID, but they stopped giving them out. It was an ID for some kind of welfare program that you were on? Yes. And I did have a birth certificate when I first came here. I moved to a shelter, and my intake worker, she sent out for my bilth certificate for me and my children. So they had moved. She took a copy and gave me the original. And that was an original birth certificate from the Cook County Hospital? Yeah. From Cook County Hospital. 16 And you said you had that when you first came A 2 here? I didn't have them. I didn't have no papers when I came, you know, saying who I was. I went straight to the shelter, me and my children. And then they sent me down there to get some assistance for us so we could move and get our own home. And she had sent off. She called down to Chicago, Illinois, where I'm from They sent my 25 birth certificate to her. And she gave it to me. ~ A misplaced. Do you know how long it took her to get that birth A A certificate -- It didn't take her long. -- from Cook County? It did not take her long MR. KAUL: And let me instruct you. When she's asking a question, make sure you wait until she's done. Page 1 2 THE WITNESS: Okay. MR. KAUL: It helps her keep a clear 3 transcript. THE WITNESS: Okay. Okay. s BY MS. SCHMELZER: 6 When you say it didn't take long, did it take more 1 than a week, do you recall? s A I'm not sure. When you had that birth certificate, did you ever use that to get any other form of ID here m Wisconsin? A No. Did you ever have a driver's license here in Wisconsin? 15 A No. I don't know how to drive. No. 16 So it would be fair to say you never had a driver's license m any other state either? A No. Is that correct? A Correct. Sorry. I just want to make sure the record reads correctly. A Okay. 2 I saw m some of your paperwork that you were on 25 supplemental security income, SSL (800) 8-72

9 _. [ // A Yes. 2 Did you have to show any ID to get those benefits? 3 A I don't know. I don't -- well, I don't know. Do you know how long you've been on SSI? s A Maybe -- I'm not sure. I'm not sure. 6 Would it help to say would it be more than ten 7 years that you've been on SSI? Is that something 8 you -- A Close to about eight. Close. And I think in some of your paperwork it talked about the FoodShare benefits that you were on. A Yes. Did you have to show -- how long have you been on FoodShare? 15 A Since I've been in Milwaukee. 16 Is Milwaukee the first place you came from Illinois, when you came from Illinois? A Yes. Have you ever moved out of Milwaukee -- A Yes. -- since being here? A Yes. I moved out. Yes. So when you came from Illinois, you came to 2 Milwaukee first? 25 A Yes. Cassandra Stlas Page Page 1 And how long did you live in Milwaukee before 2 moving again? 3 A Before moving again? Maybe -- MR. KA UL: And while she's thinking 5 about that, can I ask for a clarification? 6 MS. SCHMELZER: Sure. 7 MR. KAUL: Do you mean moving at all or 8 moving out of the city of Milwaukee? I think that may help. BY MS. SCHMELZER: Let me rephrase that. When you came from Illinois to Milwaukee, how long did you live in Milwaukee before you moved outside of Milwaukee to another city? 15 A About ten years. About ten years. 16 And what city did you move to then? 1 7 A I went to Minneapolis, Minnesota. How long did you live in Minnesota? A One month. Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 MR. KAUL: Even that was too long. MS. SCHMELZER: I agree. BY MS. SCIDvIBLZER: And how long -- where did you go after Minnesota? 1 A No. 2 You've been here ever since? 3 A Yes. When ym1 were in Minnesota for that one month, did s you try to get a state ID from Minnesota? 6 A No, because they were still using the county IDs. 7 And I just showed them my Milwaukee County ID, my a Milwaukee -- my welfare ID. And how long have you been in Milwaukee since moving from Minnesota? A Not long. About more years. And do you recall if you had to show any identification or provide any identification to go on the FoodShare benefits? 15 A No. They just wanted my social security number 16 and my number. It never changed. 1 7 You have a social security card; correct? A Yeah. Well, no. I don't have a social security card because all my papers got lost. It's like a 2 o number they give you, and I give them that number. Who gave you that number after your social security card got lost? A Who gave me the number? 2 Right. Where did you go to get that? 25 A The number for the food stamps? Page 1 You said your social security card got lost, and 2 they gave you a number. 3 A No. I'm just wondering who they are. 5 A I'm talking about the number for the food stamps. 6 That's what I use when I call down there so they 7 can know who I am. s So you do have a social security number, though, that's different? A Yes. Yes. All right I'm going to talk a little bit about the steps that you took to get an ID here in Wisconsin. A Okay. 1s When did you first try to get an ID here in 16 Wisconsin? A In January 15. And what did you do? A First, I talked to my sister. She sent for hers. She had no problem sending for hers. And, you know, she was telling me the ways to go about and d get mine. My daughter, she said, Let's go to Chicago. I said, No. I'm going to call first. 2 A Back to Milwaukee. 2 When you said you talked to your sister, was she 25 And did you leave Milwaukee after you came back? 25 also born in Cook County Hospital? ~ ~ (800) 8-72

10 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 // A Yes. We have the same last name and everything. 2 She had no problem getting hers. 3 And what did you do after talking with your sister to try and get an ID? 5 A She told me get a money order, send it through 6 UPS. And I get it back, like, in a couple days Cassandra Silas Page 2. Page Page 26 1 had something with my name on it and who I was. 2 So this was someone at the social security office 3 that gave you the printout? A Gave me the printout. 5 For you to take to -- 6 A TheDMV. 7 and send the money for my birth certificate, get a 1 -- the DMV? 8 money order. I sent the money order downtown to Chicago, Illinois. They sent it back. They said they couldn't find it; call Springfield, Il1inois. They gave me the number. I called Springfield, Illinois. I talked to a guy. I don't remember his name. He wanted me to fax my name, my birthdate, a letter, B A And I had a picture ID of myself. I had the Transit Plus. And I had a letter showing my address. So I went down. The lady gave me a number, and I think -- did they tum me around the first time? I think they did. Then I went back down to the DMV. Okay. So you got there the first time with your 15 my mother's maiden name. I went to the Workforce 15 paperwork? 16 on Dr. Martin Luther King Drive, and a guy helped 15 A Yeah. With some paperwork. Yeah. me fax the papers over to hirn. Then I had to send 1 7 Did you fill out any additional paperwork when you some money for the birth certificate. 1s were there the first time? Let me stop you right there because we got a lot A The first time, I think -- no. I think the second of infomiation. A Okay. So this started in January of 15 that you did this? 2 A Yeah And A 3 7 A 8 A 15 16, A A 8 A A A 25 when I took that ID, they gave me the impression (BOO) 8-72

11 ~~~~~~~~~~~~~ ~~~~~~~~~-..., Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 //16 Cassandra Silas Page 28 l they was going to give me my picture ID. When I 1 look at Exhibits 1 and 2. 2 took the ID, I'm under the impression I was going 2 A Okay. 3 to get it. But then I had to stand back in line 3 Are these documents that you filled out at the and see another lady. DMV? s Okay. So you thought you were going to get an ID s A Yes. 6 that first day at the DMV? 6 I see Exhibit 1 is signed January, 15, is 7 A Yeah. The day I went and took the ID and had to 7 that correct, by your signature there? B stand in rain. She got on the phone. She called s A Yes. Page Page 30 somebody in Madison, and I could hear them talking Does that match your recollection of when you went to them. I don't know what they was telling her. to the DMV? But when she got off the phone, she was saying, A Yes. No, you won't be able to get an ID. So you wanted to get an ID to vote, you said; correct? 1s A To vote. 16 And also for when you go to the doctor, you wanted an ID? 1s A Yes. Any other reasons you wanted a photo ID? A Just I need to show who I am because I didn't have that Milwaukee County ID, and that Transit Plus ID only get me so far. You lrnow, I don't have no problem getting my check every month. I don't 2 have no problem getting my food stamps. So why 25 should I have a problem getting my ID to vote? Page 2 1 You know, I was wondering why DMV was giving me a 1 2 hard time. 3 Okay. Let's -- we left off when you were coming back a second time to DMV. s A Right. 6 And you said you brought some additional paperwork 7 then? B A Yes. And what happened after that? A Like I said, they took my ID, told me have a seat, and gave me another number. When she called me, I got in front of her and she was looking at my papers. Then she said, I have to call Madison. And she called them, and I was still standing at 15 her -- at the desk. And when she got off the 16 phone, she said, no, 1 wasn't going to get -- I couldn't get the ID. Had you already filled out some paperwork at the DMV, a petition to get your ID? A I don't remember ifit was the first time or the second, but I know I signed some papers for them to waive it (Exhibit Nos. 1 and 2 marked for identification.) 2 BY MS. SCHMELZER: Do you know whether that was the first or second time? A It's the first time. 1s And then Exhibit 2, is that another form you 16 filled out at the DMV? A Yes. 1a And that's for a free ID; correct? A Um-hum. MR. KAUL: Is that a "yes"? THE WITNESS: Yes, ma'am. BY MS. SCHMELZER: And did you fill these Exhibit 1 and Exhibit 2 2 out -- did you fill those out the same day? 2s A Um-hum. Page 31 MR. KAUL: You need to say "yes" or "no" just so it's clear. 25 Okay, Ms. Silas. I'm going to have you take a 25 didn't talk to her no more. I was talking to my ---~--- (800) THE WITNESS: Yes. I'm sorry. Yes. BYMS. SCHMELZER: s And these are your signatures on these documents? 6 A Yes. 7 And you said that the second time you went back, 8 A T2 A 15 they called Madison and said you couldn't get an ID that day; correct? Yes. What happened after that as far as getting an ID? After that, that's when I started calling downtown to Chicago and I sent -- I sent the money down there. 16 A Yes. Is that what we talked about earlier where you said you started calling back and lb forth? A Yes. 2 o So did anyone instruct you to do that? A No. Your sister, you said you talked to her about that? 2 A Yeah. I talked to my sister about that, but I

12 --~~~~~~~ Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 //16 Cassandra Silas Page Page 32 Page 3 1 daughter. 1 I don't remember the name ofit, but it's 2 Did anyone at the DMV during your first or second 2 downtown. Cook County Hospital is on Harrison, 3 visits tell you that you needed to -- 3 and that building is further downtown. A Yeah. Was it some kind of government office in Chicago? 5 6 A 7 8 A A follow that process? Get my birth certificate, yes. They didn't tell me how to go about and get it. They just wanted me to have that birth certificate. And tell me what happened in your efforts to get that birth certificate from Cook County. I did what my sister told me she did. I sent the money through UPS. How much money did you have to send? l don't remember. I know the -- I don't remember. I really don't. And it was a money order, you said? s A A 15 A 16 Yeah. In Chicago. I don't know if it was the Daily building. I know -- because I've been down there with my mother. I knew it was in the basement where we used to go down there and get our birth certificates. But I never attempted to call the county hospital. When you said you know the building because you would go down and get your birth certificates - With my mother. Okay. When would you do that? When I was a young girl, you know, staying in Chicago, going with my mother. A Yes. It was a money order. So this isn't the first time in your life that A A 2 25 Where did you send it to? I sent it to Chicago, Illinois, and they -- Did you have to send anything along with that, like a form or an application or anything? Just an -- did they send me an application? I sent the money order and just an address and the money order with my name and things like -- that's it. Page 33 A A 2 25 you've had to go get a copy or try - Right. -- to get a copy of your birth certificate? Yeah. When 1 was younger, I didn't get a copy. My mother -- maybe she wanted a copy of hers or try to get her mother's death certificate or something like that. So I been downtown with my mother at that building. Page 35 1 What other infomiation did you have to provide 1 Another family member was getting a birth 2 3 A them? Did I give them a copy of my -- I didn't get them no copy or nothing. I just gave them my name. And I talked to them over the phone, you know, let them know that I was sending it, and they told me how much it costs. They did not tell me it wasn't there at first, you know, when I sent the money or 2 3 A e A certificate? I went with my mother. I remember going with my mother. I remember going by myself before, you know, getting my birth certificate. So you have gotten a birth certificate from this building before? Yes. anything. They just told me how much the birth For yourself? A certificate costs. And did you hear back from them on the status of your birth certificate? Yes. A For myself, for my children, because they was born in Cook County Hospital, three of them was. So we talked about earlier, when you first came to Milwaukee, that someone here had gotten a copy of What did you hear? your birth certificate for you and gave it to you; 15 A 16 I was waiting on my birth certificate. But they sent it back, and they sent some papers with it A correct? Yes, ma'am. Yes. They signed the envelope, telling me they couldn't 1 7 That wasn't the first time, though, that you got find my ID. I had to call Springfield, Illinois, because if it's not down there, the records should be in Springfield, IHinois. 1 s your birth certificate; correct? You said you just --you'd gone to that building in Chicago before? So they couldn't find it at the Cook County A No. That wasn't my first time. A Hospital? No. I didn't call Cook County Hospital. I never So when did you -- when did you first get a copy of your own birth certificate from that building 2 attempted to contact them because it's in another 2 in Chicago? 2s building downtown. I don't remember the building. 25 A Maybe about when I had my first son. --~~~~~~~~~~~~~~~~~~~~~~~~ (800) 8-72

13 ~~~~~~~~--~ //16 Cassandra Silas Page Page 36 Page 38 1 What happened to that birth certificate? Do you 1 Okay. You tried calling the downtown building in 2 recall? 3 A No. I gave it to my mother, I know, to keep it when I was in Chicago to put it in safekeepings 5 for me. 6 Did you ever have to go to that building in 7 Chicago and get a copy of your birth certificate 8 again after that? A No. Do you know if your mother kept that copy of your birth certificate? A No, because I asked her, and she doesn't have it. When did you ask her? A My mother stays up here now. She moved up here. 15 And I asked her last year. When I asked her, 16 Mama, how your last name spelled, your maiden name? And she said H-A-R-P-E-R. And when you asked her last year, she said she didn't have the copy of your birth certificate anymore? A No. So was this when you were filling out this -- going through this process with the DMV that you 2 asked your mom if she had your birth certificate? 25 A After they contacted me and they say they couldn't Page 37 1 find it in Springfield, I said, Mom, you know, 2 they can't find my birth certificate. I want to 3 k:nmv what's going on. They had a copy up here before. And you done got copies yourself, and I 5 had copies of it. Why they can't fmd my birth 6 certificate? 7 And when I talked to the guy on the 8 phone, he said, Do you think a letter is missing? 1 said, Well, yeah. You could check that. And I gave him my sister's and brother's name, and he still said they couldn't find it. I'm going to have you take a look at Exhibit 1. It's the one right in front of you. A Okay. 1s And you have your mother's last name as 16 H-0-P-P-E-R, Hopper. 1 7 A That's wrong. 1 B That was wrong? A Um-hum. Did you correct that at some point with the DMV? A Yes. Do you know when you did that? A I don't know ifl corrected with DMV. I'm not 2 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 sure. But I corrected the birth certificate. I 25 am not sure ifl corrected with the DMV. 2 Chicago first, correct, to get your birth 3 certificate? A Yes. s And they said they didn't have it; is that 6 correct? 7 A They didn't have it. a A Yes. Then you called Springfield, you said? 1 o And they got back to you? A Yeah. I called them. They gave me different numbers to call. And he said ifl couldn't contact him, ask for another lady. I talked to her. It was just real -- then she said, Well, you 15 might have to go in front of a judge. I said, 16 Well, I will ifl have to. 1 7 And who told you that you might have to go in 1s front of a judge? A The lady that I was with. I don't remember her name. Was it the lady in Springfield? A I assume I was talking to someone in Springfield. It wasn't anyone from the DMV? 2 A No. I don't think 25 Sure. 1 A I don't think. You know, they gave me so many 2 numbers that I was taking down. And I was so 3 frustrated and depressed about it. I could have been calling Madison. I could have been calling s Springfield. I don't know. I was just trying to 6 get my birth certificate so I can get my ID. 7 Were you following the instructions that people s Page.3 were giving you when you said you were calling all different places? 1 o A Yes. What I understood. Some of it, I didn't understand. When she told me to call my -- when she told me to call my high school, I understood. She gave me the number, and I called. But they say they don't no longer hold the records, and she 15 gave me another number to call their school board. 16 Do you know who you were talking to when they told you to call the school? A No. It was on the letter. It was on the letter they sent me, all I can do to obtain a birth certificate. (Exhibit No. 3 marked for identification.) BY MS. SCHMELZER: Ms. Silas, I want to have you take a look at 2 what's been marked Exhibit 3. 2s A Okay. (800) 8-72

14 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 //16 Cassandra Silas Page ~ ~~ Page 0 Page 2 I ~ Do you recognize this letter? And take yom time, 1 THE WITNESS: Yeah. Okay. Um-hum. 2 please. 2 Yes. 3 A Yes. I probably did get this letter, but I really 3 BY MS. SCHMELZER: don't remember all this. And like I told the And I'll ask my question again. Is there anything lawyer-- MR. KAUL: I'm going to instruct you not to give any information of what you told any A in this letter that is confusing to you or not consistent with your memory? No. 8 lawyers. 8 So I think we left off where you said you had THE WITNESS: Okay. Okay. Like I said, me and my daughter -- I was moving. And we had to move. And the landlord didn't give us a lot of A called your high school and tried to get your school records; correct? Yes. time. A lot of my papers, I couldn't take them Were you successful in getting any school records? with me. So, you know, I don't remember. A No. I had called them -- I had called them, like, BY MS. SCHMELZER: in October -- no. I had called them, like, in 15 Do you remember getting some letters from DMV, or 15 this year and -- not Manley. The school where 16 a letter at least? 16 they had the records at. A Yes. And did that Jetter tell you you could get school The lady's name that I had wrote down, she wasn't in. So the lady told me to leave my records that might help with getting an ID? name and my phone number. She'll get back with A Yes. you tomorrow. No one called. So no. And was it something sort oflike this Exhibit 3? Did you follow up again after leaving your name I know you can't say for sure. and phone number and no one called back? A Yes. Something like this. A No. Because I'm fmstrated. 2 And I know there's some on the back too. It's a 2 I know you said you recall getting a letter from 25 two sided copy. 25 the DMV. I know you said you didn't recall if it ~~~--+~~~~~ Page 1 Page 3 1 A Right 1 was this exact one or not, but something like 2 Okay. 2 this; correct? 3 A Okay. Can you answer questions? I know -- 3 A Yes. MR. KAUL: Let me interject. You and I Did you get any other letters from the DMV 5 can talk after the deposition, but she doesn't -- 5 regarding your efforts to get an ID? 6 her job is to ask the questions today, not answer 6 A Yes. The last letter, I didn't understand it. 7 any. Okay? 7 When did you get that last letter? a THE WITNESS: Okay. a A In March. Maybe April. Maybe April. Sorry. MR. KAUL: Does that make sense? April. THE WITNESS: Yeah. Okay. (Exhibit No. marked for identification.) BY MS. SCHMELZER: BY MS. SCHMELZER: And let me ask this, Ms. Silas. Is there anything Ms. Silas, can you take a look at Exhibit No.. on this letter that is confusing or doesn't match MR. KAUL: And, Jody, let me stop you up to your recollection? MR. KAUL: And let me just say for Ms. Silas's attention, because I'm not sure if she caught it when you said it before, that letter is two-sided, so there's a back side to it too. I want to make sure you saw that. THE WITNESS: Oh, okay. MS. SCHMELZER: On the back. Yeah here. I'm going to object to any questions related to Exhibit. Ms. Silas was a represented party in this case at the time that she received this letter. It, frankly, shouldn't have been sent to her. And so she was subject to the advice of counsel in this case in connection with her actions related to this letter. So because of MR. KAUL: I'm sorry. Youmightwantto that, I'm going to object to any question related ask the question again. to this. 2 MS. SCHMELZER: Sure. We'll give her a 2 MS. SCH!'vffiLZER: I'll just ask if she 2s, chance to review it. 25 received it. (BOO) 8-72

15 .i ~~~~~~~~~~. //16 Cassandra Silas Page Page Page 6 1 MR. KAUL: That's fine. 2 BYMS. SCHMELZER: 3 Did you receive this letter that's marked as s A 6 7 Exhibit? Yes. So after you tried to get your school records, did you take any other efforts to try and get a birth 8 A certificate or any other documentation to help you get that ID? I was going to try to write a letter to him in Springfield again, because they had wrote me a letter last year, I think, and said the money I had sent them, they was going to keep ifl A A Did you go to the doctor before you went to the DMV to get your ID? No. I went to the DMV. When did you go to the doctor and have them hold that medicine for you? The day of my appointment I had. I don't remember couldn't come up with nothing else to prove who I ifitwasin15. ljustdidn'tgo. Ijust 15 am. 16 Now, I'm t1ying to call you all because 1 7 my birth certificate should be somewhere in 1s Illinois. It's not my fault. And, yes, I did. So you said -- A I was going to write the Jetter, but I didn't get to do it. No. Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 15 of 2 So after trying to get your school records, was there any -- and you tried to write a letter, but 2 you didn't, was there anything else that you did 25 to try and get those documents to get your state Page5 l ID? 2 A No. I was going to try to -- after that, I tried 3 to contact Cook County Hospital. That was going to be the last thing I could come up with. 5 Because ifl had gave the doctor that $300, that 6 would have been $300 just gone down the drain, 7 because DMV -- how I got it, I assumed that they 8 was going to give me -- because they kept telling me to come back. Come back this day; come back that day. I assumed that they was going to give me my ID so I can show the doctor the ID. So the lady, she say, Well, I'll hold the prescription until you can bring the ID back. But the hospitals had all -- they had pictures of 15 my ID, you know, the ID that they took from me 16 that they accepted because they knew who I was. Okay. So you had given the doctor some money, thinking that you could go get an ID and come back? A Yeah. I had to pay, because they ain't take my msurance. And that was $300? A Yeah. I didn't give it to them. I was going to 2 give it to them, but I didn't have no ID. I told 25 them I went down to the DMV. They got all my records from the hospital, you know, showing, you know, my illness and everything. So they say, Well, since you -- because they had took my ID. Since we took your ID, we're going to hold it. They want me to pay them the money, and they was going to hold my prescription. So I declined. I just said no. 15 didn't go to that doctor anymore. 16 Have you been able to get that prescription since then? lb A I went to another doctor. They accepted my transportation ID. Plus, I come from another -- come from Froedtert Hospital, so they knew who I was. Other people, I've been here close to over -somc years. My daughter,vas five when I came up here. So they knew who I was. 2 At the new doctor that you went to? 25 A No. From the old doctor -- from the old doctor, -~---< Page 7 1 the new doctor taking, you know, my-- I be 2 forgetting what I'm going to say. 3 That's okay. A When they take x-rays and everything like that, s MR-- 6 MRI? 7 A Yeah. Taking that. So they have my name and B everything, so I didn't have no problem getting into the new one. So you said that you tried to contact Cook County Hospital? A No. I said ifl knew I can get it from -- that's why I said I didn't understand. If I knew I can call Cook County Hospital where I was born, I 15 would have been -- had called them before I even 16 called Manley High School. 1 7 Did you try and call Cook County Hospital? 1s A No. Because I really didn't understand. I was under a lot of stress, you know, with moving, and I didn't understand some ofit. Have you done anything else to get any additional documents to get your state ID, anything else besides what we talked about already? 2 A No. 25 I don't think I have that much more, but I want to (800) 8-72

16 ~~~~~~~~~~~~~~~~~~~ //16 Cassandra Silas Page 15 Page 8 Page 50 l B A talk a little bit about -- you said one of the 1 You voted in a presidential election? 2 reasons you want it is to vote; correct? 2 A Yeah. Remember, you saying the one they took out 3 A Yes. 3 and then they said we didn't need one? Did you vote regularly before the ID requirement Yes. 5 came into place? 5 A Yes. I voted. 6 A Yes. 6 I know you said you wanted to come down and vote 7 When did you first start voting in Wisconsin? 7 early. Absentee, I believe they call it. When did I first start voting? I started s A Yep. voting -- I've been started voting. Do I have to Is that something that you had ever done before say who I voted for? when you did vote? No. You don't have to tell me that. No. Just A No. But I want to try it, you know, and I wanted wondering if you remember what kind of election it to do it before -- you know, I want to try it.out, was. That would be helpful. you know, do it early, because I have surgery I'm A It was president elections. thinking about having for my knees, and I want to, 15 Do you remember who any of the candidates were? 15 you know, get it done. Because I'm thinking about 16 A Yes. Clinton and Obama. And Clinton before that 16 having it in the fall. So I would like to have I'm assuming that was Bill Clinton. it. A Yes. Bill Clinton. If they gave you the two weeks before the election So presidential elections? to do that, would that be enough time to come down A Yes. Mostly. early and vote? Did you vote in any other elections when there was A If they gave me two weeks? Can you explain? no presidential election? Sure. lfyou could come down and vote for two A No. weeks before the election, come in person and vote 2 Do you know about how many times you voted here in 2 with that absentee ballot, would that be enough 25 Wisconsin? 25 time for you? Page Page 51 1 A 2 3 A A A Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page 16 of 2 About how many times? I don't remember. I don't remember. But mostly was for presidential. So every four years? Yeah. Would there have been any times you would have voted between the presidential elections? Yes. Like the one -- I wanted to vote this time. I wanted to vote, you know -- I would like to sometime vote before -- you know, come down and vote.before, you know -- I forgot what you call it. Before the time of the vote, you can vote early. I be wanting to come and do that, and I wanted to vote the one that they had in Wisconsin when they had the democrat and republican, but I know I couldn't do it. Was that a couple weeks ago - Yes. -- in April? Did you vote in any elections -- I know there was one in that had the voter ID requirement, and then it stopped for a little bit, and then it came back on. Did you vote in any of those elections in between there? 2 A The one when I don't need an ID. Yes. 25 Presidential. Right. 1 A Yes. 2 Did you ever have to register to vote in one of 3 those presidential elections that you said you voted in? s A Did I have to register? 6 Yeah. Did you move where you had to register or 7 were you already in the poll books? s A Sometime I had to register. Most times I was in the books. 1 o So you've never had any problems with bringing proof of where you live or anything? A No. Have you ever been married, Ms. Silas? A No. 15 Have you ever opened a bank account since you've 16 been here in Wisconsin? A No. Have you applied for a job since you've been here in Wisconsin? A Yes. Did the fact that you didn't have a state ID affect that process at all for you? A No. 2 Have you ever bought a home here in Wisconsin? 25 A No. (800) 8-72

17 . I //16 Cassandra Silas Page ~-~ Page 52 Page 5 1 I know airplanes and trains require some type of 2 photo ID. Have you traveled outside of Wisconsin 3 on an airplane -- A No or transit like that? 6 Before becoming a plaintiff in this 7 lawsuit, did you ever work with or volunteer for 8 the groups One Wisconsin or the Citizen Action of Wisconsin? A No. Do you belong to any other civic type of organizations? u A No. Or any civil rights type of advocacy groups? 15 A No What about any political advocacy groups? Do you 16 belong to any of those? 1s A No. Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 1 A Yes. 2 Can you explain what you understand this form to 3 say. A What I understood, they say I misspelled my 5 mother's name. And then they come to say "and you 6 were born at Cook County Hospital." I was born in 7 Cook County Hospital. B What else do you understand the form to say? A Besides No. 3? 1 o Just overall. What do you understand the form to say? A Okay. I didn't understand that the DMV here was talking to -- who was they talking to in Chicago -- well, Springfield, Illinois, Cook County, Chicago, Illinois, who was they talking to about my record? I didn't understand that. I thought I was always talking to somebody in Springfield, not no one in Madison. I didn't MS. SCHMELZER: That's all I have, Josh. understand that. MR. KAUL: I have a few really quick No., Wisconsin Vital Records Office things. Are you okay to go right into it? returned the amended petition application MS. SCHMELZER: Sure. reporting the State of Illinois could still not EXAMINATION verify the birth records on the file. DMV 2 BY MR. KAUL: 2 compliance staff contacted Cook County Hospital. 25 You were asked a few questions about your trip to 25 I didn't even know they was contacting my hospital Page 53 p;ge 55 1 the DMV before, and you said a few times that you 1 I was in. 2 had -- the DMV took your ID orthe DMV had your 2 And my question, I guess, is broader. 3 ID. I just want to make sure we're clear what you 3 So what do you understand the form meant by that. overall to be telling you? 5 A Okay. s A That I needed some more -- if they was contacting 6 Did you mean that the DMV took your picture when 6 Cook County Hospital, okay, why they don't have 7 you were there so they have a copy of your 7 any information? They got my birthday. I gave s picture? B them my birthday and everything. So if they was A Yes. contacting Cook County Hospital, why they couldn't Okay. The second thing I was going to ask you get no infonnation about me? about, you said that when you had your first sor1, I'm a citizen. My mother had me there. you went to get a birth certificate. I was born there September the I 8, 67. Why they Do you remember that? couldn't -- why they couldn't get -- why there A Yes. wasn't enough information for them to get me an 15 Were you going to get-- whose birth certificate 15 ID? 16 were you going to get when you had your first son? 16 Let me ask you about the back of the form. Can 1 7 A My oldest son, Alfred Silas. He didn't come to 1 7 you take a look at that? 1s Milwaukee with me. 1s A Okay. So it was his birth certificate you were getting? Did you read through this part earlier today? 2 o A Yes. Because I only had him. A Yes. And then the last one I want to ask you about is What do you understand the back of the form to be Exhibit 3, which is this one right here. telling you? A Um-hum. Okay. A Okay. They saying baptism certificate. I was 2 Can you just -- you read through this before 2 baptized. Church, it's not even -- I don't know 25 today; is that right? 25 if it's still standing. I haven't been to Chicago (800) 8-72

18 Case: 3:15-cv-0032-jdp Document #: Filed: 05//16 Page of 2 //16 Cassandra Silas Page Page 56 Page 58 l in maybe 15 years or longer. Okay? 1 three children came. 2 The hospital birth certificate -- that's 2 When the intake worker, she was doing what I'm saying. I don't understand. Okay. If they could use the hospital birth certificate, they say they contact them, why they couldn't get the hospital birth certificate? What they gave me in the hospital is not the welfare, getting me on, she signed for me and my three children: Alicia Silas, Gabriel Tolbert, Laval Tolbert. And Cassandra Silas. She signed for all four of ours to be sent to Milwaukee, Wisconsin. 8 a real birth certificate. It's just my name, a 8 And I think you said -- I asked you did you ever footprint ofmy baby. And, like l said, we go to the birth certificate place to get the birth certificates then. Now it might be different. ask your mom for that birth certificate because I thought it was yours. And you said, yeah, I did ask her. And what I didn't understand is delayed Did you ask her for the one that she birth certificate and the census record. Where already had of you? Is that what you're saying? would I get a census record from? A Yes. 15 Anything else you understood this form to be 15 And she didn't have that anymore? 16 telling you? 16 A She's 70 years old. She done move so much, she A Okay. The other documentation the DMV accepts is don't -- no. proof of name, date of birth, or United States citizen. So, okay, I could get something with my MS. SCHMELZER: I have nothing further. THE WITNESS: Okay. name on it, and they know it, and my b:i.tthday. (Deposition concluded at 3:08 p.m.) 2 25 And I'm a United States citizen. So why they still holding my ID from me? MR. KAUL: Okay. l don't have any more questions for you. Ms. Schmelzer might have a few more. Page Page 5 1 THE WITNESS: Okay. 1 STATEOFWISCONSIN ) ) SS: 2 EXAMINATION 2 COUNTY OF MILWAUKEE ) 3 BY MS. SCHMELZER: 3 I, Lindsay De Waide, a Registered Merit I just want to follow up on -- you told us when Reporter, Certified Realtimc Reporter, and Notary 5 you were you went to the place -- the building 5 Public in and for the State of Wisconsin, do hereby 6 in Chicago that had the birth certificates, and 6 certify that the preceding deposition was reported by 7 you told me that you got one for yourself, your 7 me and reduced to writing under my personal direction. 8 birth certificate. 8 I further certify that said deposition was A No. For my son. I was trying to get on welfare taken at MILWAUKEE STATE OFFICE BUILDING, 8 North 6th with my baby. 1 O Street, Milwaukee, Wisconsin, on the st day of Apn1, So you didn't get one for yourself, then? 16, commencing at 1 :6 p.m. A No. My mother already had one for me, I further certify that I am not a relative or Did you yourself ever go to that building and get employee or attorney or counsel of any of the parties, a birth certificate for yourself? or a relative or employee of such attorney or counsel, 15 A I don't remember. I probably did. I don't 15 or financially interested directly or indirectly in 16 remember for myself, but I know for my children, 16 this action. 1 7 I probably did get one for myself, but I don't 1 7 In witness whereof, I have hereunto set my remember. hand and affixed my seal of office at Milwaukee, And when you said that you gave that birth Wisconsin, this 25th day of April, 16. certificate to your mother, that was your son's birth certificate? A Yeah. For her to keep. But she had my birth - LINDSAY DEWAIDE, RMR, om- Notary Public, State of Wisconsin certificate. So I had the welfare in Chicago - My Commission Expires: January,. 2 they had all of ours, me and my four children. My 2 25 oldest son didn't come to Milwaukee with me. My 2s (800) 8-72