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CAUSE NO. 2021-60942 1 INDEX
HASAN GOKAL § IN THE DISTRICT COURT OF 2
PAGE
Plaintiff, § 3
§ 4 APPEARANCES................................ 2
VS. § 5 EDWARD ANDERSON
§ HARRIS COUNTY, TEXAS 6 EXAMINATION
BY MR. AHMAD........................... 4
HARRIS COUNTY, TEXAS § 7
d/b/a HARRIS COUNTY § CORRECTION PAGE............................ 206
PUBLIC HEALTH, § 8 SIGNATURE PAGE............................. 207
REPORTER'S CERTIFICATION................... 208
Defendant. § 333RD JUDICIAL DISTRICT 9
10
EXHIBITS
ORAL AND VIDEOTAPED DEPOSITION OF 11
NO. DESCRIPTION PAGE
EDWARD ANDERSON 12 Exhibit 1 LinkedIn page; 7 pages 4
SEPTEMBER 14, 2022 Exhibit 2 Declaration Under C.P.R.C.
VOLUME 1 13 Section 132.001(f) of
Edward Anderson; 56 pages 17
14 Exhibit 3 Investigation Report
Public Corruption Case
15 #21-0001; GOKAL000240 to
Oral and videotaped deposition of Edward GOKAL000260 45
Anderson, produced as a witness at the instance of the 16 Exhibit 4 Thumb drive 55
Exhibit 5 Dr. Gokal Investigation
Plaintiff and duly sworn, was taken in the above styled 17 Summary; 1 page 191
and numbered cause on Wednesday, September 14, 2022, from Exhibit 6 Dr. Gokal Investigation
10:17 a.m. to 5:01 p.m., before Rene N. White, CSR, CRR, 18 Summary; 1 page 191
Exhibit 7 Employment and Benefits; 3
RPR in and for the State of Texas, reported by 19 pages 197
computerized stenotype machine, at the Harris County 20
Attorney's Office, 1019 Congress, 15th Floor, Houston, 21
Texas, pursuant to the Texas Rules of Civil Procedure and 22
23
the provisions stated on the record herein. 24
25

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1 APPEARANCES 1 (Exhibit 1 marked.)
2
2 THE VIDEOGRAPHER: Today's date is
FOR THE PLAINTIFF:
3 JOSEPH Y. AHMAD, ESQ. 3 September 14th, 2022. The time is 10:17 a.m. We're on
KAITLIN HOPKINS, ESQ. 4 the record.
4 AHMAD, ZAVITSANOS & MENSING, P.C.
1221 McKinney, Suite 2500 5 EDWARD ANDERSON,
5 Houston, Texas 77010-2009 6 having been duly sworn, testified as follows:
713.655.1101
6 joeahmad@azalaw.com
7 EXAMINATION
7 8 BY MR. AHMAD:
FOR THE DEFENDANT: 9 Q. State your name, please, sir.
8 PAM REA, ESQ.
MELISSA MARTIN, ESQ. 10 A. I'm Edward Anderson.
9 HARRIS COUNTY ASSISTANT ATTORNEY 11 Q. And, Mr. Anderson, my name is Joe Ahmad, and I
1019 Congress, 15th Floor
10 Houston, Texas 77002 12 don't believe we've met before --
713.755.5101 13 A. We have not.
11 pam.rea@harriscountytx.gov 14 Q. -- but I represent Dr. Gokal in a case between
12
Also Present: 15 Dr. Gokal and the County. You understand that?
13 DR. HASAN GOKAL 16 A. I do.
MR. SAM AMONG - THE VIDEOGRAPHER
14 17 Q. Okay. You understand you'll be giving testimony
15 18 here today. I'll be asking you questions, and you will be
16
17
19 giving answers under oath.
18 20 You understand that?
19 21 A. I do.
20
21 22 Q. Okay. Is there any reason why you couldn't give
22 23 accurate and truthful testimony here today?
23
24
24 A. No, except that there has been some time that has
25 25 lagged since the events have happened, and I'm no longer

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 EDWARD ANDERSON - 9/14/2022
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1 with the County, so I'm doing something totally 1 Q. Okay. And in front of you I have marked as
2 different now. But I will remember them to the best of 2 Exhibit 1 to your deposition.
3 my ability. 3 Can you identify that document?
4 Q. Okay. And if you -- and it's fine if I ask you 4 A. Yes. That's -- looks to be a printout of my
5 something and you don't know -- 5 LinkedIn page.
6 A. Okay. 6 Q. Okay. And I see as -- your active job I
7 Q. -- or don't remember. You can simply tell me 7 believe, as you testified to, is as director of human
8 that -- 8 resources for Texas Ear Nose & Throat Specialists; is
9 A. Okay. 9 that correct?
10 Q. -- okay? 10 A. That is correct.
11 If you do give answers, you understand that 11 Q. And you took that position in February of 2022?
12 you've been sworn under oath to tell the truth, correct? 12 A. That is correct.
13 A. Yes. 13 Q. And how many employees, generally speaking,
14 Q. And that carries the penalties of perjury under 14 does -- and I'll call it Texas ENT, if that's all right?
15 the law. You understand that? 15 A. Yes, that's fine.
16 A. I do understand. 16 Q. How many employees does Texas ENT have?
17 Q. Okay. And we're going to rely on your answers 17 A. Texas ENT has around 300. But I should explain
18 in this case. You understand that? 18 that Texas ENT is a part of a bigger organization called
19 A. I do. 19 Elevate ENT based out of Miami. We fall under their
20 Q. Okay. If I ask you -- and for that reason, you 20 umbrella.
21 know, my job is to, you know, get accurate and truthful 21 So with Texas ENT and Elevate ENT, I
22 testimony. But if I ask you a question which you don't 22 believe there's around a thousand between Florida and
23 understand -- 23 Miami -- Florida and Texas.
24 A. Uh-huh. 24 Q. Okay. And what is your level of
25 Q. -- or isn't clear, just ask me to rephrase. If 25 responsibility? Is it just Houston?

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1 you don't hear me, ask me to repeat, okay? 1 A. It is. Right now, I'm the regional director
2 A. Okay. 2 for just Texas.
3 Q. That's fine. 3 Q. For just Texas?
4 And if you need a break, just let me know. 4 A. Uh-huh. So if there's any other offices that
5 Generally speaking, I'd like you to answer the question 5 are open in the state of Texas, they would be my
6 pending, if there is one. But, otherwise, we can take a 6 responsibility.
7 break anytime you'd like. 7 Q. Okay. And are all those offices called Texas
8 A. Okay. Fair enough. 8 ENT, or are they called something different?
9 Q. Did you have a chance to talk to the -- anybody 9 A. As of today, they are Texas ENT, but Elevate
10 in the County attorney's office about what we're going 10 ENT is in a merger and acquisition mode. And so if they
11 to be doing here today? 11 acquire a facility, it would more than likely keep the
12 A. Only Pam. 12 same name that they're currently under. So as of now,
13 Q. Pam Rea? 13 all the locations are Texas ENT.
14 A. Uh-huh. 14 Q. Okay. And I -- I take it it employs doctors or
15 Q. Who's seated to your right? 15 are they contractors?
16 A. That is correct. 16 A. No, they are physicians, yes.
17 Q. Okay. And you did have a chance to talk to 17 Q. As employees?
18 her -- 18 A. As employees. Technically, I believe their
19 A. Yes. 19 relationships may be partners.
20 Q. -- privately about what -- what was going to 20 Q. Sure.
21 happen today in this deposition, correct? 21 A. I'm not involved in that part of the process,
22 A. Just about the deposition, yes. 22 and so I don't really -- I don't really know. We -- we
23 Q. Yes, yes. 23 call them employees.
24 How are you employed right now? 24 Q. Okay. And do you have audiologists at all or
25 A. I'm employed by Texas ENT Specialists. 25 is that --

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1 A. We do have audiology, that is correct. We have 1 Q. Okay.
2 around 20 audiologists. 2 A. But I do recall being -- well, I moved from
3 Q. Okay. Throughout Texas? 3 Indigo Beam to the County, so it would have been
4 A. Well, both organizations if you count Elevate 4 sometime in 2015.
5 ENT as well as Texas ENT, yes. 5 Q. Yes, and that's why I asked. It would have
6 Q. Okay. And what other types of employees might 6 been probably May 2015 or afterwards?
7 you have? 7 A. In that -- I would say in that general
8 A. The rest of them are traditional medical staff, 8 ballpark, yes.
9 so front office, medical assistants, some technicians, 9 Q. Okay. And I'm not sure we have it on this
10 physician assistants -- we do have some physician 10 LinkedIn page, but what was your position with the
11 assistants -- and some LVNs. 11 County?
12 Q. Okay. 12 A. So with the County, I was director of human
13 A. But what I would consider just generic -- 13 resources for Harris County Public Health.
14 general medical staff for traditional-type clinics. 14 Q. Okay. And did you hold that position the
15 Q. Okay. And I may be missing it here, but I'm 15 entire time --
16 assuming prior to that, you were employed by the County? 16 A. Yes.
17 A. I was -- 17 Q. -- you were with the County?
18 Q. Okay. 18 A. I was hired into that position.
19 A. -- yes, just prior to Texas ENT. 19 Q. And who hired you into that position?
20 Q. Okay. And it may be just the way we printed it 20 A. At the time, it would have been our deputy
21 up. Is that on your LinkedIn page? 21 director, Les Becker, and he reported to our executive
22 A. It should be. 22 director, which would have been Umair Shah,
23 Q. It may be. I -- 23 Dr. Umair Shah.
24 A. I see it -- 24 Q. Okay. And did you interview with Dr. Shah?
25 Q. -- just don't see it. 25 A. I did not. I was reporting directly to Les

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1 A. It looks as if -- 1 Becker, so I reported -- I interviewed with him as well
2 Q. You know what, it's cut off. 2 as some of the additional senior leadership team.
3 A. It got cut off, yeah, that's correct. The top 3 Q. And who hired you at Texas ENT?
4 of page 2 shows some remnants of this -- 4 A. That would be the VP of HR who sits in Miami.
5 Q. Yes. 5 Q. And do you know that person's name?
6 A. -- but that would have been Harris County 6 A. Uh-huh, yeah, it's Ellen Charlton.
7 Public Health. 7 Q. Okay. Do you -- in your job at Texas ENT, do
8 Q. Okay. Well, since it's cut off -- 8 you work with anybody that you worked with at the
9 A. Uh-huh. 9 County?
10 Q. -- let me just ask you: During what period of 10 A. There is one individual who was -- who joined
11 time were you employed for the County? 11 us recently. I didn't know her. She was a contractor
12 A. That's a good question. Date-wise, I ended in 12 working for us during COVID, and that's the only
13 2022, and I was with the County around seven years, so I 13 individual that I work with currently that would have
14 think I started -- it would have been maybe 2015. 14 been -- come from the County, although she was not a
15 Q. Well, I noticed prior to that, it looks like 15 County employee. She was a contractor.
16 you were at Indigo Beam Consulting as a senior 16 Q. And do you know who that is?
17 director of -- 17 A. I believe her name is Alexis Vega.
18 A. Uh-huh. 18 Q. Okay.
19 Q. -- HR operations? 19 A. She was -- as far as I remember, she was
20 A. That's right. 20 working maybe in one of our COVID testing or vaccination
21 Q. And it says August 2014 to May of 2015. Is 21 sites.
22 that accurate? 22 Q. Okay.
23 A. I believe it is, although I will say with dates 23 A. I did not have direct contact with her, though,
24 sometimes with LinkedIn, I'm not putting exact dates in 24 during my time at Public Health. You know, as you are
25 there. 25 aware, we were moving extremely rapidly hiring for

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1 testing sites and vaccination sites because of the 1 may be on your LinkedIn page even though it's not on
2 urgency of the situation, and so we were hiring 2 this exhibit -- I have down 2002 to 2008. Did you go to
3 sometimes hundreds of people at a time so -- on the 3 Waste Management and come back?
4 contract side, so I didn't know her personally. 4 A. That -- those dates don't seem accurate. I
5 Q. And when you say "the urgency of the 5 wasn't at Waste Management for that -- that amount of
6 situation" -- 6 time.
7 A. Uh-huh. 7 Q. And how long were you at Waste Management?
8 Q. -- just to make clear, you're talking about the 8 A. I believe -- again, I'll state that I don't
9 COVID outbreak? 9 recall specific dates today because I was not
10 A. For our COVID response specifically, yes. 10 necessarily anticipating answering questions regarding
11 Q. Okay. I noticed you have -- and I've mentioned 11 my entire work history.
12 one of them already -- you have three other positions 12 Q. Sure, I understand.
13 mentioned -- kind of in descending time order, positions 13 A. So I hope that's a fair statement.
14 at Indigo, Icon, and -- DISYS, if I've got that right? 14 I believe I was with Waste Management under
15 A. Uh-huh, yes, that's correct, DISYS. 15 four years, roughly.
16 Q. Okay. And are all those, to the best of your 16 Q. Okay. Early 2000s?
17 knowledge, correct as they're written here in Exhibit 1? 17 A. It was definitely early 2000s, yeah.
18 A. I -- I would say as best as you can with 18 Q. And before that, Enron?
19 LinkedIn? Is that a complete history of my work 19 A. Uh-huh. That's correct.
20 history? No. 20 Q. Human resources senior recruiting specialist?
21 Q. I was going to ask you about that because I 21 A. Uh-huh. That was one of the titles I had while
22 believe -- but I'll ask you. Prior to Icon, you worked 22 I was there.
23 at Kelsey-Seybold? 23 Q. Okay. Did you have other titles?
24 A. That is correct, yeah. 24 A. They were probably in the same general type of
25 Q. Manager of recruitment there? 25 title, but I couldn't tell you specifically. I moved

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1 A. That was my title, yes. 1 around internally there about three or four different
2 Q. Okay. 2006 to maybe early 2008 time frame? 2 times, so I had different supervisors and different --
3 A. I would say ballpark that's close to accurate. 3 slightly different roles, but they were all general --
4 Again, like I said, with LinkedIn, I'm not putting exact 4 generally speaking, talent related.
5 dates because it isn't a document of record. It's just 5 Q. And were you there a year or less?
6 a networking tool for professionals. 6 A. I was there at Enron around two years, but part
7 Q. Yeah, and if you -- if you know a more 7 of that time was as a contractor. I started there as a
8 accurate -- if you know more accurate information -- 8 contract employee with a staffing firm.
9 A. Sure. 9 Q. Got it. Okay.
10 Q. -- sitting here today, I'd just ask that you 10 Also on Exhibit 1, you have a university
11 give it. 11 degree from A&M, bachelor's degree in political science.
12 A. Okay. Yeah, I don't recall dates specifically, 12 I assume that's accurate?
13 so I would say, you know, what I have on my LinkedIn 13 A. That is accurate, yes.
14 page is as close to accurate as I can remember today. 14 Q. And then you have some certifications listed.
15 Q. Got it. Okay. And prior to Kelsey-Seybold, 15 I assume those are accurate certifications, to the best
16 did you work at Cemex as a manager of US recruiting? 16 of your knowledge sitting here today?
17 A. At -- in terms of chronological order, I don't 17 A. Yes, the SHRM-CP as well as PHR.
18 recall exactly the order, but I did work at Cemex prior 18 Q. And -- and then the certificate -- I guess some
19 to Kelsey-Seybold, yes. 19 type of certificate from Rice and human resources
20 Q. Roughly 2006 to early 2008 time frame? 20 management?
21 A. That would be a ballpark, yes. 21 A. Uh-huh, yeah, that's correct, those are all HR
22 Q. Okay. And prior to that, do you remember at 22 certifications.
23 some point working at Waste Management? 23 Q. And what is PHR?
24 A. Uh-huh, yes, I worked at Waste Management. 24 A. Professional of human resources.
25 Q. One question I have is -- I have down -- and it 25 Q. Okay. And -- and SHRM, I vaguely recall it's

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1 like society of human resources -- 1 Q. Okay. And if you go to the next page, it looks
2 A. Management. 2 like you got a subpoena directed at you and your -- in
3 Q. -- management, yeah. 3 your capacity as director of human resources for Harris
4 A. Uh-huh. 4 County Public Health; is that correct?
5 Q. Okay. And that's a -- that's a fairly common 5 A. Attachment A, yes.
6 certification for HR professionals, would you say? 6 Q. And that's on the next page of Exhibit 2,
7 A. I would actually say it's the certification for 7 correct?
8 HR professionals. 8 A. Page 2, yes.
9 Q. Well, I was starting off -- 9 Q. Okay. There is some writing, it looks like, on
10 A. I understand. 10 both the left and the right. Is that your handwriting?
11 Q. -- conservative, but, yes. 11 A. That is my handwriting, yes.
12 A. I would associate it very similarly to a CPA. 12 Q. The one on the left, it looks like it's just A,
13 That's the same type of level of -- of certification. 13 B, C, correct?
14 Q. Got it. 14 A. That is correct. I wrote those in there just
15 THE COURT REPORTER: Can I remind you to 15 to identify the sections to make it easier for me to be
16 please talk one at a time. 16 able to report on what it was that they were asking for.
17 (Comments off the record.) 17 Q. Got it. And the ones on the right, it looks
18 Q. (BY MR. AHMAD) Do you remember filling out any 18 like it's a notation included, which I assume means
19 affidavits or technically declarations in this case? 19 you're providing the records, correct?
20 A. So in this particular case, I don't recall. I 20 A. That is correct, the notations on the right
21 do recall filling out information regarding -- I think 21 indicated whether or not I had records or not records to
22 it may have been a criminal case related to Dr. Gokal. 22 include for the affidavit.
23 But, unfortunately, I don't recall when I left versus 23 Q. Okay. And then "no record" means there were no
24 when this case started, so I'm not sure. 24 records to provide?
25 (Exhibit 2 marked.) 25 A. It meant that I had no records to provide.

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1 A. Ah, okay. Yeah. 1 Q. Okay. And do you know, for example, with
2 Q. (BY MR. AHMAD) And I have -- I think I have 2 respect to B and C, B being administrative protocols --
3 what you were talking about marked as Exhibit 2. Is 3 medical or administrative protocols in place on
4 that correct? 4 December 29, 2020, as well as C, training materials or
5 A. I don't know. Is this related to this case, or 5 manuals provided to Dr. Gokal.
6 is this related to the criminal case? 6 Do you know whether those records exist
7 Q. Well, if you look at the top -- 7 apart from being in your possession at the County?
8 A. Uh-huh. 8 A. Regarding B and C, no, I didn't know if they
9 Q. -- you will see. 9 existed or not because that wasn't really part of my
10 A. Okay. 10 role within the County. The medical procedures and
11 Q. I'll represent to you it's a criminal case. I 11 those training materials regarding COVID-19 would have
12 think I know that because if you look at the right-hand 12 been housed somewhere -- if they were there, they would
13 top of the first page -- 13 have been under someone else's control.
14 A. I see. 14 Q. And starting with B, a copy of all medical or
15 Q. -- it says: "County Criminal Court At Law 15 administrative protocols in place on December 29th,
16 Number 8." 16 2020, regarding the administration or handling of
17 A. Okay. 17 COVID-19 vaccine, where did you look for those records?
18 Q. Okay. And so did you give a -- an affidavit or 18 A. With the situation regarding the affidavit, I
19 declaration, as it's titled here, for County Criminal 19 maintain HR records, and so I -- I keep files on all
20 Court At Law 8? 20 these things. So those items were not included in my
21 A. Yes, regarding this particular affidavit, that 21 files. I did ask some individuals regarding who might
22 is correct. I did do this one. 22 have those documents because obviously it was me that
23 Q. Okay. And you signed this first page dated 23 was responding to the affidavit. But in terms of asking
24 February 8th, 2021; is that correct? 24 for those things, I didn't receive them. Doesn't
25 A. Yes, that is correct. 25 necessarily mean they didn't exist. It just meant I was

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1 not able to get my hands on them. 1 A. -- in terms of incident command.
2 Q. Who did you ask? 2 So I'm trying to think of the sequence of
3 A. That would have been, at the time, individuals 3 events on the documents because I was dealing with
4 in our incident command structure. I don't recall at 4 multiple roles in COVID response. I had my regular
5 the moment exactly who I asked today. But it would have 5 position, and I had a COVID role too.
6 been following our leadership chain within incident 6 There were emails sent to incident command,
7 command. 7 which would have been Mac and Jennifer, regarding
8 Q. And what types of individuals might that be, 8 documents. I didn't receive anything back in terms of
9 for example? 9 documents. I did receive a response back from Mac and
10 A. Our incident command was -- headed up our 10 Jennifer stating that there were no documents at the
11 emergency preparedness group, which was led by Mac 11 time. That was pretty much the end of it at that point.
12 McClendon, Jennifer Kiger. 12 With these types of situations, once I got
13 Q. What about Trey Frankovich? 13 word back from Mac and Jen, it was -- it was my chance
14 A. In terms of the question, did I ask him if they 14 to respond because there's not -- we wouldn't be
15 had -- 15 creating the protocols after the fact. If they told me
16 Q. Would he have been in incident command? 16 there's no protocols, there's no protocols, and that's
17 A. Yes, Trey was in incident command. I didn't 17 what I responded back with.
18 interface with Trey much, though. Our roles were 18 Q. Okay. And just to be clear, Jennifer -- or Jen
19 drastically different. 19 is Jennifer Kiger?
20 Q. And what did they tell you about any medical or 20 A. Jennifer Kiger, yeah.
21 administrative protocols as described in this 21 Q. And Mac is Mac McClendon?
22 Attachment A? 22 A. That is correct.
23 A. Specific -- could you repeat that question? 23 Q. Okay.
24 I'm sorry. 24 A. Yeah.
25 Q. Sure. You said you asked incident command 25 Q. And so, I mean, you were testifying honestly --

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1 about these records or the existence of them. What did 1 A. Uh-huh.
2 they tell you? 2 Q. -- that to the best of your knowledge after
3 A. I just didn't get a response back. You know, 3 reasonable inquiry, there were no such records as you
4 during the situation, I did the best I could to 4 notated on Attachment A?
5 accumulate the documents I didn't have, but at some 5 A. That is correct, yes. In terms of my best
6 point, I had to respond back to the affidavit that there 6 efforts to gather documents, I was told there were no
7 were no records since I didn't receive any internally. 7 documents to give.
8 I will say getting communications 8 Q. By Kiger and McClendon?
9 through -- during -- during COVID was challenging only 9 A. By -- yes.
10 because our teams were spread pretty thin in the 10 Q. And they would know presumably, correct?
11 incident command structure. So at some point, I 11 A. Hard for me to assume, but in terms of their
12 couldn't wait any longer. I had to respond to the 12 roles, they would have been responsible because they
13 affidavit. 13 were the incident commanders.
14 Q. Okay. Because you -- you understood that you 14 Q. Yeah. Well, they should know, right?
15 swore on February 8th, 2021, that there were no such 15 A. I would say based on incident command
16 records for B and C of Attachment A? 16 structure, it's a fairly defined structure and they
17 A. I swore that I didn't have any records. 17 would be in charge.
18 Q. Well, you understand that this subpoena was 18 Q. Okay. I mean, they shouldn't tell you there's
19 directed to you in your capacity at Harris County Public 19 no records if there are?
20 Health, correct? 20 A. I would agree --
21 MS. REA: Objection, form. 21 MS. REA: Objection, form.
22 A. Yeah, can -- can I go back to the previous 22 A. -- with that, yes, they shouldn't --
23 question? Because I'm not sure I phrased it 23 shouldn't -- they would not be -- they would not lie to
24 correctly -- 24 me. They shouldn't be lying to me.
25 Q. (BY MR. AHMAD) Sure. 25 Q. (BY MR. AHMAD) Okay. And so you believed

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1 them, there were -- that there were no records? 1 Q. Okay. Is it -- do you remember Dr. Gokal being
2 A. I believed them, yes. 2 hired roughly at about this time?
3 Q. And that's why you signed on the first page of 3 A. I would say it's -- as far as I can recall,
4 Exhibit 1? 4 it's accurate. But I wasn't involved in every single
5 A. That's correct. 5 offer, every single start, so . . .
6 Q. If you go to -- I think it's page 22. And you 6 Q. Were you involved at all in the hiring of
7 know what, these aren't marked by page numbers, so kind 7 Dr. Gokal?
8 of have to go by page number. But tell me when you get 8 A. Other than the fact that Mylinh reported to me,
9 to -- actually, I'll cut it kind of short. I'll just 9 no.
10 show it to you. 10 Q. Were you aware of Dr. Gokal's hiring?
11 Do you see this offer letter, Harris County 11 A. Yes.
12 Public Health? It's signed at the bottom by Hasan 12 Q. And -- and how did you become aware?
13 Gokal. It's a letter from -- I can't say -- Mylinh Mai? 13 A. I don't recall specifically, but there were
14 A. Give me one second. I'm not there yet. 14 reports that were coming out weekly on who we were
15 Q. No problem. 15 hiring for certain roles. I also had update meetings
16 MS. REA: How far from the end is it so we 16 with our recruiting team, which was Mylinh, so I more
17 can -- 17 than likely found out about it that way, but I don't
18 MR. AHMAD: Excellent question. I don't 18 recall specifically.
19 exactly know. I can -- I can count. Three, four -- 19 Q. Did you have any approval role with respect to
20 MS. REA: Oh, okay. I think we both found 20 Dr. Gokal? In other words, were you involved in the
21 it. 21 actual -- well, let me ask you this.
22 A. Yeah, I found it. 22 Were you involved in the actual hiring
23 MS. REA: I think we both found it. Thank 23 decision?
24 you. 24 A. No.
25 Q. (BY MR. AHMAD) Okay. And I'll describe this 25 Q. Okay. And do you -- do you know -- and if you

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1 because it doesn't have a number label at the -- at the 1 don't, that's fine. Do you know who would have been
2 bottom. But it looks like it's written on Harris County 2 involved in making the decision to hire Dr. Gokal?
3 Public Health letterhead with the logo, specific 3 A. The only thing I could answer on that is I know
4 letterhead looks like Umair Shah as executive director, 4 that Mac McClendon did talk to Dr. Gokal because I
5 but looks like stamped at the bottom Mylinh Mai, 5 remember Mylinh mentioning it because at the time of
6 recruiting program coordinator. Is that correct? 6 offer, I want to say in passing Mylinh mentioned that
7 A. Yes, that letter is correct, yes. 7 Mac McClendon had done an interview and was ready to
8 Q. And that's an offer letter to Dr. Gokal; is 8 make an offer.
9 that right? 9 Q. Do you remember seeing Dr. Gokal's employment
10 A. That is an offer letter, yes. 10 application?
11 Q. And does it appear -- well, first of all, it 11 A. I don't. I don't recall looking at it. But
12 appears that Dr. Gokal is going to be starting on 12 should I say to finish the answer to that question, I
13 April 13th, 2019, if you look at the fourth paragraph. 13 wouldn't have normally because that would have been
14 A. Yes, the offer letter does say that that was 14 Mylinh's job to do so.
15 the start date. 15 Q. Got it. So, for example, you -- if you go on
16 Q. Okay. To the -- to the best of your knowledge, 16 to the next few pages, you'll see Dr. Gokal's employment
17 is that accurate? 17 application.
18 A. I don't have a memory of exactly when Dr. Gokal 18 A. Yes, I do see it.
19 started. With offer letters, sometimes the date on the 19 Q. Have you -- to your knowledge, have you ever
20 letter and the actual start date do differ by a little 20 even seen that before?
21 bit just depending on the circumstances. 21 A. To my knowledge, yes, I've seen it because I
22 The County was requiring drug and 22 was the one who physically made the copies for this
23 background screening; we wouldn't allow individuals to 23 subpoena, so I pulled his file and flipped through. Did
24 start without. So there were times that those start 24 I read it? No. Did I see that it was his application?
25 dates would be potentially altered, delayed potentially. 25 Yes.

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1 Q. And then after the application, there is a 1 Q. More than ten?
2 position -- I guess I'll call it a position summary and 2 A. I would say yes. I would say yes. Sorry, it's
3 job duties on Harris County Public Health letterhead 3 so difficult with as many meetings and as many hours as
4 right after his employment application? 4 we worked. I don't remember a lot of things.
5 A. Yes, that is titled Physician Emergency 5 Q. Do you know why this job description was
6 Response. That would have been his job description. 6 established?
7 And we would have used this -- or parts of this 7 A. As far as I know, it was established because
8 description to post the position when we were 8 our COVID activities were getting to be sizeable and we
9 advertising for it. 9 wanted dedicated -- not we. I shouldn't say "we." I
10 Q. Did you draft any part of this position summary 10 can take that back.
11 and job description? 11 Mac McClendon and Jennifer wanted a
12 A. I don't recall drafting it, but I more than 12 dedicated physician for emergency response, which in
13 likely did edit it because this is the newer format that 13 this case would have been specifically for our COVID
14 we were using for Public Health when I was there, and I 14 response.
15 changed the format. So I -- I believe that I edited 15 Q. And were you aware -- I mean, was the County
16 this one. 16 aware of COVID when this position was created -- when
17 Q. Did you ever meet Dr. Gokal? 17 this job description was created?
18 A. Yes. 18 A. Recalling dates, we would have just been
19 Q. When did you -- when did you have occasion 19 underway with COVID. If I'm not mistaken, COVID for us
20 to -- to meet him or work with him? 20 started with activation in March. I can't remember a
21 A. I don't recall the specific dates. Dr. Gokal 21 specific date. So I believe Gokal -- it would have
22 and I were on a number of calls. I more than likely met 22 been -- sorry -- it would have been March of 2019, and
23 him on a Teams call. Public Health, and particularly 23 Gokal was hired after that.
24 the leadership in the incident command, used Teams 24 Q. Well, we may have our dates off. And maybe I'm
25 meetings quite a bit, so I think it was quite a while 25 wrong, but I seem to remember -- you know, it's been a

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1 before I met him in person. 1 while since COVID started. I seem to remember it March
2 Q. Okay. How many times do you think you met him 2 of 2020.
3 in person? 3 A. Okay. Then that's very possible. I will say
4 A. I don't really have an accurate number that I 4 with COVID, all the days blended together, so dates,
5 could give you on that. 5 years, I don't remember specifics as much as I used to.
6 Q. Okay. I mean, more than twice? And I'm not 6 Q. Got it. Okay.
7 counting the -- the time of his termination. Would you 7 A. So if that's the case, then I -- what I recall
8 have met him in person twice before that? 8 was the position was hired specifically for COVID, but
9 A. I -- I don't know because we had so many calls 9 that may not be the case based on the dates that I'm --
10 and so many meetings on Teams. We were trying to limit 10 I'm unsure of at this point.
11 our contact with people because of COVID and we were all 11 Q. Do you know whether -- you know, I think we saw
12 out in the field doing different activities. I don't -- 12 April 2019 -- I'm not sure that's even correct. But let
13 I cannot remember the first time or times that I met him 13 me just ask it this way if you know.
14 in person. I don't -- I don't recall. 14 Do you know if Dr. Gokal was hired after
15 Q. Okay. You know you at least met him in person? 15 the COVID outbreak or before?
16 A. I want to say yes, but I really can't recall 16 A. Now that you're mentioning the dates, I don't
17 because we were doing so many meetings via Teams. 17 recall. I -- I -- if the dates for COVID were 2020,
18 Q. Okay. And how many times did you have a Teams 18 then he would have been hired before.
19 meeting? 19 Q. Yeah, and I think, you know, part of the
20 A. Oh, I don't know if I could put an accurate 20 confusion is -- and I'll represent to you I think the
21 number on it. I mean, I would be guessing if I did. I 21 actual date was wrong, you know. But --
22 mean, we were having Teams meetings on the leadership 22 A. So --
23 time -- on the leadership side on a daily basis 23 Q. -- but I'm just asking if you remember him
24 sometimes. So I'm not sure he was on all those calls, 24 being hired before or after COVID, and if you don't,
25 but it would have been a significant number of calls. 25 that's fine.

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1 A. Yeah, I -- I really honestly don't recall. 1 County," I mean general Harris County, not Public
2 What I would probably suggest is there -- I mean, we -- 2 Health.
3 we could still pull a date from the system. Our ERP 3 Q. And let me ask it a little bit differently.
4 system had his hire date in there. 4 Was it required that Harris County have an emergency
5 It's very possible that the dates were 5 response physician? In other words, was it a
6 wrong. I -- I honestly don't remember at this point. 6 requirement for the County, therefore becoming a
7 Q. Yeah. And not -- I tell you what, if you go 7 requirement of the County?
8 after this job description, you'll see Dr. Gokal is 8 A. Was it a requirement for the County? I don't
9 filling out his W-4 -- 9 know how to answer that because it was a position that
10 A. Uh-huh. 10 Mac McClendon felt he needed, which he's part of Harris
11 Q. -- and you'll see it's actually April 13th, 11 County Public Health. And it was an ask he had
12 2020. Do you see that? 12 specifically for COVID, so I'm not sure I could -- I
13 A. I do see that. 13 mean, I don't know how to answer -- I don't know how I
14 Q. And if that's right, it would have been after 14 would answer that.
15 COVID. 15 Q. Well, if you don't know, you know, it's fine to
16 A. Which was my initial thought was he was hired 16 say you don't know.
17 for COVID. 17 A. It was an ask on Mac's part for the -- for the
18 Q. Correct. Correct. 18 COVID response.
19 A. Yeah. 19 Q. Okay.
20 Q. Okay. 20 A. And I should finish that answer. He had to get
21 A. Yeah, I apologize. It really -- just from a 21 approval in order to fill it, though, so it was a new
22 date standpoint, I -- I was not involved in every -- 22 position that didn't -- that hadn't existed before
23 Q. I think -- 23 within the Harris County Public Health structure.
24 A. -- hire. It just -- 24 Q. Got it. And, by the way, these documents are
25 Q. I know. I think we got thrown off because the 25 all documents that you provided as part of Dr. Gokal's

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1 offer letter -- 1 employment file?
2 A. Right. 2 A. The ask from the affidavit, I believe, was
3 Q. -- evolved -- 3 everything in the employment file.
4 A. Yeah. 4 Q. And if we -- I'm going to -- again, I think
5 Q. -- by -- 5 we're going to have to identify these by title. But if
6 A. That's wrong. 6 you go back now from his offer letter a few pages, it
7 THE COURT REPORTER: Please, one at a time. 7 looks to be about 10 to 12 pages, you'll see some
8 THE WITNESS: I'm sorry. I'm sorry. I 8 compensation -- actually, you'll see a termination
9 keep forgetting. 9 letter on January 7th, 2021, so I can start there.
10 Q. (BY MR. AHMAD) Yeah. Do you know if there's a 10 A. Yes, yes. Yes, I'm there.
11 requirement at the County to have this position for 11 Q. And you signed that?
12 which Dr. Gokal was hired? 12 A. I did sign that letter, yes.
13 A. I'm not sure I understand the question. Could 13 Q. Okay. And if you go to the next page, there is
14 you possibly rephrase that? 14 an employee compensation form. Do you see that?
15 Q. Sure. This is a job description for physician 15 A. I do see it.
16 emergency response or emergency response physician, 16 Q. And I guess it has some classification
17 maybe ERP. Do you know that there is a County 17 information for him. Do you see that?
18 requirement for that position? 18 A. I mean, I see the form, so, yes.
19 A. I don't. 19 Q. Are these compensation forms -- were these true
20 Q. Okay. 20 and correct compensation forms from the County file for
21 A. No, I don't. In terms of when the position was 21 Dr. Gokal?
22 created, it was -- started with a conversation with Mac 22 A. This is what was in his employee file. And the
23 McClendon. So I know there was an ask on his part for 23 form is actually a County -- Harris County auditor's
24 the position, but I don't believe it was a requirement 24 form that we're required to complete and send in.
25 from the County's perspective. And when I say "the 25 So as for its accuracy, I didn't fill this

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1 one out. Looking at it, it looks -- it looks accurate, 1 dated April 13th, 2020. Can you tell who -- whose
2 to the best of my knowledge, but, again, I didn't 2 signature that is?
3 complete this form and wasn't responsible for it 3 A. Employer's authorization. I don't recall that
4 ultimately. 4 signature at all. I don't know who would have signed
5 Q. Who is Candice Oliphant? 5 that.
6 A. Candice worked for me as a HR business partner. 6 Q. Okay. And then the next form is a new hire
7 Q. Would she have been the one filling it out? 7 general information form?
8 A. She would have been the one completing it in 8 A. Yes.
9 the system -- well, the system completes it for us. She 9 Q. Were you familiar with any of this information?
10 would have been the one that printed it and got it 10 A. I don't really look at new hire -- general
11 signed -- 11 information on every new hire, so the only time I would
12 Q. You would agree with me -- 12 have seen it would have been printing the copies for
13 A. -- by Dr. Gokal. 13 this particular affidavit, and then -- even then, I'm
14 Q. Oh, I'm sorry. 14 not sure I read it. I just noted that it was there in
15 You would agree with me it should be 15 the employee file.
16 accurate? 16 Q. At some point did you become aware that
17 A. It should be because this was the record that 17 Dr. Gokal was Asian, South Asian, Pakistani?
18 would have gone into the system as to Dr. Gokal's 18 A. I'm not sure I understand the question.
19 employment. 19 Q. I take it you knew that Dr. Gokal was some type
20 Q. It's a County record, in other words? 20 of Asian ethnicity?
21 A. It is a County record because it is a Harris 21 A. Visibly, yes.
22 County auditor's form, so . . . 22 Q. Did you know anything more than Asian, for
23 Q. And just to be clear, all the documents in this 23 example, South Asian or Pakistani?
24 exhibit after the declaration page and -- and the 24 A. I mean, I typically -- in dealing on the HR
25 subpoena page, those are all County records, correct? 25 side, I mean, I typically refer to things through the

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1 A. Could you repeat that because you said it was 1 general EEOC-type terminology, so I would have used
2 after the -- 2 Pacific Islander probably.
3 Q. Yeah. You remember, the first page is the 3 Q. You mean Asian/Pacific Islander?
4 declaration page. The second page is your responses, 4 A. Uh-huh.
5 Attachment A. And then after that are several different 5 Q. Yes?
6 types of Harris County records, correct? 6 A. Yes.
7 A. I -- it appears that everything would be 7 Q. Were you aware that he was Pakistani?
8 related to Harris County, although some of them are 8 A. I don't recall ever asking or knowing or
9 specific to public health -- Harris County Public Health 9 discussing it, so I don't know.
10 at least. But, in general, all of them would be Harris 10 Q. I'm just -- yeah, and I'm not asking whether
11 County records. 11 you asked or anything like that. I'm just wondering if
12 Q. And these are documents that -- that you 12 you were aware, you know, somewhere in your mind that he
13 provided as part of your declaration, correct? 13 was Pakistani.
14 A. They are the documents I provided for this 14 A. I'm not sure I had enough interaction to really
15 criminal declaration, yes. 15 even go any further than that -- than the general EEOC
16 Q. And if you go to the next page of the -- 16 category.
17 there's another form also entitled Employee's 17 Q. Okay. And the EEOC category is Asian/Pacific
18 Compensation Form. Do you see that? 18 Islander?
19 A. Bear with me one second. I flipped to look -- 19 A. I believe they've changed it a few times, and I
20 Q. Yeah. 20 can't tell you exactly what it is right now because I
21 A. -- at the rest of the documents. 21 don't fill out those forms and haven't for quite a
22 Q. This is the page after the one signed by 22 while.
23 Candice Oliphant. 23 Q. But it's something like that?
24 A. Okay. I see it now. 24 A. It's similar to Asia/Pacific Islander, yes.
25 Q. There's an employer authorization signature 25 Q. Did you ever form an opinion about Dr. Gokal's

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1 performance on the job at the County? 1 would know better about what to do in a medical
2 A. Me personally? Not really. I mean, I was in 2 emergency more than Dr. Gokal at the -- at the County?
3 meetings with him, but our roles didn't cross much, so 3 A. Yeah, I don't --
4 I'm not sure I would have had an opinion or any 4 MS. REA: Objection, form.
5 observation of his direct performance. 5 A. I would say Mac has been in a lot of responses.
6 In general, in -- Dr. Gokal was very active 6 But were they medical, I don't know. And I think my
7 to some degree in some of our employee activities, so we 7 knowledge of Dr. Gokal -- I don't know his background.
8 did a lot of team building activities, and so I would 8 I mean, I think that was kind of clear in the discussion
9 see him there on -- -- you know, there were some videos 9 we had earlier regarding his application. I really
10 that he shot that were really funny. 10 didn't know his medical credentials or his work history,
11 I would generally say that I enjoyed seeing 11 to say the least, so I'm not sure I'm capable of saying
12 him participating in those activities because it was -- 12 that he would be anything.
13 he had a great personality and a good sense of humor, so 13 Q. (BY MR. AHMAD) And to be clear, Mac McClendon
14 it was -- that's probably the only opinion I would have 14 is not a physician?
15 had of him in terms of interacting with him. 15 A. He's not a physician, no. And when I referred
16 Q. Do you know anybody that had an opinion of 16 to Mac McClendon, I specifically said he was more
17 Dr. Gokal's performance? 17 knowledgeable in emergency responses in general because
18 A. I don't really remember any conversations. I 18 he was -- I know his experience dates back to boots on
19 mean, I would just -- based on the fact that he was 19 the ground at 9/11 and a number of other emergency
20 reporting to Mac and Jennifer and the response, if 20 responses.
21 anyone would have comments, it would have been them 21 But in terms of medical and specifically to
22 because they were his direct supervisors, but I don't 22 Dr. Gokal, I'm not sure I'm qualified to say he would
23 really recall any conversations regarding performance 23 be -- he would or would not be the most knowledgeable.
24 specifically about Dr. Gokal. 24 I just don't have the context.
25 Q. Okay. You understood that Dr. Gokal was going 25 Q. Well, I -- and I think you mean to say you just

Page 42 Page 44
1 to be the department of public health's lead physician 1 don't have the knowledge, because the context is -- I
2 for emergency response activities? 2 think I provided that.
3 A. He was hired specifically for the COVID 3 A. Okay. Fair enough.
4 response, so, yeah, he was our lead medical adviser 4 MS. REA: Objection, form.
5 for -- for the response. 5 A. Yeah.
6 Now, there were also -- as a part two to 6 Q. (BY MR. AHMAD) I think -- I think what you're
7 that answer, there were also health authorities, sworn 7 saying -- but correct me if I'm wrong -- is that you're
8 health authorities that did play a role as well in the 8 just not qualified to say?
9 COVID response. But Dr. Gokal was hired specifically 9 MS. REA: Objection, form.
10 for emergency preparedness, which was the group that Mac 10 A. I would say at this point, I don't know
11 and Jennifer were in charge of. 11 Dr. Gokal well enough to form an opinion of whether or
12 Q. And he was the lead physician for that? 12 not he would have been the most knowledgeable at the
13 A. He was the only physician for that. 13 time.
14 Q. Okay. And I take it -- well, do you know 14 The role itself of the lead physician in
15 anybody that would know better what to do in an 15 emergency response was a significant role, but there
16 emergency than the emergency response physician -- 16 were also other medical authorities that were involved
17 MS. REA: Objection, form. 17 as local health authorities. So we would have had a
18 Q. (BY MR. AHMAD) -- at -- at Harris County? 18 number of individuals that would have had medical
19 MS. REA: Objection, form. 19 experience, but, again, I can't -- I cannot be the -- I
20 A. I'm not an expert in emergency response. 20 can't tell you which -- which one of them would have
21 I'm -- as you went through my LinkedIn profile, I'm an 21 been the most qualified to take care of this type of a
22 HR person. 22 situation.
23 Q. (BY MR. AHMAD) And I'm not saying you are. 23 Q. (BY MR. AHMAD) And who were those medical
24 A. Sure. 24 authorities when it comes to emergency response
25 Q. I'm saying do you -- do you know of anybody who 25 preparedness?

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1 A. Well, specifically emergency response, that 1 be the district attorney's office; is that correct?
2 would have been with Dr. Gokal. There were other local 2 Q. You're correct. I'm sorry. If I said -- if I
3 health authorities, though. They're not -- they did not 3 said --
4 work in emergency prepared -- the emergency preparedness 4 A. Okay.
5 group. 5 Q. -- Harris County Attorney's Office, I meant to
6 Q. Any other physicians that you're aware of in 6 say Harris County District Attorney's Office.
7 Harris County Public Health? 7 A. Yeah, the Harris County District Attorney's
8 A. There were -- 8 Office investigation, they did ask for documents from
9 MS. REA: Objection, form. 9 me, and I do believe it was -- it was Vanessa Cook who
10 A. -- a handful of physicians. 10 did ask for no different than what you presented to some
11 Q. (BY MR. AHMAD) And who were they as of the 11 degree in Exhibit 2.
12 time you left? 12 Q. Did you -- do you know whether Vanessa Cook,
13 A. Oh, at the time that I left? At the time that 13 investigator for Harris County District Attorney's
14 I left, Dr. Brown. I believe Dr. Onyiego was already 14 Office, do you know whether she interviewed you as part
15 gone. I don't recall the rest. I don't know -- I don't 15 of the Gokal investigation?
16 know who was there when I left now. I couldn't tell you 16 A. I honestly don't remember talking to her.
17 the rest. I know Dr. -- I know Dr. Brown had been 17 Q. Do you remember talking to anybody in the
18 recently hired when I left. After that, I don't know. 18 Harris County District Attorney's Office?
19 Q. Do you know if Dr. Brown is a medical doctor, 19 A. There were a couple of calls from the district
20 licensed? 20 attorney's office regarding the documentation I had on
21 A. I did not hire her. She was hired through our 21 Dr. Gokal. Do I remember them specifically? No. There
22 new executive director. In terms of qualifications for 22 were maybe two or three, and it wasn't just one
23 Dr. Brown, I don't know. I don't know. 23 individual. There were multiple individuals on the call
24 (Exhibit 3 marked.) 24 from the district attorney's office.
25 Q. (BY MR. AHMAD) I have in front of you what's 25 They identified themselves as lawyers, but

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1 been marked as Exhibit 3 to your deposition. 1 I did not get names. There were probably four of them
2 Have you seen this document before? 2 on a call. So I don't specifically recall talking to
3 A. I have not seen this document. No. 3 Vanessa Cook, but I do recall discussing the situation
4 Q. Okay. Do you remember an investigation report 4 and the investigation that I conducted with the district
5 or an investigation by the Harris County attorney's 5 attorney's office.
6 office into Dr. Gokal? 6 Q. And the situation and investigation was
7 A. I don't recall because the investigation in 7 regarding Dr. Gokal?
8 terms of the event that led then to termination was 8 A. That is correct. The -- specifically the claim
9 actually conducted by me. So I'm not -- I don't -- I'm 9 that Alison Hare brought to us on January the 6th of
10 not actually aware of really this at all. I would need 10 twenty twenty -- I can't remember the year. It was
11 to read through it to even see what it's referring to. 11 January 6th. I know that.
12 Q. Okay. Do you remember talking to an 12 Q. 2021?
13 investigate -- couple of investigators named Cook or 13 A. That sounds correct.
14 Gonzales? 14 Q. Do you know any of the names of the people you
15 A. I -- I vaguely remember the name Cook. And 15 talked to at the Harris County District Attorney's
16 specifically mentions here is Vanessa Cook, but I don't 16 Office about Dr. Gokal?
17 remember a Gonzales at all. And I don't recall -- I 17 A. Other than recognizing Vanessa Cook's name? I
18 don't recall -- I mean, I know the name, but I'm not 18 don't remember. I said I do know there were three or
19 sure I remember a conversation with her. 19 four attorneys on a couple of Teams calls, but I don't
20 Q. Okay. I just want to be clear on that last 20 remember names specifically.
21 part. Do you remember talking to Vanessa Cook at the 21 I wasn't really much involved with the
22 Harris County District Attorney's Office about 22 district attorney's office other than providing them
23 Dr. Gokal? 23 with some documentation, a list of names, and similar --
24 A. Oh, okay. This is not the Harris County 24 similar documents that were provided for the Exhibit 2
25 Attorney's Office. I'm sorry. Can -- this appears to 25 document.

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1 Q. Okay. Well, do you know if you gave what the 1 A. I just don't remember that conversation. I
2 Harris County District Attorney's Office considers an 2 don't.
3 interview? 3 Q. You don't remember meeting them at all?
4 A. I don't -- 4 A. I mean, I -- now that I read it, it sounds
5 MS. REA: Objection, form. 5 vaguely familiar, but I don't -- I can't tell you that I
6 A. -- remember. 6 remember that particular conversation.
7 Q. (BY MR. AHMAD) Okay. 7 Q. Have you ever met with people from the district
8 A. I had many discussions with them. I don't know 8 attorney's office?
9 their definition of an interview. I'm not sure I know 9 A. I've talked to them -- I have talked to them,
10 your definition of an interview, but I did have 10 yes, particularly about Dr. Gokal and -- but I don't
11 discussions with them regarding the specific case with 11 remember this particular interaction.
12 Dr. Gokal and the investigation I conducted. 12 Q. Well, have you ever met with people from
13 Q. Were you aware that those interviews were tape 13 district -- the district attorney's office before other
14 recorded or voice recorded? 14 than with Gokal for any reason?
15 A. I don't remember. Yeah, I don't remember them 15 A. Met with -- I don't -- I don't think there was
16 saying they were recorded or not. I don't know. 16 much interaction that I had with the district attorney's
17 Q. Are you saying they didn't tell you that it was 17 office. It would only have been in something that the
18 being recorded, or you just don't remember whether they 18 DA's office would have taken up as a case. I've never
19 told you? 19 had anything with the district attorney's office other
20 A. I don't remember recording coming up at all, so 20 than Dr. Gokal.
21 I don't know if they were recorded. I don't know if 21 Q. I'm just asking because I would think it would
22 they mentioned they were being recorded. I don't -- I 22 be a fairly memorable occasion if you met with somebody
23 don't remember any part of a recording, unfortunately. 23 from -- you know, criminal authorities from the district
24 Q. Okay. You're not saying they didn't mention 24 attorney's office. I would think that would be fairly
25 it. You're just saying you don't remember? 25 memorable. Is it -- but --

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1 A. I just don't remember, no. Those calls 1 A. It isn't.
2 happened fairly infrequently. There were maybe two or 2 MS. REA: Objection, form.
3 three of them. There were a number of people on the 3 A. It's actually not. And I'll tell you why.
4 call that I don't really know. The attorneys in the 4 Because there were so many different things going on at
5 district attorney's office I don't typically deal with, 5 that particular time, working 15 to 18 hours a day.
6 so I don't know them. 6 There were incidents at our COVID sites with patients,
7 Q. Okay. Well, let me see if this will help. 7 with contractors, with employees. I had a number of,
8 A. Okay. 8 just, issues. It was a pretty stressful time.
9 Q. If you go to page 2, which is GOKAL000241. 9 And, unfortunately, I'm now out of it, and
10 A. Uh-huh. 10 so I don't remember every single conversation I had with
11 Q. Do you see where it has kind of on one line 11 every single person. There probably were notes from a
12 towards the bottom Herbert Trey Frankovich. Do you see 12 meeting, if -- I mean, this meeting, if there's a
13 that? 13 recording, great. But I don't remember it specifically.
14 A. I do, yes. 14 I just don't. I'm sorry.
15 Q. Now, if you go to the paragraph above that, do 15 Q. (BY MR. AHMAD) So it wasn't a very memorable
16 you see where it says -- and I'm just going to quote 16 meeting with the district attorney's office?
17 from the paragraph -- "On Monday, January 11, 2021, ADA 17 MS. REA: Objection, form.
18 Hartman, Investigator Gonzales, and I went to the Office 18 A. I didn't say that. I just said that I don't
19 of Public Health located at 2223 West Loop South, Suite 19 remember it. Whether it's memorable or not, that's a
20 735, Houston, Harris County, and met with Trey 20 totally different answer.
21 Frankovich, Alison Hare, Michael McClendon, and Ed 21 Q. (BY MR. AHMAD) Fair to say there was a lot
22 Anderson." 22 going on back then with the COVID response?
23 A. I do see that part in -- on that page 2. 23 A. There was a lot going on, yes. And my role was
24 Q. Do you remember meeting with anybody from the 24 extremely stressful because at a moment's notice, the
25 district attorney's office? 25 judge's office would call and say we need 300 more

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1 people hired, and I would be given three days. 1 (Exhibit 4 marked.)
2 And so the stress of trying to hire and 2 THE VIDEOGRAPHER: We are back on record.
3 maintain our COVID testing and vaccination sites and 3 Time is 11:53 a.m.
4 having all of that happen all at the same time and 4 Q. (BY MR. AHMAD) Okay. Mr. Anderson, you've had
5 working 18 hours a day was pretty stressful. 5 a chance to look at the interview summary in Exhibit 3,
6 Q. Can you imagine that it was pretty stressful 6 correct?
7 and overwhelming for somebody like Dr. Gokal? 7 A. I have looked at the section labeled Edward
8 MS. REA: Objection, form. 8 Anderson, yes.
9 A. Yeah, I can't answer that. I don't know what 9 Q. Anything in there that you know of that's
10 Dr. Gokal was -- was thinking or feeling. It was 10 inaccurate?
11 stressful for a lot of people. I can say that much. 11 A. Well, that's kind of hard to say because the
12 Q. (BY MR. AHMAD) You just don't know whether it 12 individual that wrote this up was obviously not me. I
13 would be stressful for somebody like Dr. Gokal? 13 can definitely say that there's some things in here that
14 A. I could say -- 14 are slightly concerning and not accurate as well as the
15 MS. REA: Objection, form. 15 slant and the timing -- the timing in terms of the order
16 A. -- it was stressful to everyone, I mean, not 16 is not -- it's not a timeline, although it appears that
17 singling out any one particular individual. I don't 17 they may have written it as -- as such.
18 know how Dr. Gokal feels. He may work great under 18 For example, if you look at the very first
19 pressure. Some people don't. 19 line of the document of the section labeled Edward
20 Q. (BY MR. AHMAD) Do you think there was a lot of 20 Anderson, it says that I was the human resource director
21 pressure on health care professionals back then? 21 for Harris Health, and that's not accurate. I was the
22 MS. REA: Objection, form. 22 director for Harris County Public Health.
23 A. I don't think it's my job to think for everyone 23 And so I don't know -- you know, I don't
24 else, but I will say personally there were a number of 24 know who wrote this. I don't remember the conversation.
25 individuals that were stressed in public health. 25 But there are definitely things in here that are

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1 Q. (BY MR. AHMAD) Now, if you go -- you'll see, 1 definitely a slant on the conversation.
2 by the way, they have a list of the people that they met 2 Q. And what are those things?
3 with and a summary. 3 A. Well, like I mentioned, the -- the title, for
4 A. Uh-huh. 4 one thing. I mean, this wasn't -- the conversation as
5 Q. If you actually look at the last line of the 5 it's depicted now, some of these things were part of my
6 paragraph that I read to you, it says: "The following 6 investigation process, and so I was working with our
7 is a summary only of the interviews." And then it goes 7 leadership team, and some of the items in here were not
8 through first Trey Frankovich, then Alison Hare, then 8 necessarily my thoughts or beliefs. It was speaking on
9 McClendon. And then on page 8, or GOKAL000247, at the 9 behalf of the leadership team because we were having
10 top, it goes to you. Do you see that? 10 conversations about the -- particularly the section
11 A. I do see that. 11 regarding second doses and how second doses would have
12 Q. Okay. Can you read that over? It looks like 12 been administered and the thought of potentially
13 it's about three pages -- almost three pages. Not 13 Dr. Gokal taking doses to give to those individuals as
14 quite. 14 second doses since they were claimed to be bedridden,
15 A. Yes, I can read it over. 15 that was not my thought necessarily. That was our
16 Q. Okay. Do you want to -- do you want to do 16 leadership's -- team's discussion. That would have
17 this? Would you like some time to read it over? 17 included Gwen Sims, Mac McClendon, Jennifer Kiger, and
18 A. Yeah, I would because I haven't seen this 18 such.
19 document before. If that's possible, that would be 19 So I don't know the person, I mean,
20 great. 20 specifically who wrote this, but it definitely has some
21 Q. It is possible. Why don't we take a break. 21 things in it that are, again, not -- it's not a timeline
22 A. Okay. That works. Thank you. 22 and it's -- it's definitely not my 100 percent beliefs,
23 THE VIDEOGRAPHER: We're off record. Time 23 so to speak.
24 is 11:23 a.m. 24 (Melissa Martin joins the proceedings.)
25 (Short recess.) 25 Q. (BY MR. AHMAD) Well, is there anything in

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1 there -- anything other than what you've mentioned 1 Q. The employee was Alison Hare?
2 that's not your belief that's listed in your interview 2 A. Alison, that's correct.
3 summary? 3 Q. Okay. Did she use those words, "bragging"?
4 MS. REA: Objection, form. 4 A. She used -- I don't know if she used those
5 A. I mean, I would say at this point -- there's a 5 exact words, but she alluded to the fact that he was
6 lot of things in here that I would say if you're looking 6 bragging about it, so I may have paraphrased and said in
7 at this as a timeline, it isn't. If you're looking at 7 a bragging fashion, but she used the word "bragging."
8 these as quotes directly from me, I don't believe some 8 Q. She used that word?
9 of them are. 9 A. Uh-huh.
10 Again, I don't know the individual who 10 Q. Yes?
11 wrote this, but, in general, that discussion was -- 11 A. Yes.
12 was -- the individual who has -- has tried to document 12 Q. And when -- well, let me ask you this: Were
13 this may or may not have gotten it exactly the way it 13 Jennifer Kiger, Mac McClendon, Trey Frankovich, were --
14 was. 14 were they in the office -- 2223 West Loop South, were
15 Q. (BY MR. AHMAD) Do you feel like you said 15 they in the office at the time you were interviewed?
16 anything to the criminal authorities that was 16 MS. REA: Objection, form.
17 inaccurate? 17 A. I -- in my office?
18 A. That, I can't tell you because I don't -- I 18 Q. (BY MR. AHMAD) Well, in the office.
19 don't recall the conversation at this point. 19 A. That, I wouldn't know. I mean, they -- those
20 Q. Okay. 20 investigators came to meet with me. I'm not sure I
21 A. And I had a number of conversations and I 21 would have known if Mac and Gwen and Trey or any of them
22 don't -- I can't say that at this point. I just don't 22 would have been in the office at the same time, like, in
23 remember it. 23 the same building. I don't know if I would have known
24 Q. Okay. Well, we have a -- a recording of the 24 that.
25 conversation. 25 Q. You weren't aware that they were interviewed

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1 A. Okay. 1 along with you?
2 Q. Would it help to play some of that? 2 A. You know, with my contact with the DA's office,
3 A. I -- that's not my decision. 3 it was pretty limited. They asked me obviously to meet,
4 Q. Okay. Well, it's mine, so we'll -- 4 clearly, and they may have asked for a list of employees
5 A. Okay. 5 that were potentially involved. But after that, I
6 Q. Why don't we play it. I have, by the way -- 6 really had no involvement with their scheduling or
7 for the record, I have the entire conversation marked as 7 investigation whatsoever.
8 Exhibit 4 on a flash drive. 8 Q. Well, you understood that this was a criminal
9 A. Okay. 9 investigation for the purposes of determining whether
10 Q. Let's start with the beginning part and see if 10 Dr. Gokal had committed a crime, correct? You
11 this is -- hopefully -- 11 understood that?
12 (Audio playing.) 12 A. I understood that there was -- there was an
13 Q. (BY MR. AHMAD) I'll stop it right there. 13 investigation, but I would have never known who they
14 Is -- is that your voice responding to the 14 were going to officially interview because I wasn't a
15 district attorney's questions? 15 part of that investigation plan. The DA's office does
16 A. Yes, that's my voice. 16 their own thing.
17 Q. Okay. Anything you've said inaccurate so far? 17 So I wouldn't have known who they were
18 A. Anything that I've said inaccurate? No. 18 going to meet with, when they were going to meet with
19 Q. You mentioned that Dr. Gokal had said -- I 19 them, if they were in the same building at the same time
20 think you said in a bragging fashion had taken a vial of 20 as me. I would have never known that.
21 COVID-19. 21 Q. But you understood that the Harris County
22 What did you mean by a "bragging fashion"? 22 District Attorney's Office was investigating a possible
23 A. Sure. Actually, I said it, but that wasn't 23 crime by Dr. Gokal?
24 what I said, if that makes any sense. I'm quoting what 24 A. Yes, yes, that, I did know.
25 the employee told me. 25 Q. And do you know who contacted the Harris County

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1 District Attorney's Office? 1 with the thought process that he was being terminated
2 A. I don't. The -- it was brought up in one of 2 for this, for the fact that we couldn't trust him based
3 our discussions that the case may be referred over to 3 on his actions.
4 the district attorney's office, but I don't know who 4 And so I wanted to make sure he understood
5 mentioned that in the discussion. 5 that it was a fairly serious matter and that anything
6 Q. Was it you? 6 that he did after he walked out the door, it might be a
7 A. No, no. I -- and like I said before in the 7 problem for him. And so it was more of just a be
8 previous testimony, I had very little contact with the 8 careful, I would say like a warning, you need to be
9 district attorney's office other than for this 9 cautious as to what you do next, just looking out for
10 particular case, so it would not have normally been any 10 him.
11 part of my normal protocol. 11 Like I mentioned before, on all of the team
12 Q. So you don't know who thought of the idea of 12 building activities, I mean, I really liked Dr. Gokal.
13 contacting -- 13 I mean, he would have been a person that I would have
14 A. Huh-uh. 14 loved to have spent more time with. Unfortunately, that
15 Q. -- Harris County District Attorney's Office? 15 just didn't happen with our COVID response. But that's
16 A. Sorry. 16 really the only reason I mentioned it in that meeting
17 No, it was not something that I would have 17 was to make sure he understood that it was a fairly
18 ever dealt with. My role there was to identify -- I 18 serious matter that may continue on.
19 obviously talked to the employee, Alison Hare, with the 19 Q. Going down on Exhibit 3 to the next paragraph
20 complaint and then conduct a full investigation as to 20 under the first paragraph, you'll see it says:
21 what happened. 21 "Mr. Anderson advised that -- that they believe that any
22 Other than that, that would have -- 22 patient forms that contained Dr. Gokal's signature would
23 anything else outside of that would have been outside of 23 have been forms that he would have taken off-site, so
24 my scope of normal job duties. I would never have been 24 they looked for patient forms that contained what they
25 the one to determine whether it was a criminal case or 25 believed to be Dr. Gokal's signature."

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1 not a criminal case. 1 Is that accurate?
2 Q. Okay. And I think, like you said, you've never 2 A. I would say there definitely was a conversation
3 been interviewed by the Harris County District 3 with patient forms with myself and specifically Jennifer
4 Attorney's Office before? 4 Kiger in trying to determine and validate Alison's claim
5 A. I have never had any reason to discuss anything 5 that Dr. Gokal said that he had given the doses to
6 other -- other cases other than this Gokal case. 6 friends and family off-site. So there was a process as
7 Q. And you don't know who actually contacted the 7 a part of the investigation to go through to look at the
8 Harris County District Attorney's Office to inform them 8 patient records.
9 of a possible crime? 9 I didn't have direct access to the patient
10 A. No, I don't. But as you can see through some 10 records. Jennifer did. So I asked her to go through
11 of the write-up, I mean, there were conversations with 11 the documents to see if she noted any signatures and/or
12 other attorneys, but I don't know who it would have been 12 names that would be similar to Dr. Gokal's.
13 that -- that would have referred the case. 13 Q. Okay. So this statement that I just read, is
14 I heard that it was going to be referred, 14 it accurate?
15 but I'm not sure even who told me that it may be 15 A. I would say it's mostly accurate.
16 referred to the -- to the case, because if you'll note 16 Q. Okay. What's the inaccurate part, if any?
17 in the termination conversation with Dr. Gokal, I did 17 A. I mean, it's indicating more so that I did all
18 give Dr. Gokal the heads-up that it may be referred to 18 those things and I didn't. It was just part of my
19 the district attorney's office. But I don't know who 19 investigation.
20 was -- who did that. 20 Q. Okay. "Mr. Anderson stated that they initially
21 Q. And why did you tell Dr. Gokal that? 21 located five or six that they believed matched
22 A. I was concerned for Dr. Gokal. I mean, 22 Dr. Gokal's signature."
23 obviously, we didn't really work that closely together. 23 A. Uh-huh.
24 But I generally liked the guy, and he was -- in the 24 Q. Do you see that?
25 termination meeting, he was having a very difficult time 25 A. Yes.

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1 Q. How did you determine whether something matched 1 A. I'm sorry. You'll have to rephrase that
2 his signature? 2 because now I'm not sure what you're asking.
3 A. I was going off of what -- Jennifer's 3 Q. Yeah, prior to the termination meeting,
4 investigation of the patient files because she had the 4 obviously, you'd already made the decision to terminate,
5 most knowledge of Dr. Gokal's signature. 5 correct?
6 Q. Were you aware that she's not familiar with his 6 A. No.
7 signature? 7 Q. No?
8 A. At the time, I -- that didn't come up. I mean, 8 A. No, that's not accurate.
9 she indicated as if she had gone through them all and 9 Q. Okay. Prior to that termination -- well,
10 knew Dr. Gokal's signature. 10 you finished your investigation before meeting
11 Q. Well, it looks like based on what was being 11 Dr. Gokal, right?
12 said here, that she was matching them up based on a 12 A. I had finished my investigation, yes.
13 comparison to signatures they had for him in his 13 Q. Okay. Did you conclude before meeting
14 employee file. 14 Dr. Gokal that he had given the vaccine to friends and
15 A. Isn't that what I just said? 15 family?
16 Q. Well, I was asking whether she was familiar 16 A. There was no 100 percent on anything. We
17 with his signature, and apparently she had to use a 17 looked -- it looked to be that there could be a
18 comparison to the signatures on file as opposed to being 18 possibility, but, again, it was a part of the
19 personally familiar with it. 19 investigation process. So in looking at it when there
20 A. Okay. That part -- 20 were individuals with the same last name as Dr. Gokal,
21 MS. REA: Objection, form. 21 we had some assumption that there was a possibility that
22 A. -- I don't remember specifically. I'm not sure 22 he gave it to friends and family.
23 how she determined they were his or not, but she 23 It wasn't until the termination meeting
24 indicated that she would go through the patient records 24 when I ran through what was claimed by the employee,
25 because I didn't have access to patient records. I was 25 Alison Hare specifically, of what transpired was when

Page 66 Page 68
1 not in a position to have patient data. 1 Dr. Gokal said, "Yes, I did give it as you stated to
2 Q. (BY MR. AHMAD) The next line says: 2 friends and family."
3 "Mr. Anderson also explained that the patient forms that 3 Q. Well, to be clear, there's only one employee --
4 they've identified were also individuals of the same 4 one person, rather, not employee, who was given the
5 nationality as Dr. Gokal (Asian). So at that point, it 5 vaccine with Dr. Gokal's name, correct?
6 looked as though the forms would belong to friends and 6 A. I haven't looked at the patient files in a
7 family." 7 while, but I know there was at least one.
8 Is that what you explained? 8 Q. Okay. Well, if you go back and look at
9 A. That was part of the investigation process 9 Exhibit 2. You've attached the patient files to
10 regarding the friends and family. So is it exactly what 10 Exhibit 2, have you not, starting on the third page?
11 I explained? I don't know. I mean, I wouldn't have put 11 A. Yes, those are the patient records that were
12 Asian in quotes, and I wouldn't have done it that way. 12 believed to be the ones that were given by Dr. Gokal.
13 So, again, we're talking about the investigator -- I 13 Q. Can you identify anybody besides Maria Gokal
14 don't know. 14 that is a family member of Dr. Gokal's?
15 Q. Did you conclude in your investigation that 15 A. So I wouldn't know that specifically as to who
16 Dr. Gokal gave it to friends and family? 16 his additional family members were other than the one
17 A. Did I conclude in my investigation? 17 that had the same last name.
18 Q. Yes. 18 Q. Okay. But you said "family members," and I'm
19 A. Well, I did because he told me he did. 19 just trying --
20 Q. Okay. 20 A. I said "friends and family" initially, so it
21 A. He validated in that termination meeting when I 21 was indicated that he gave it to friends and family. I
22 asked him did you give it to friend. And I ran through 22 was trying to do part of my investigation to at least
23 the summary of what happened, and he admitted to it. 23 get some validity before I walked into the room to talk
24 Q. Well, prior to the termination meeting, did you 24 to Dr. Gokal.
25 come to that conclusion? 25 In the room with Dr. Gokal, we wanted to

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1 give him due process and give him a chance to explain 1 MR. AHMAD: -- play more of it.
2 what happened based on the scenario that was presented 2 MS. REA: -- if we could just play the end
3 by the employee. It wasn't until that point that once 3 of the --
4 he admitted to the scenario of him taking the vial 4 MR. AHMAD: Yeah, yeah, yeah, we can do
5 across town, giving it to friends and family, that we 5 that. That's not a problem.
6 then determined that it was termination due to the 6 MS. HOPKINS: Do you want me to replay
7 trust -- the lack of trust. 7 the --
8 Q. Okay. Well, if I understand, you -- you 8 MR. AHMAD: Yeah, yeah, replay it.
9 validated the allegation that he gave it to friends and 9 (Audio playing.)
10 family prior to meeting? 10 Q. (BY MR. AHMAD) Okay. I played a lot after it
11 A. Not 100 percent. 11 just to make sure.
12 Q. Maybe -- 12 MS. REA: I think that was -- yeah, I think
13 A. I can't say that that's accurate, no. 13 he's just talking about scheduling now, so we're fine
14 Q. You validated it to some extent, maybe more 14 with that.
15 than 50 percent? 15 MR. AHMAD: Okay. Yeah, so I just want to
16 A. There was some instance that could say that it 16 make sure I addressed your objection.
17 was possible at that point. 17 MS. REA: Yes, I think you did.
18 Q. And did you conclude that -- that based upon 18 Q. (BY MR. AHMAD) First, that is your voice
19 the fact that the patient forms looked like they were 19 explaining this to the district attorney's office,
20 the same nationality as Dr. Gokal? 20 correct?
21 A. There was no conclusion on any of that until he 21 A. Yes, that's my voice, uh-huh.
22 admitted that it was friends and family in the meeting 22 Q. And your words back then were that based on the
23 with -- for termination. 23 patient forms, it looked like Dr. Gokal had given the
24 Q. Well, here, but you said it was the patient 24 vaccine to friends and family, correct?
25 forms. 25 A. That's right, yeah, but I put emphasis on the

Page 70 Page 72
1 A. We noticed that it was a possibility of friends 1 word "looks like." There's -- that's not definitive by
2 and family, but there was no conclusion at that point. 2 any means.
3 Q. You don't say that here, do you? 3 Q. Okay.
4 A. I don't say a -- 4 A. And as the video -- or the audio recording goes
5 MS. REA: Objection, form. 5 on to say, that we were going to give him due process to
6 A. -- a lot of things here. I mean, there was a 6 explain himself as to what the employee had reported --
7 lot of things in the investigation that aren't included 7 Q. Okay. Well --
8 necessarily in my -- one conversation with the district 8 A. -- because, again, there was no -- it was not
9 attorney's office. 9 100 percent. I mean --
10 Q. (BY MR. AHMAD) Do you think it would have been 10 Q. Well, it --
11 important to say -- and I can play that. Maybe we can 11 A. -- it looks like it, but --
12 just play it instead of using this. 12 Q. Yeah.
13 MR. AHMAD: Can we -- 13 A. -- not 100 percent.
14 (Audio playing.) 14 Q. It looked like it enough to draft a termination
15 MR. AHMAD: Stop there. 15 letter.
16 Q. (BY MR. AHMAD) I mean, it sounds like you were 16 A. That wasn't necessarily the driver for -- the
17 saying you could tell. 17 only driver for the termination letter. I mean, there
18 MS. REA: I'm going to object only to the 18 were multiple discussions that happened even -- well,
19 portion -- if we could hear the end -- I think he was in 19 we're talking at two different points in time because,
20 the middle of a sentence. If we could just -- and maybe 20 obviously, the investigator here is well after the case.
21 it doesn't -- I mean, maybe it has nothing to do with 21 But during the investigation, there were
22 it. 22 multiple discussions as to the different scenarios
23 MR. AHMAD: Go back and we'll play the -- 23 for -- for Dr. Gokal, particularly including the second
24 play -- 24 doses and were they potentially short dosed.
25 MS. REA: Yeah -- 25 All in all, those things were what led for

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1 me to draft the letter to talk about trust -- the lack 1 was concerned about the number of individuals he
2 of trust in Dr. Gokal to continue on with the position 2 injected, so we did have a short conversation about that
3 of the emergency preparedness physician. 3 as well as we did talk about the second doses, none of
4 Q. Well, wasn't the gist of it that he had taken a 4 which of those things really amounted to much other than
5 vial and administered the vaccine to friends and family 5 the fact that he did say that -- that it was only ten
6 off-site? 6 doses is what he administered.
7 MS. REA: Objection, form. 7 The short dose piece, I don't really
8 A. No, what it was, was is he took something that 8 remember if there was an answer on that. At that point,
9 wasn't his and went across town and he gave it to 9 you know, the -- the admission of guilt for, you know,
10 friends and family, which he admitted to, making us lose 10 taking the vial and giving it to friends and family was
11 trust in his ability to make good decisions in the field 11 already done, so that triggered what we had already
12 for COVID moving forward. 12 discussed from a leadership standpoint, which was if
13 Q. (BY MR. AHMAD) Okay. Does he say -- or do you 13 there was an admission of guilt, it would be -- we just
14 say anywhere in here that Dr. Gokal said he gave it to 14 could not trust him anymore with the vaccine and dealing
15 friends and family? 15 with COVID, so we would terminate. So at that point, I
16 MS. REA: Objection, form. 16 pulled out my termination letter.
17 A. If you look at -- let's go to your document 17 Q. What if he hadn't given it to friends and
18 here from the district attorney's office, which is on 18 family? What if it had been random people who met the
19 page 8, paragraph -- under Edward Anderson four, I 19 1b criteria for getting the vaccine?
20 believe, one, two, three -- four, it mentions that I 20 MS. REA: Objection, form.
21 discussed the allegations and our potential findings and 21 A. Yeah, great question except I don't know the
22 that he admitted that they used -- the investigator used 22 answer because I -- that's not -- that was not my job to
23 "he did it," but that -- that would be where it would be 23 determine that. All I was -- all I was determined to do
24 referencing when I discussed Dr. Gokal and read through 24 as a part of my role was to investigate the employee
25 the employee allegations where he admitted to the 25 charges and then discuss with leadership the actions if

Page 74 Page 76
1 allegations, which were he took the vial off-site, drove 1 we found what Dr. Gokal did was true.
2 across town, and gave it to friends and family. I gave 2 The -- the discussion further went on to
3 him an opportunity to tell me otherwise, and he didn't. 3 say that if he -- we had no objections to him giving it
4 Q. (BY MR. AHMAD) Okay. 4 to other people. It was taking it off-site without
5 A. He agreed to all of it. 5 making a phone call to talk about what to do with the
6 Q. So the confession that he did it was the 6 vaccine. He took it and gave it to friends and family,
7 confession that he took the vaccine off-site and gave it 7 which from a County standpoint, you can't use County
8 to friends and family, correct? 8 resources to benefit family members. So a lot of those
9 A. I can't speak for this particular investigator, 9 things would have been determined that we just couldn't
10 but in terms of my investigation, there was an admission 10 trust him in his role as a COVID -- the COVID medical
11 to all of it. I gave him multiple opportunities. I ran 11 adviser.
12 through the employee allegations at least three times 12 Q. (BY MR. AHMAD) And you keep saying "family
13 giving him the opportunity to tell me something 13 members," but you only know of one?
14 different, and he didn't. 14 A. Is there -- was that a question?
15 Q. Well -- but I just want to be very clear. When 15 Q. Yes.
16 you -- 16 A. Oh, okay. Sorry. I didn't -- didn't hear
17 A. Me too. 17 that, then. It was -- I don't know how. There was also
18 Q. When you said he did it, okay, or he admitted 18 some thought that one of them was either his mother or
19 he did it, "he did it" was in response to taking the 19 mother-in-law, and then the friends component was her
20 vaccine off-site and giving it to friends and family? 20 friends, because it was noted that most of the
21 A. Yes, that's correct. 21 individuals that were given the vaccine were bedridden,
22 Q. Okay. Did you ask him about short dosing? 22 which is what Dr. Gokal had mentioned.
23 A. In the conversation, Dr. Gokal and I talked 23 Q. Okay. Who do you think may have been another
24 about a number of things including the number of doses 24 family member?
25 between -- because we had found 13 potential forms. I 25 A. That part, I didn't need to know, so I'm not

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1 sure -- it didn't matter to me at that point because I 1 level, so it would have been driven more so with Mac and
2 don't know all of Dr. Gokal's family members. I mean, 2 Gwen.
3 they all could have been family members for all I knew. 3 Q. Well, who would have recommended that Dr. Gokal
4 I just needed an amount of information to 4 be terminated?
5 be able to determine whether he had -- whether these 5 MS. REA: Objection, form.
6 allegations were true and then what our actions were 6 A. If the things -- as the discussion happened, if
7 going to be if they were true. 7 the things were true in the allegation, it would have
8 Q. Okay. So let me be -- let me make sure I 8 been an executive director decision. In this case, it
9 understand. You walked into the termination meeting 9 also included Mac.
10 with Dr. Gokal, correct? 10 Q. (BY MR. AHMAD) So who recommended his
11 A. I walked in -- yes, I walked into -- 11 termination?
12 Q. You're with me so far? 12 A. I thought I just answered that question, but
13 A. Yeah, yeah -- 13 I'll answer it again. It would have been --
14 Q. Okay. 14 Q. Please.
15 A. -- I walked into a meeting with Dr. Gokal to 15 A. -- the executive director Gwen Sims, and it
16 discuss the allegations. 16 would have had some input from Mac McClendon.
17 Q. On January 7th? 17 Q. So is your testimony Gwen Sims and Mac
18 A. It was January 7th, that is correct. 18 McClendon recommended termination?
19 Q. You had a termination letter in hand? 19 MS. REA: Objection, form.
20 A. I had one prepared, correct. 20 Q. (BY MR. AHMAD) Is that your testimony?
21 Q. But you weren't prepared to terminate until you 21 A. They would have been giving me ultimate
22 heard from him first? 22 approval on termination.
23 A. That is 100 percent correct. 23 Q. I'm just trying to find out who made the
24 Q. Was there anybody with you? 24 recommendation.
25 A. Mac McClendon, which is protocol for your -- it 25 A. I did the investigation and presented what we

Page 78 Page 80
1 would be a supervisor, so that was his supervisor. 1 felt was the employee allegation, and then as a
2 Q. Okay. And then based upon Dr. Gokal admitting 2 leadership team, we discussed it. It was more than one
3 it, you decided to go forward with the termination? 3 person. It was our executive team, which would have
4 A. I didn't decide. It was predetermined that if 4 been Gwen Sims; it would have been Mac McClendon. Our
5 the things were true, that I was to then present the 5 time -- at the time, our deputy director Will Hudson
6 termination letter. 6 would have known. Our legal counsel would have -- would
7 Q. Okay. Who predetermined that? 7 have been involved. It was not a one-person decision.
8 A. That would have been our leadership team. 8 Q. Well, I'm -- I'm really just trying to find out
9 Q. And who was that? 9 who recommended it.
10 A. That would have been included -- the ultimate 10 A. I don't -- we were on calls together. I don't
11 decision would have been our executive director because 11 know who -- I mean, from a recommendation standpoint on
12 all terminations had to run through our executive 12 this one, normally, there would be a write-up for me to
13 director. So even though I may make a recommendation on 13 say I recommend termination.
14 termination based on an investigation, not talking about 14 But when the -- when the incident started,
15 Dr. Gokal's case specifically, I would have to get 15 it was discussed with our senior leadership team, myself
16 executive director approval. 16 included, that if the allegations were true based on the
17 In this case, there were conversations with 17 situation, we would terminate, and it wasn't just one
18 Mac because of the vaccine component to it, and we did 18 person.
19 have legal counsel there as well. 19 Q. But you were one of the people?
20 Q. You gave the recommendation to terminate based 20 A. I was involved in the conversation.
21 on your investigation, correct? 21 Q. Did you -- did you make the recommendation to
22 A. Actually, no. I agreed that it -- if that was 22 terminate?
23 the case, that we needed to terminate, but I did not 23 A. I'll refer back to my last answer. I wasn't --
24 give a recommendation on that one. It all happened kind 24 I did not make a recommendation to terminate, but I was
25 of quick, and it was driven mostly at the executive 25 a part of the discussion where the leadership team

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1 determined that we would terminate if the allegations 1 Do you see that?
2 were true. 2 A. Yes, that's -- I see it.
3 Q. The leadership team would determine? 3 Q. And did you write that investigation timeline
4 A. Yes, which would have been Gwen Sims, Mac 4 summary --
5 McClendon, our legal counsel. I think those were the 5 A. This --
6 only -- and myself. 6 Q. -- the Dr. Gokal investigation timeline
7 Q. So you were part of the leadership team -- 7 summary?
8 A. I was part of the discussion, yes. 8 A. Yes, I typed this one. And it was a summary
9 Q. So you were part of the group that recommended 9 based on my -- only my conversations and/or actions.
10 his termination, correct? 10 Q. And to be clear, you did the investigation into
11 A. If the allegations were true, I was a part of 11 Dr. Gokal, correct?
12 the team that -- that determined and decided 12 A. Yes.
13 termination. 13 Q. And you did that all on one day, January 6?
14 Q. And who determined that the allegations were 14 A. It was definitely a fairly short investigation,
15 true? 15 but, yes. It was time sensitive due to the nature of
16 A. Dr. Gokal, because he admitted in the meeting 16 COVID.
17 that the allegations were true, and then we -- it 17 Q. Okay. And if we go to the bottom of that first
18 triggered our decision -- our predetermined decision 18 page of the timeline summary, January 6 of 2021,
19 that if the allegations were true, we could no longer 19 4:13 p.m., Ed Anderson receives call from Jennifer
20 trust him to be our lead medical adviser for COVID. 20 Kiger, Mac McClendon, and Marva Gay.
21 Q. Okay. I'm -- I'm just trying to understand it 21 Do you see that?
22 because -- and I want to be very clear. So you're -- 22 A. Uh-huh. I see that.
23 you're telling me that until you met with Dr. Gokal, 23 Q. Who is Marva Gay?
24 there had been no decision to terminate Dr. Gokal; is 24 A. Marva would have been at the time the County
25 that correct? 25 attorney who was sitting with Public Health. So she

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1 A. No, that's not correct. As I just explained in 1 would have been our primary legal individual as assigned
2 the previous answer, there were -- there were 2 by the County attorney's office.
3 discussions ahead of time to say that if the allegations 3 Q. Because it has down here that she doesn't see a
4 were true, that it would lead to termination due to a 4 reason why we can't terminate Dr. Gokal on Thursday
5 lack of trust in Dr. Gokal to complete his duties as 5 morning.
6 emergency preparedness physician for COVID. 6 Do you see that?
7 Q. Is it fair to say you knew you were going to 7 A. I do see that, uh-huh.
8 terminate him when you walked into the meeting with him 8 But this is --
9 on January 7th? 9 Q. Did any --
10 A. No, it's not fair -- 10 A. I'm sorry.
11 MS. REA: Objection, form. 11 Q. Well, did anybody see a reason why you couldn't
12 A. -- at all because if he tells me something 12 terminate Dr. Gokal Thursday morning?
13 otherwise, then I'm not pulling out the termination 13 A. If the allegations were true and he admitted to
14 letter and I'm going to go back to leadership and figure 14 them, then, no, there was the ability for us to
15 out where we go next in terms of investigation. 15 terminate. They didn't see any other reason why we
16 Q. (BY MR. AHMAD) Well, if we go back and look at 16 couldn't.
17 Exhibit 2 and you see the part after the patient forms 17 Q. Well, I didn't see that part down here. You
18 and you have -- the first document is an email from 18 didn't write that part.
19 Alison Hare to you, correct? 19 A. Well, that's right, yeah, because this is a
20 A. That is correct. That's a statement I asked 20 summary, which is the title of the document. It's a
21 her to write after a phone conversation with her. 21 timeline summary. It's not every single word that I
22 Q. And then the second page is several document -- 22 said during the Dr. Gokal investigation.
23 or several pages. It looks like three maybe going on to 23 Obviously, three pages would not -- or four
24 a fourth page entitled Dr. Gokal Investigation Timeline 24 pages, whatever you referred to, would not show every
25 Summary. 25 single action step that I took during that particular

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1 day. 1 claimed.
2 Q. Okay. Well, would it be more accurate to say 2 Q. Okay. Well, if you go up above, you see an
3 that -- well, one reason you wouldn't terminate is 3 entry January 6, 2021, 6:41 p.m. You see after that
4 because we haven't spoken to Dr. Gokal yet, correct? 4 entry and before the 7:00 o'clock -- or after
5 A. I mean, I could have put that in there, but I 5 7:00 o'clock --
6 didn't. I mean, I didn't type it -- 6 A. Uh-huh.
7 Q. Well -- 7 Q. -- entry on January 6th, do you see that?
8 A. -- but that was -- that was the plan for that 8 A. I see it, uh-huh.
9 particular day. 9 Q. Do you see summary?
10 Q. Would that have been more accurate if you said 10 A. I see the summary, yes.
11 that -- 11 Q. "A COVID vaccine issue was brought to the
12 MS. REA: Objection, form. 12 attention of our OPHRP leadership. After an
13 Q. (BY MR. AHMAD) -- in the summary? 13 investigation, it was determined that Dr. Gokal at least
14 A. A lot of things would have been more accurate, 14 one vial of COVID vaccine for his personal use. His
15 but, unfortunately, I didn't write them all down. This 15 actions were not approved by HCPH leadership and could
16 was, like I said, a summary document. 16 be considered theft. As a result, Dr. Gokal will be
17 And at one point in this document -- and 17 terminated on January 7th, 2021. The situation will be
18 I'm not sure exactly where it is, but I do talk about 18 reported to the medical board, and the CAO may refer
19 due process. If you'll look at page -- if you could 19 this to the DA's office."
20 turn to the third -- second page of the investigation 20 Do you see that?
21 summary, at the very bottom for -- on 1-7 at 2:12 p.m., 21 A. I do see that, yes.
22 I mentioned that I'm going to be the one to lead the 22 Q. Is that true, what you wrote on January 6th?
23 meeting and that I'm going to set the stage for what the 23 A. It was a summary of multiple conversations that
24 allegations were and then I'm going to make sure he has 24 if the actions were true, that those -- that's how it
25 due process. 25 will be determined, yes.

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1 Q. Well, you -- you -- to be clear, your words are 1 Q. Well, it doesn't say that, does it? It doesn't
2 different than that, right? You say: "Ed is to set the 2 say if they were true?
3 stage for what happened and ask Dr. Gokal if he has 3 A. Sure. But, again, a lot of this document is --
4 anything to say about the event, giving him due 4 was quick notes to try to get as much as we could get
5 process." 5 down now because at some point, we would need some
6 A. Right, yes, correct, I'm giving him due 6 documentation as to what happened.
7 process. 7 Q. Okay. Is there any reason why you couldn't
8 Q. Because you knew you were going to terminate? 8 have used the words "if true" or "if Dr. Gokal
9 MS. REA: Objection, form. 9 admits" --
10 A. We knew that if the allegations were true, 10 MS. REA: Objection.
11 we were going to terminate. This was doctor -- this was 11 Q. (BY MR. AHMAD) -- he will be terminated? Is
12 Dr. Gokal's chance to tell us something different than 12 there any reason why you couldn't put that in here?
13 what we heard from the employee. 13 A. There's --
14 Q. (BY MR. AHMAD) So -- 14 MS. REA: Objection, form.
15 A. If he tells me something different, then the 15 A. -- a lot of things that I could have included.
16 termination letter is not coming out and he's been given 16 Unfortunately, due to timing and the nature of the
17 his -- he's been given his due process. 17 response, I did the best that I could to document as
18 Q. Well, you wrote down that you were just going 18 much as I could for my own personal use.
19 to give him the due process, correct? 19 This was my investigation notes to help me.
20 MS. REA: Objection, form. 20 These were never necessarily intended to be anything
21 A. I don't understand that question. 21 more than that, and so I just needed things to help me
22 Q. (BY MR. AHMAD) Well, do you understand that 22 remember when things were said and done.
23 you knew he would be terminated on January 7th? 23 Q. (BY MR. AHMAD) Well -- but this timeline
24 A. No, I didn't know he was going to be terminated 24 summary, these are the words you chose, correct?
25 until he admitted to the -- to the incidents that were 25 A. They're not all the words I chose because I

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1 could have written a whole lot more. This was all I had 1 They told me it was urgent to -- to get it taken care
2 the time to do based on the nature of how things were 2 of, to investigate and get a summary and follow through.
3 going with the other work that I had to do. 3 Q. Who told you that?
4 Q. Okay. So you're saying if you'd had more time, 4 A. That was executive director and our incident
5 instead of saying Dr. Gokal will be terminated on 5 command team.
6 January 7th, you would have said Dr. Gokal may be 6 Q. And who specifically?
7 terminated on January 7th -- 7 A. So that would have been Gwen Sims and Mac
8 MS. REA: Objection, form. 8 McClendon specifically.
9 Q. (BY MR. AHMAD) -- if he admits it? 9 Q. Okay. Did they tell you there was any kind of
10 A. I -- I could have used the terminology 10 a deadline to make a decision on Dr. Gokal's
11 differently, yes. In looking back at the notes now, 11 termination?
12 obviously, there's process steps to show that we were 12 A. They didn't mention a deadline. They just said
13 going to give him a chance to explain, but it is not 13 that there was some urgency due to the fact that it was
14 worded probably the best way. Not sure what I would 14 vaccine related and that we would have to report back to
15 have typed otherwise at this point because this is in 15 the State of Texas quickly.
16 the past, but I would have probably written this 16 Q. Did they tell you that you'd only have one day
17 differently if it were today. 17 to do an investigation?
18 Q. Because you just didn't have enough time? 18 A. No, they never set timelines on when I do
19 A. Uh-huh. I was working 16, 17 hours a day. 19 investigations. But they said that I needed to be --
20 Didn't see my family. Was in a high-stress position, 20 you know, I needed to treat it as a high priority.
21 being asked to do things by the judge's office that were 21 Q. Okay. But to be clear, you could have taken an
22 incredibly difficult. 22 extra day to investigate?
23 Q. Any rush to terminate Dr. Gokal? 23 MS. REA: Objection, form.
24 A. There was urgency in getting it addressed 24 A. I mean, you -- you could say a lot of things
25 quickly only because the State -- we were going to have 25 about investigations. But in terms of how I did the

Page 90 Page 92
1 to file some -- some notice with the State of Texas 1 investigation, there wasn't -- there wasn't as much
2 because the vaccine technically was not -- not -- it was 2 needed on this particular investigation because it only
3 in the care of Harris County. It was actually owned by 3 contained a few items, and there was only a handful of
4 the State of Texas. 4 people to talk to, and then we were going to give
5 And so there was a Dr. Plasencia who was at 5 Dr. Gokal a chance to talk through the scenario that was
6 the State of Texas level. We were going to have to 6 presented as the allegation. So there wasn't a whole
7 report to him the issue, and there was -- so there was 7 lot more that would have needed to have been done at
8 some urgency in getting the case resolved. 8 that point.
9 In reality, there wasn't much investigation 9 Q. (BY MR. AHMAD) Well, how about this? How
10 to it when you look at the overall summary because we 10 about on January 6th before you draft up a termination
11 were going to give Dr. Gokal the chance to explain 11 letter, how about asking Dr. Gokal what happened?
12 himself. And then he did. He admitted to the -- to the 12 MS. REA: Objection, form.
13 claims, and it was over with quickly. 13 A. I'll say that every investigation is different,
14 If there was any other reasons as to why it 14 and they can always be done a variety of different ways,
15 was so quick, only thing I can say, it was COVID and it 15 and this is the way I dealt with this one.
16 was vaccine, and vaccine was very sensitive at that 16 Q. (BY MR. AHMAD) Okay. Is there a reason why
17 time. There were numbers of articles regarding how 17 you didn't talk to Dr. Gokal during the investigation
18 health departments were treating the vaccine equitably. 18 time frame?
19 There were issues with people trying to get vaccine that 19 A. It wasn't part of my investigation plan.
20 weren't eligible. It was just a difficult time. 20 Q. I mean, you could have, for example, asked him
21 Q. Mr. Anderson, I just want to be clear. I mean, 21 which patient forms were the ones that he gave the
22 you're suggesting that there was some urgency to it, but 22 vaccine to --
23 who was telling you it was urgent to terminate 23 MS. REA: Objection, form.
24 Dr. Gokal? 24 Q. (BY MR. AHMAD) -- you know, after hours. You
25 A. No one told me it was urgent to terminate. 25 could have asked him that, right?

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1 MS. REA: Objection, form. 1 A. Uh-huh.
2 A. There's a lot of things I could have asked him, 2 Q. GOKAL000248. Top line says: "Mr. Anderson
3 but that's not how it went. I can only speak to what 3 advised Dr. Gokal, was informed that at no point in our
4 happened. I'm not going to speak to hypotheticals. I'm 4 process does it say take the vaccine off-site and
5 not going to speak to what I could do differently the 5 administer to your friends and family."
6 next time or what I could have done differently this 6 Do you see that?
7 time. I can only speak to what happened in this 7 A. I see that part, yes.
8 particular instance. 8 Q. "Mr. Anderson advised that he also tried to
9 Q. (BY MR. AHMAD) And you tried to write down 9 explain the equity component to the distribution of the
10 what happened as best you could in this investigation 10 vaccine to Dr. Gokal and informed him that the fact that
11 timeline summary, correct? 11 he gave the doses to only one nationality was not an
12 A. I tried to write down the high points of things 12 equitable distribution."
13 that I needed to know in order to track what was going 13 Did you advise Dr. Gokal of that?
14 on knowing that I was also trying to manage 14 A. Yes. But I will say that this is taken
15 2,000-something contractors scattered all over the place 15 completely out of the conversation from me and
16 in the county dealing with a pandemic, so this was as 16 Dr. Gokal. This is the investigator's notes.
17 good as it was going to get for that particular 17 Timeline-wise, Dr. Gokal was struggling
18 timeline. 18 with -- after the -- after the termination, Dr. Gokal
19 Q. Anybody you think was more influential in the 19 was struggling with the fact that he felt that he was
20 decision to terminate Dr. Gokal than you? 20 doing what was right in terms of the vaccine. He felt
21 A. I would say I wasn't necessarily as highly 21 he was getting it into arms, which is what he was
22 influential at all. I mean, I would say it goes to our 22 instructed to do as a health provider during COVID.
23 executive director and the incident commander because it 23 And I was trying to make him understand
24 was dealing with vaccine and it was dealing with their 24 that, yes, although we want to get it into people's
25 trust levels in -- in Dr. Gokal to be able to be the -- 25 arms, that at no point did we give him advice to take it

Page 94 Page 96
1 the medical adviser on a COVID-19 pandemic response. 1 off-site and give it to friends and family. That was
2 Q. Who was more influential in the decision to 2 never a part of our COVID-19 plan. That's not -- was
3 terminate than you? 3 not acceptable.
4 MS. REA: Objection, form. 4 This part about equity came after the
5 A. Okay. I thought I just answered that, but I'll 5 termination discussion when Dr. Gokal was stating that
6 say it again is that -- 6 he was going to go to the media because he wasn't happy
7 Q. (BY MR. AHMAD) Do these people have names that 7 with his termination. And I informed him that I
8 you can say? 8 couldn't advise -- I couldn't tell him what he could and
9 A. Yes, for the record, I mean, can we -- okay. 9 couldn't do because we can't -- obviously, we can't do
10 Gwen Sims, Mac McClendon. 10 that. He can do whatever he wants to do.
11 Q. Okay. And did they -- do you know whether they 11 But I was trying to inform him that based
12 based whatever their view was in terms of Dr. Gokal's 12 on equity in the news, the media was concerned with
13 termination on your investigation? 13 people getting doses equitably, and for him -- for the
14 MS. REA: Objection, form. 14 picture of him that he presented to me, which was he
15 A. That, I can't say because I can't speak for 15 took the one dose used vial, threw it in his backpack,
16 them. They didn't talk about it specifically. We only 16 drove across town, gave it to friends and family, who
17 talked about the scenario as a group. As I noted 17 happened to be all of one national -- national origin
18 before, that if we presented the allegations to -- to 18 or -- or however you want to describe it, that might be
19 Dr. Gokal, we would have a termination letter ready. If 19 seen as a nonequitable distribution.
20 he admitted to it, then we were to proceed. If not, 20 So I was trying to give him some help,
21 then we would take a step back and do something 21 because what I -- I mentioned before, I like Dr. Gokal.
22 different. 22 I didn't want him to go out there and start making
23 Q. (BY MR. AHMAD) Well, if we go on to page -- 23 comments that could potentially come back and hurt him.
24 and I'll go back to Exhibit 3. It's the top of page 9 24 I was trying to make him understand that he might want
25 of the investigation report. 25 to think about it, because I've seen this happen in

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1 other terminations where people have a hard time 1 A. That, I don't know because, again, I don't
2 comprehending what just happened and they make a rash 2 remember the recording. I don't remember details of
3 decision to do something and then it hurts them -- it 3 this meeting. It is documented elsewhere that I talked
4 hurts their reputation long-term. 4 to Dr. Gokal three times about the incident that was
5 So those two things, although they were 5 acclaimed and that he brought up the conversation.
6 stated in a similar and like manner, they were not 6 And I'm sure that you've got Mac McClendon
7 stated in the same context as to what the district 7 on your list to speak to. When Dr. Gokal mentioned in
8 attorney's investigator has written in this report. 8 the discussion -- again, the district attorney's
9 Q. So you're saying that the context of this, even 9 document is one thing. What happened in the room is
10 though it's not written here at all, this is another 10 something completely different. This is an investigator
11 change that you have, that this is in the context of 11 who was only getting high points and asking questions.
12 Dr. Gokal saying he's going to go to the media, and that 12 They were not in the room with me.
13 when you're saying that giving doses to one nationality 13 Q. Sir, I just played the tape. That's not --
14 is not an equitable distribution, what you meant to say 14 A. The tape of a meeting with the district
15 was, well, the media doesn't think it's an equitable 15 attorney's office, not of what happened in the room with
16 distribution. 16 Dr. Gokal. That investigator was not in the room with
17 MS. REA: I'm going to object to the form. 17 Dr. Gokal.
18 A. Yeah, I don't -- I don't -- I think we're not 18 Q. But you were.
19 understanding each other on this. This isn't a 19 A. Correct. But I was not giving the investigator
20 timeline, which is what I was trying to state. The 20 a word-for-word, play-by-play discussion of what
21 investigator here did not document exactly word for word 21 happened in the room.
22 the meeting notes from Dr. Gokal and myself and Mac 22 Q. Were you trying to be as accurate as possible
23 McClendon. 23 when giving the investigator information about potential
24 Q. (BY MR. AHMAD) Well -- 24 criminal charges against Dr. Gokal?
25 A. So this isn't accurate from that context. 25 A. I had nothing to do with the criminal charges.

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1 Q. Okay. Well, why don't we just play the 1 So at this point, I'm just -- I'm answering district
2 recording and I'll play as much or a little of it as you 2 attorney questions at a high level. I did not give them
3 want. 3 verbatim word for word as to what happened in the room.
4 A. That's up to you. It's not my decision. 4 Q. So you're telling me now, 2022, September 2022,
5 (Audio playing.) 5 you remember that the part about the equitable
6 MR. AHMAD: We'll go a little bit back 6 distribution came up in the context of him going to the
7 earlier because I want to make sure we have the proper 7 media. Is that what you're telling me?
8 context. 8 A. That's not what I'm telling you. What I'm
9 (Audio playing.) 9 telling you all along is -- and as I've documented
10 Q. (BY MR. AHMAD) Okay. I think I played before 10 elsewhere, that in the discussion with Dr. Gokal, the
11 and after it. And just so we're clear, that's your 11 equitable distribution came up because Dr. Gokal was
12 voice, is it not, Mr. Anderson? 12 claiming he was going to go to the media. I was trying
13 A. That's my voice, yes. 13 to give him some advice as to how the picture might be
14 Q. I don't hear anything about the media. Did 14 painted if he went to the media based on what he had
15 you? 15 just admitted to me.
16 A. Yes. Again, we're talking about the district 16 Q. So you're saying that part about the equitable
17 attorney's conversation with me, not what happened in 17 distribution was what would happen if he went to the
18 the room. This is not meeting notes from the room. And 18 media?
19 that's what I was trying to explain, that although, yes, 19 A. I -- what I had said to him, which is -- and
20 some of these things are true, there's not -- it's not a 20 I've mentioned it already as part of my answer is that
21 word-for-word discussion as to what happened in the 21 when he went and said he might go to the media, I was
22 meeting with Dr. Gokal. 22 trying to give him some advice to tell him that if we
23 Q. Well, let me just back up because what you told 23 paint the picture to the media as how it happened as he
24 the district attorney didn't have anything about 24 had just admitted to, that the -- that people might not
25 Dr. Gokal suggesting he would go to the media, correct? 25 take too kindly to a nonequitable distribution where he

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1 gave it to friends and family. 1 A. The meetings are different, yes.
2 Q. If I'm hearing that conversation you had with 2 Q. So --
3 the district attorney's office, it sounds like you 3 A. I didn't go verbatim to the district attorney's
4 didn't believe it was an equitable distribution? 4 office as to what I said to Dr. Gokal in that room.
5 A. It was a conversation with the district 5 Q. Okay. So did you fudge a little bit to the
6 attorney's office that was not a word-for-word 6 district attorney?
7 discussion in the meeting. He was not -- the district 7 A. Absolutely not.
8 attorney conversation was not Dr. Gokal and Mac and I in 8 Q. Did you leave anything out that --
9 a room. 9 A. The district attorney's account of the
10 Q. But you were -- 10 conversation they had with me.
11 A. This is a separate conversation. And it was 11 Q. Sir, I'm going to stop you. I'm talking about
12 not a timeline based on what happened in the room. 12 what you said to the district attorney that is in a
13 Q. But you were in the room and you were trying to 13 recording. So explain to me why you didn't mention
14 give the best description you could, right? 14 these things four days after you terminated Dr. Gokal to
15 A. For the district attorney's investigation, I 15 the district attorney who's investigating possible
16 was answering the questions that they asked of me as to 16 crimes from Mr. -- for Dr. Gokal.
17 what happened. I did not give them a word-for-word, 17 MS. REA: Objection --
18 play-by-play of the incidents that happened in the room. 18 Q. (BY MR. AHMAD) Explain to me why you didn't
19 Q. Did you tell the district attorney anything 19 mention this.
20 that is misleading? 20 MS. REA: Objection, form.
21 A. Not that I'm aware of. 21 A. I never said I didn't mention it. I just said
22 Q. Did you tell the district attorney anything 22 that -- first of all, I didn't recall the conversation
23 that's inaccurate? 23 even with the district attorney's office because of all
24 A. At this point, I can't say yes or no because as 24 the things that were going on. I can tell you, though,
25 I've -- as I've seen in this report, obviously, they 25 from the conversation with the district attorney's

Page 102 Page 104

1 don't even know who I work for. So there are some 1 office, it was not a play-by-play of what happened in
2 things in here that are not -- that are definitely 2 the room with Dr. Gokal. It was an over -- overall
3 slighted a different way than -- than what necessarily 3 situational description not knowing where they're going
4 happened. 4 with the -- with their case, because to me it was of no
5 And their investigation was completely 5 interest to me.
6 separate as to mine. Theirs was criminal. Mine was 6 I'm not in the district attorney's office.
7 just to determine whether or not Dr. Gokal did the 7 My job was to investigate what Dr. Gokal did, and it was
8 things he did and whether or not we could trust him 8 to work with our senior leadership team on the outcome
9 moving forward as the emergency preparedness medical 9 of his actions.
10 adviser. 10 Q. (BY MR. AHMAD) Did you believe that this was
11 Q. Well, sir, I want to focus back on the tape. 11 an equitable distribution of the vaccine?
12 Forget about -- you know, I understand instead of 12 A. I'm not qualified to make decisions on any of
13 writing Harris County Public Health, they wrote Harris 13 that because that's not my job as an HR person.
14 Health. 14 Q. Do you think your memory's better today about
15 But your -- what you say on January 11th, 15 the decision to terminate Dr. Gokal and your
16 four days after the termination, to the Harris County 16 investigation -- the events of January 6th and
17 District Attorney's Office should be accurate. Wouldn't 17 January 7th of 2021 -- is your memory about those events
18 you agree? 18 better today than it was on January 11th, 2021, when you
19 MS. REA: Objection, form. 19 were being interviewed by the Harris County District
20 A. What I'll agree to is that we're talking about 20 Attorney's Office?
21 two different instances, one conversation with the 21 A. I mean, I -- I mentioned it before in the
22 district attorney's office about the generalities as to 22 previous testimony that a lot of things have happened
23 what happened versus the conversation that Mac and I had 23 since then, and I don't remember everything that
24 with Dr. Gokal in the meeting. They're different. 24 happened because there was a lot of time between, you
25 Q. (BY MR. AHMAD) Really? 25 know, then and now.

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1 I can definitely tell you the part about 1 Q. (BY MR. AHMAD) Okay. And I'm not -- again,
2 the equitable distribution specifically because I took 2 I'm not talking about the summary that the district
3 extreme offense to Dr. Gokal mentioning that I might be 3 attorney's office gave. I'm talking about what you said
4 a racist in the media. My name was mentioned more than 4 when you were being interviewed by the district
5 one time, so it's very clear to me what happened in that 5 attorney's office.
6 meeting because of that. 6 A. I additionally provided --
7 In the meeting, I discussed with Dr. Gokal 7 MS. REA: Objection, form.
8 that -- as trying to give him personal advice as to 8 A. -- the district attorney's office all the
9 running to the media -- because I have seen this happen 9 documentation that you have here. So they've seen the
10 time and time again -- I was trying to advise him that 10 notes. They've seen my executive summary. They've seen
11 it may not be in his best interest to do so because it 11 this timeline. I've walked through with them what was
12 may make him look the way he doesn't want to look, 12 on the recording was one interview, but I did provide
13 because the media can twist things around considerably. 13 them the additional documentation of what happened in
14 I was trying to give him personal advice 14 the room. It's just not on this particular document.
15 mentioning the equitable distribution. I thought it was 15 Q. (BY MR. AHMAD) Okay. Again, my question is:
16 going to help, and in retrospect, I wish I would have 16 Between the interview you gave to the district
17 never said any of it because he turned around and used 17 attorney's office on January 11th, 2021, and what you're
18 it in the media against me when all I was trying to do 18 saying today, if a jury finds those two pieces of
19 was help him. 19 evidence, your testimony today, January 11th interview,
20 MR. AHMAD: I'll object to the 20 to be inconsistent in any way, what would you tell the
21 nonresponsive portion. 21 jury they should rely on?
22 Can we play back my question. 22 MS. REA: Objection, form.
23 (Requested material was read.) 23 A. I -- I can't advise juries on documents. Like
24 A. Fair enough. I apologize for not answering 24 I said, I can only tell you what I know, which is
25 your question. 25 there's two separate documents here. One is the

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1 I would say just based on what I've said 1 district attorney's criminal court, and the other is the
2 before, obviously, time has passed. My memory is not as 2 additional documentation that I have as to what happened
3 good as it once was, but there are certain things that I 3 in the room. And they're -- they're not mutually
4 remember specifically. 4 exclusive. They should be used together because this is
5 Q. (BY MR. AHMAD) If we have to choose between 5 not a full, detailed report as to what happened in the
6 what you say here today and what you told the district 6 room. It was never intended to be that way from the
7 attorney's office on January 11th of 2021, should we go 7 district attorney's office. They were after something
8 with what you said on January 11th or what you're saying 8 different than what my original investigation was.
9 here today? 9 Q. (BY MR. AHMAD) Were they after something
10 A. I don't think that's my decision. Those are 10 different than the truth?
11 two different instances. One's a county -- a district 11 MS. REA: Objection, form.
12 attorney's office investigation for criminal, and my 12 A. The only thing I can say about the district
13 investigation was for -- to determine whether or not we 13 attorney is obviously they had filed charges on
14 were to terminate. So I cannot be the one to say which 14 criminal. That was not my job. My job was to determine
15 one you would want to use. That's not my job. 15 whether or not Dr. Gokal did what he said he did and
16 Q. Well, can we agree that the truth should be the 16 help leadership determine what the outcome would be.
17 same no matter what? 17 Q. (BY MR. AHMAD) And you did that?
18 MS. REA: Objection, form. 18 A. I did that.
19 A. I can say that what I have said is the truth. 19 Q. Did the district attorney ever tell you when
20 How the district attorney's office has documented it in 20 they were interviewing you that they only wanted
21 their recording and this piece, they did not have 21 generalities?
22 necessarily this -- they were not in the meetings that I 22 A. They asked for a summary of events, and that's
23 was in, so they couldn't possibly know exactly word for 23 what I gave them.
24 word in every single thing -- in every single meeting 24 Q. Well, they asked you specific questions,
25 that I was in pertaining to Dr. Gokal. 25 correct?

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1 A. They asked questions, yes. But their questions 1 Department of Health Services had a view on whether
2 don't necessarily mean that they covered the exact 2 Dr. Gokal should be terminated?
3 details as to what happened in the room. I don't make 3 A. Huh-uh. Because I left that all up to
4 the district attorney's office questions. They brought 4 Dr. Onyiego. I had no involvement with the Texas State
5 in investigators that asked me questions, but it doesn't 5 Health and Human Services, no.
6 necessarily mean they asked me all the right questions. 6 Q. So you have no idea whether they had a view --
7 Q. Do you think maybe they didn't ask you the 7 A. Huh-uh.
8 right questions? 8 Q. -- of whether Dr. Gokal should be terminated?
9 A. That's not for me to say because I'm not part 9 A. No. And I would have never -- I'm sorry. I
10 of their investigation. I never would be -- I don't 10 talked over you again.
11 deal with anything criminal. I was -- I was there to 11 No, I would never have been in that
12 investigate the actions of Dr. Gokal to determine 12 discussion. I left it up to Dr. Onyiego.
13 whether or not they were true, and then to help 13 Q. Did anybody tell you that they had a view on
14 leadership with the outcome. 14 Dr. Gokal's termination?
15 Q. Do you think that the district attorney's 15 A. Not that I can remember.
16 office needed a full and complete picture of what 16 Q. Do you know of anybody that Dr. Gokal could
17 happened? 17 have given the vaccine to other than the people he gave
18 MS. REA: Objection, form. 18 it to? Do you have any specific people that you know he
19 A. Yeah, I -- they -- 19 could have given it to?
20 Q. (BY MR. AHMAD) Or -- or in your view, were you 20 A. I don't necessarily, but that wasn't my job to
21 just there to answer questions? 21 know. I did talk to Mac and Jen as a part of the
22 A. I was there to answer questions and to give 22 conversation during the investigation, and they had
23 them an overall summary of what transpired to get us to 23 mentioned they were starting to accumulate lists of
24 the point that we were at to terminate Dr. Gokal. 24 people, which I actually do think I mention that in one
25 As to their specific intent, obviously, I 25 of the documents that -- that Dr. Gokal -- we could have

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1 knew it was criminal. They did ask a few things about 1 potentially gotten it into the hands of school nurses
2 the -- the vials and the dosing and that kinds of 2 and a few other individuals. I believe it's referenced
3 things, but other than that, you know, I gave them the 3 in the district attorney's document, but I need to go
4 answers to the questions and the summaries that they had 4 back and look at that. One second.
5 asked for. 5 But in terms of your direct question of
6 Q. Did you ever tell them that the County actually 6 asking me did I personally know? No.
7 didn't own the vaccine? 7 Oh, I see. Here it is. Page 9, second
8 A. I don't know if I remember that part in here. 8 paragraph from the bottom. It mentions I explained to
9 At some point, I thought I mentioned -- yes, I did 9 Dr. Gokal that he should have called someone in the
10 mention it on page 10. If you look under the section 10 incident command structure and they would have found
11 where it's one, two, three -- third -- third paragraph 11 someone to administer the vaccine to. That's what Mac
12 from the bottom, it talks about the Texas department -- 12 McClendon and Jennifer Kiger told me.
13 or Texas State Department of Health Services was the 13 Then I say I provided examples of school
14 actual owner of the vaccine and that we were notifying 14 nurses, EMTs, fire departments and/or other County
15 Carlos Plasencia regarding the actions for Dr. Gokal. 15 departments. Also, that is not coming directly from me.
16 Dr. Onyiego, one of our local health 16 That is what was told to me by Mac and Jennifer.
17 authorities, was actually involved in that. She knew 17 Q. Do you have any idea how you would -- how
18 Dr. Plasencia. 18 anybody would have gotten ahold of them after hours?
19 Q. Did -- were you informed that the State wanted 19 A. That would have been a phone call to Mac and
20 to press criminal charges? 20 Jennifer. And as we discussed with the discussion with
21 A. No, I didn't know that. 21 Dr. Gokal is he should have called them to ask them what
22 Q. I'm just asking. 22 to do with it. And that's -- how they would have done
23 A. No, yeah, if I did, I didn't know. I didn't 23 that, I would have had no part of that, but that's
24 know that. 24 what -- that's what they should -- that's what should
25 Q. Do you know whether or not the Texas State 25 have happened in the incident command structure. He

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1 should have notified them that there was a vial that was 1 specifically for COVID-19 activities.
2 going to be unused, and then they would have figured it 2 Q. It looks like -- this is going back -- I think
3 out together as to who to give it to. 3 this is Exhibit 2.
4 Q. Do you know whether Dr. Gokal contacted Trey 4 I'll tell you what, why don't we take a
5 Frankovich? 5 break for lunch, unless you don't want a lunch, in which
6 A. I don't know directly, but in the discussion I 6 case, you know, we'll take a short break. I'll leave
7 had with Dr. Gokal, it was mentioned that he should have 7 that up to you and counsel. The court reporters
8 contacted someone from the incident command structure 8 probably want a break. They want to break. All right.
9 regarding the unused vaccine, and he didn't say that he 9 So --
10 had contacted anyone. 10 A. That's fair.
11 Q. Even Trey Frankovich? 11 Q. -- we'll go off the record and then kind of
12 A. He didn't say he contacted anyone. 12 discuss.
13 Q. Would that have been important for you to know? 13 THE VIDEOGRAPHER: We're off record. Time
14 A. Definitely, yeah. I mean, it would have 14 is 1:12 p.m.
15 definitely been important for me to know. 15 (Lunch recess.)
16 Q. Why -- 16 THE VIDEOGRAPHER: We are back on record.
17 A. But, again, he didn't say it -- he didn't say 17 Time is 2:29 p.m.
18 it in the meeting. I mean, I can only go off of what he 18 Q. (BY MR. AHMAD) Okay. Mr. Anderson, we're back
19 did or didn't say in that discussion, which is what I 19 from taking a lunch break.
20 was -- which is what the instruction was. 20 Is there anything you thought about that
21 Q. And why would that have been important to you? 21 you need to change in your testimony?
22 A. If it would have been important to me, then it 22 A. Not that I can think of right off the top of my
23 would have completely changed the employee allegation. 23 head.
24 If he had contacted Trey and been instructed on what to 24 Q. Okay. Why did you leave Harris County Public
25 do or what not to do with it, then it would have shown 25 Health?

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1 that he was following the incident command structure, 1 A. There was a change in our executive leadership.
2 and it probably would have led us to make some 2 They brought in a new executive director, and I was not
3 additional phone calls and additional investigation to 3 asked to stay, so I resigned. A number of our leaders
4 see what we would do with the next thing. But I would 4 had already left. The team had gone from, like, 12 down
5 not have terminated. 5 to, like, 4. So the timing was right and I resigned.
6 Q. Do you know who DeAndra Bankston is? 6 Q. And when you say "not asked to stay," is that
7 A. I want to say I recognize the name, but I don't 7 like being asked to leave or --
8 know -- I don't know that person. 8 A. I would say it's pretty typical with, you know,
9 Q. Tieauna Sheree Middleton? 9 executive leadership changes. They want to do things
10 A. Again, I know the name, but I don't know . . . 10 differently and bring in their own teams, and that's
11 Q. Wykeshia Atilee? I may not be pronouncing it 11 kind of what happened.
12 right. 12 Q. Okay. I mean, did they tell you they want to
13 A. Yeah, I think it's the same list that's in the 13 bring in their own team?
14 Exhibit 3. 14 A. Not directly, necessarily. I mean, you could
15 Q. Yeah. 15 see it with some of the staff who had already left. Our
16 A. I don't know any of those people. And, like I 16 interim director that I mentioned -- executive director
17 said, I wouldn't really know all of them that well 17 that I mentioned, Gwen Sims, had left. Will Hudson had
18 because we were hiring so many people so fast. And 18 left -- I mentioned his name -- as deputy director. And
19 their names never came up in any of the conversations 19 it was just a lot of change with the new executive
20 that I had with Mac and Jennifer or even with Dr. Gokal 20 director coming in.
21 in the room. 21 Q. And what position does Gwen Sims had?
22 Q. Okay. 22 A. She -- at the time, she would have been the
23 A. They look to be just -- if you're referring to 23 interim executive director.
24 the individuals on page 11, they look like they're 24 Q. I mean, did -- did you talk to her about
25 probably all contract workers that we hired for -- 25 leaving?

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1 A. She had already left at that point, so we had a 1 A. Being the termination. Correct.
2 few discussions just because a lot of the leadership 2 Q. Do you know what ImmTrac is, I-m-m-T-r-a-c?
3 team had -- had left at that point. 3 A. It's out of my scope of normal knowledge. The
4 Q. Who did you talk to about the possibility of 4 only thing I do understand about it, I guess, I believe
5 staying or the possibility of leaving? 5 it is the State's tracking system for -- for vaccines.
6 A. I mean, there was a few -- it was a -- it was a 6 It's used, I believe, for anyone who gets a vaccine.
7 different time for the County because at the same time, 7 Primarily, originally, I believe it was used for
8 they were -- there was a component of human resources 8 children. I think that's what its intent was initially.
9 that was being centralized through what is termed HRRM, 9 And it got expanded from what I understand to be used
10 and so there were some discussions with them. Other 10 for COVID.
11 than that, it was just the time for me to leave. 11 But, again, I'm not an expert on it by no
12 Q. And why was that? 12 means. I'm only stating what I know just from the
13 A. It just wasn't the right fit for me anymore 13 conversations that I had internally at Public Health. I
14 based on leadership changes. 14 am not an expert.
15 Q. Who was your supervisor or person you reported 15 Q. Okay. And do you know whether it's needed to
16 to when you left Harris County Public Health? 16 track whether somebody's got the vaccine so they follow
17 A. At the very end, I guess -- I mean, it would 17 up with them and get a second vaccine?
18 have probably been Director Robinson, although she would 18 A. From my understanding, again, not an expert, it
19 have only been my direct supervisor for a matter of 19 was -- I was informed by someone in the incident command
20 maybe a month. 20 structure more on the medical side that ImmTrac was used
21 Q. Did you talk to her about -- 21 to track first doses so that they could account for who
22 A. She was -- 22 was getting the second dose.
23 Q. -- whether -- 23 So to your question, I believe the answer
24 A. -- not accessible. 24 then would be yes, it was tracked for second doses.
25 Q. Okay. What about before Robinson? Who did you 25 Q. Okay. Did you -- did you have a thought as to

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1 report to? 1 the patient forms that were signed by Dr. Gokal that
2 A. I reported to a number of individuals: Gwen 2 they had to have been the ones taken off-site?
3 Sims, Will Hudson, Les Becker. They would have all 3 A. A lot of the forms in terms of patient records
4 been -- Gwen was a interim executive director. Les was 4 that may have been tracked to Dr. Gokal were -- I really
5 a deputy director. Will was a deputy director. 5 left that expertise up to Jennifer because I just
6 Q. Did you report directly to the deputy director 6 didn't -- it wasn't in my normal scope of job duties,
7 or to the executive director? 7 and I had no access to ImmTrac or the patient records.
8 A. Most of the time during my almost seven years, 8 So I solely based it on her.
9 I was reporting to the deputy director. 9 She was specifically looking for time and
10 Q. And at the time Dr. Gokal was terminated, who 10 date stamps that would have been after the site
11 was that? 11 potentially closed because based on the claim, Dr. Gokal
12 A. That would have been Will Hudson. 12 had done it after the site closed.
13 Q. Will Hudson didn't have anything to do with the 13 Q. And if we look -- and we can, you know,
14 termination of Gokal, did he? 14 certainly look, for example, at Exhibit 2. For example,
15 A. He was aware of it, but he had a number of 15 if you go to where the patient records start off on page
16 other responsibilities in the COVID response. And so 16 3, Zahera Kazemi. Do you see that?
17 I'm not sure why Gwen didn't bring him into this 17 A. Zahera Kazemi, yes, I'm here.
18 discussion. 18 Q. I see a date. I don't -- maybe there's a
19 She did make him aware, because at one 19 time -- well, there is a time, actually.
20 point in my notes, I did make a note that she said she 20 A. There is, yes, sir.
21 had brought Will up to speed on the situation, but he 21 Q. 12:30. Is that the time?
22 wasn't a part of the -- he wasn't a part of those calls 22 A. I'm not familiar with these forms because I
23 or discussions about the investigation or the ultimate 23 wasn't filling them out or receiving them. I would be
24 outcome. 24 like you and assume that that would be the time.
25 Q. Ultimate outcome being the termination? 25 Q. Okay. So this wouldn't be after hours, would

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1 it? 1 is no time listed.
2 MS. REA: Objection, form. 2 Q. Okay. Do you know why this one was picked?
3 A. I don't -- I can't say that because I don't -- 3 A. I think that they were looking at -- I
4 I don't know for sure. 4 should -- I should clarify. Take that back.
5 Q. (BY MR. AHMAD) Okay. Well, is there anything 5 When I asked Jennifer to look at the
6 in this form that you see that would indicate that it 6 patient records, I think she was looking for anything
7 was after hours? 7 that could have been signed by Dr. Gokal and/or elderly
8 A. I -- again, it wasn't my job duties to do that 8 patients, because in the claim that we had received from
9 or track it. I would be reading it just like an average 9 the employee, it was mentioned that Dr. Gokal was seeing
10 person. So my assumption is the time that it was 10 elderly and bedridden individuals, so she was looking
11 administered is the time it was administered. 11 for a pattern -- my understanding is she was looking for
12 Q. Yeah, and I'm just looking at it like an 12 a pattern of age and/or time and date stamps.
13 average person too. 13 Q. I'm assuming it's fine to give it to older
14 A. Sure. 14 people because they would have qualified, right?
15 Q. I'm just asking: Is there anything that you 15 A. I don't actually remember the qualifications
16 can see that indicates -- 16 for that particular time period. There was -- I know
17 A. Sure. 17 age was one of the things, but it was -- that was
18 Q. -- that it was given after hours? 18 outside of my scope as to knowledge basis on who should
19 A. On that particular record, it would be the time 19 and shouldn't get it.
20 administered, which was 12:30. In these documents, that 20 We were vaccinating, though, only at the
21 was probably the one -- I did not focus on that when we 21 site. That was the first day of our mass vaccinations.
22 were looking at the documents. The one I was focusing 22 Q. I understand, but you don't know whether the
23 on was Maria Gokal, and that was the time and date stamp 23 Farida Ebrahim or Zahera Kazemi was given on-site,
24 that really put it over the top for me in terms of it 24 right?
25 was a possible problem. 25 A. That is correct, there is no indication on the

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1 Q. Okay. But to be clear, 12:30 is not after 1 forms whether they were done on-site or off-site.
2 hours, right? 2 Q. Do you see a time on any of the rest? I'm just
3 A. There is no indication of a.m. or p.m. on this 3 looking at -- going through it. Somebody Deerbhoy,
4 one, so I'm -- I don't know. 4 Iqbal Fatima.
5 Q. I mean, did you think it was 12:30 a.m.? 5 A. I see -- I see those. In looking at those --
6 A. I really never looked at the dates, so I can't 6 Q. And then --
7 really answer that today. I've never looked at that 7 A. -- most of those have no timestamp. They had
8 particular time as a.m. or p.m. 8 date stamps, but no timestamps. The one -- one record
9 Q. I mean, that -- that sounds like it would be 9 that I focused on mostly due to the claim that Dr. Gokal
10 after expiration. 10 was -- was injecting friends and family was Maria Gokal,
11 A. Again, that wasn't in my scope of 11 which had a time administered of 7:00 p.m. on the date
12 responsibilities whether it was in -- in -- in time and 12 of 12-29, which was by all accounts from Dr. Gokal
13 date or not. That was not my thing. 13 supposedly administered at almost midnight that same day
14 Q. Okay. I mean, you were the one doing the 14 off-site.
15 investigation, right? 15 I found it intriguing that there was a
16 A. I was the one conducting the investigation, but 16 7:00 p.m. date on this -- a 7:00 p.m. time because
17 this is not the record that I would have used to 17 Dr. Gokal was supposed to be the site supervisor for the
18 determine whether this one was after hours or not. 18 Lyons location. So in questioning this particular
19 Q. Okay. If we -- you talked about Maria Gokal? 19 record, this was the one that definitely gave me some
20 A. Uh-huh. 20 insight as to some serious concern because this was done
21 Q. And then the next one after that is Farida 21 at 7:00 p.m. when he was supposed to be done -- when he
22 Ebrahim? 22 was supposed to be wrapping up the injection site at
23 A. Yes, the next one after one that is -- 23 Lyons.
24 Q. Is there a date on this one? 24 Q. Okay. But didn't Lyons close at 7:00 p.m.?
25 A. There is a date on this one, 12-29, but there 25 A. It did except he told us that this was done --

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1 that he injected his wife -- which I believe this is his 1 assumption, if he's told us that he's done them after
2 wife. He injected her at home at midnight on that day 2 the site closed and this was one of them, then why was
3 or right before midnight on 12-29. So there -- it 3 it at 7:00 p.m. and not after 7:00 p.m., because the
4 didn't add up. 4 site he was at was way across town and all the
5 And so the rest of them having no time and 5 injections he had -- had admitted to were done in and
6 date stamps, Jennifer concluded to some degree that 6 around the Fort Bend County/Sugar Land-ish area, which
7 these were the ones that possibly could have been 7 is a significant drive from Lyons. There's no way you
8 friends and family, which was why we wanted to give 8 could have injected -- no way you could have closed the
9 Dr. Gokal a chance to explain what he was doing. 9 site at 7:00 and gotten all the way across town and
10 Q. And why did you conclude or why did she 10 given an injection at the same time.
11 conclude that these could be possibly -- 11 Q. So why is that suspicious? I mean, why is it
12 MS. REA: Objection, form. 12 suspicious if he put 7:00 p.m. as opposed to 7:30 p.m.
13 A. I -- 13 or 8:00 p.m.?
14 Q. (BY MR. AHMAD) -- friends and family? 14 A. Well, it led to further questioning as to was
15 A. Yeah, I don't know her criteria because I 15 he even at the site, so there was some discussion as to
16 wasn't sitting there when she did it. I know she was 16 when was the last time people saw him at the site.
17 looking for mostly -- that particular day, she was 17 Unfortunately, due to the fact that we
18 looking for anything that might have been elderly 18 didn't have cameras at that particular time at any of
19 because of the bedridden comments that had been made, 19 our sites, there was no way to verify. We did talk to
20 and she was looking for ones that had been signed off on 20 some individuals. I believe that may have been
21 by Dr. Gokal directly. 21 something Trey was asked to do by Mac. But there was no
22 Q. But looking at these records, other than Gokal, 22 confirmation. We were, unfortunately, never able to get
23 you can't tell me which ones were after hours? 23 any confirmation as to whether or not he was there or
24 A. The only one that I can say that I know was 24 not at 7:00 p.m. when the site closed.
25 done after hours is the one that Dr. Gokal admitted to, 25 Q. Was this part of your investigation on the 6th?

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1 which was he told me his wife was administered close to 1 A. It was part of that discussion on the 6th,
2 midnight on the 29th. And here I have a patient record 2 yeah, with Mac.
3 showing that he injected her at 7:00 p.m. 3 Q. But you can't dispute that he was at the site
4 Q. Is it written down anywhere I -- that he 4 the entire time?
5 injected her close to midnight? 5 A. I can't because I wasn't there and there were
6 A. If you watch any of the media reports and/or 6 no cameras, so we're only having to base it off of what
7 interviews that he's done, he's advertised that story as 7 he -- he had said. He had said he had done all of
8 he injected his wife right before it expired at 8 these -- all of the ones that were indicated as friends
9 midnight. 9 and family as he described were done off-site.
10 Q. Okay. But nothing in the -- in the records? 10 Q. Well, weren't there people with him close to
11 A. Only the fact that when we discussed the 11 when the -- the site closed?
12 friends and family, he didn't disagree with anything we 12 A. That's the problem is there was nobody there
13 had to say. 13 who could identify that he was there at the end of the
14 Q. Did you ask him if he injected her prior to 14 site day.
15 midnight? 15 Q. Did you ask anybody?
16 A. I did not ask him specifically, but we talked 16 A. That was done through Mac with Trey.
17 at length about friends and family. 17 Q. Okay. So you don't know?
18 Q. I mean, I'm just wondering where the comment 18 A. I don't know, no.
19 that he had injected her at midnight came from. You 19 Q. Do you know if he entered these patient forms
20 learned that after the fact, after he was terminated? 20 into ImmTrac?
21 A. That's correct, because he did not share that 21 A. Great question. But I'll go back to the
22 in the -- in the meeting that we had. 22 ImmTrac comment. I don't know ImmTrac specifically.
23 But this one did give us some concern 23 What I was told was the identifying number at the top of
24 because he had already informed us that he had done all 24 each of those pages was the ImmTrac number. But, again,
25 of the injections off-site after the site closed. So by 25 I am not -- oh, I'm sorry. If you look at -- I'm still

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1 on Maria Gokal's record. 1 would need to be treated as County property in order to
2 Q. Okay. 2 maintain the same rules that would apply for any
3 A. So if you look at the top number right under 3 other -- any other employee or staff member dealing with
4 the date -- the stamp that says "complete," it's a 4 County property.
5 number that starts with 236. 5 Q. Did he tell you this, or is this your opinion
6 Q. Yep, I see it. 6 on your own?
7 A. It's -- what I was told was -- by the 7 A. That's actually a two-part answer. So the
8 individual -- I think it was Jennifer because she knows 8 vaccine part is Mac. So Mac obviously had the knowledge
9 ImmTrac -- I'm sorry, Jennifer Kiger who knows ImmTrac. 9 of the vaccine and the State department relationship
10 I was -- I was informed that that was the ImmTrac 10 because that is outside of my scope.
11 tracking number. 11 In terms of County policies, then that's
12 So as far as I understand, any -- any -- 12 just -- it's not my opinion. It's -- it's just the
13 and this was confirmed when I talked to Dr. Gokal in our 13 County rules in terms of doing things with County
14 meeting when we were discussing how many doses. He did 14 property.
15 indicate to me that he had turned in -- any injection 15 Q. Well -- but where does it say that if it's
16 that was done off-site, he had turned in the -- the 16 State property that's in the care of the County, that
17 completed forms for so that those could get into 17 those rules -- that the County rules apply? Where does
18 ImmTrac. So he did that -- he did validate that with 18 it state that?
19 me. So I'm -- as far as I understand, the number at the 19 A. Yeah, I couldn't answer that question because
20 top of that page is the ImmTrac number. 20 it's not in my normal scope of what -- of policy. I
21 Q. You said, I believe, in part of the recording 21 would never oversee any of that.
22 that we listened to to the criminal authorities that at 22 Q. Do you know what the State rules are regarding
23 no point in our processes does it say that he can take 23 the vaccine?
24 the vaccine and administer it to friends and family. 24 A. No. Again, it's outside of my scope of COVID.
25 There weren't really any processes in effect? 25 I was very narrowly focused on people because that was

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1 A. Is that a question? 1 my role.
2 Q. Yes. 2 Q. Do you know if Ms. -- if Dr. Gokal got any
3 A. I'm sorry. Could you rephrase it as a question 3 direction from the State as to what to do with the
4 maybe? 4 vaccine?
5 Q. Sure. Were there any processes with respect to 5 A. That's a great question. I don't know what the
6 the vaccine in terms of administering it to friends and 6 State told him to do with it. No. I wasn't part of any
7 family? 7 of those calls. If anyone would have known anything
8 A. Okay. Thank you. So when it gets into the 8 about that, it might have been a Mac or a Jennifer
9 processes, those were outside of my scope, so I did have 9 Kiger.
10 to rely upon Mac and Jennifer regarding any protocols 10 Q. Do you think that Dr. Gokal should have
11 with vaccines. As far as I understand, there wasn't 11 listened to direction from the State Department of
12 much documented in terms of what to do with the 12 Health --
13 vaccines. As a part of the County rules, though, you're 13 MS. REA: Objection, form.
14 not allowed to do -- to give things that are County 14 Q. (BY MR. AHMAD) -- regarding the vaccine?
15 property to friends -- to friends and family. 15 A. I can't tell you what Dr. Gokal should or
16 Q. And just to be clear, this -- this was State 16 shouldn't do. I do know that in dealing with any
17 property, not County? 17 disaster-type response, which pandemic is included in
18 A. It was State -- it was -- it gets complicated 18 that, it's pretty common knowledge to know that those
19 at that point, and I'm not sure I fully understand 19 responsible are handled by incident command structure.
20 because I was not -- it wasn't my job to know. It was 20 So with anything -- you wouldn't be getting
21 really Mac's job to know what was going on and how we 21 direct -- in a response and the way that individuals are
22 were getting the vaccine. 22 trained in what's called the ICS structure, the incident
23 But what -- the way it was described to me 23 command structure, which is a FEMA-related program --
24 by Mac was it was State -- the vaccine was State's 24 it's used across the country; it's standardized -- the
25 property but in our care, and so anything in our care 25 standard policy is you're reporting to someone in the

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1 ICS structure, so you would take direction from whoever 1 A. I don't --
2 that person is above you. 2 Q. Unless they're -- unless they're stealing.
3 Q. Where does it say that in the policies that 3 A. But -- but I --
4 he -- he is supposed to listen to incident command as 4 MS. REA: Objection, form.
5 opposed to directly take orders from the State? Where 5 THE WITNESS: Sorry.
6 does it say that? 6 A. I can't tell you that -- in my knowledge base
7 A. I can't -- I can't comment on what it says 7 of the situation, I can't tell you that that's a yes or
8 comparatively to the State, but I can tell you that the 8 a no. I can't -- I just don't know enough about the
9 FEMA guidelines are -- the incident command structure in 9 relationship with the State and the agreement that they
10 terms of reporting relationship and duties that you're 10 had with Harris County Public Health or the County in
11 supposed to carry out in terms of hierarchy, it is all 11 general. I don't -- I was not involved in that at all.
12 lined out in the incident command structure. 12 Q. (BY MR. AHMAD) Do you know who Andrew Foland
13 Q. That's FEMA? 13 is?
14 A. That's the FEMA incident command structure that 14 A. Yes.
15 we were operating under, yes. 15 Q. Who is that?
16 Q. Where is that that says that you listen to 16 A. Andrew at one point in time was the director of
17 incident command as opposed to the State with respect to 17 operations for Harris County Public Health. He -- the
18 vaccine -- 18 best way to describe his role is it was sort of a
19 A. Well, like I said, I can't talk about the State 19 facilities director-type role. So he was responsible
20 because I don't -- I'm not an expert on FEMA or -- I 20 for all of our sites, shipping and receiving, equipment,
21 mean, I've been trained in ICS policies, but they don't 21 supply chain-type stuff.
22 go as detailed as to talking about when you do this 22 Q. Did -- do you know whether he ever asked
23 versus the State. That's usually not applicable. 23 Dr. Gokal help for getting somebody's grandmother
24 In the ICS structure, there's very clear 24 vaccinated?
25 delineation as to hierarchy and who you're supposed to 25 MS. REA: Objection, form.

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1 report to and listen to. And it's a FEMA thing. I 1 A. I don't have firsthand knowledge of it. I
2 don't have documentation on it. I'm not an expert on 2 wasn't there, but I do understand that there was a -- I
3 it. 3 was informed that there was a possible conversation
4 Q. I'm just trying to find out -- 4 between Andrew and Dr. Gokal on getting someone that was
5 A. Yeah. 5 elderly injected.
6 Q. -- that -- you know, whether there's any County 6 Q. (BY MR. AHMAD) Who told you that?
7 policy with respect to taking direction from the State 7 A. I don't recall now, unfortunately.
8 concerning State property. 8 Q. Would this have been improper?
9 A. I wouldn't -- 9 MS. REA: Objection, form.
10 MS. REA: Objection, form. 10 A. Let's -- so I would say it would be
11 A. Yeah, I wouldn't know that. I wouldn't know if 11 inappropriate maybe is the better question because we
12 there was State policies regarding the County. It's 12 really weren't supposed to be -- going back to the
13 outside of my scope of work. 13 intent on dealing with the vaccine, there was proper
14 Q. (BY MR. AHMAD) Would you -- would you have any 14 channels for people to register to get the vaccine.
15 idea that the State could take the vaccine away from the 15 There were rules. As you mentioned
16 County? 16 previously, the 1as and 1bs -- again, I don't know the
17 A. I had heard that was a possibility, but I heard 17 details, but there were rules on how people were
18 that from Mac and/or Jennifer. I'm not sure which one 18 supposed to get injected. So it would have been not
19 told me, but it was one of the two of them. 19 necessarily appropriate for them to have a conversation
20 Q. I mean, that kind of indicates that it's their 20 to get someone injected out of the scope of the work we
21 property, right? 21 were doing.
22 A. That, I don't know. 22 Q. (BY MR. AHMAD) I'm sorry. Say that last part
23 MS. REA: Objection, form. 23 again.
24 Q. (BY MR. AHMAD) Well, I mean, if they can take 24 A. It would have been inappropriate for them to
25 it away. 25 have that discussion on getting someone vaccinated

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1 outside of the protocols and/or processes that we were 1 attorney's report because it did come up in that. I was
2 vaccinating people. 2 asked to follow up with Dr. Shah specifically about a
3 Q. Was it inappropriate for Foland to ask 3 text -- I would say conversation, but that's probably
4 Dr. Gokal for this? 4 not the right word -- but a text string between --
5 A. If that's what happened, it would have been, 5 between him and Dr. Gokal after Dr. Gokal had been
6 yeah. 6 terminated.
7 Q. Was that investigated? 7 Q. Okay. If you want to look -- and I think I
8 A. There were some things with Andrew that were 8 know where you're talking about, but I'll just ask you.
9 investigated. He was eventually taken out of COVID 9 A. Okay.
10 response and demoted. 10 Q. If you look at Exhibit 3, page 9, GOKAL000248.
11 Q. Was -- 11 A. Yes, I'm on page 9.
12 A. Not necessarily due to that incident, but . . . 12 Q. And if you go down to the fourth paragraph.
13 Q. Was he disciplined at all for this incident? 13 A. Yeah.
14 A. For that incident, he would have reported to 14 Q. Is that what you're talking about?
15 Will Hudson, our deputy director at that point. And I'm 15 A. Yes. So in the district attorney's ask -- they
16 not sure what conversation Will had with him, but Will 16 didn't have -- Dr. Shah had left Harris County Public
17 was aware of it. 17 Health. He was the health director for Washington State
18 Q. But you don't know whether Foland was 18 at the time. But I had a lot of contact with him off
19 disciplined for it? 19 and on through his cell phone, so I had his contact
20 A. I don't remember. I mean, at some point, it 20 information -- his personal contact information since he
21 was -- as with a lot of employees, there's an ongoing 21 had no more ties to the County.
22 documentation and ongoing issues that ultimately end up 22 And so it had been discussed in the meeting
23 in some action, and the end action for Andrew at some 23 that I had with Dr. Gokal and Mac McClendon that
24 point was to be demoted. 24 Dr. Gokal had mentioned in that meeting that he had --
25 Q. And I understand that. I'm just trying to find 25 after the injections after hours, he had texted Dr. Shah

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1 out was he disciplined for asking about this grandmother 1 something regarding it. And he told me in the
2 being -- 2 meeting -- and you'll see it in the quote here -- that
3 A. Yeah, at this -- 3 he said that Dr. Shah texted him "back way to go."
4 Q. -- injected off-site. 4 And so the -- I found -- found that highly
5 A. Sorry. At this point, I just don't remember if 5 unlikely in the years that I was dealing with Dr. Shah
6 he was disciplined for that particular incident. 6 specifically that that didn't sound like something that
7 Q. Do you know whether he was investigated for 7 Dr. Shah would probably say.
8 that particular incident? 8 So when I mentioned it to the County --
9 A. I honestly don't remember. We were dealing 9 sorry. Excuse me. When I mentioned it to the district
10 with so many different issues and so many different 10 attorney's office, they asked me to follow up on it
11 staff members that were -- had so many different 11 because I had contact with Dr. Shah and they didn't.
12 problems. I don't -- I don't remember having 12 And so when I went back and asked Dr. Shah about the
13 documentation on it at this point. 13 text communication with Dr. Gokal, his response back to
14 Q. Did you have any communications with Dr. Shah 14 me was that he had responded back to Dr. Gokal's, you
15 about Dr. Gokal? 15 know, claim of taking the vaccine and vaccinating people
16 A. Is there a reference point? I mean, I talked 16 off-site as that might be a problem for you.
17 to Dr. Shah a few times about Dr. Gokal. 17 And I'm not sure -- that's not a direct
18 Q. When? And I'm assuming you did it at hiring, 18 quote, but Dr. Shah's message back to -- what Dr. Shah
19 right? 19 told me was his message back to Dr. Gokal was is that
20 A. I did not talk to Dr. Shah about Dr. Gokal at 20 might be a big problem, and that was the extent of the
21 hire -- when we hired him, no. 21 conversation that I had with Dr. Shah.
22 Q. Okay. So what would have been the occasion to 22 Q. Was this a conversation or a --
23 talk to Dr. Shah about Dr. Gokal? 23 A. It was --
24 A. So there was -- in the notes that I have, there 24 Q. -- text?
25 is a reference -- and I believe it is in the district 25 A. -- a text, yeah. It was -- oh, I'm sorry.

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1 Before I answer that, let me think about it. 1 Q. District attorney?
2 It started as a text because I texted 2 A. District attorney's office. Thank you.
3 Dr. Shah and said -- if I'm not mistaken, I said, "I 3 But at that point, I didn't really say much
4 need to talk to you," because it wasn't going to be 4 more than that because I didn't know what they were
5 something that I could have gotten easily answered by a 5 going to do with it other than it had been mentioned
6 text string. 6 that it would be turned over to the DA's office and
7 So Dr. Shah and I then talked about it. 7 there might be criminal charges. That was as far as I
8 Yes. So it was -- it was a text and then a phone call. 8 knew at that point.
9 I think it was only one phone call, though. 9 Q. Okay. And did you tell him that it would be
10 Q. Well, the reason I'm curious is it says -- it 10 reported to the medical board?
11 says that you advised -- that you know Dr. Shah and that 11 A. I don't remember if I told Dr. Gokal directly
12 you did not believe that this would have been okay. 12 if that was going to be reported to the medical board.
13 A. I didn't believe that Dr. Shah would have given 13 We had a couple of conversations about the medical
14 him a response as "way to go" if Dr. Gokal had told him 14 board, but I'm not sure at this point if I mentioned
15 "I took the vaccine off-site and gave it to friends and 15 that in that meeting. We -- we discussed a lot of
16 family." 16 different things in that meeting, but I don't remember
17 Q. Had you talked to Dr. Shah by this time, 17 the medical board specifically.
18 January the 11th? 18 Q. Did you tell him it was going to be reported to
19 A. At the point of January 11th, let me think 19 the State health department, DSA -- DSHS?
20 about that for just a second. 20 A. I don't think I said that. I do think I
21 I talked to Dr. Shah sometime after the 7th 21 referenced the fact that we were going to have to talk
22 because that was the meeting with Dr. Gokal where it 22 to -- and I don't know if I mentioned the name
23 came into -- came up is that Dr. Shah had said this, 23 specifically, but I do -- I think we mentioned that we
24 because I had to report it to -- to the district 24 were going to have to report it to Dr. Plasencia with
25 attorney's office. 25 the State. I may have just referred to it as the State,

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1 I don't recall the date that I actually 1 but I do believe that I did let him know that we were
2 talked to Shah. It was definitely after the 7th, but 2 going to report -- we had to report it to the State.
3 was it -- it would have been -- based on the notes from 3 And that was not my doing. That was Mac's
4 the district attorney's office from the conversation 4 request. I didn't report it to the State. He asked
5 they had with me, it appears that I have not talked to 5 Dr. Onyiego to -- to talk to the State.
6 Shah at this point. 6 Q. Have you talked to the State about Dr. Gokal at
7 Q. It does appear that way. Okay. 7 all?
8 A. It does not appear that I talked to him -- 8 A. I've never talked to the State about Dr. Gokal,
9 Q. Did -- 9 no.
10 A. -- yet. 10 Q. Did anything come out of reporting it to the
11 Q. Do you have the text chain with Dr. Shah? 11 State?
12 A. I don't have that, no. 12 A. I don't know because I never followed up on it.
13 Q. You don't have it anymore? 13 I didn't need to. It wasn't -- it was turned over to
14 A. I haven't looked for it, so I don't think I do. 14 Dr. Onyiego. And I'm sure she and Mac may have had
15 I've changed phones since then. And I haven't talked to 15 discussions, but, no, I wasn't a part of that.
16 Shah -- I haven't talked to Dr. Shah since the -- he 16 Q. And I think you testified earlier Dr. Gokal
17 flew into town for the grand jury. In passing, I said 17 said he took ten doses off-site?
18 hello and that was it. That's the only communication 18 A. When I had the discussion with Dr. Gokal, he --
19 I've had with him. 19 I asked him specifically about the 13 possible patients
20 Q. At your termination meeting, I think you 20 that were injected because I was really curious to find
21 mentioned that he might be prosecuted criminally, 21 out if there was -- the concern was that there was a
22 correct? 22 second vial potentially, and he assured me that there
23 A. I didn't say that. What I said was is that it 23 was not a second vial, and he said specifically that he
24 appears that the case may be referred to the County 24 had only done no more than ten.
25 attorney's office -- 25 And then he proceeded to get either in his

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1 bag or in a box that was with his bag. It was like a 1 point and left it -- and left it alone. I left it for
2 backpack-type of a bag. And he said, "Here, let me give 2 Jennifer and Mac to figure out how they were going to
3 you the vial. I still have it." And so I took the vial 3 give the patients the second doses.
4 from him, and then he continued to, you know, get the 4 And at some point in that process, as I had
5 rest of the items. 5 mentioned the -- when Dr. Gokal was talking -- when we
6 At that point, from what I understand, is 6 were talking about the fact that he had the ability to
7 he only had the vial. He had already turned in the 7 potentially pitch a mobile-type unit to go to
8 patient forms. I'm not sure who he turned them in 8 individuals' houses to do vaccines, eventually, that's
9 because we had already had the patient forms at that 9 what Public Health did. It was not until a significant
10 point. 10 time later. But my assumption was is that Mac and
11 Q. Were you suspicious that Dr. Gokal was lying 11 Jennifer would take care of those patients' second
12 about it just being ten doses? 12 doses. So I had no reason to be concerned too much at
13 A. Was I -- I was not suspicious because I had at 13 that point after that.
14 that point no reason not to trust that he was telling me 14 Once I had a conversation with Dr. Gokal --
15 the truth. 15 like I said, I had no -- I liked Dr. Gokal. I mean, I
16 Q. Did you suspect that he had been short dosing 16 know what's happened has happened. I still like him
17 people on their vaccinations? 17 today. But there was definitely concern in the
18 A. In the initial thought based on the fact that 18 beginning because we weren't really sure what had
19 we found possibly 13 patients, there was a discussion 19 happened. We had a story that was told to us that was
20 that we had about possibly being short dosed, but I'm 20 then validated by Dr. Gokal that in -- after dark, he
21 pretty sure when he and I were talking about the vial 21 had taken this vial, put it in his backpack, drove
22 and the ten doses, I'm pretty sure he said, no, that it 22 across town, and gave it to people. In what type of a
23 was only ten doses and they were regular dozes. I'm 23 setting, we didn't know.
24 pretty sure. And I had no reason at that point not to 24 And when I say "we," it was the leadership
25 believe him. 25 team, Gwen Sims, Mac McClendon, myself. I'm not sure

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1 Q. Okay. So after the termination meeting, you -- 1 who else. Maybe our legal counsel.
2 you had no reason not to believe him and no reason to 2 But we had the discussion as to, well, was
3 suspect he was short dosing? 3 it in temperature. There wasn't medical -- direct
4 A. I would say that's accurate. 4 medical staff on-site. All of our vaccine sites had
5 Q. Okay. Did you think that Gokal's actions were 5 dedicated ambulances. What -- what happened if there
6 premeditated at all with respect to the vaccine? 6 would have been somebody who has an adverse reaction to
7 MS. REA: Objection, form. 7 it? We had a lot of conversations as to what
8 A. Okay. That's -- that's a harder question. So 8 potentially could have happened, but once we actually
9 do I think it was premeditated? I had concerns only 9 got to that termination meeting, I had no reason not to
10 because -- not that it was premeditated. Sorry. I 10 trust Dr. Gokal at that point.
11 should clarify. 11 Q. (BY MR. AHMAD) Okay.
12 I had concerns regarding the second dose 12 A. I'm not sure I answered your question, so sorry
13 because my initial concern was if he did it off-site, 13 about that.
14 did we have -- how -- how were these patients as they 14 Q. I'm not sure you did either. But my --
15 were described to me as bedridden and not able to get to 15 A. Okay. So if you want to repeat it, I'll try
16 a site, if the only way we were doing second injections 16 again.
17 was at a site, how did he intend to get them second 17 Q. I'll repeat it.
18 doses? I mean, we put -- it appeared that he had put 18 A. Sorry.
19 them in the correct paperwork to get them into ImmTrac, 19 Q. My question was: As of the termination date --
20 which means they would get notified of a second dose. 20 A. Sure.
21 But I did have still some slight concerns as to how he 21 Q. -- okay, like, right after the termination, did
22 was going to get the second dose to those individuals. 22 you have any reason to believe or suspect that
23 At that point at the termination, once I'd 23 Dr. Gokal's actions were premeditated?
24 cleared up the -- you know, the fact that he told us it 24 A. Oh, I'm sorry. You're right. It was the
25 was ten doses, one vial, I kind of dropped it at that 25 premeditated question. I'm so sorry.

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1 Where I was going with that was at some 1 but then she left the County at some point and I do
2 point, there may have been some thoughts that he had a 2 believe another person may have taken over.
3 plan to do second doses. But at the time of the 3 But I think at the point of this
4 termination, once I had a chance to actually talk to him 4 conversation with the DA's office, Eileen was the one
5 and we walked through what had happened with the doses, 5 who started it. And I was -- I thought that Eileen had
6 I didn't really have any reason to think that it was 6 already talked to Dr. Gokal, so I wasn't sure.
7 premeditated at that point. 7 Q. The next paragraph, you say: "Dr. Gokal was
8 Q. Do you know Eileen Begle or "Begle"? 8 terminated for policy violation."
9 A. Eileen Begle, yes. 9 MS. REA: I'm going to object to form. Are
10 Q. Let me tell you what I'm referencing. 10 you talking about -- unless I'm wrong, I'm just making
11 A. Yeah, no problem. 11 sure you're talking about the district attorney's
12 Q. It's page 10. 12 summary?
13 A. Yeah, okay. 13 MR. AHMAD: Yes, I am.
14 Q. Paragraph 3. 14 MS. REA: Okay.
15 A. Yes. 15 Q. (BY MR. AHMAD) Do you remember telling the
16 Q. "Mr. Anderson stated that we should reach out 16 district attorney that?
17 to Eileen Begle at the County attorney's office and 17 A. It did come up in the conversation. This looks
18 advise she might have information concerning Dr. Gokal's 18 probably at the time close to what I said. I was
19 character." 19 getting advice from attorneys within the County.
20 A. Yes, so that reference -- we had a lot of 20 Q. Okay. And I don't want to talk about that.
21 contact with County attorneys, so I can't remember 21 A. Okay.
22 specifically how that came up in the questioning with 22 Q. It looks like you couldn't identify a specific
23 the DA's investigators, but there was other 23 policy, correct?
24 investigations that were going on, some that I weren't 24 A. There was -- I was asking specifically the
25 aware of. The way the County was handling their -- 25 County attorney's office about -- how should I phrase

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1 their fraud, waste, and abuse hotline, there weren't -- 1 it? It was related to personal use, I think, of County
2 I didn't get every single investigation on my desk, so 2 property. We were exploring a lot of different
3 there were some things that Eileen had been doing. 3 conversations, and so this -- this discussion was trying
4 I think, though, at the time of this 4 to determine if Dr. Gokal had broken any County
5 conversation, Eileen had actually left the County, but I 5 policies.
6 knew that a lot of those individuals knew her and could 6 It was part of the investigation. It
7 reach out to her personally because I know that she had 7 wasn't the ultimate decision-maker for anything at that
8 had some involvement in an investigation. 8 particular time, but we did have a discussion when I
9 I believe the investigation then got turned 9 talked to the DA's office about all the things -- or not
10 over to another County attorney, and I think that in -- 10 all the things because they didn't document all the
11 in reference to this is Dr. Gokal was interviewed in -- 11 things that we talked about. But for some reason, they
12 in another -- another case of some sort. And I just 12 have identified this as -- as some of the statements to
13 referenced to them that if they wanted any additional 13 put in here. At one point, there was a discussion as to
14 information, they might talk to her to see what she got 14 whether or not it was a policy violation.
15 on another investigation. 15 Q. But you didn't know a specific policy that
16 Q. I mean, do you know what she would know about 16 Dr. Gokal had violated?
17 his character? 17 A. I was actually asking the -- I was getting
18 A. I don't. No. It was just in passing. I had 18 advice from the attorney's office as to how to proceed,
19 heard of a couple of fraud, waste, and abuse claims. 19 so I was looking for policies to be able to reference if
20 Not about Dr. Gokal necessarily. I don't know what they 20 I needed to.
21 were about. I just knew that Dr. Gokal had been 21 Q. Did you find one?
22 interviewed for a couple of ongoing investigations that 22 A. I didn't find one, which is why I was asking
23 the County attorney's office was doing. 23 them where it was. I had been through some additional
24 Q. And that Eileen Begle was involved in? 24 training.
25 A. I believe she was involved in those at first, 25 The County has a few training videos on

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1 ethics and a few other things, and it's mentioned in 1 A. Right, right. But it was handwritten into some
2 those trainings about personal use of County property. 2 of the documents, so I'm not sure why that was even
3 So I was under the assumption there was a policy. I 3 there, but that wasn't -- it was only looked at -- when
4 couldn't find it, but I will also say I didn't have a 4 I had Jennifer pulling the patient records, we were just
5 lot of time just based on the COVID activities we were 5 looking for documents that could be tied to friends and
6 doing. So I had asked for assistance from the -- from 6 family where Dr. Gokal's name was there on that
7 an attorney to find the policy. 7 particular date and if it had a time and date stamp
8 Q. When did you -- when did you ask for this 8 after hours. That's what they were -- that's what
9 assistance? 9 Jennifer was generally looking for.
10 A. I don't remember because there were a lot of 10 Q. When you say "some familiarity with names" --
11 conversations between the 6th and this date that they 11 A. Uh-huh.
12 wrote this summary. It would have probably been -- 12 Q. -- who was familiar with these types of names,
13 based on the notes, most of the conversations regarding 13 you, Jennifer, somebody else?
14 the legality of the situation happened on the 6th. So 14 A. I mean, I've worked in a lot of international
15 there were calls with more than one attorney on the 6th 15 workplaces that had numbers of different nationalities
16 before we go into the termination -- well, what ended up 16 and ethnicities and races, and so there's definitely
17 being the termination meeting on the 7th. 17 some names I recognize as fitting into certain
18 Q. But you never got the policy back from the 18 categories.
19 attorney? 19 Q. As fitting into Asian categories?
20 A. I never received anything other than the -- I 20 A. Well, I mean, technically by the way we fill
21 think it's called the ethics training video where they 21 out our EEO paperwork, if an individual doesn't
22 mention County -- County property. But, no, I never 22 identify, we physically have to identify what an
23 received anything policy related. 23 individual is. So I'm used to -- as a part of an HR
24 So there was -- if you'll -- if you look at 24 job, I'm used to visibly looking at people and put --
25 the verbiage on the termination letter, there is no 25 having to put them into a category if they don't

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1 reference to a policy violation and no reference to a 1 identify themselves, so . . .
2 policy number for that reason because I never got 2 Q. Is it fair to say that all of these patient
3 anything back from the attorneys. 3 forms would fit into the Asia, South Asia, Pakistan
4 Q. So let me ask you this and we can -- I think 4 category?
5 we've been over the patient forms. 5 A. It's --
6 A. Uh-huh. 6 Q. Asia Pacific Islander.
7 Q. And we can -- you know, just to put it in front 7 A. Sure, sure. It's fair to say it's possible
8 of you, again, it's Exhibit 2, and it starts on page 3. 8 based on some of the names. I would never say
9 I noticed that I believe three people mentioned Pakistan 9 100 percent unless they had all marked, you know, Asia
10 as ethnicity/race. It's possible that there's another 10 or Pacific Islander.
11 one, but I don't think so. 11 Q. Is there any name you think is not Asian
12 Did you ever notice that there were an 12 sounding?
13 unusual number of Pakistanis on these patient forms that 13 A. I don't know if I could judge that
14 were pulled? 14 specifically.
15 A. At some point looking at the forms, I mean, 15 Q. Yeah, I just wanted to know if there's somebody
16 it -- there was some that had indicated they were, you 16 you think is not Asian.
17 know, Asia Pacific Islander, and there were others that 17 A. I would say -- I think the majority of the
18 weren't checked at all. I think there was some 18 forms actually wrote in or clicked off they either put
19 familiarity with last names, so I think they were 19 Asian or they wrote in Pakistani or something else. So
20 potentially looked at as possibly being Asian or Pacific 20 I think we were able to identify most of them could be.
21 Islander. There was one or two maybe that had written 21 Yeah, could -- I think in looking at all of
22 in Pakistani. I'm not sure exactly how that -- why that 22 them now, again, I mean, based on my experience in
23 would be there. It's not an ethnicity or race. I mean, 23 working in international workforces, a lot of the names
24 it doesn't fit. 24 sounded as if they could be.
25 Q. It's in Asia. 25 Q. Could be Asian?

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1 A. Could be, yes. 1 family? Other than Gokal, how would you --
2 Q. Did you ever comment to Jennifer that the names 2 A. Sure.
3 were -- well, that they were from Pakistan or Asia or 3 Q. -- know? Is it based on the names?
4 anything to that effect? 4 A. I think some of it was -- well, we found
5 A. I didn't mention to Jennifer that they were 5 obviously spouse. That was -- that looked to be pretty
6 Pakistan because I would never refer to it as that. 6 clear. We were looking at dates, and I think there was
7 That's not how I would have done it. As I said before, 7 just -- it was specifically -- so -- so in the -- on the
8 I typically refer to EEOC category terminology for the 8 site what Jennifer told me was -- is that Dr. Gokal
9 most part. 9 historically wasn't injecting at the site.
10 Jennifer and I had a conversation 10 So the way our COVID sites worked -- the
11 specifically regarding the claim that it was friends and 11 way our COVID sites were running is, is we had other
12 family. So as a part of the investigation, did we look 12 individuals doing injections for the most part. He was
13 at these patient records, the ones that she had found, 13 there as a site supervisor along with, I believe,
14 to see if they could be friends and family, because the 14 Franaldo Curl, if I'm not mistaken. So the team
15 report was it was spouse, possibly mother, mother's 15 underneath them would have been doing the actual
16 friends, and in looking at that, it was possible that 16 injections.
17 these were those individuals. 17 So when Jennifer and I had the discussion,
18 Q. Did you ever mention to Jennifer Kiger the race 18 it was look for Gokal's signature because that would be
19 of the individuals in the patients form -- patient 19 the key indicator that it was possibly one that was done
20 forms? 20 off-site because he wasn't traditionally giving them
21 A. Actually, with Jennifer, I'm not sure I ever 21 on-site.
22 actually mentioned ever race. I think we 22 And then after that, then there seemed to
23 had discussions -- I think we had discussions that it 23 be this pattern. Obviously, these are all 12-29 with
24 was possible that these were friends and family, but we 24 his name on it, and then it -- then the next thing we
25 never talked specifically about race or Asia Pacific 25 looked at was age where they fell in -- it appeared

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1 Islander. 1 again as a part of the investigation looking at the age
2 Really, the only time that the Asian or 2 was key because of the fact that it was mentioned that
3 Pacific Islander came up was in the meeting we had with 3 they were possibly homebound or bedridden.
4 Dr. Gokal where I was trying to give him some advice on 4 And all of those things, then, led to say,
5 the equity component. That was the only time that that 5 okay, well, if it is friends and family, it's possible,
6 came up. 6 they are possible. The names could be potentially
7 Q. Okay. I'm specifically talking about 7 friends and family. And that's as much as we left of
8 conversations with Jennifer Kiger, okay? 8 that. There was no discussion of specific race or --
9 A. Uh-huh. 9 you know, there was no mention of Asia Pacific Islander
10 Q. Did you ever mention to her that the names 10 or Pakistani or any country or anything at that point.
11 sounded Pakistani or Asian? 11 We were looking for something very specific with Gokal's
12 A. I never said the word "Pakistani." 12 name on it first, and then the rest of it just kind of
13 Q. Okay. How about Asian? 13 fell in a line of things we were looking for.
14 A. Sorry. I was going to finish the second part 14 Q. You understand -- and this is a question.
15 of that, which was the Asian piece. So I -- I think 15 A. Sure.
16 that when she and I had had that conversation, I don't 16 Q. That Jennifer Kiger testified that you
17 think I used the term "Asia Pacific Islander." I think 17 mentioned the nationality of some of the individuals in
18 when we were having that conversation, I'm pretty sure 18 the patient forms?
19 we just stuck to the -- to the comments -- the original 19 A. I don't know what Jennifer testified as and --
20 comments, which they were friends and family. 20 but I don't remember specifically saying Asia or Pacific
21 So when she and I had that discussion, it 21 Islander to her. I don't. I don't remember that at
22 was friends and family. We weren't talking race, 22 all.
23 ethnicity, country of origin, none of those things. 23 Q. Okay. And so you think as far as it got was
24 Q. But how did you know? I mean, other than the 24 just that based on the names, they could be friends and
25 names, how would you know whether they're friends or 25 family?

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1 A. There was definitely a could be about it 1 driving between sites at the time when I needed to call
2 because, again, we were looking for the pattern of all 2 her back. So I pulled over and then just told her I
3 of those things. We were looking for Gokal's name as a 3 don't have anything to write with. Can you document it
4 signature, the particular date, anytime a date stamps 4 and send it to me in an email.
5 the elderly because of the bedridden. And then looking 5 Q. Okay. If you go -- go after the patient forms
6 at the name -- I mean, yes, did we notice that a lot of 6 on Exhibit 2 to your timeline summary.
7 them had selected Asia -- Asia or Pacific Islander. On 7 A. Uh-huh.
8 our form, it's only listed as Asian. And then some 8 Q. And the first entry, January 6, 2021, at
9 others had written in either South Asian or Pakistan. 9 2:30 p.m.; do you see that?
10 I mean, did we notice it? Yes, I mean, it 10 A. I do, yes.
11 definitely was one thing that was an indicator, but it 11 Q. Is this the first notice you got?
12 wasn't the sole -- it wasn't the sole thing we were 12 A. That is the first call, yes.
13 looking at. We were looking at the signature first 13 Q. Okay.
14 because that indicated that he potentially did it 14 A. It was Jennifer. Okay. So it was Jennifer and
15 off-site. 15 not an attorney. I thought there was an attorney on
16 Q. Were these -- these 13 that are attached -- 16 that call.
17 A. Uh-huh. 17 Q. Okay.
18 Q. -- in Exhibit 2, were these the only ones that 18 A. There was not.
19 Gokal signed? 19 Q. Yeah, it was -- it looks like it was Gwen
20 A. That, I don't know, because I left the patient 20 Sims --
21 records up to Jennifer because I had no access to 21 A. Yeah.
22 patient records. And, again, when we talked about it 22 Q. -- Jennifer Kiger and Mac McClendon, correct?
23 before, in my discussion with Dr. Gokal, I was pretty 23 A. Yeah, I remembered it more so as Gwen and Mac,
24 confident that he told me the truth of only ten. So 24 but, yeah --
25 obviously when we're looking at these patient records, 25 Q. And --

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1 we -- if there's 13 here, we've clearly identified some 1 A. -- Jennifer was probably involved.
2 that weren't -- weren't possibly friends and family. 2 Q. And prior to January 6th, you had no idea that
3 I mean, that's why in the -- in the -- in 3 this issue with Dr. Gokal and giving unused --
4 my statement, it said I'm -- these were possible. This 4 A. Uh-huh.
5 wasn't -- it wasn't an exact science. We didn't have 5 Q. -- vaccines had ever -- had ever happened?
6 100 percent confirmation. We were just looking at the 6 A. No, this was the first time I've heard of it,
7 trending of the name, the date, the age, possibly the 7 yeah. And I --
8 ethnicity. 8 Q. Do you know if Sims, Kiger, or McClendon had
9 Q. How did you first become aware of these unused 9 been aware of it prior to January 6th?
10 vaccines being given by Dr. Gokal? 10 A. On the call, they mentioned it specifically
11 A. I got a call from -- the very first time I 11 that Alison had just told them about it. That's what
12 heard about it was Gwen Sims and Mac McClendon -- I want 12 they indicated. Now, is that accurate? I don't know.
13 to say -- I think it may have just been the two of them. 13 I'm not sure I ever validated that with Alison. I
14 It could have been our -- one of our attorneys. They 14 wasn't so much concerned about the date that it started,
15 got a call from me to say that they had been informed by 15 more so about the incident so I could start, you know,
16 an employee that Dr. Gokal had told this individual 16 an investigation.
17 of -- of, you know, taking the vaccine off-site and 17 Q. But it looks like Dr. Gokal told Alisa Hare
18 vaccinating people outside of the scope of our site. 18 about it, correct?
19 From there, I asked who it was. They told 19 A. He -- it's Alison Hare and -- but, yes, as far
20 me who it was. And then I got on the phone with this 20 as --
21 individual, had them tell me over the phone -- which 21 Q. Oh, I'm sorry.
22 that would have been Alison Hare at this point. 22 A. That's okay.
23 Q. That's the one that reported it to you? 23 As far as I understand, they had had a
24 A. Yes. So she did over the phone first, and then 24 conversation, but I'm not sure I ever documented the
25 I asked her to write a statement because I was actually 25 date of that conversation. I did have Alison send me an

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1 email, which I think is included in this packet. I 1 reason not to believe it. He told me that it was ten
2 could look there to see, but I don't -- I don't remember 2 doses, and I believe him.
3 it firsthand. Let's see. Is her -- 3 Q. But he's told everybody that it was ten doses.
4 Q. Well, I guess my question is just he told her? 4 He's never given a different amount --
5 A. As far as I knew, it was just -- it was a 5 A. No, I agree. Yeah, that's -- I agree 100
6 conversation. I just don't know when in terms of 6 percent.
7 timeline. Gwen and Mac made it seem like it was that 7 Q. If it had been ten Caucasian people unrelated
8 day because of the urgency in getting it started in 8 to him, would that have made a difference?
9 terms of the investigation. 9 A. I think ultimately in the discussion, it
10 Q. Okay. I'm trying to find that email, but -- 10 wouldn't have because he took the vial off-site against
11 A. I thought it was included in here and -- 11 the protocols, didn't ask that he could do it.
12 Q. It -- I think it is. I vaguely recall that. 12 If he had called in and talked to Mac and
13 Ah, you know what, it's -- the reason I can't find it, 13 Jen and they would have said we've got ten school nurses
14 it's -- 14 five minutes away from you, can you go inject them, not
15 A. It's on the back? 15 even considering race, nationality, anything, they would
16 Q. It's on the -- it's on, yeah, the previous 16 have probably told him, yeah, go do it.
17 page. 17 I think from a protocol standpoint in
18 A. Oh, oh, okay. Oh, yeah, okay, I'm there. 18 talking with Mac, it was more so about the fact that he
19 Q. And this is the email that she sent to you -- 19 just did it on his own with no -- no discussion, and
20 A. Right, yeah. 20 then to make it even worse, it was friends and family.
21 Q. -- where -- where you asked, I guess, her to 21 And so those things were all factored into the
22 document it, correct? 22 discussion on whether or not we should terminate.
23 A. That is correct, yes, I asked her -- I had a 23 Q. Okay. But there is no -- again, there's no
24 conversation with her sometime before that, and she 24 protocol that you know of?
25 documented. And looking at the note, it -- she's made a 25 A. In terms of the OPHPR, or the emergency

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1 note here that she talked to Dr. Gokal on the 6th, so it 1 management group, COVID response, I just don't get to
2 looks as if she talked to Gwen and Mac on the same day 2 that level of detail. I don't know. They told me there
3 and then it came straight to me right after. 3 was -- you know, there wasn't much at that particular
4 Q. To be clear, Gokal has, to your knowledge, 4 time as -- from the dates of when we started doing
5 never denied to anybody that he took these doses -- ten 5 activities on vaccine, that was day one.
6 doses off-site. To your knowledge, he's never denied 6 We were going fast and furious, and they
7 that, correct? 7 didn't give us -- "they" meaning the State and/or the
8 A. No. Yeah, as far as I know, he's never denied 8 Feds didn't give us much notice that they were about to
9 it as far as I'm aware. 9 do this at a mass scale. The planning for us was always
10 Q. He's never tried to hide that? 10 more of what you would call more safety net.
11 A. No, no. And in the conversation with him, he 11 So we thought we were going to be going
12 did keep going back to the fact that he felt he was 12 into the underserved communities and doing smaller-type
13 doing the right thing by doing it, which Mac and I -- 13 setups. We were never -- thought we were going to be
14 you know, we're not necessarily disagreeing that -- that 14 doing these massive scale sites. And so there was
15 they shouldn't have been vaccinated. It was just how it 15 some -- in an emergency, they operated as such and they
16 got to that point without asking, without -- at least as 16 set it up the best they could.
17 it was reported to me, without asking, we would have had 17 Did they go back and write policies and
18 a different protocol than going house to house at that 18 procedures, I don't know. I wasn't a part of that
19 point because we didn't have the capability of doing 19 process. I was just the HR unit lead in dealing with
20 that. 20 the people problems of the response.
21 Q. Okay. Well, let me ask you this: Would it 21 Q. So bottom line, at least as it existed on
22 have made a difference to you if he had picked -- and, 22 December 29th, 2020, there were no protocols that you
23 by the way, he's always been consistent, as far as you 23 knew of?
24 know, that it was ten doses? 24 MS. REA: Objection, form.
25 A. Yes, I would agree with that because I have no 25 A. Yeah, I wasn't in that group, so I don't know

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1 what they had or what discussions they had or what 1 doesn't correct me on anything.
2 meetings they had. I'm not aware of them, but I'm not 2 I gave him three opportunities to tell me
3 an expert in that area either. 3 something different, and to some degree, I was hoping he
4 Q. (BY MR. AHMAD) And I asked you a hypothetical 4 was going to tell me something different because it
5 if it makes a difference. Do you know if the ultimate 5 didn't seem possible that someone in his position would
6 decision would have changed if it had been Caucasian 6 take something that wasn't his and -- and give it to
7 people, or is that a hypothetical that's hard to figure 7 friends and family in that particular situation.
8 out right now? 8 THE COURT REPORTER: Can we take a break?
9 A. Oh, that's -- 9 MR. AHMAD: Yes, we can take a break.
10 MS. REA: Objection, form. 10 THE VIDEOGRAPHER: We're off record. Time
11 A. -- definitely a hypothetical. I'm not sure I 11 is 3:38 p.m.
12 could answer that. I mean, I know in the conversation, 12 (Short recess.)
13 it wasn't so much about ethnicity as it was about 13 THE VIDEOGRAPHER: We're back on record.
14 friends and family and the fact that he had taken it in 14 Time is 4:07 p.m.
15 the night, put it in a backpack, not sure about 15 Q. (BY MR. AHMAD) Okay. Mr. Anderson, if we can
16 temperature control, not sure about safety protocols, 16 go to Exhibit 2. Go to your timeline if you know where
17 not sure about patient protocols. That was the concern 17 that is again. I think we were just talking about it.
18 and . . . 18 A. Okay. I'm there.
19 Q. (BY MR. AHMAD) But when you confronted 19 Q. Okay. And if you go to January 6, 5:43 p.m.
20 Dr. Gokal, did you ask him about the temperature? 20 A. 5:43 p.m. yes.
21 A. I didn't because at that point, it wasn't -- I 21 Q. And it says: "Ed Anderson receives a call from
22 mean, it was too late. I mean, it is what it was at 22 Bobbie Risner, CAO."
23 that point. He had admitted to doing it. The trust 23 Do you see that?
24 factor was gone. We didn't feel -- "we," meaning the 24 A. I do see that, yes.
25 leadership team, didn't feel that he could continue on 25 Q. CAO is County attorney's office?

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1 and that they could trust him in that role. 1 A. Yes.
2 Q. And I just want to make sure we've got 2 Q. Why did you get a call from Bobbie Risner?
3 everything he admitted to. He admitted, you're saying, 3 A. So I don't really remember why I got a call
4 that he took it off-site for friends and family? 4 from Bobbie. Bobbie was my primary HR contract for the
5 A. He admitted to that part, yes. 5 attorney's office. So I'm not sure if she had gotten
6 Q. Did he admit to anything else? 6 called -- oh, I do remember. I'm sorry. Let me go back
7 A. The way I phrased it to him was the -- the 7 to state that.
8 overall event, so it was -- what he -- what he clarified 8 I believe what happened was Marva Gay, who
9 to me by saying, yes, he did all those things, it was he 9 was mentioned earlier in -- I don't remember which page,
10 took the vaccine off-site. He didn't ask anyone if he 10 she was the County attorney who was -- I think it's in
11 could do it. He put it in a backpack. He drove across 11 here somewhere, but I don't know now. Marva Gay was the
12 town, multiple counties, and gave it after hours to 12 County attorney assigned to Public Health for general
13 friends and family. 13 legal. I think she called Bobbie Risner because this
14 Q. And what were the -- you said he drove through 14 wasn't -- it was an employment issue and Bobbie was the
15 multiple counties. As far as I know, it went from 15 County attorney's representative for HR, which meant she
16 Harris to Fort Bend. Was there any county involved? 16 would have been responsible for HR issues. So Marva
17 A. I didn't really track it. It was just the fact 17 looped Bobbie in, so Bobbie then called me.
18 that it -- it definitely went across town, I guess. 18 Q. Okay. And it says -- next line says:
19 Q. Okay. And -- and to be clear, did he tell you 19 "Discussed DA and possible theft."
20 he didn't talk to anybody? 20 Do you see that?
21 A. When I made that statement, I gave him the 21 A. I do.
22 opportunity to correct me. So I ran through the 22 Q. What is DA?
23 scenario with him as to what was claimed, ran through 23 A. District attorney.
24 the scenario with he took the vaccine, backpack, drove 24 So this is how I would have gotten first --
25 it across town, gave it to friends and family. He 25 somewhat first notice of the district attorney's office

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1 doing investigation, possibly going to the district 1 A. That's probably pretty close --
2 attorney's office and then doing something with it. 2 Q. Okay.
3 Q. Does this refresh your recollection as to who 3 A. -- probably.
4 contacted the district attorney's office? 4 Q. Okay. I just wondered if -- if you knew.
5 A. My assumption -- well, I shouldn't say 5 A. It's the emergency planning group. That would
6 assumption. I don't know because Marva -- I know in 6 have been the Mac -- that would have been the group that
7 this situation, Marva called Bobbie to discuss that it 7 Mac McClendon was over. I'm sure we could probably look
8 was an employment-related issue. I don't know how the 8 up the Harris County Public Health's website right now
9 DA's office got involved. I don't know, because there's 9 and it probably actually defines it on there. But I
10 not a normal transition of contact between the County 10 cannot remember off the top of my head exactly the
11 attorney's office and the DA. 11 acronym now.
12 I just don't have enough experience to know 12 Q. And January 6 after 7:00 p.m. --
13 who would have been the one contacting the DA's office, 13 A. Uh-huh. I see it.
14 but I do know that Bobbie called me because Marva had 14 Q. -- it says -- yeah, it says: "A meeting invite
15 looped her in on the issue. 15 was sent to Mac McClendon, Jennifer Kiger, and Dr. Gokal
16 Q. Okay. 16 to discuss staffing issues."
17 A. And I should clarify too they asked me 17 A. Yes, I see that. Was there something
18 specifically, which you can see in the next line, which 18 directly -- question on that one?
19 is how much -- they wanted to know how much the vaccine 19 Q. Was it accurate to say staffing issues, or was
20 would have cost, like a value to it. I didn't have that 20 that just what was put down so as not to make Gokal
21 knowledge firsthand. I had to make phone calls. But 21 suspicious?
22 that was directly related to the mention that they had 22 A. It would be the latter. So it was a -- I
23 of possible theft. 23 needed to set up a meeting, and I didn't really want
24 Q. But the County didn't actually pay for the 24 Dr. Gokal to know exactly what that was at that point.
25 vials, did they? 25 Now, I did explain that to him when he got

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1 A. I don't really know the relationship. I know 1 into the room that the meeting was not that, that it was
2 they came -- as we mentioned before in the previous 2 to discuss these allegations. Sometimes I do that to
3 questions regarding the State of Texas, I know we got 3 try to make it less stressful for the individual.
4 them from the State of Texas. But I don't know what 4 There's nothing worse than knowing 8 to 12 hours before
5 that relationship was. I don't know. 5 coming in knowing that you're going to have to talk
6 Q. Okay. And then we go down -- and we talked 6 about a situation that may be difficult. So I didn't
7 about this before, summary. Do you see that? 7 want to put necessarily any undue stress on him.
8 A. Yeah, the summary. 8 Q. Okay. But it also didn't allow him to prepare,
9 Q. What does OPHRP stand for? 9 I assume?
10 A. Sure. Acronym -- sorry for using acronyms. 10 A. I mean, you could say that, but I don't -- you
11 Q. I think I know what it stands for, but -- 11 know, in terms of the way the meeting was going to go,
12 A. That's okay. 12 I'm not sure there would have been much to prepare for.
13 Q. -- I'd rather make sure. 13 Q. Okay. January 7th, 9:00 a.m.
14 A. Sure. For the record, it's the office of 14 A. Uh-huh. I see it.
15 planning -- now I can't remember. I started it off. 15 Q. "HR training room not available. Changed
16 I'm sorry. Office of planning -- I actually can't 16 meeting to Ed Anderson's office." And it says at the
17 remember. I'm sorry. I've been away from Public 17 end: "Mac and Ed discussed he may know we are going to
18 Health. 18 terminate."
19 It's -- basically in a nutshell, it's our 19 What led you to believe he may know we were
20 emergency preparedness group. They went by the term 20 going to terminate? Is it just because he responds that
21 OPHPR. And it does mean something in terms of emergency 21 he's working from home?
22 planning, but I can't remember. 22 A. Yeah, it was just kind of an abrupt all of a
23 Q. Okay. And I would have guessed wrong, 23 sudden he was going to be working from home. He was
24 actually. For some reason, I thought it was like office 24 originally scheduled to come into the office.
25 public health response preparedness. 25 Q. Okay. Do you have any reason to believe that

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1 he actually knew? 1 A. It's -- not exactly. I mean, I did explain to
2 A. I don't. It was just a thought based on the 2 Dr. Gokal that we were not there to discuss the County
3 fact that he made an all -- you know, a quick decision 3 attorney's -- the invitation that I had sent regarding
4 change to work from home. 4 the County attorney's investigation, and then I pretty
5 Q. Okay. 5 much went straight into the employee charges and so on.
6 A. It happens before a lot of times when people 6 Q. And then it looks like the next paragraph is
7 have to meet with HR, it's -- they try to avoid it. 7 what Dr. Gokal says in response?
8 Q. Okay. But you don't -- you wouldn't dispute 8 A. No. It's actually -- so I phrased -- again,
9 that he didn't know? 9 like we talked about in the previous questions, I walked
10 A. I didn't know for sure if he knew or not. It 10 through the scenario of what the employee claimed. So I
11 was just a -- at that point, it was just a -- a guess. 11 walked through the taking the vaccine off-site, putting
12 Q. And then at 9:30, it looks like you send a 12 it in a backpack, driving to Sugar Land, injecting
13 meeting request for the same afternoon. And it says: 13 friends and family.
14 "Tried to get him to the office by saying County 14 And then I asked -- as you can see, I asked
15 attorney's office needed to talk to him about being a 15 if he says -- has anything to say, and he just basically
16 witness in a CAO investigation about M. Schaffer." 16 said, yeah, that's what I did. I took -- I took the
17 A. I see that. Is there -- is there a question 17 vaccine and did those things.
18 for that one? 18 Q. Where is the part about putting it in a
19 Q. Yeah. I mean -- 19 backpack and -- and --
20 A. Okay. 20 A. It's in here if you look at the second
21 Q. -- I'm assuming you said that not because it's 21 paragraph. It specifically says -- line 2 on that same
22 true, but because you didn't want to tip him off? 22 page. "He said he took the vial and the forms in his
23 A. That's -- yes, that's accurate, I was using the 23 backpack and drove them back near his home in Sugar
24 investigation that I knew a little bit about. I think 24 Land."
25 we referred to it in previous testimony that they were 25 Q. Well, yeah, except that's not really what I'm

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1 investigating. That's Michael Schaffer is who that is. 1 asking. That's what he said. Where did you say that
2 Q. But, in fact, that's not actually -- 2 that was the accusation against him?
3 A. No. 3 A. Well, this isn't -- as we were talking about
4 Q. -- why you were meeting with Dr. Gokal? 4 before, this is my summary. It isn't word for word
5 A. That's correct. I was not meeting with him 5 exactly what was said. I started the meeting by running
6 because of that, but I did need a reason to get him in 6 through the scenario of what was told to us, and so I
7 the office face to face because, one, I didn't want to 7 mentioned the backpack to begin with.
8 give him -- I didn't want him -- I needed to talk to him 8 Q. Okay.
9 that day, and I wanted to talk to him in person. It was 9 A. And he further mentions it as he responds back
10 not something that I would have done from working from 10 to -- when I gave him the chance to say something, he
11 home. It's too serious to do that. 11 mentions it as well.
12 Q. Now, going to the next page, January 7th, 2021. 12 Q. Who told you that he put it in a backpack?
13 A. Okay. 13 A. It may have been in the conversation with
14 Q. And it says you meet to discuss the 14 Alison, but at this point, I'm -- I'd have to go back
15 investigation. I'm paraphrasing, of course. 15 and look at that documentation to -- to show for sure.
16 Ed presents the situation and the 16 Q. Do you see it anywhere?
17 investigation findings. "It was reported that Dr. Gokal 17 A. I mean, looking at the page where I documented
18 took a partial vial of Moderna COVID vaccine from Lyons 18 that he said he took the vial and put it in his
19 Park on December 29, 2020, injected in at least ten 19 backpack. So that would be my documentation that it
20 friends and family members, and turned in signed 20 came up somewhere, but I can't point to a particular
21 registration forms." And it says: "Ed asked Dr. Gokal 21 page.
22 if he has anything to say for himself." 22 Q. Well, I mean, I just want to make sure we're
23 Is that accurate so far? 23 clear because you're saying that that was part of the
24 A. Yes. 24 accusations against him and -- but what I'm reading here
25 Q. That's how the meeting started? 25 is the accusation was -- and you say: "It was reported

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1 that Gokal took a partial vial of Moderna COVID vaccine 1 don't -- I don't have quotes to say Ed said this,
2 from Lyons Park on 12-29-2020, injected at least ten 2 Dr. Gokal said that, Mac said this.
3 friends and family members, and turned in signed 3 At any point prior to that, I don't know if
4 registration forms." And then you write down: "Ed asks 4 I mentioned backpack or not at this point. I mean, it
5 Dr. Gokal if he has anything to say for himself." 5 was -- it's been a while since we were in that room, and
6 At which point in time, you say: 6 that's why I'm using this document as -- that's why I
7 "Dr. Gokal admits that he took one vial of Moderna 7 created this document for myself.
8 vaccine that had one dose used." And then: "He said he 8 Q. Okay. And I'm just trying to find out --
9 took the vial in -- forms in his backpack and drove them 9 A. Yeah.
10 back near his home in Sugar Land, Texas." 10 Q. -- sitting here today, do you remember anything
11 But where did -- where did you get this 11 else that you told him about the investigation findings
12 idea prior to Dr. Gokal saying that? 12 other than what you wrote in the following sentence
13 A. That part, I can't tell you at this point. I 13 starting with "it was reported that Dr. Gokal took a
14 mean, it really -- honestly, it really doesn't matter 14 partial vial of Moderna COVID vaccine"? Anything that
15 where he put the vial. Backpack, box, pocket. I -- I 15 you can remember, sitting here today, that you told him
16 can't say. 16 about the investigation findings?
17 But that to me wasn't important. It was 17 A. At that point of the conversation, I don't
18 more so the fact that he took it off-site. You know, 18 remember anything else. But I did not document it word
19 whether he mentions it to me at that point, you know, 19 for word, so I -- I can't say that I remember it or not.
20 after that discussion, you know, it was always referred 20 I mean, yeah, I can't -- I can't say it because I don't
21 to as backpack after that, so . . . 21 have a record of the exact conversation.
22 Prior to that, it wouldn't have mattered. 22 Q. Is this what you have written here notated
23 I wouldn't have cared where he had it, so . . . 23 December 7th, 2021, at 12:15 p.m., is this your best
24 Q. Okay. So you're not sure whether you know it 24 recollection of what happened during that termination
25 before Dr. Gokal told you or not? 25 meeting?

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1 A. I can't say it at this point. No, I don't 1 A. It is my best recollection of the summary
2 know. 2 because again, like I said, I wasn't putting word for
3 Q. Okay. 3 word exactly what people said. This was my account of
4 A. And I may have picked it up from his 4 the summary of that meeting.
5 conversation because that's the terminology I've used 5 Q. Okay. Well, I don't want to confine it to
6 pretty much since. So after this -- after the part 6 summary. Is this the best recollection you have,
7 where Gokal mentions it, that is the verbiage that I've 7 sitting here today, of what occurred during that
8 used. I used it two more times in that meeting as 8 termination meeting?
9 backpack, and then when we went back to his office, it 9 A. I can't say it's the best recollection. It's
10 was -- he pulled out a backpack. 10 what I documented to help me remember the conversation.
11 Q. Okay. Well, I just -- again, I want to be very 11 Q. Is there anything that you remember, sitting
12 clear. 12 here today, that is not in this time entry of
13 A. Sure. Fair enough. 13 December 7th, 2021, 12:15 p.m.?
14 Q. When you were giving him the investigation 14 A. I'd have to review it. I haven't looked at
15 findings, you have written down: "It was reported that 15 this since right after he was terminated, so . . .
16 Dr. Gokal took a partial vial of Moderna COVID vaccine 16 Q. Please do.
17 from Lyons Park on December 29, 2020, injected in at 17 A. Okay.
18 least ten friends and family members, and turned in 18 Q. It's -- it's less than a page.
19 signed registration forms." 19 A. Sure.
20 Did you tell him about any other 20 After reading it, I mean, it's -- again,
21 investigation findings other than what you have written 21 it's a summary. I mean, it doesn't go into detail about
22 in this paragraph? 22 the conversation that I had with Dr. Gokal when he
23 A. This paragraph was a summary, and it was 23 mentions the media -- going to the media. So there's a
24 intended for me to help me remember parts of that day. 24 few things that are -- like I said, it's not step by
25 This is not verbatim of exactly who said what. I 25 step, word for word exactly what we discussed.

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1 Q. Okay. 1 help me remember. It was not a word for word of the
2 A. It doesn't mention that I gave him three -- I 2 details of that meeting. I would never take detailed
3 reiterated the scenario three different times to give 3 notes as to he said, she said like a script. That's not
4 him more of a chance to tell me something different, so 4 how investigations and notes go --
5 it doesn't have that in there either. 5 Q. Okay.
6 Q. Okay. 6 A. -- from the HR perspective.
7 A. But it is overall a summary of the events that 7 Q. Okay. So I'll ask you again. When you
8 happened in the meeting. 8 repeated it -- twice you say now -- did you repeat it
9 Q. Okay. Well, I -- yeah, you keep saying 9 any differently than is reported in the first paragraph
10 "summary," but I'm just trying to find out is there 10 of the entry on January 7th at 12:15 p.m.?
11 anything that occurred that's not written in this time 11 A. So I think I just answered that question, but
12 entry. And you've told me that he -- he said he was 12 I'll answer it again is that once Dr. Gokal gave me more
13 going to go to the media, correct? 13 details as to the vials and the forms in his backpack, I
14 A. He mentioned that he might go to the media. 14 used some of that information in addition to the
15 Q. Which is not in here? 15 employee complaint to make sure that I understood the
16 A. That is correct, yes. 16 full picture as to what it was he did and to make sure
17 Q. It's not in any document? 17 he had a chance to tell us anything else.
18 A. I have it documented somewhere because I've 18 Q. Okay. So you added the part about the
19 mentioned it to multiple people. It may be in my email 19 backpack?
20 that's not included here, but I don't have access to any 20 A. After he told me about the backpack, yes.
21 of those files anymore. 21 Q. And then him driving back near his home to
22 Q. Okay. But you remember it, sitting here today? 22 Sugar Land, injecting them into his mom and his -- her
23 A. Oh, yeah, I mean, Mac and I had a conversation 23 friends, added the part maybe about drove from house to
24 about it after as well, and I had a conversation with 24 house as all these individuals were older and either
25 Gwen about it as well. 25 bedridden and unable to get to a vaccine site and that

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1 Q. Okay. And you also said you repeated the 1 he needed to get the vaccine into arms since it was
2 allegations against him three times? 2 about to expire in five -- five hours.
3 A. It was three times. Yes. 3 Is there --
4 Q. And the allegation, is it the same as what's in 4 A. I'm sorry.
5 the first paragraph? 5 Q. Is there anything else that you added the
6 A. It is probably closer to more of the detail as 6 second time before terminating him?
7 to after he admitted the detail of the forms and the 7 A. I mean, I took the components of what he said,
8 vial in his backpack. I went back to make sure that we 8 because obviously he had gave us more detail than what
9 were understanding exactly what it was that he did and 9 we originally had because we assumed it was friends and
10 giving him the opportunity to tell us something 10 family. We didn't know for sure.
11 different, because in the paragraphs after, then I -- I 11 We knew that he drove across town, but we
12 pull out the termination, and after the termination, we 12 didn't know the process of the house to house
13 do have discussions regarding why he shouldn't have done 13 necessarily. So he validated those things. So I used
14 it the way he did it. 14 the original complaint and then the detail that he
15 Q. Okay. Well, I want to -- again, I want to make 15 provided to make sure that it was -- it was what he was
16 it very clear. Did you give him three opportunities 16 telling us, and then also to give him a chance to give
17 prior to proceeding with the termination, or did you 17 us any additional information.
18 give him some of those opportunities after you gave him 18 Q. Okay. So when you gave him two chances to
19 the termination letter? 19 explain himself or when you asked if he had anything to
20 A. There was at least two times prior to the 20 say for himself, everything you told him would have been
21 termination. 21 contained in paragraphs 1 and 2 of the time entry on
22 Q. Okay. You don't mention that here? 22 January 7th, 2021, at 12:15 p.m.?
23 A. That's correct, yeah, this is -- 23 A. Prior to the termination, yes.
24 Q. But you remember it? 24 Q. Okay. And so the part -- it looks like the
25 A. -- again this is a summary of what happened to 25 part about him going to incident command was after

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1 giving him the termination letter? 1 responsibility to know. So at that point, again, I was
2 A. The -- the instruction as to whether -- what he 2 dealing with the people and not the vaccine itself.
3 should have done -- 3 Q. Okay. I want to play a little bit more of
4 Q. Yes, where it says he should have contacted 4 the -- the recording that the -- that the district
5 incident command. 5 attorney's office did.
6 A. Yes, that was -- we were -- we were -- 6 MR. AHMAD: If you can go ahead and play
7 Dr. Gokal was having a difficult time understanding what 7 that.
8 he did wrong. He felt that what he did was right, and 8 Q. (BY MR. AHMAD) It goes on for a few minutes,
9 so we were trying to provide him some information as to 9 so just bear with us.
10 what should have happened but didn't. 10 (Audio playing.)
11 Q. And this was after you gave him the termination 11 Q. (BY MR. AHMAD) And was that your voice
12 letter? 12 answering those questions from the district attorney's
13 A. That's correct, yeah. 13 office?
14 Q. Okay. And then if we go to the next entry on 14 A. Yeah, that was me talking, yes.
15 12:45 p.m., it looks like you're telling Mac McClendon 15 Q. Okay. I'm going to hand you two exhibits.
16 that you will get with Dr. Onyiego to complete the Texas 16 (Exhibits 5 and 6 marked.)
17 Medical Board complaint about Dr. Gokal? 17 Q. (BY MR. AHMAD) Exhibits 5 and 6. I think 5 is
18 A. Yes, that's correct. We were just talking 18 on top, 6 is on the bottom.
19 about next steps. We had previously had a discussion 19 Exhibit 5 looks to be titled Dr. Gokal
20 that if the allegations were true and that Dr. Gokal had 20 Investigation Summary. It says at the bottom reported
21 done what he had -- what was claimed, that we would be 21 by you; is that correct?
22 filling out a medical board submission and that it would 22 A. Yeah, these are draft documents of things I was
23 be me that was doing it. So I was just verifying with 23 putting together, yes.
24 Mac to make sure he understood that that was my next 24 Q. And it looks like Exhibit 5 is dated
25 step. 25 January 8th of 2021; is that correct?

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1 Q. Okay. And then it looks like at the end of 1 A. Yes.
2 your timeline, you signed and wrote your name and dated 2 Q. And Exhibit 6 says at the top that it's dated
3 it. Is that -- is that your signature at the end? 3 January 8th, 2021. But it looks like it has some
4 A. That is my signature, yes. 4 changes. I notice at the top, while it's still titled
5 Q. Did you know the definition of groups 1a and 1b 5 Dr. Gokal Investigation Summary, it has under that:
6 in terms of priority groups as of December 29th, 2020? 6 "Dr. Hasan Gokal. Hire date: April 13th, 2019."
7 A. No. I think you asked that question earlier 7 And Exhibit 6, which is not on Exhibit 5,
8 today, and it's the same answer that I would have for 8 the issue seems to be a little bit longer, and there's
9 that is I'm not an expert on any of that stuff, and I 9 also an addendum at the bottom with an entry from
10 would have had no reason to know what those groups were. 10 February 5th, 2021.
11 I knew I wasn't in them personally, so it didn't -- 11 So I'm guessing Exhibit 6 was done after --
12 other than that, I would have never looked at those 12 on or after February 5th, 2021; is that correct?
13 things. 13 A. These were both draft documents, so I'm not
14 Q. And you weren't aware of any plan for unused 14 sure I know -- there was a final one. The one Exhibit 6
15 vaccines that the site may have had at the end of the 15 was started on the 8th, but there was additional
16 day? 16 information that was included. Obviously dated
17 A. So I was in a lot of the planning calls on all 17 February 5th because I've made a record of that. But
18 of COVID because there was usually a human component to 18 neither -- these were just living and breathing
19 it. Did I hear things about vaccine unused? Yes, I've 19 documents that I was -- I was using as a part of what
20 heard things on those calls. But was I part of that? 20 they were asking me to report as an executive summary.
21 Not -- I mean, no. So I don't have detailed knowledge 21 See, usually after an investigation, I'll
22 of anything to do with the waste. 22 do an executive summary and submit it. I don't know if
23 Q. You don't know what the plan was for unused 23 either the two of these were submitted, because there's
24 vaccines at the end of the day? 24 no initial or signature. I have my name, but normally
25 A. I don't. And it wouldn't have been my 25 at the end, I will either initial or sign off like I did

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1 on the other summary document. So, yeah, that's -- 1 A. Uh-huh.
2 that's what I know about those two. 2 Q. Yes?
3 Q. Okay. Exhibits 5 and 6 were written by you; is 3 A. Yes, it is.
4 that correct? 4 Q. Okay. Did you write the termination letter to
5 A. I haven't read them specifically, but I know 5 Dr. Gokal?
6 that I started typing them. But without an initial or a 6 A. Yes, I did, as I would have pretty much all the
7 signature, I can't tell you that these are my documents. 7 termination letters.
8 Q. Do you know anybody else that would have 8 Q. Okay. Have you handled on behalf of the County
9 written this? 9 any EEOC complaints made against the County or any
10 A. For all intents and purposes, sir, it could 10 County employees or officials?
11 have been you. I mean, without having an initial on it, 11 A. I mean, I want to say there were a couple
12 I don't know who wrote these documents. I mean, they 12 during my tenure that I was there. But I can't tell you
13 were documents that I was working on, but were they 13 how many or specifically names right this second.
14 finished and did people change them? I don't know. I'm 14 Q. Did you work on any EEOC --
15 no longer with the County anymore. I don't have access 15 A. I have worked on EEOC complaints before, yes.
16 to any of those forms. 16 Q. Okay.
17 Q. Well, it says: "Report by Edward H. Anderson," 17 A. For the County.
18 correct? 18 Q. Are there sometimes internal discrimination
19 A. Correct. But as you know with a computer, 19 complaints that don't get reported to the EEOC?
20 anyone could type anything at any point and put my name 20 A. Well, I don't know because from an EEOC
21 on it. 21 standpoint, it has to be the individual or the employee
22 Q. Well, I mean, Exhibits 5 and 6 are one-page 22 or former employee who files the EEOC claim, so I
23 documents? 23 wouldn't know who or -- who did or didn't file
24 A. Uh-huh. 24 complaints.
25 Q. Is there anything you see that you didn't 25 Q. Is there an internal process for complaining

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1 write? 1 about discrimination?
2 A. I mean, I would love to read both of the two of 2 A. There's an internal process for complaining
3 them and I could tell you probably for sure. 3 about everything, anything.
4 Q. Please do. 4 Q. Okay. And have people used that internal
5 A. (Witness reading.) 5 process to complain about discrimination?
6 Okay. 6 A. I can't remember specifically. I mean, there's
7 Q. Okay. Did you write Exhibits 5 and 6? 7 been internal complaints, but I don't remember
8 A. It looks like content that I probably wrote. I 8 specifics. I don't.
9 definitely will say that Exhibit 5 was a draft because I 9 Q. Can you remember any discrimination complaints
10 started it. 10 using this internal process at the County?
11 Exhibit 6 looks closer to final, but I 11 A. There probably were, but I can't remember any
12 can't say that it's final final without a signature, but 12 specifically.
13 the content looks accurate. 13 Q. Okay. Has your -- has there been -- has there
14 Q. Okay. And then I'll tell you one document that 14 ever been an instance where somebody complained against
15 I think does have your signature on it. If you go to 15 you for discrimination?
16 Exhibit 2. After your timeline -- I think we finished 16 A. Not that I'm aware of.
17 with your timeline, which has your signature. And then 17 Q. To your knowledge, nobody in your career has
18 you'll see a letter to Dr. Gokal dated January 7, 2021? 18 complained that you discriminated in any way?
19 A. Yes, the termination letter? 19 A. Not that I'm aware of.
20 Q. Yes. 20 Q. Are you aware of any discrimination complaints
21 A. Yes. 21 against Jennifer Kiger?
22 Q. Dated January 7, 2021? 22 A. Not that I'm aware of.
23 A. Yes. 23 Q. Against Mac McClendon?
24 Q. And that's your signature at the bottom of that 24 A. Not that I'm aware of.
25 letter to Dr. Gokal? 25 Q. And to be clear, I'm not just -- that question

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1 doesn't pertain to actual EEOC complaints. It's any -- 1 Q. What does that mean?
2 A. Right, any complaint. 2 A. That meant for every dollar that the employee
3 Q. -- any formal complaint involving any type of 3 put into the plan, they would get 225 percent matching.
4 discrimination. 4 So $2.25.
5 A. I don't remember any complaints on Mac and 5 Q. And when would the employee typically vest?
6 Jennifer regarding discrimination, no. 6 A. I believe, unless something's changed,
7 Q. And any informal complaints against you? 7 obviously I'm not an employee anymore, I think it was at
8 A. Not that I'm aware of. 8 eight years for 100 percent vested.
9 Q. Ever? 9 Q. Okay. And did it vest partially before then?
10 A. Never. That I'm aware of. I mean, not that 10 A. No. Again, I'm not the benefits person. I
11 I'm aware of. 11 don't know the plan design details, but I don't believe
12 Q. Okay. 12 it did.
13 (Exhibit 7 marked.) 13 Q. So the best -- to the best of your knowledge,
14 Q. (BY MR. AHMAD) I'm handing you what's been 14 it was 100 percent at eight years and nothing before
15 marked as Exhibit 13. 15 then?
16 THE COURT REPORTER: 7. 16 A. I believe that's how the plan was, yes. Now,
17 Q. (BY MR. AHMAD) Oh, I'm sorry. 7. 17 there was differences on the length that you stayed with
18 Do you recognize that document? 18 the County regarding if you got County-paid benefits at
19 A. Actually, I don't. It looks like it might have 19 100 percent after retirement, but I don't know the
20 been something printed off of our website. 20 details on most of those plans because I wasn't
21 Q. Were you aware that Harris County Public Health 21 responsible for them.
22 employees got certain benefits? 22 Q. Did you vest in the -- in the pension plan?
23 A. Well, yes, I mean, I was an employee, so I got 23 A. No, I was a little over six years.
24 benefits, yes. 24 Q. Less than eight?
25 Q. Okay. In other words, did they get their 25 A. Definitely less than eight, yes.

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1 health insurance paid? 1 Q. Okay. I think we talked earlier about there
2 A. For the employee, yes, it was paid at 2 was some investigation involving Matt Schaffer; is that
3 100 percent. 3 correct?
4 Q. Dental was 100 percent employer paid? 4 A. It would be Michael Schaffer.
5 A. I am not an employee anymore, so I don't -- I 5 Q. Oh, I'm sorry. Michael --
6 mean, I don't remember dental specifically. 6 A. That's okay.
7 Q. Vision, 100 percent? 7 Q. -- Schaffer.
8 A. I don't remember. 8 Do you know what that was about?
9 Q. Disability, do you remember there being 9 A. The one I referred to earlier, I really don't
10 disability insurance? 10 have any details. I -- I believe that it came through a
11 A. I mean, I vaguely remember that it was there. 11 fraud, waste, and abuse complaint through the County.
12 I can't remember if it was paid by the employer or not. 12 That was a new program that the County had in place for
13 Q. Life insurance, do you remember that? 13 maybe up to a year at that point. But they didn't turn
14 A. I remember it existed, but I don't know 14 over those investigations to the local HR department.
15 details. I should also say that although I was head of 15 And when I say "local," those were
16 HR, benefits administration was all handled by the 16 handled -- each division or department within the County
17 benefits department within HRRM. 17 has their own structure for HR, and so they would
18 Q. Was there ever a retiree life insurance? 18 typically keep those at either HRRM or I believe the
19 A. I didn't administer those plans. I think there 19 County attorney's office.
20 was, but I don't know details on it. 20 Q. And do you know who made the complaint about
21 Q. Was there a pension plan? 21 Michael Schaffer?
22 A. There was a pension plan, yes. 22 A. I have no details on the Michael Schaffer at
23 Q. It looks like on page 2 of Exhibit 13 [sic], it 23 all. I do know there was a complaint because there was
24 says it's a 225 percent match? 24 an investigation. I did get some -- I got some
25 A. That's correct, yeah, it was. 25 indication that there was an investigation because they

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1 were looking for some -- some of the employees to speak 1 A. He was a public health employee.
2 with as to what their roles were and would they be able 2 Q. What was his position?
3 to talk, but other than that, I never got any additional 3 A. He was division director for environmental
4 information on the Michael Schaffer investigation. 4 public health.
5 Q. Did you do the investigation? 5 Q. Okay.
6 A. On the County attorney's, no. 6 A. That was his primary role. And then during
7 Q. On -- on Michael Schaffer. Did you do any part 7 COVID, he held a bunch of different titles for our COVID
8 of the investigation? 8 response while he was still the division director for
9 A. Which -- which investigation are you referring 9 environmental public health.
10 to regarding Michael? 10 Q. Do you know any public health employee, other
11 Q. Oh, were there more than one? 11 than Dr. Gokal, who was referred to the district
12 A. There was more than one. 12 attorney's office?
13 Q. Okay. 13 A. Specifically for Public Health?
14 A. There was one three years ago. It was an 14 Q. Yes.
15 internal one that I handled, and then the one I've 15 A. No.
16 referred to a couple of times in the statements has been 16 Q. I mean, Dr. Gokal was specifically Public
17 the County attorneys, which was handled outside of 17 Health, correct?
18 Public Health's HR, which would be me. 18 A. Yes, he was. And I'm sorry, I should have
19 Q. Do you know what he was alleged to have 19 clarified that answer. I wasn't involved in really
20 defrauded or wasted? 20 district attorney stuff at all, but the only one I knew
21 A. No, no, that's -- they didn't give me any 21 about would have been Dr. Gokal's situation.
22 details on what the complaint was. I'm not -- I don't 22 Q. Do you know anybody -- any Public Health
23 know if it was fraud, waste, abuse, or something else. 23 employee that was ever prosecuted by the district
24 What we did find is that there were some 24 attorney's office other than Dr. Gokal?
25 reports of employees using it for just regular, like, 25 A. Not that I'm aware of, no.

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1 complaints. 1 Q. Okay. I have one more tape. And I think we'll
2 Q. Using what? 2 be at 5:00 o'clock.
3 A. Using the fraud, waste, and abuse hotline. So 3 (Audio playing.)
4 they created this hotline to allow employees to complain 4 Q. (BY MR. AHMAD) Okay. And that was your voice
5 anonymous -- or file a complaint anonymously if they 5 as well, right?
6 wanted to, but there was -- from what I understand of 6 A. It was, yes.
7 the program, it wasn't just always used for fraud, 7 Q. Okay.
8 waste, and abuse. There were times when employees would 8 A. Yeah.
9 claim harassment or things like that. 9 Q. And -- and Eileen Begle would have been talking
10 If there were -- what they told me with 10 to Gokal regarding the Michael Schaffer investigation?
11 the -- with the -- with the hotline was is that if there 11 A. I don't know what investigation she was doing.
12 was a more local-based complaint like a harassment or 12 She did tell me she interviewed, and that -- that
13 unfair practices in the workplace, they would kick that 13 obviously helped me because I forgot about that part of
14 to the local HR team, which would have been my team. If 14 the conversation with Eileen.
15 it was something fraud, waste, and abuse, they kept the 15 I believe she was interviewing him for
16 investigation themselves, so . . . 16 the -- for the Michael Schaffer investigation. That's
17 Q. The County attorney's office did? 17 what she alluded to on the phone, but like you heard in
18 A. That's what I was told, yes. 18 the recording, I didn't have much to go off of. And it
19 Q. Do you know if Schaffer was ever referred to 19 was an investigation they were handling, so I didn't
20 the district attorneys? 20 really get involved much at all.
21 A. Not while I was there. Well, I shouldn't say 21 Q. So you have no idea what she was talking about?
22 that. I don't know because I wasn't a part of that 22 She --
23 investigation, but as far as I understand in that one, I 23 A. I don't.
24 don't think he was, but I don't know for sure. 24 Q. -- was --
25 Q. He was a public health employee? 25 A. I'm sorry. I talked over you. I apologize.

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1 MR. AHMAD: How much time do I have left? 1 SIGNATURE PAGE
2
2 Because it's 5:00 o'clock. I, Edward Anderson, have read the foregoing
3 THE COURT REPORTER: 4 hours 29 minutes. 3 deposition and hereby affix my signature that same is
true and correct, except as noted on the correction page.
4 MR. AHMAD: Okay. Well, I'm going to stop 4
5 now because I think we talked about stopping at 5
6 5:00 o'clock. ____________________________
6 EDWARD ANDERSON
7 You know, most of what I would have left, 7
8
8 frankly, it's just verifying the recording, but we can
9 THE STATE OF TEXAS )
9 talk about that now that we're off the record. COUNTY OF _____________ )
10 MS. REA: Like, in other words, just a 10
11 Before me ____________________ on this day personally
11 stipulation that that's his voice? I mean, he's said appeared EDWARD ANDERSON known to me [or proved to
12 the -- 12 me on the oath of __________________ or through
_____________________ (description of identity card or
13 THE COURT REPORTER: Should we go off? 13 other document)] to be the person whose name is subscribed
14 MS. REA: Yeah. to the foregoing instrument and acknowledged to me that
14 he/she executed the same for the purposes and
15 MR. AHMAD: Yeah, we can go off. consideration therein expressed.
16 THE VIDEOGRAPHER: We're off record. Time 15 Given under my hand and seal of office this ______
day of _______________, 2022.
17 is 5:01 p.m. 16
18 (Proceedings adjourned at 5:01 p.m.) 17
__________________________________
19 18 NOTARY PUBLIC IN AND FOR
20 THE STATE OF T E X A S
19
21 20 My Commission Expires:
22 _______________________
21
23 22
24 23
24
25 25 JOB NUMBER 24766

Page 206 Page 208

1 CORRECTION PAGE 1 CAUSE NO. 2021-60942
2 HASAN GOKAL § IN THE DISTRICT COURT OF
2 WITNESS NAME: EDWARD ANDERSON DATE: 09/14/2022 Plaintiff, §
3 PAGE LINE CHANGE REASON 3 §
VS. §
4 __________________________________________________________ 4 § HARRIS COUNTY, TEXAS
5 __________________________________________________________ HARRIS COUNTY, TEXAS §
5 d/b/a HARRIS COUNTY §
6 __________________________________________________________ PUBLIC HEALTH, §
6 Defendant. § 333RD JUDICIAL DISTRICT
7 __________________________________________________________ 7 REPORTER'S CERTIFICATION
8 __________________________________________________________ DEPOSITION OF EDWARD ANDERSON
8 TAKEN SEPTEMBER 14, 2022
9 __________________________________________________________ 9 I, Rene N. White, Certified Shorthand Reporter in and
10 __________________________________________________________ for the State of Texas, hereby certify to the following:
10 That the witness, Edward Anderson, was duly sworn by
11 __________________________________________________________ the officer and that the transcript of the oral deposition
11 is a true record of the testimony given by the witness;
12 __________________________________________________________ That the amount of time used by each party at the
13 __________________________________________________________ 12 deposition is as follows:
13 JOSEPH Y. AHMAD - 04:29:26
14 __________________________________________________________ PAM REA - 00:00:00
14
15 __________________________________________________________
That pursuant to information given to the deposition
16 __________________________________________________________ 15 officer at the time said testimony was taken, the
following includes counsel for all parties of record:
17 __________________________________________________________ 16
18 __________________________________________________________ JOSEPH Y. AHMAD - ATTORNEY FOR PLAINTIFF
17 PAM REA - ATTORNEY FOR DEFENDANT
19 __________________________________________________________ 18 I further certify that I am neither counsel for,
20 __________________________________________________________ related to, nor employed by any of the parties in the
19 action in which this proceeding was taken, and further
21 __________________________________________________________ that I am not financially or otherwise interested in the
20 outcome of the action.
22 __________________________________________________________ Further certification requirements pursuant to Rule
23 __________________________________________________________ 21 203 of TRCP will be certified to after they have occurred.
22
24 __________________________________________________________ 23
24
25 JOB NUMBER 24766
25

52 (Pages 205 to 208)

HANNA & HANNA, INC.
713.840.8484
 EDWARD ANDERSON - 9/14/2022
Page 209
1 Certified to by me this 28th day of September, 2022.
2
3
4 _____________________________________
Rene N. White, CSR, CRR, RPR
5 CSR NO. 3070; Expiration Date: 1-31-23
6
HANNA & HANNA, INC.
7 CRF # 10434; Expires 10-31-2022
8582 Katy Freeway, Suite 105
8 Houston, Texas 77024
713-840-8484 – 713-583-2442
9
10
11
12
13
14
15
16
17
18
19
20
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22
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Page 210
1 FURTHER CERTIFICATION UNDER RULE 203 TRCP
2 That the deposition transcript was submitted on
3 _________________ to the witness or to the attorney for
4 the witness for examination, signature and return to Hanna
5 & Hanna, Inc., by __________________;
6 The original deposition was/was not returned to the
7 deposition officer on __________________________;
8 If returned, the attached Changes and Signature page
9 contains any changes and the reasons therefor;
10 If returned, the original deposition was delivered to
11 JOSEPH Y. AHMAD, Custodial Attorney;
12 That $ ______________ is the deposition officer's
13 charges to Plaintiff for preparing the original deposition
14 transcript and any copies of exhibits;
15 That the deposition was delivered in accordance with
16 Rule 203.3 and that a copy of this certificate was served
17 on all parties shown herein and filed with the Clerk.
18 Certified to by me this _______ day of
19 __________________, 2022.
20
21
22 _____________________________________
HANNA & HANNA, INC.
23 CRF # 10434; Expires 10-31-2022
8582 Katy Freeway, Suite 105
24 Houston, Texas 77024
713-840-8484 – 713-583-2442
25

53 (Pages 209 to 210)

HANNA & HANNA, INC.
713.840.8484