A month prior to that Hayes and Ferguson were slated to give the projects? Yes by that document.

March 19th 2004- document from Awni Qaqish to DLZ. Regarding contract CM 2012. Awards contracts to the 3 lowest bidders Posen, L D'Agostini and Lanzo for 654,655, and 656.

Witness says they are big but Walbridge is bigger as is Inland. Posen, D'agostini and Lanzo not minority owned.

Rataj says this document about a month after the text message we read of February 18th? Yes.

You are aware that DLZ had bonding issue for 2012? They were never asked for it says witness so I wouldn't call it a bonding issue.

DLZ just managed the execution of these contracts? Yes.

Rataj brings out another document. Message from Michael Faith with DLZ on March 19th 2004, same date as previous document, addressed to Daniel Edwards at DWSD. Lists contracts under CM 2012. Has the numbers WS 642 for Hayes, WS 649 Hayes, WS 650 and 651 for Ferguson, Eagle construction had WS 653, Posen had 654, 655 for D'Agostini and 656 for Lanzo. So those were contractors for those contracts? Yes says witness.

So there was a contract not listed that is not awarded? no it's here.

Wasn't there a 657? I'd have to see something to refresh my memory sir.

At this point, there is one minority contractor who has been awarded a contract?

Rataj and EPA agent get into it a little bit.

Witness says that she needs to see contract file to see chronology of events.

As of this date it looks like it has been awarded? It is absent from the document, yes.

Document from April 1 2004, 2 weeks after previous document, to Pratap at DLZ. Asking to assemble contract documents for 657 to be awarded to Willie McCormick.

McCormick had contract 657? He did.

How many messages did the government obtain from the defendants and others? Somewhere between 300,000 and 500,000.

How many texts being used in this trial? About 200.

Would you says that Ferguson is someone who has tremendous racial pride? Pride asks witness.

He's proud to be a b lack man? I would hope so says witness.

He's a type A personality? "So am I" says witness.

And he wanted to help other black people? Yes.

He did speak in colloquialisms- Rataj can't spit it out and says "you know what I'm taking about".

"He used street language!" says Rataj.

He used Black Man as salutation? Yes he did says witness.

He called Kwame Black? Yes he did.