1 STATE OF INDIANA ) ) SS: 2 COUNTY OF MONROE ) 3 IN THE CIRCUIT COURT OF MONROE COUNTY 4 CAUSE NO. 53C06-2203-PL-000509 5 6 COUNTY RESIDENTS AGAINST ANNEXATION, ) INC., an Indiana not for profit ) 7 corporation, et al., ) ) 8 Remonstrators/Appellants/Petitioners, ) ) 9 -vs- ) ) 10 THE COMMON COUNCIL of the City of ) Bloomington, Monroe County, Indiana, ) 11 et al., ) ) 12 Respondents. ) 13 14 DEPOSITION OF LEE RHYNE 15 16 The deposition upon oral examination of LEE RHYNE, a witness produced and sworn before me, 17 Janine A. Ferren, RMR, CRR, CSR-IL No. 84-4852, Notary Public in and for the County of Hamilton, 18 State of Indiana, taken on behalf of the Respondents, at the offices of Bloomington City 19 Hall, 401 North Morton Street, Bloomington, Monroe County, Indiana, on the 1st day of March 2024, 20 scheduled to commence at 12:45 p.m., pursuant to the Indiana Rules of Trial Procedure with written 21 notice as to time and place thereof. 22 23 24 25 2 1 APPEARANCES 2 FOR THE REMONSTRATORS/APPELLANTS/PETITIONERS: 3 William J. Beggs BUNGER & ROBERTSON 4 211 South College Avenue Bloomington, IN 47404 5 812.332.9295 wjbeggs@lawbr.com 6 7 FOR THE RESPONDENTS: 8 Andrew M. McNeil 9 Stephen C. Unger BOSE McKINNEY & EVANS LLP 10 111 Monument Circle Suite 2700 11 Indianapolis, IN 46204 317.684.5000 12 amcneil@boselaw.com sunger@boselaw.com 13 14 ALSO PRESENT: 15 Margaret Clements 16 17 18 19 20 21 22 23 24 25 3 1 INDEX OF EXAMINATION 2 Page 3 DIRECT EXAMINATION . . . . . . . . . . . . . . .5 Questions by Andrew M. McNeil 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 1 INDEX OF EXHIBITS 2 Deposition Exhibit No.: Page 3 Exhibit 52 - Handwritten notes beginning 23 with "Set for 1A & 1B" 4 5 6 7 Previously Marked Exhibits: Page 8 Exhibit 28 - Amended and Supplemented 23 Answers of County Residents 9 Against Annexation, Inc. to City of Bloomington's 10 Interrogatories 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 1 (Time noted: 12:34 p.m.) 2 LEE RHYNE, 3 having been duly sworn to tell the truth, the whole 4 truth, and nothing but the truth relating to said 5 matter, was examined and testified as follows: 6 7 DIRECT EXAMINATION, 8 QUESTIONS BY ANDREW M. McNEIL: 9 Q Please state your name for the record. 10 A My name is Lee D. Rhyne. 11 Q Mr. Rhyne, we met just before we went on the 12 record. My name is Andrew McNeil. I'm one of 13 the attorneys for the City of Bloomington in the 14 annexation remonstrance case. 15 Have you ever had an opportunity to give 16 deposition testimony before? 17 A Yes, I have. 18 Q How many times? 19 A On one other occasion. 20 Q How long ago was that? 21 A It must have been almost 20 years ago. 22 Q Well, the process remains the same; the 23 technology may have upgraded some. I'm going to 24 ask you a series of questions, and your job 25 today is to answer them as truthfully and as 6 1 completely as you can. Do you understand that? 2 A I understand. 3 Q If you don't understand my question, will you 4 let me know? 5 A Yes, I will. 6 Q If I need to rephrase something or you didn't 7 hear me, will you let me know that too? 8 A No doubt. 9 Q Excellent. This is probably going to be about 10 30 minutes, give or take. 11 A Okay. 12 Q Even so, if you need to take a break for 13 whatever reason, will you let me know? 14 A Sure. 15 Q Did you do anything to prepare for the 16 deposition today? 17 A Yes. I spoke to friends, neighbors who have had 18 objections to the annexation, and tried to get 19 as much input as possible to come here and speak 20 today. 21 Q All right. Let's write that down, we'll come 22 back to that in a second. 23 In addition to speaking to friends and 24 neighbors and collecting information from them, 25 did you do anything else to prepare for the 7 1 deposition? 2 A Not really. I looked over previous 3 correspondence that I've had from the City just 4 to prepare myself and be aware of what's 5 happening here. 6 Q And the correspondence from the City you're 7 referring to, are those materials you would 8 receive from time to time about the annexation? 9 A Correct. 10 Q Anything else to prepare? 11 A None at all. 12 Q What is your address? 13 A 701 West Hedgewood Drive, Bloomington, Indiana 14 47403. 15 Q Is that in Annexation Area 1B? 16 A I believe it's in 1A. 17 Q Which part of town is it? Is it west or south? 18 A It's south. 19 Q How long have you owned that property? 20 A Since 1996, so 28 years. 21 Q Does anyone live there with you? 22 A Yes. 23 Q Who? 24 A My wife. 25 Q So you and your wife, have you both lived there 8 1 since 1996? 2 A Correct. 3 Q Do you own any other property in Annexation 4 Area 1A or 1B besides the Hedgewood Road 5 residence? 6 A That is my sole property. 7 Q Do you work? 8 A I do have a little side hustle. 9 Q What do you do in your side hustle? 10 A I am a bank courier. 11 Q Are you otherwise retired? 12 A Otherwise retired, correct. 13 Q Where did you retire from? 14 A I retired from FedEx. 15 Q When you worked for FedEx, what location? 16 A Here in -- I managed a location here and in 17 Columbus, Indiana. 18 Q Do you have any present plans to move, sell your 19 house? 20 A Not at this time. Perhaps if this annexation 21 goes through, it certainly would affect, you 22 know, my decision to move and to sell. 23 Q In what way? How would it affect that decision? 24 A I think that the economic impact that it would 25 have on me. I'm pretty much on a fixed income 9 1 and social security. My wife retired in June, 2 and so we have her small retirement and social 3 security. 4 Q Where did your wife retire from? 5 A The school system, MCCSC. 6 Q Have you looked at potential relocation options? 7 A I think that if we looked at options, it would 8 be probably Greene County or a move to Hendricks 9 County. It would put us a little closer to good 10 medical facilities. 11 Q If I understand your current mindset, you're not 12 currently looking to move; is that fair? 13 A I'm not currently looking to move, no. 14 Q You said one concern you would have if the 15 annexation went forward was the economic impact 16 it would have on you. What specific impact are 17 you thinking of when you say that? 18 A Well, I'm thinking about, you know, the 19 increased taxes and if this would impact the 20 County. Would it cause the County to increase 21 their taxes? 22 MCCSC has had two referendums the last two 23 voting periods. So you know, as things continue 24 to -- prices continue to increase, we're looking 25 at every opportunity, you know, to save our 10 1 cash. 2 Q And the "we" in that sentence is you and your 3 wife? 4 A Me and my wife, correct. 5 Q Have you looked into, if the annexation were to 6 occur, what your new annual property tax 7 liability would be? 8 A I'm not sure of where this amount came from, but 9 I seem to have heard that we're looking at 10 between 600 and $1,200 per year. 11 Q And I understand you front loaded that answer 12 with saying you can't remember where it came 13 from. 14 A I can't remember the source. 15 Q Can you help narrow down what the potential 16 sources could be based on what you've looked at 17 or read or heard in the past? 18 A I'm not sure if it was from the paper or from 19 some of the critics of this annexation. I 20 remember the source seemed very credible. And 21 it was pretty much an average, if I can remember 22 correctly. 23 Q Do you remember the time frame where that 24 information came to your attention? 25 A It probably was a little more than a year ago, 11 1 maybe a little longer. It was during the 2 pandemic, probably '20, '21. 3 Q Did you attend any informational meetings or 4 gatherings at the county fairgrounds? 5 A Yes, I did. 6 Q Was there information available there about the 7 potential property tax increase? 8 A I was in and out of there pretty quick because I 9 saw that my help, you know, was not needed. 10 There was adequate coverage and people 11 disseminating information, so I didn't think my 12 help was needed. I picked up the information 13 that they provided to me and moved on. 14 Q Was there anything in that information that 15 addressed property tax increase? 16 A There could have been. I can't remember if 17 there was. I just -- I just do remember that it 18 was a pretty credible source, and it was a range 19 of increases that we were looking at. 20 Q Have you ever used a property tax calculator 21 that's available either on the City of 22 Bloomington's website or the auditor's website 23 or a state agency website? 24 A No, I don't think so. 25 Q Are there other ways -- other than the property 12 1 taxes, are there other ways you believe the 2 annexation would have an economic impact on you 3 and your household? 4 A Those are the ones that are probably paramount, 5 probably most important. 6 Q I'm going to ask you about -- you're looking at 7 some paper in front of you? 8 A Uh-huh. 9 Q Can you describe for the record what it is 10 you're looking at? 11 A I'm looking at some notes I took to address 12 today, if given the opportunity. 13 Q We'll give you the opportunity. 14 A Okay. 15 Q But let's talk about how you put those notes 16 together. 17 Is that information that -- you mentioned 18 earlier you talked to neighbors and friends? 19 A Yeah. 20 Q Is there information you gathered from those 21 folks that's been reduced to your notes there? 22 A Yes, it is. 23 Q And then some of it -- is some of it just your 24 own thoughts? 25 A Yes, it is. 13 1 Q And when did you put those notes together, you 2 think? 3 A I put them together probably a week ago. 4 Q I see one page in front of you. Is there just 5 one page of notes? 6 A Just one page of notes, yes. 7 Q Would you have an objection to us putting an 8 exhibit sticker on those notes and making them 9 part of the official transcript of your 10 deposition? 11 A No, I wouldn't. 12 Q Or we can go make a copy of them and you can -- 13 A Well, I hope you can understand some of these 14 things, because some of them are abbreviated and 15 just talking points, you know, for me. 16 Q I would certainly ask you to talk through them. 17 Let's save the notes for a second. We'll come 18 back to those. 19 A Okay. 20 Q We kind of jumped into it. Let me take a step 21 back. 22 A Okay. 23 Q We talked about financial, the economic impact 24 on you and your household. 25 Did you sign a remonstrance petition? 14 1 A Yes, I did. 2 Q When you signed it, did you understand that was 3 lodging your official objection to the 4 annexation? 5 A Yes, I did. 6 Q And are you still opposed to the annexation? 7 A Yes, I am. 8 Q Other than what we've already talked about, can 9 you tell me the reasons why you are opposed to 10 the annexation? 11 A Well, one of the main things that I'm opposed to 12 is the annexation and the division of the zones 13 were set for us to fail as petitioners. Rather 14 than including all the areas that the City had 15 proposed to annex, they divided it up. And 16 given that only about 60 percent of voters vote 17 for major elections, I think that the City knew 18 right away that it was going to be impossible 19 for us to get enough signatures not to -- for us 20 to fail as petitioners. That's the first thing. 21 We get nothing out of it except for higher 22 taxes. When I came to an organizational meeting 23 or the dog and pony show that the City put on, 24 they informed us that we would get police 25 protection, and we get nothing out of that. I 15 1 already have police protection. I have two 2 sheriffs that live less than a half a mile from 3 me. The city is short on officers. 4 They offered us fire protection. Firemen 5 are leaving the fire department. I'm not sure 6 if we have a permanent fire chief right now. 7 But many of the firemen are unhappy with future 8 increases in their wages and leaving for the 9 county fire department. 10 Also, I think that the money that the City 11 has paid so far on this endeavor could have been 12 spent for the homeless. And it doesn't frighten 13 me, but I have been approached on two occasions 14 just recently, you know, by homeless people. So 15 I don't think that -- and adding more policemen 16 probably you don't want, won't fix that. 17 They're going to need to add additional 18 policemen if they annex these areas. 19 The trash pickup, already have. Streets, 20 I'm not sure that they could even keep up, you 21 know, with the streets. If you go down Third 22 Street, I think it's evident that, I think they 23 do their best with what they have. But if you 24 go down Third Street probably from College to 25 the police station, it's pitted with potholes. 16 1 So I don't look for anything from the street 2 department. 3 The other thing, I never intended to be in 4 the city in the first place when I purchased my 5 home. And I had no idea when I bought my home 6 that that was even possible. 7 You know, the other thing that -- there 8 used to be a guy in my neighborhood, his name 9 was Maurice Jones. My cousins used to go a 10 block out of the way not to confront Maurice 11 because he'd beat them up. I feel the same 12 thing is happening with the City. They want to 13 force this on us. We never -- if they wanted to 14 be democratic about this, why don't they put it 15 on a ballot and allow us to decide if we want to 16 be in the city? But I never intended to be in 17 the city in the first place, and I didn't know 18 when I signed my contract for my papers. 19 Of course, I'm sure that everybody here has 20 bought homes before, and they put a piece of 21 paper in front of you and they said, "Initial 22 here," and that's what you did, because I needed 23 a house. I sold my house in Kankakee County, 24 Illinois, and I needed a place to live. During 25 those closings, you never have time to read 17 1 through a stack of paper two inches thick, so I 2 never did get a chance to do that. 3 But I never had a chance, you know, to know 4 that I was buying into being in the city at some 5 point in time. So I think that it's something 6 that's being forced upon us, and I don't see 7 that as being democratic, I don't see it as 8 being the right thing. I think that perhaps 9 they have -- perhaps this is legal, but laws 10 change. One thing that's constant is the right 11 thing. I don't think this is the right thing. 12 Q Thank you for that, Mr. Rhyne. And I noticed 13 while you were talking, you were glancing down 14 at your notes. 15 A Yes. 16 Q Is there anything else on your notes? Have you 17 covered everything from the notes? 18 A Well, I said something that perhaps, you know, 19 we could have done -- the City could have done a 20 better job of this by collaborating and 21 coordinate it through the County. 22 The other thing that I object to is some of 23 the ordinance that may affect us also. 24 Q Any particular ordinances? 25 A Well, the only one that comes to my mind -- 18 1 perhaps I should have did a little more 2 research, you know, on this. I have -- I got 3 almost a quarter of an acre. I got 21 trees. 4 We've just went through the winter. I have all 5 kind of stuff I could burn right now. So the 6 burning is one of those things. 7 I'm not sure about some of the others. I 8 probably could do, you know, a little further 9 research to find out how those ordinances are 10 different than the County. 11 Q So is it your practice currently to burn the 12 tree debris? 13 A About once or twice a year I will. 14 Q So sticks, branches, leaves? 15 A Yes, sticks and branches. I don't burn any 16 leaves; I compost those. 17 Q Do you have a dedicated fire pit area in your 18 yard? 19 A Yes. 20 Q Sitting here right now, the burn ordinance is 21 the one that comes to mind? 22 A The one that comes to my mind immediately. 23 Q You mentioned the police protection in the city 24 being short on officers. 25 A Yes. 19 1 Q What is the source of that understanding? 2 A The last thing I saw in the Herald-Times was the 3 police department was short 31 officers. 4 Q So that was a news article? 5 A Yes. 6 Q Do you remember when you saw it? 7 A I think it was shortly before the end of the 8 year, probably sometime in December. 9 Q Of 2023? 10 A 2023, yes. 11 Q You said you have two sheriffs that live near 12 you. There's two uniformed sheriff deputies 13 that live nearby? 14 A Yes. 15 Q Have you ever spoken with them about staffing 16 levels at the Bloomington Police Department? 17 A No, I have not spoke to them about that. 18 Q Have you spoken with them about staffing levels 19 at the Monroe County Sheriff's Office? 20 A No, I haven't. 21 Q The fire protection issue you identified, you 22 said you're not sure if they have a permanent 23 chief right now. What do you mean by that? 24 A Shortly after the administration changed from -- 25 in the city, the fire chief resigned, and 20 1 someone has taken that job on an interim basis, 2 the last that I heard. I'm not sure if anyone 3 has been hired since that time. But I do know 4 that the fire chief resigned, and he resigned 5 over future raises and salaries for those 6 firemen. 7 Q And the source of that information about the 8 reason why he resigned, was that something you 9 read in a news article? 10 A Yes, news article, and on the internet. 11 Q You said, too, about fire protection, I think 12 you made a reference that many firefighters were 13 leaving for the county or other departments. 14 What's your source of that information? 15 A I spoke to one of the senior firemen and just 16 talked about their staffing levels. And he told 17 me that many of the young officers were leaving 18 because the salaries were higher out in the 19 county. 20 Q What's that person's name? 21 A I don't -- I can't remember his name or I don't 22 know his name, you know. It was somebody that I 23 just -- I see a lot of folks on a daily basis by 24 being out, picking up money and taking money to 25 folks. And so it is not unusual for me to just 21 1 ask folks their opinion and just speak to them 2 about what they do. 3 Q So this was someone that you met in the course 4 of your daily activities? 5 A Someone I met in the course of my daily 6 activities, yes. 7 Q Do you have a mortgage on your property? 8 A Yes. 9 Q Does the mortgage company have an escrow fund 10 through which your property taxes are paid? 11 A Yes. 12 Q So you have your monthly house payment that 13 includes a piece of that that goes to the 14 property tax? 15 A Yes. 16 Q Have you observed that your property taxes have 17 increased in the last three or four years? 18 A Yes, it has, tremendously. 19 Q Do you remember what your property taxes were 20 for 2023? 21 A I think it was about $1,400. I didn't bring 22 that information with me. 23 Q Okay. 24 A But that's gone from under a thousand to $1,400 25 in just a few years, probably three years. 22 1 Q If I suggested that the 2023 tax for your 2 property was $2,179, does that sound right or 3 does that sound too high? 4 A It could be. I didn't bring that information 5 with me. And honestly, I should remember that 6 because I just did my taxes. 7 Q But even -- you understand that the property tax 8 increase of the last few years is connected to 9 the increased assessed value of your property? 10 A Correct. 11 Q And to your knowledge, your escrow company has 12 paid the property taxes on your behalf every 13 year? 14 A Yes. 15 Q Have we covered all the notes that you have? 16 A Yes, we have. 17 Q Could I see those, please? Thank you. 18 A I hope you can understand that. 19 Q I've spent 27 years as a lawyer reading other 20 people's handwriting. 21 A All right. Some of it I just wrote down and 22 needed just for talking points. 23 MR. McNEIL: So we're going to put an 24 exhibit sticker on that. 25 MS. CLEMENTS: Would you care for a copy of 23 1 that back, Mr. Rhyne? 2 THE WITNESS: Yes. 3 MR. McNEIL: We'll make a copy before you 4 go. 5 (Deposition Exhibit 52 marked for 6 identification.) 7 BY MR. McNEIL: 8 Q So we've identified your notes. Please confirm, 9 Mr. Rhyne, that we've designated your notes 10 Exhibit 52 for purposes of the deposition. 11 A Okay. 12 Q For the record, is that what we've done? 13 A Yes, we have. 14 Q If you can pass those to Mr. Beggs so he can 15 look at it. And we'll make a copy of that 16 before you take off. 17 A Okay. 18 (Deposition Exhibit 28 previously marked 19 for identification.) 20 Q So you have a document by your left hand there, 21 Exhibit 28. It's the amended and supplemented 22 answers of the County Residents Against 23 Annexation to the City of Bloomington's 24 interrogatories. I want to turn your attention 25 to page 11. If you could turn there, and there 24 1 will be a question Number 12 on that page. 2 So question 12 says, "Identify and list all 3 facts and documents supporting the contention 4 that the annexation will have a significant 5 financial impact upon the residents and owners 6 of land in the annexation area," and identify 7 witnesses. 8 Do you see that? 9 A Yes, I do. 10 Q If you turn, please, to page 12, there's a 11 supplemental answer that says, "If called to 12 testify, the following individuals may be asked 13 to testify about the significant economic 14 impacts of annexation upon Areas 1A and 1B." 15 Do you see your name listed in about the 16 middle -- 17 A Yes, I do. 18 Q -- of the third, fourth line there? 19 A Yes. 20 Q Have you covered all of the ways in which you 21 believe the annexation would have a significant 22 economic impact on Areas 1A and 1B? 23 A I think that I have. It's all that I can 24 support, yes. 25 Q And then if you look at question 13 on page 12, 25 1 similar intro, "Identify facts and documents 2 supporting the contention that the annexation is 3 not in the best interest of the owners of land 4 in the annexation territory." 5 Do you see that? 6 A Yes. 7 Q And if you turn to page 13, there is a 8 supplemental answer, "See Supplemental Answer 9 Number 5. In addition, if called to testify, 10 the following would be asked to testify about 11 the impact of annexation upon them and upon 12 their businesses." 13 Do you see your name -- 14 A Yes, I do. 15 Q -- in the last row of names? 16 A Yes. 17 Q Have we covered all the ways in which you 18 believe the annexation is not in the best 19 interest of you or the landowners in the 20 annexation area? 21 A To the best of my ability. 22 Q Anything else come to mind that you would like 23 to add today, right now? 24 A I can't think of anything at this time. 25 MR. McNEIL: Mr. Rhyne, I have no further 26 1 questions. I thank you for your time. 2 MR. BEGGS: Mr. Rhyne, I have no questions. 3 Thank you very much. 4 (Time noted: 1:05 p.m.) 5 AND FURTHER THE DEPONENT SAITH NOT. 6 7 8 ____________________ 9 LEE RHYNE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 27 1 STATE OF INDIANA ) ) SS: 2 COUNTY OF HAMILTON ) 3 I, Janine A. Ferren, a Notary Public in and 4 for the County of Hamilton, State of Indiana at 5 large, do hereby certify that LEE RHYNE, the 6 deponent herein, was by me first duly sworn to tell 7 the truth, the whole truth, and nothing but the 8 truth in the aforementioned matter; 9 That the foregoing deposition was taken on 10 behalf of the Respondents, at the offices of 11 Bloomington City Hall, 401 North Morton Street, 12 Bloomington, Monroe County, Indiana, on the 1st day 13 of March 2024, commencing at the hour of 14 12:34 p.m., pursuant to the Indiana Rules of Trial 15 Procedure; 16 That said deposition was taken down 17 stenographically and transcribed under my 18 direction, and that the typewritten transcript is a 19 true record of the testimony given by the said 20 deponent; and thereafter presented to said deponent 21 for his signature; 22 That the parties were represented by their 23 counsel as aforementioned. 24 I do further certify that I am a disinterested 25 person in this cause of action; that I am not a 28 1 relative or attorney of any party, or otherwise 2 interested in the event of this action, and am not 3 in the employ of the attorneys for any party. 4 IN WITNESS WHEREOF, I have hereunto set my 5 hand and affixed my notarial seal on this 15th 6 day of March 2024. 7 8 9 <%21167,Signature%> ________________ 10 Janine A. Ferren 11 12 Seal, Notary Public My Commission Expires: 13 State of Indiana April 22, 2024 14 Janine A. Ferren County of Residence: Commission No. NP0681591 Hamilton 15 16 17 18 19 20 21 22 23 24 25 Veritext Legal Solutions 1100 Superior Ave Suite 1820 Cleveland, Ohio 44114 Phone: 216-523-1313 March 15, 2024 To: William J. Beggs, Esq. Case Name: County Residents Against Annexation, Inc., Et Al. v. The Common Council Of The City Of Bloomington, Monroe County, Indiana, Et Al. Veritext Reference Number: 6465811 Witness: Lee Rhyne Deposition Date: 3/1/2024 Dear Sir/Madam: The deposition transcript taken in the above-referenced matter, with the reading and signing having not been expressly waived, has been completed and is available for review and signature. Please call our office to make arrangements for a convenient location to accomplish this or if you prefer a certified transcript can be purchased. If the errata is not returned within thirty days of your receipt of this letter, the reading and signing will be deemed waived. Sincerely, Production Department NO NOTARY REQUIRED IN CA 1 DEPOSITION REVIEW CERTIFICATION OF WITNESS 2 ASSIGNMENT REFERENCE NO: 6465811 3 CASE NAME: County Residents Against Annexation, Inc., Et Al. v. The Common Council Of The City Of Bloomington, Monroe County, Indiana, Et Al. DATE OF DEPOSITION: 3/1/2024 4 WITNESS' NAME: Lee Rhyne 5 In accordance with the Rules of Civil Procedure, I have read the entire transcript of 6 my testimony or it has been read to me. 7 I have made no changes to the testimony as transcribed by the court reporter. 8 _______________ ________________________ 9 Date Lee Rhyne 10 Sworn to and subscribed before me, a Notary Public in and for the State and County, 11 the referenced witness did personally appear and acknowledge that: 12 They have read the transcript; 13 They signed the foregoing Sworn Statement; and 14 Their execution of this Statement is of their free act and deed. 15 I have affixed my name and official seal 16 this ______ day of_____________________, 20____. 17 ___________________________________ 18 Notary Public 19 ___________________________________ Commission Expiration Date 20 21 22 23 24 25 1 DEPOSITION REVIEW CERTIFICATION OF WITNESS 2 ASSIGNMENT REFERENCE NO: 6465811 3 CASE NAME: County Residents Against Annexation, Inc., Et Al. v. The Common Council Of The City Of Bloomington, Monroe County, Indiana, Et Al. DATE OF DEPOSITION: 3/1/2024 4 WITNESS' NAME: Lee Rhyne 5 In accordance with the Rules of Civil Procedure, I have read the entire transcript of 6 my testimony or it has been read to me. 7 I have listed my changes on the attached Errata Sheet, listing page and line numbers as 8 well as the reason(s) for the change(s). 9 I request that these changes be entered as part of the record of my testimony. 10 I have executed the Errata Sheet, as well 11 as this Certificate, and request and authorize that both be appended to the transcript of my 12 testimony and be incorporated therein. 13 _______________ ________________________ Date Lee Rhyne 14 Sworn to and subscribed before me, a 15 Notary Public in and for the State and County, the referenced witness did personally appear 16 and acknowledge that: 17 They have read the transcript; They have listed all of their corrections 18 in the appended Errata Sheet; They signed the foregoing Sworn 19 Statement; and Their execution of this Statement is of 20 their free act and deed. 21 I have affixed my name and official seal 22 this ______ day of_____________________, 20____. 23 ___________________________________ Notary Public 24 ___________________________________ 25 Commission Expiration Date 1 ERRATA SHEET VERITEXT LEGAL SOLUTIONS MIDWEST 2 ASSIGNMENT NO: 3/1/2024 3 PAGE/LINE(S) / CHANGE /REASON 4 ___________________________________________________ 5 ___________________________________________________ 6 ___________________________________________________ 7 ___________________________________________________ 8 ___________________________________________________ 9 ___________________________________________________ 10 ___________________________________________________ 11 ___________________________________________________ 12 ___________________________________________________ 13 ___________________________________________________ 14 ___________________________________________________ 15 ___________________________________________________ 16 ___________________________________________________ 17 ___________________________________________________ 18 ___________________________________________________ 19 _______________ ________________________ 20 Date Lee Rhyne 21 SUBSCRIBED AND SWORN TO BEFORE ME THIS ________ 22 DAY OF ________________________, 20______ . 23 ___________________________________ Notary Public 24 ___________________________________ 25 Commission Expiration Date