• A client of ours, Chris Sheffield, was sued for wrongful death and has been charged with involuntary manslaughter. We are representing him in both cases. Part of the case involved us requesting certain public records from the recorder's office. We were provided with a copy of a deposition conducted previously with a recorder's office employee, Lawrence Patterson, which we might want to use in his defense. A copy of the has been provided for you:

Paraphrasing Tool | QuillBot Al X View Assessment X 5 Deposition Transcript.pdf X + C @ File | /Users/megan/Downloads/Deposition%20Transcript.pdf = Deposition Transcript.pdf 1 / 74 Paused 100% + HO IN THE SUPREME COURT OF OHIO ORIGINAL ACTION IN MANDAMUS Phe STATE ex rel. DATA TRACE INFORMATION SERVICES LLC, ET AL. , Relators, VS . Case No. 2010-2029 RECORDER OF CUYAHOGA COUNTY, OHIO Respondent. 2 DEPOSITION OF LAWRENCE PATTERSON Thursday, December 30, 2010 Deposition of LAWRENCE PATTERSON, called by the Relators for examination under the Federal Rules of 3 Civil Procedure, taken before me, the undersigned, Rebecca L. Brown, Registered Professional Reporter, Notary Public in and for the State of Ohio, at the offices of Baker & Hostetler LLP, 1900 East Ninth Street, Suite 3200, Cleveland, Ohio 44114, commencing at 1:07 p.m. the day and date above set forth.Paraphrasing Tool | QuillBot Al x View Assessment X 5 Deposition Transcript.pdf X + C @ File | /Users/megan/Downloads/Deposition%20Transcript.pdf = Deposition Transcript.pdf Paused 2 / 74 100% + APPEARANCES : On Behalf of the Relators: David L. Marburger, Esq. Jack Blanton, Esq. Baker & Hostetler LLP 1900 East 9th Street Suite 3200 Cleveland, OH 44114-3485 dmarburger@bakerlaw . com On Behalf of the Respondent: Matthew Cavanagh, Esq. 2 McDonald Hopkins LLC 600 Superior Avenue East Suite 2100 Cleveland, OH 44114 216-348-5400 mcavanagh@mcdonaldhopkins . com - - 3Paraphrasing Tool | QuillBot Al x View Assessment X 5 Deposition Transcript.pdf X + C @ File | /Users/megan/Downloads/Deposition%20Transcript.pdf Paused = Deposition Transcript.pdf 4 / 74 89% + MR. CAVANAGH: I just want to state on the record that AWNH Mr. Patterson is here today solely because the Relators have issued a subpoena compelling him to be hore today for deposition. He's not here under Rule 30 (b) (5) , and, in fact, the Relators have not issued a Rule 30 (b) (5) Notice to the Recorder in 10 this case. 11 Mr. Patterson is not testifying 12 on the Recorder's behalf here today, 2 13 and the Recorder has not designated 14 him to testify on its behalf today. 15 He's instead here testifying as an 16 individual. 17 It is the Relators, and not the 18 Recorder, who have chosen 3 19 Mr. Peterson to testify here today. 20 The Recorder therefore objects to 21 the extent the Relators attempt to 22 uso Mr. Peterson's testimony as that 23 of the Recorder's office. RUMAH 24 MR. MARBURGER: I take 25 exception to the objection. TheParaphrasing Tool | QuillBot Al X View Assessment X 5 Deposition Transcript.pdf X + C @ File | /Users/megan/Downloads/Deposition%20Transcript.pdf Paused = Deposition Transcript.pdf 5 / 74 89% + Rules of Evidence will decide how we can use Mr. Patterson's testimony. MR. CAVANAGH: I'm sorry. I AWN called you Peterson, Mr. Patterson. LAWRENCE PATTERSON 2 called by the Relators for examination under the Federal Rules of Civil Procedure, after having been first duly sworn, as hereinafter certified, was 10 examined and testified as follows: 11 EXAMINATION 12 BY MR. MARBURGER: 3 13 Q I'm David Marburger. I represent two companies 14 that have asked for electronic copies of records that 15 are recorded with the Recorder's office and have sued 16 the Recorder to get those copies, as well as to try 17 to compel the Recorder to charge less money than the 18 Recorder had wanted to charge for electronic copies 19 of the records that these companies have asked for. 20 One is called Data Trace Services, and the other one 21 is called Property Insight. 22 Would you state your name and spell it. 23 A Lawrence Patterson, L-A-W-R-E-N-C-E -- 24 Well, not that part, but the Patterson. 25 A Patterson, P-A-T-T-E-R-S-O-N. 5