Transcript of the Testimony of Charles Kuehn

Date: November 6, 2013 Volume: I Case: In Re: Joplin Critical Investigation

Printed On: November 13, 2013

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 1

IN RE:

JOPLIN CRITICAL INVESTIGATION

SWORN STATEMENT OF

CHARLES KUEHN

Taken on Wednesday, November 6, 2013, from 5:36 p.m. to 5:38 p.m., at the law offices of Juddson H. McPherson, LLC, 626 S. Byers, in the City of Joplin, County of Jasper, State of Missouri, before SHARON K. ROGERS, C.C.R.650, a Certified Court Reporter and a Notary Public within and for the County of Jasper, and State of Missouri.

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 2

APPEARANCES

MR. THOMAS E. LORAINE Loraine & Associates, LLC 4075 Osage Beach Pkwy., Suite 300 Osage Beach, MO 65065

tellaw@loraineandassociates.com

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 3

S T I P U L A T I O N

IT IS HEREBY STIPULATED that this Sworn Statement may be taken by steno-mask type recording by SHARON K. ROGERS, a Certified Court Reporter, and afterwards reduced into typewriting. It is further stipulated that the signature of the witness is hereby waived, and that said Sworn Statement of said witness shall be of the same force and effect as though said witness had read and signed Sworn Statement.

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 4

I N D E X

Page/Line

DIRECT EXAMINATION BY MR. LORAINE

5-4

E X H I B I T S

(sic) - typed as spoken (ph.) - phonetic

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. A. A. Q. CHARLES KUEHN Having been first duly sworn and examined, testified as follows: DIRECT EXAMINATION BY MR. LORAINE: Q. A. Q. A. Q. A. Q. Sir, would you state your name? Charles Kuehn. What is your employment, sir? I own Four State Homes. Four State Homes? Yes, spelled out F-O-U-R. You're aware that I've been hired by the City to do an investigation. I've got two guys

primarily to investigate, one of them is a friend of yours and one of them probably isn't a friend of yours. He's still a friend. Okay. The one that I'm asking you about is

Mr. Woolston, okay? Can I get some clarification from you? Sure. Just exactly what are you here to investigate on Mike Woolston? Well, I can tell you what I'm here to investigate on Mike Woolston. Facts and

circumstances and ethical considerations

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Q. A. Q. A. A. Q. A. surrounding the involvement of Council member Woolston with Charlie Kuehn, Four State Homes, its subsidiaries and related entities, and the City's master developer, Wallace-Bajjali, with respect to the purchase, sale, or leasing of real estate for current or future development. That's what Is that a

I'm supposed to talk to you about. surprise or anything? Yeah.

What did you think we were talking about? Just land purchases that Mr. Woolston has purchased for me, or as a -Well, I think this covers that. It covers that and a whole lot more. Yes, it does. So I'm going to elect to leave and if we want to talk any further I'll bring my attorney because that is not what I understood that Mr. Woolston was being investigated for all of that. Okay. Goodbye.

(SWORN STATEMENT CONCLUDED)

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 7 1 2

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Charles Kuehn

In Re:

Joplin Critical Investigation

Page 8

REPORTER'S CERTIFICATE

STATE OF MISSOURI ss. COUNTY OF JASPER I, SHARON K. ROGERS, Certified Court Reporter in the State of Missouri, do certify that pursuant to the foregoing Stipulation the witness came before me on the 6th day of November, 2013, was duly sworn by me, and was examined. That examination was then taken by me by

steno-mask recording and afterwards transcribed; said Sworn Statement is subscribed by the witness as hereinbefore set out on the day in that behalf aforesaid and is herewith returned. I further certify that I am not counsel, attorney, or relative of either party, or clerk, or stenographer of either party or of the attorney of either party, or otherwise interested in the event of this suit.

_________________________ SHARON K. ROGERS, CCR-650

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