Talked about 10 witnesses about 501c4. Mr. Leeman talked about broad scope of 501c4- education regarding legislative issues. all things that you see in original articles of incorporation and restated ones from July 2001. 

You can see bills from William Phillips for activity from about May 2001, July 2001 when articles are restated. On August 26th when newsflash happened about Jon Rutherford and real estate business in August 2001. 

Bob Berg was present at political meetings. Berg obviously there for Civic Fund issue. why is this important? As it was with Cadillac Escalade, as it was with polling. Gary Leeman said you can apportion certain expenses that were considered by the board. shortly before this Kwame had resigned and Civic Fund was run by Christine Beatty, miller and others. 

when they want to ascribe criminal culpability to Kwame, I want you consider between 2002 and 2007, the government is concerned with $13,000 expenditures in question. 

Between 2002 and 2007, there was $1,725 million in contributions. 

Now looking at alleged personal expenses for person who didn't take a salary. 

Personal expenses: $13,953 out of $1.725 million. 

As a result of text message scandal, he was prosecuted, had to resign position and went to jail. Before he went to jail, William Phillips met with the board at the Manoogian Mansion dining room table. after Kwame left, there was a vote of the board to pay for some of his housing, his moving expenses a certain portion of which were reimbursed. he had no money and was going to jail. 

April Edgar testified about her experience and what she thought. That testimony is measured a little bit. You heard from Erik Rayford who was at the meeting. Kwame didn't tell anyone to do anything. The board decided because he was in need. The board action was taken and they independently considered they did the right thing, why is Kwame Kilpatrick here? 

You heard about the Lacosta Resort. You know that the image of Detroit is important. He takes a trip to Lacosta, he is the mayor of Detroit and his wife is the first lady. 

I asked Carol Paszkiewicz why she testified that Kwame signed CM 2012. When I asked her on cross if she was sure, she said yes but she didn't have a copy. 

On the next day, there is no signature on the document. Victor Mercado's signature is on it but not Kwame's. 

Heard from special agent Ron Sauer who told us he had no expertise on 501c4. but that changed from first cross to a month later. He gave his opinion on what he thought were proper expenditures. 

We had Gary Lemman, sweet guy got sick and couldn't come back. Government brought Mr. Carl Selz who is not a special agent. He sat throughout the trial and was supposed to be independent. Selz has only testified in 2 cases but Leeman testified in 150. he came in to offer independent opinion on what Sauer said or couldn't say. He wasn't independent because he is on the government's payroll. He rubberstamped what the government said. 

Here is a man who cam here and said he was part of Certified Fraud Examiners. "He had to eat it the next day." He actually was not certified because he had been suspended 2 years earlier for failing to take his credits and he was not up to date. 

There are time in this case when I see the government has extended itself too far. this is one of them. 

There are times when agents have gotten chippy in a hockey way, argumentative and pushed back. 

If there is gifting going on, isn't that a sign? When government tells you they have eliminated every possibility for cash, is that advocacy? 

The cash receipts showing that he spent more than he had in income is a flawed account. Gary Leeman talked about science. to the extent that they ignored income that Kwame and Carlita earned before 2002, that's a flaw. You're going to see his income tax records for the three years prior, they made $375,000 in adjusted income living on Leslie with little expenses. 

Carlita's accounts weren't considered. He is trying to do cash analysis- is that scientific. 

When he says there is no evidence of gifting. Carolyn Cheeks Kilpatrick giving $4,000. special agent Sauer going to Athenaeum to check Marvel Cheek's 90th function which by the way was a Civic Fund thing. He had a 90th birthday and tried to make it a community function. 

That's the same place he had the "Splash of Red." Sophie Plastiras told you there were $1,500 people for his party and they gave as much as William Tandy. You do the math, i don't want to do it. $15,000. that's evidence of gifting the government missed as his 30th birthday and wedding. 

They haven't talked to employees and appointees. 

Sharon McPhail talked about cash gifts. We know it's not 15 because he got a Rolex watch and a trip for his family. Other than that, there are 13 potential gift raising events. You heard from Kizzi Montogomery and Sharon McPhail who talked about the appointees at base giving $25 to $50, directors giving $500. There were well over 20 directors. there were 10 cabinet members at $1000. Multiply that by 13. 

Government's graph did not rule out non-taxable income. Government completely ignored gifts and loans. You can't ignore that.