Dillon: I don’t recall.

2:50 p.m.

Green: Do you recall getting an email on June 7th from Kevyn Orr?

Dillon: No. It said ‘based on this we expect a significant reduction in already accrued benefits… and the only way to address this would be in a chapter 9.

Dillon still did not recall receiving the email but he did say, “I remembered the numbers getting worse and did not have a lot of confidence in the numbers we received.” 

As of July 9th Dillon said he “did not know what the underfunding of the pensions were and I had not seen a set of numbers that told me what the actual number was.” 

Dillon: I thought it best to at least to see if there was common ground to determine what the underfunding was and then you can go from there. 

Dillon believed there were creative options to deal with pensions.

Green: Did you ever share them with anyone, the unions or retirees?

Dillon: No

Green: What changed between July 9th and July 18th? You said something different today than deposition.

Dillon: The pensions were not the major driving issue for me to file. Out of 18 billion that number between what the city’s were and the unions was relevant but not a driving factor as to whether 9 was necessary. Nothing gave me reason to call the governor to say things are better or things are worse.

Green: There was as general understanding that pensions were protected. The governor and Kevyn Orr understood the constitutional protection existed. It was talked about early on and had to be grappled with.

Dillon: The discussions that the state was not responsible for local pensions and there was also the issue of the constitution.

Green: Do you recall citing this constitutional protection to unions prior to filing?

Dillon: I don’t recall.

3 p.m.

The courts will ultimately decide what would happen with pensions and the constitutional requirements

Dillon: It was pretty clear that I was prohibited to lend money to local government. I swore an oath to uphold the constitution and I did.

Green: And if there were

Dillon: If I had loaned money to a local form a government it would have been in violation of the constitution.

Green: How about with the pensions? Were you concerned about violating the constitution there?

Dillon: I don’t know that that provision influenced him [the governor] in any way. We had it in PA72, Pa 4 and PA 436 it was always there.

Green: Do you recall receiving a memo about pension obligations and the constitutional protection in June of 2012?

Dillon: I don’t have a direct recollection.