1 IN THE UNITED STATES DISTRICT COURT

 FOR THE SOUTHERN DISTRICT OF FLORIDA

2

 MIAMI DIVISION

3

 CASE NO. 1:22-cv-24066-KMM

4

5 GRACE, INC., et al.,

6 Plaintiffs,

7 vs.

8 CITY OF MIAMI,

9 Defendant.

_______________________

10

11

12 DEPOSITION OF

13 JARED A. JOHNSON

14

15 DATE TAKEN: Wednesday, October 18, 2023

 TIME: 2:00 p.m. - 4:42 p.m.

16 PLACE: 333 S.E. 2nd Avenue

 Suite 3200

17 Miami, Florida

18

 Taken on behalf of Defendant by

19 Beatriz Valdes-Prieto, FPR, and Notary Public in

 and for the State of Florida at Large.

20

21

22

23

24

25

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1 APPEARANCES

2 On behalf of the Plaintiffs:

3 CAROLINE MCNAMARA, ESQ.

 ACLU

4 4343 West Flagler Street

 Suite 400

5 Miami, FL 33134

 cmcnamara@aclufl.org

6

7 On behalf of the Defendant:

8 GEORGE T. LEVESQUE, ESQ.

 GrayRobinson, P.A.

9 301 South Bronough Street

 Suite 600

10 Tallahassee, Florida 32301

 george.levesque@gray-robinson.com

11

12 - - - - -

13

 I N D E X

14

15 DEPOSITION OF

JARED A. JOHNSON

16

Direct Examination by Mr. Levesque 4

17 Cross-Examination by Ms. McNamara 84

Redirect Examination by Mr. Levesque 90

18

Certificate of Oath of Witness 94

19 Reporter's Certificate 95

Read Letter 96

20 Errata Sheet 97

21

22

23

24

25

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1 E X H I B I T I N D E X

2 Defendant's Description Page No.

3 Exhibit 8224 Resolution 23-271

 City's Proposed Remedy 35

4

 Exhibit 8212 Appendices 39

5

 Exhibit 77 City of Miami Commission

6 Districts Adopted

 June 14, 2023 44

7

 Exhibit 2438 Declaration of Jared

8 Johnson 46

9 Exhibit 8234 Plantiffs' Map 1 70

10 Exhibit 2480 1997 Plan 72

11 Exhibit 8235 Plaintiffs' Map 2 74

12 Exhibit 8236 Plaintiffs' Map 3 78

13 Exhibit 8237 Plaintiffs' Map 4 79

14 Exhibit 2482 2013 Plan 81

15

16

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18

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21

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1 THE COURT REPORTER: Raise your right hand,

2 please, sir, to be sworn.

3 Do you solemnly swear or affirm that the

4 testimony you are about to give will be the

5 truth, the whole truth, and nothing but the

6 truth?

7 THE WITNESS: Yes.

8 THE COURT REPORTER: Thank you, sir.

9 THEREUPON:

10 JARED JOHNSON

11 was called as a witness and, having been first

12 duly sworn remotely, was examined and testified

13 as follows:

14 DIRECT EXAMINATION

15 BY MR. LEVESQUE:

16 Q. Good afternoon, Mr. Johnson. My name is

17 George Levesque. I'm an attorney with GrayRobinson

18 and our firm represents the City of Miami in this

19 redistricting litigation. Before we get started in

20 earnest, have you ever been deposed before?

21 A. No.

22 Q. Okay. Have you ever been a plaintiff in a

23 lawsuit before?

24 A. No.

25 Q. Okay. What I'm going to do is I'm going to

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1 go over some of the ground rules first so we have a

2 good base to work from. Obviously, the format is

3 question and answer. I ask questions, you provide

4 answers. As I'm asking questions and you're nodding

5 your head, the court reporter is taking down

6 everything that we say. So I might ask a yes or no

7 question, you might nod your head or shake your head.

8 I know exactly what you mean because if we were

9 sitting in a restaurant having a beer or something

10 like that, I would know. But because she's taking

11 down everything that we say out loud, I'll need you to

12 answer audibly. I'm not always the best about it.

13 Your counsel might be better than I am about it.

14 Sometimes the court reporter is better than all of us

15 because she's the one that takes it down. So at

16 different times somebody might say, "is that a yes."

17 They're not meaning to be rude or anything. They're

18 just trying to get an accurate transcription of the

19 record.

20 One of other the things that's important

21 is, as we're having communications, sometimes in the

22 course of a communication you may know exactly where

23 I'm going with my question and you might start to

24 answer. If we're in a situation where we're both

25 talking over each other that makes the court

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1 reporter's job more challenging. So let's try to make

2 her job easier by letting me finish my question and

3 I'll do my best to let you finish answering the

4 question and try not to interrupt so that we're not

5 talking over each other. Is that fair?

6 A. Yes.

7 Q. At different times I may ask a question

8 that is confusing or a question that you don't

9 understand. Please ask me to repeat it or rephrase it

10 and I'll do the best that I can. That happened a

11 little bit in the last deposition because sometimes my

12 questions are not always the clearest questions. At

13 different times I might ask a question that might be

14 objectionable and your counsel may object. If she

15 does object, what I'd ask you to do is just allow her

16 to get her objection on the record, and then from

17 there I might ask if you understand the question, go

18 ahead and answer the question. At different times she

19 might instruct you not to answer. I can't give you

20 legal advice what to do but I might confirm whether

21 you're going to follow your counsel's instruction.

22 Are you on any medication that would impair

23 your ability to recall or testify truthfully today?

24 A. No.

25 Q. Can you please state your full name for the

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1 record?

2 A. Jared Arin Johnson.

3 Q. And how do you spell that middle name?

4 A. A-R-I-N.

5 Q. What is your current residential address?

6 A. 255 Southwest 11th Street, Apartment 1302,

7 Miami, Florida 33130.

8 Q. And how long have you lived in that

9 residence?

10 A. It's been over two years. Two years and a

11 few months.

12 Q. And roughly when did you move into that

13 residence?

14 A. I believe, July of 2021.

15 Q. Where did you live before then?

16 A. New York City.

17 Q. And what brought you down to sunny south

18 Florida?

19 A. My wife is currently attending law school

20 at the University of Miami.

21 Q. And what year is she in?

22 A. She's now in her third year.

23 Q. Okay. There's a light at the end of the

24 tunnel.

25 A. There is.

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1 Q. And how long did you live in New York City?

2 A. I lived in New York for almost five years.

3 I moved to New York in September of 2016.

4 Q. And where did you live before New York

5 City?

6 A. I lived in Arlington, Virginia.

7 Q. And how long did you live in Arlington?

8 A. I believe around, maybe, six years. I

9 think I moved there in 2010.

10 Q. Where were you born?

11 A. Alexandria, Virginia.

12 Q. Did you generally live in the Virginia area

13 from the time of your birth until the time that you

14 moved to New York?

15 A. Yes. Correct.

16 Q. Can you briefly describe your academic

17 background?

18 A. Yes. I have a bachelor of science in

19 systems engineering from the University of Virginia.

20 That's my latest amount of education acquired.

21 Q. And what do you currently do?

22 A. Self-employed as a digital product manager.

23 Q. And I honestly don't know the answer to

24 this question. What is a digital product manager?

25 A. I know. Whenever someone asks me, there's

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1 a lot of different answers. Essentially we work with

2 companies to create digital applications -- web,

3 mobile applications from like strategy through

4 development and implementation.

5 Q. Do you hold any certificates in any areas?

6 A. Nothing since graduation. I had a minor in

7 engineering -- in business, but, no, no other

8 certificates since graduation.

9 Q. And how long have you been self-employed?

10 A. Since August of 2021.

11 Q. Is that roughly around when you moved to

12 South Florida?

13 A. Yes.

14 Q. Where were you employed in New York City?

15 A. At a digital agency called Work & Co.

16 Q. And what did they do?

17 A. Web and mobile application development for

18 various clients.

19 Q. And do you currently rent an apartment?

20 A. I do.

21 Q. And do you have documentation that would

22 reflect that that is your primary residence?

23 A. Yes.

24 Q. What type of documentation would you have?

25 A. A lease -- leasing agreement.

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1 Q. And that's in your name?

2 A. Yes.

3 Q. Do you have a Florida driver's license?

4 A. Yes.

5 Q. Does it reflect that address?

6 A. Yes.

7 Q. Do you have a voter ID?

8 A. I don't know what a voter -- but they gave

9 me a piece of paper that said I --

10 Q. It's a piece of paper that tells you what

11 precinct that you vote in and --

12 A. Yes, I do. Yes.

13 Q. And do you know if -- are you registered to

14 vote at that address?

15 A. Yes.

16 Q. And have you voted in any of the elections

17 in Miami-Dade County since moving to Florida?

18 A. Yes.

19 Q. Which elections have you voted in?

20 A. I voted in the gubernatorial -- last

21 gubernatorial election.

22 Q. And that would have been the DeSantis/Crist

23 election?

24 A. Correct. Yes.

25 Q. Other than voting for the governor, did you

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1 vote for the other candidates that were on the ballot

2 in that election?

3 A. Yes.

4 Q. Did you vote for all of them?

5 A. Yes.

6 Q. And just for clarity of that question, you

7 voted in all of the races; you didn't necessarily vote

8 for all of the candidates?

9 A. I voted for all the candidates that were

10 provided on the ballot.

11 Q. How did you become -- how did you come to

12 be involved in this litigation?

13 A. It was as a member of the Engage Miami

14 organization.

15 Q. And what is Engage Miami?

16 A. It's an activism organization based here in

17 Miami, Florida.

18 Q. How did you become acquainted with Engage

19 Miami?

20 A. Upon moving to Miami I was looking for

21 organizations to get involved in both as a way of

22 meeting people and building community, as well as

23 finding people with similar interests to mine, and did

24 a Google search and found Engage and then became a

25 member.

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1 Q. And what did you have to do to become a

2 member?

3 A. I believe there was a form -- an online

4 form that I filled out that, you know, made that

5 membership official.

6 Q. And other than completing a membership

7 form, did you do anything else to become a member?

8 A. I believe I also paid an amount of money to

9 them as well.

10 Q. Did they recommend an amount or did you

11 make just a particular donation?

12 A. I can't recall if there was -- it was a

13 couple years ago so I can't recall if there was an

14 amount or not that was recommended.

15 Q. Was it a one-time payment that you made?

16 A. I do remember that there is a recurring

17 donation that I do make to the organization.

18 Q. And is that a recurring donation that you

19 make annually?

20 A. I believe it's quarterly.

21 Q. Do you recall what that is?

22 A. I believe it's $50.

23 Q. As part of your membership did you have to

24 make a pledge or affirm certain statements or

25 positions of Engage Miami?

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1 A. No.

2 Q. Did you have to attest to a certain code of

3 conduct or behavioral requirements for Engage Miami's

4 members?

5 A. No.

6 Q. Are you aware of any type of requirement

7 that would either restrict or prescribe membership if

8 someone disagrees with the positions that Engage Miami

9 takes?

10 A. Not that I'm aware of.

11 Q. And then specifically related to this

12 litigation, I think you indicated that you became

13 involved through Engage Miami?

14 A. Uh-hum.

15 Q. How did you become involved as a plaintiff?

16 A. I had a conversation with Yani who is a

17 member of Engage Miami.

18 Q. Is that Yani Valdes?

19 A. Yes.

20 Q. And do you know what her title is?

21 A. I do not know off the top of my head her

22 exact title. I know she's in the leadership of the

23 organization.

24 Q. And what was your conversation with Yani?

25 A. Just being made aware of the lawsuit and

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1 talking through whether I would like to be a member as

2 a plaintiff of the lawsuit.

3 Q. And did you speak to anyone else about the

4 decision to become a plaintiff in the lawsuit other

5 than Yani?

6 A. Probably mentioned it to my wife as well.

7 Q. And this will be true -- as much as I might

8 like to know, I don't want to know any of the

9 conversations between you and your wife or --

10 A. Sure.

11 Q. -- you or your counsel.

12 A. Okay.

13 Q. Other than your wife, and I'm assuming at

14 some point you did speak to your counsel, but other

15 than those, did you speak to anyone else other than

16 Yani related to joining this lawsuit?

17 A. No.

18 Q. And what did you -- what did she tell you

19 the lawsuit would involve?

20 A. She mentioned, from my recollection, it

21 would involve a suit against the City in regards to

22 racial gerrymandering -- racially motivated

23 gerrymandering of the commission district.

24 Q. When the City was drawing its districts in

25 2022 or in late 2021 going into 2022, you were a

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1 resident of the City at that time, correct?

2 A. That's correct.

3 Q. Did you attend any of the city commission

4 meetings?

5 A. No, I did not.

6 Q. During the 2023 period in June of this

7 year, did you attend the city commission meeting where

8 they were drawing the 2023 plan?

9 A. No.

10 Q. And when I refer to the 2022 plan, do you

11 understand that I'm referring to the plan that they --

12 the plan that they drew in 2022?

13 A. Yeah. The initial map.

14 Q. The original rewrite?

15 A. Yes.

16 Q. And then, when I refer to the 2023 plan,

17 I'm referring to the plan that passed in June of 2023.

18 A. Yes.

19 Q. What is your understanding of the history

20 of redistricting in the City of Miami?

21 A. I don't have a lot of context around the

22 history of redistricting in Miami.

23 Q. So you've not like read any books, done any

24 research as to, you know, the way pre-1997 how the

25 City used to hold its elections and then after 1997

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1 how the City held its elections and how the districts

2 were designed in 1997, 2003, or 2013?

3 A. I don't recall any context around pre-1997

4 elections.

5 Q. What about after 1997?

6 A. No. Well, now, I obviously know about

7 what's happened since the map has been -- you know,

8 from the 2022 map. But between 1997 and 2022 my

9 knowledge of the redistricting process is limited.

10 Q. Okay. In terms of even as a source of your

11 limited knowledge from 1997 to 2022, what would be the

12 source of your knowledge?

13 A. I'm sorry. Can you repeat that question?

14 Q. Sure. You indicated that your knowledge of

15 whatever happened between 1997 and 2022 is limited?

16 A. Yes.

17 Q. That implies there's a little bit. It

18 might not be a lot but a little bit. What would be

19 the source of that knowledge?

20 A. Just understanding, you know, the idea of

21 an at-large -- the at-large districts that were done

22 previously versus the district structure that exists

23 now. I can't recall the exact source of that insight.

24 That's the only -- that's the extent of the insight

25 that I have around, kind of, the history of the

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1 structure of Miami elections.

2 Q. Mr. Johnson, I am going to start with

3 showing you a copy of the First Amended Complaint, and

4 we're not going to mark this one simply because it's a

5 big document. We don't need to get crazy with it.

6 A. Sure.

7 Q. And I'll give you a second to look at that

8 and then I will ask you, do you recognize that

9 document?

10 A. Yes.

11 Q. What is that document?

12 A. This is the First Amended Complaint in

13 regards to this case.

14 Q. Did you see that document before it was

15 filed?

16 A. I cannot recall the timing at which I

17 viewed the document.

18 Q. If I represent to you that the document was

19 filed on February 10th, 2023, does that help orient

20 you as to whether you saw it before or after it was

21 filed?

22 A. No. It does not.

23 Q. Okay. And on page 5, paragraph 26, you are

24 identified as a Black resident of Brickell in District

25 3; is that correct?

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1 A. Yes.

2 Q. And to the best of your knowledge is that a

3 truthful statement?

4 A. Yes.

5 Q. And also, in paragraph 30, it goes on to

6 assert that the enacted plan, which is referring to

7 the 2022 plan, places plaintiffs Cooper, Johnson, and

8 Valdes and organizational plaintiffs' members in

9 districts where they are not the predominant racial

10 group. Do you know what the predominant racial group

11 is in District 3?

12 A. I'm not a hundred percent sure. My

13 assumption is Hispanic.

14 Q. And why would that be your assumption?

15 A. Based on observation of those in my

16 district.

17 Q. Would it be fair to say, based upon

18 observation, that a significant majority of the

19 residents of the City of Miami are Hispanic?

20 A. No.

21 Q. Okay. Are you aware of whether super

22 majority of the residents of Miami are Hispanic?

23 A. No.

24 Q. No knowledge of that?

25 A. No.

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1 Q. Okay. Do you observe a lot of Hispanics

2 living in your neighborhood?

3 A. Define my neighbor. Can you define my

4 neighborhood?

5 Q. You identified Brickell as an area where

6 you live. Would you consider that your neighborhood?

7 A. Yes. Brickell.

8 Q. So in Brickell, are there a lot of Hispanic

9 residents?

10 A. There's a good amount of Hispanic

11 residents.

12 Q. Do you know if they -- would you consider

13 them to be the majority race or ethnic population for

14 that area of Brickell?

15 A. It is not clear to me whether or not that

16 is the case.

17 Q. Okay. In terms of other race or ethnic

18 population that might rival the size of the Hispanics,

19 and I don't mean that they're necessarily battling

20 each other but just in terms of quantity, what other

21 races or ethnicities might be comparative to their

22 size?

23 A. I would say white Caucasian.

24 Q. So do you know what race or ethnicity the

25 commissioner from District 3 is?

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1 A. Yes.

2 Q. And what is that?

3 A. Hispanic.

4 Q. Do you have a problem being represented by

5 a Hispanic commissioner?

6 A. No.

7 Q. Do you have a problem with your current

8 commissioner?

9 A. Define problem, please.

10 Q. Is he somebody that you would support?

11 A. No.

12 Q. Okay. Do you believe that you were placed

13 into District 3 because you were Black?

14 A. I believe that the drawing of District 3

15 had racial intention.

16 Q. What is your basis for making that

17 statement?

18 A. My basis is both -- well, validation,

19 number one, is through the preliminary injunction that

20 was issued by Judge Moore and looking at the map that

21 was presented by the City.

22 Q. Okay. We've got some things there to

23 unpack.

24 A. Sure.

25 Q. Well before the judge issued the

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1 preliminary injunction --

2 A. Sure.

3 Q. -- there's an amended complaint that was

4 filed that asserted that you were placed into a

5 district where you were not the predominant race and

6 further allegations that indicate that you were placed

7 in that district because of your race. So let's put a

8 pin in the preliminary injunction one.

9 A. Sure.

10 Q. What are -- and I apologize. I got

11 distracted and didn't write down the second one. Do

12 you recall what the second basis was?

13 A. Well, that's why I said -- it wasn't a

14 basis. I just wanted to make the note that the judge

15 issued that preliminary injunction that did validate

16 my concern. I said initially the concern was based on

17 the map that was initially -- that 2022, I believe,

18 that initial map that was issued by the City.

19 Q. That's right. And so related to the 2022

20 map --

21 A. Yes.

22 Q. -- what about that map makes you believe

23 that you were placed in your district because of your

24 race?

25 A. You know, I believe that based on the way

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1 in which those lines were drawn indicated that there

2 was -- and other statements that were made by

3 commissioners around the creation of the map --

4 indicated there was an intention to create those

5 borders or those boundaries, rather, based on racial

6 intent.

7 Q. So in drawing District 3, what is your

8 understanding of what the City's intention was?

9 A. My assumption about the City's intention is

10 to ensure that boundaries are drawn that, essentially,

11 compile people of the same race into their own

12 individual districts, including District 3.

13 Q. So in drawing District 3, it was the City's

14 goal to unite people of the same race in District 3?

15 A. I believe that the goal is to broadly --

16 you know, not in an absolute term but broadly,

17 essentially, place people of the same race in the same

18 district.

19 Q. Okay. What district do you think you

20 should be in?

21 A. Personally, I -- I have a preference for

22 being in District 2.

23 Q. Have you analyzed the statistical numbers

24 for the 2022 plan?

25 A. I have reviewed those numbers -- the

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1 numbers that were provided by -- I forgot the name of

2 the professor that provided those numbers, but I did

3 review them.

4 Q. Okay. Is the professor that you're

5 referencing Dr. Abott who performed an expert analysis

6 in this particular litigation?

7 A. Yes.

8 Q. Have you ever spoken with Dr. Abott?

9 A. No.

10 Q. In paragraph 30 of the amended complaint

11 you state that "The enacted plan sends the message

12 that their commissioner's job is to represent the

13 predominant group, not them." What is your basis for

14 that statement?

15 A. If the intention is to create borders or

16 boundaries of districts based on race, then I think it

17 follows that you would assume that a commissioner's

18 job is primarily to serve the interests of those who

19 they're intentionally racially gerrymandering for.

20 Q. Let me ask you about that.

21 A. Sure.

22 Q. Are you aware that the plaintiffs have

23 proposed four plans in this litigation as

24 alternatives?

25 A. Yes.

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1 Q. Have you reviewed those plans?

2 A. Yes.

3 Q. Have you reviewed the statistical analysis

4 of those plans?

5 A. Yes.

6 Q. Are you aware that those plans also have

7 three districts that will likely elect a Hispanic

8 candidate, one district that is specifically designed

9 to elect a Black candidate and that is required by the

10 Voting Rights Act, and then a plurality district that

11 doesn't have a majority of any particular race or

12 ethnicity?

13 A. I think that the assumption that three

14 Hispanic commissioners would be elected and one Black

15 representative would be elected is just an assumption.

16 Q. Do you know if the plaintiffs have put

17 forth expert analysis at least as to the Black

18 district, D5, that a Black preferred candidate would

19 be elected from that district?

20 A. I am not aware of additional expert

21 analysis of District 5, no.

22 Q. And I want to be clear. When we're talking

23 about those districts, we're talking about districts

24 that not necessarily are going to elect a Black

25 candidate or a Hispanic candidate, but that would

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1 elect a Black preferred candidate or Hispanic

2 preferred candidate. Do you currently know who serves

3 in District 5?

4 A. I am not aware of who serves in District 5,

5 or I can't recall the name of the representative.

6 Q. Do you currently know who serves in

7 District 2?

8 A. I am not aware of or cannot recall the name

9 of the representative for District 2.

10 Q. But you would rather have her as your

11 commissioner versus Commissioner Carollo?

12 A. It's not for me to say which of the

13 existing commissioners I would rather have. My main

14 concern is to be placed in a district that is not

15 racially gerrymandered so I feel empowered to elect

16 someone who serves my interests.

17 Q. Would you agree that -- and I understand

18 that it's the plaintiffs' position that the districts

19 were racially gerrymandered to elect three candidates

20 that would be the Hispanic-preferred candidate, one

21 candidate that would be the Black-preferred candidate,

22 and one candidate that would be the Anglo-preferred

23 candidate, apparently. Would you agree that if the

24 four plaintiffs' plans have very similar racial

25 numbers that would produce very similar results, they

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1 just, you know, break up the neighborhoods a little

2 differently, that that might be an indicator that the

3 City's plans are racially gerrymandered?

4 A. I take a little exception to a little

5 different. I think that the maps that the plaintiffs

6 have put forward -- and also based on the last

7 judgment by the judge who, I think for, I believe, Map

8 4 indicated that that map was not racially

9 gerrymandered. So I would disagree with the assertion

10 that the maps that have been agreed upon by the

11 plaintiffs and presented are a little -- have a little

12 difference to the City's map.

13 Q. You've referenced the judge's rulings

14 twice.

15 A. Yes.

16 Q. Are you aware that 11th Circuit, the people

17 who sit above him, have told him he's wrong?

18 A. I don't believe they've told him he's

19 wrong. I believe that there is an injunction to

20 actually have a court case and a trial to adjudicate

21 the claims.

22 Q. And do you understand that the injunction

23 is not actually a judgment on the merits that has been

24 issued, correct?

25 A. That is correct.

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1 Q. So the judge actually might be convinced at

2 trial that there's not a racial gerrymandering here.

3 A. Yes.

4 Q. Are you also aware that the 11th Circuit

5 said, at least in terms of the imposition of

6 plaintiffs' plan four, that it doesn't appear to

7 correct any of the racial gerrymandering that is

8 claimed?

9 A. Yes.

10 Q. So you've read the 11th Circuit opinion?

11 A. I haven't read it in its entirety. I'm

12 aware of the 11th Circuit opinion.

13 Q. In paragraph 32 you state that "The members

14 are further harmed because the enacted plan splits up

15 their neighborhoods and they are split along racial

16 lines." I want to break that up. First, is it your

17 understanding that splitting up neighborhoods is, per

18 se, racial gerrymandering?

19 A. That depends on the definition of

20 neighborhood. I can't say in absolute terms that, you

21 know, in a broad sense that it is, but in the context

22 of the districts that have been drawn for Miami,

23 specifically from the State, it's my personal opinion

24 that it is.

25 Q. So anytime the City breaks up a

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1 neighborhood or doesn't unite a neighborhood that

2 might have historically been split between two

3 districts, that's racial gerrymandering?

4 A. Again, it depends on the context and the

5 details of the demographics and the population within

6 the specific neighborhood that is being cut up.

7 Q. If we're talking about a Hispanic

8 neighborhood that has historically been divided

9 between District 1 and District 4, Hispanic on one

10 side, Hispanic on the other, and no other way to draw

11 that area other than to have it in an Hispanic

12 district, is splitting that neighborhood a racial

13 gerrymander?

14 MS. MCNAMARA: Objection to the form. You

15 can answer.

16 THE WITNESS: Looking at it in isolation,

17 if we're talking about a city that just had

18 Hispanic residents and we're splitting a 100

19 percent Hispanic city into two districts, no.

20 BY MR. LEVESQUE:

21 Q. Okay. We can set that aside. I'm going to

22 provide you a copy of the Supplemental Complaint that

23 we will not attach as an exhibit. Have you seen this

24 document before?

25 A. Yes.

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1 Q. And what is this document?

2 A. It is a Supplemental Complaint that was

3 filed by the plaintiffs.

4 Q. And did you review this document before it

5 was filed?

6 A. I cannot recall the exact time that I

7 reviewed this document.

8 Q. And this document is dated September 7th,

9 2023. Does that help identify whether you reviewed it

10 before or after it was filed?

11 A. No. It does not.

12 Q. Do you know if you would have approved this

13 document before it was filed?

14 A. I believe I would have.

15 Q. Looking at this Supplemental Complaint, on

16 page 3, paragraph 12, it indicates that you're Black

17 and you were a resident of District 3 under the 2022

18 plan and still are a resident of District 3 under the

19 2023 plan. Is that a true and accurate statement?

20 A. Yes.

21 Q. Out of curiosity, which district are you in

22 in the plaintiffs' plans?

23 A. I believe in the first I am in District 2,

24 and I believe in the subsequent three I'm in District

25 3.

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1 Q. So even in their plans they didn't put you

2 in District 2?

3 A. Well, I -- yes. In some of them.

4 Q. Did you ask to be put in District 2?

5 A. I've supported -- I've supported the map

6 that we put forth, the P4. I did advocate for being

7 put in District 2, yes.

8 Q. Were you aware that plaintiffs' plans split

9 Brickell?

10 A. Yes.

11 Q. When plaintiffs' plans split Brickell, did

12 they do it with racial reasons?

13 A. It's not the intention, no.

14 Q. Regarding either the '22 plan or the '23

15 plan, is it your contention that it's not the effect

16 of the plan it's just whatever the city commissioners

17 intended that's problematic?

18 A. I believe both can be problematic. I

19 believe the intention, as well as the result, you

20 know, also -- is also problematic.

21 Q. If the result of the 2023 plan in terms of

22 overall election performance is substantially similar

23 to the plaintiffs' plan four, in that scenario, would

24 you agree that just because the results are the same

25 that that might be an indicator that there is no

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1 gerrymandering --

2 A. No.

3 Q. -- and that you have to look at the intent?

4 A. No.

5 Q. Why would that be the case?

6 A. We're speaking hypothetically. I think the

7 intent for myself as a plaintiff, as well as the other

8 plaintiffs, to my understanding, is to intentionally

9 create maps that are not racially gerymandered and

10 that just allows the residents of the districts to be

11 able to feel empowered to elect representatives that

12 represent their interests. So that is the extent to

13 which my concern is. To remedy a map and then say,

14 oh, we didn't talk about race but you're still

15 essentially mirroring, you know, for the most part,

16 based on the analysis of the expert as well, you know,

17 to me is still problematic.

18 Q. Are you aware that Dr. Abott identified

19 that there are a lot of similarities between

20 plaintiffs' Districts 2 and 5 in plan four and the

21 2023 plan?

22 A. I cannot recall that assertion by him.

23 Q. Her.

24 A. Her. Sorry.

25 Q. Are you aware that -- let me ask you this,

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1 did you review the report of Dr. McCartan who drew

2 comparisons on compactness and population comparisons

3 between the plans?

4 A. I don't recall reviewing his report.

5 Q. And as it relates to the 2023 plan, you

6 also assert you are not the predominant racial group

7 in District 3. What is the predominant racial group

8 in District 3's plan? I'm sorry. The 2023 plan for

9 District 3.

10 A. I believe it's Hispanic. That's my

11 assumption.

12 Q. Why is that only an assumption?

13 A. Because I just can't recall. I believe I

14 did look at the statistics based on that study. I

15 just can't recall the exact number.

16 Q. And what about the crafting of the 2023

17 plan specifically conveyed the message that the

18 commissioners' job is to represent the predominant

19 group, not them?

20 A. Could you repeat the question again? I'm

21 sorry.

22 Q. What about the 2023 plan specifically --

23 because they were passed at different times.

24 A. Uh-hum.

25 Q. They say different things.

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1 A. Sure.

2 Q. What about the passage of the 2023 plan

3 sent a message that their commissioner's job is to

4 represent the predominant group, not them?

5 A. Well, as I said, in the 2022 plan because

6 of our understanding of the intentionality to racially

7 gerrymander those districts and the 2023 plan being

8 pretty similar, in my opinion, to the 2022 plan, I

9 arrived at the same conclusion for the 2023 plan.

10 Q. Did you compare either the 2022 or the 2023

11 plan to the 2013 plan?

12 A. No.

13 Q. Did you compare them to the 2003 plan?

14 A. No.

15 Q. Or the 1997 plan?

16 A. No.

17 Q. Does your opinion change if, at least in

18 terms of the progressions of the plans, they generally

19 maintain the same general shape from cycle to cycle

20 except for the equalization of population?

21 A. No.

22 Q. Why not?

23 A. First of all, I'm looking purely at the way

24 the lines are drawn now based on the demographics that

25 exist currently. I'm not aware of the demographics of

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1 different parts of Miami in the past. I think the

2 only thing I could really look at or is relevant to my

3 analysis of the maps in the context of gerrymandering

4 is the existing demographics.

5 Q. What is your familiarity with traditional

6 redistricting principles?

7 A. None.

8 Q. If a traditional redistricting

9 principle includes maintaining the core of the

10 existing district, would you have any reason to

11 believe that following that traditional redistricting

12 principle it's still racial gerrymandering?

13 A. Not in isolation.

14 Q. Are you aware of why -- and I'll represent

15 to you that maintaining the core of existing districts

16 is a traditional redistricting principle. Are you

17 able to think about why that might be a good principle

18 for someone responsible for drawing district lines to

19 follow?

20 A. Not off the top of my head.

21 Q. If the districts don't change

22 significantly, do you think that would help in

23 avoiding voter confusion?

24 A. Can you repeat the question again? Sorry.

25 Q. If the districts don't change significantly

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1 from cycle to cycle --

2 A. Uh-hum.

3 Q. -- do you think that would help with

4 avoiding voter confusion?

5 A. I'm not sure.

6 Q. If the districts don't change from cycle to

7 cycle, do you think that would allow the communities

8 of interest within the district to build stronger

9 bonds and advocate together to their commissioner?

10 A. In the absence of insight around that, I'm

11 not aware. I don't know.

12 Q. Now, Mr. Johnson, I am going to show you

13 what we are going to mark as Defendant's Exhibit 8224.

14 (Thereupon, Resolution 23-271 City's Proposed

15 Remedy was received as Defendant's Exhibit 8224

16 for identification.)

17 Q. And before I ask my next set of

18 questions -- I probably skipped this in the intro --

19 this is not intended to be the Spanish Inquisition or

20 some type of torture session.

21 A. Okay.

22 Q. If you need to take a break for water or

23 comfort or whatever, just let me know. The one thing

24 that I would ask is if we've got a question pending,

25 let's go ahead and dispose of the question pending and

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1 then we can take a break.

2 A. Okay. Great.

3 Q. Have you seen this plan before?

4 A. Yes.

5 Q. What is this plan?

6 A. This is the City's proposed remedy.

7 Q. So this would be the plan that was passed

8 earlier this year?

9 A. Yes.

10 Q. And this is the plan that the upcoming

11 elections in November will be conducted under?

12 A. Yes.

13 Q. As you look at District 3 there, what about

14 the lines of District 3 do you believe constitute a

15 racial gerrymandering?

16 A. Well, without the actual data points

17 overlaid on top of the map, just from the eye test

18 looking at the incursion into Coconut Grove of

19 District 3, is one that I can see right now. And

20 especially as it differs from the maps that we've --

21 the plaintiffs put together in trying to keep together

22 coherent geographic boundaries, it just seems that

23 that's not really the case here for District 3

24 specifically.

25 Q. Okay. Is there anything other than the

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1 incursion into Coconut Grove and the reference to

2 geographic boundaries that you're relying on?

3 A. Again, from the eye test, looking at

4 Shenandoah and The Roads being split, I'm not sure

5 exactly what the specific numbers of demographics are

6 there. That also sticks out to me.

7 Q. Is the fact that Brickell splits an

8 indicator of racial gerrymandering to you?

9 A. It is. Or it can be in the context of the

10 broader District 3.

11 Q. Okay. And when you say in the context of

12 the broader District 3, how do you mean?

13 A. Well, taking all of my statements together,

14 the incursion into Coconut Grove, the splitting of

15 Brickell, the splitting of The Roads and Shenandoah

16 collectively seemed to be a racial gerrymander. So

17 Brickell being split in insolation I don't believe

18 is -- it's part of the broader District 3.

19 Q. So if they didn't make the incursion into

20 Coconut Grove and they didn't split Shenandoah but

21 they did split Brickell, would that sort of standing

22 alone then not be sufficient to conclude racial

23 gerrymandering?

24 A. Again, without the data points, I'm just

25 relying on an eye test. You know, going into more

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1 detail as we had done with the maps that we put

2 together, you know, is our recommendation of how to

3 eliminate the racial gerrymandering particularly of

4 District 3 as well.

5 Q. Now, the incursion of District 3 into

6 Coconut Grove, specifically that area of Natoma

7 Manors -- are you familiar with that area?

8 A. I've spent some time like biking around

9 there but not intimately familiar.

10 Q. Are you aware that one of the commissioners

11 maintains a residence at almost the very point of that

12 foot?

13 A. I do know that.

14 Q. Okay. You would agree that drawing a

15 commissioner's residence into his district doesn't

16 have anything to do with racial reasons, correct?

17 A. In isolation of just saying my residence

18 and my district, no. In the context of this,

19 potentially.

20 Q. Potentially but not necessarily?

21 A. Again, I'm doing it based on an eye test.

22 We have to go into actual data. Again, we've put maps

23 together that have mitigated or eliminated the racial

24 gerrymander that was presented by the City.

25 Q. And is it your understanding that the

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1 numbers -- the data bear out that you've eliminated

2 the racial gerrymander?

3 A. I believe with the map that we have

4 recommended, that we have done so.

5 Q. Okay.

6 A. That is my opinion.

7 Q. Mr. Johnson, I am going to provide you with

8 what we are going to mark as Defendant's Exhibit 8212.

9 (Thereupon, Appendices was received as

10 Defendant's Exhibit 8212 for identification.)

11 Q. And I will represent to you that this is an

12 excerpt of the appendix that was attached to

13 Dr. Abbott's report.

14 A. Okay.

15 Q. I believe you indicated that you did look

16 at her report and have you reviewed this appendix

17 before?

18 A. I can't recall if I looked at the appendix.

19 Q. Okay. I would like to draw your attention

20 to the last data block on page 15.

21 A. Okay.

22 Q. And for the five districts, they identify

23 various districts with white voting age population,

24 Hispanic voting age population, and Black voting age

25 population. Do you see that?

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1 A. I do.

2 Q. And then they also identify white citizen

3 voting age population, Hispanic citizen voting age

4 population, and Black citizen voting age population.

5 Do you see that as well?

6 A. Yes. May I ask a question?

7 Q. Yes.

8 A. The difference between citizen and -- so is

9 this the voting -- the voting population versus the

10 citizens who are eligible to vote? Is that the

11 difference between --

12 Q. Citizen voting age population.

13 A. So those who are eligible to vote?

14 Q. I'll let your counsel explain the

15 difference there. Because there are some --

16 A. All right. Sorry.

17 Q. -- nuances and --

18 A. Okay.

19 Q. In any event, I guess my starting question

20 is, do you know the difference between the two?

21 A. Between citizen voting and --

22 Q. Just voting age population and citizen

23 voting age population?

24 A. No.

25 Q. That's fine. And you indicated that the

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1 data would reflect some of the gerrymandering that

2 occurs. Let's just look at the voting age population.

3 What about that data indicates that racial

4 gerrymandering is occurring in your mind?

5 A. I'm still trying to understand what I'm

6 seeing. Are these the proportions of --

7 Q. The voting age population --

8 A. -- the voting age population? So are we

9 looking at both the voting age and the citizen voting

10 age or one or the other? I'm just trying to

11 understand.

12 Q. Well, you had indicated that the data

13 demonstrates racial gerrymandering?

14 A. In part, yes.

15 Q. And so, I guess, what about this particular

16 data in your mind demonstrates racial gerrymandering

17 is occurring? And if you want, we can just focus on

18 District 3 for the time being.

19 A. Well, again, you're showing me one set of

20 data and I think when I say data I don't mean like one

21 table on this appendix. I'm looking at the data more

22 holistically of demographics and shifts and those

23 types of things. So based on what you're showing me

24 right now is not consistent with what I refer to as

25 data.

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1 Q. Okay. Can you explain that a little more?

2 A. I'm basing, you know, my position around

3 what was -- what was in the report that I read, not

4 this appendix. I can't recall if I read the appendix

5 or not. But based on the data that was also used by

6 Judge Moore to indicate that there was no significant

7 difference between the output of this map relative to

8 the City's original map, that's the data that I'm

9 referencing.

10 Q. Okay. Well, then let me just sort of -- in

11 looking at District 3, I think you indicated that The

12 Roads was a neighborhood that was split in District 3?

13 A. Yeah. The Roads and Shenandoah, yes.

14 Q. Okay. Do you know where the boundaries for

15 The Roads and Shenandoah are?

16 A. I don't know the specific boundary of those

17 neighborhoods, no.

18 Q. Are you able to roughly mark out -- and I

19 understand that it might not be exact but would you be

20 able to roughly mark out like the area that you think

21 The Roads is?

22 A. My assumption is that it's somewhere

23 between where it says The Roads and Shenandoah at

24 least from east to west, and then I'm assuming it's

25 between Little Havana and The Roads on the north side.

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1 Q. Okay. With that test, would you agree that

2 whatever the various potential actual boundaries,

3 would you agree that the words The Roads are entirely

4 in District 3?

5 A. According to this map, I believe maybe.

6 Q. Okay. And at this point I'm not even

7 actually asking about the boundaries for the

8 neighborhood. I'm just asking are the words "The

9 Roads" in District 3?

10 A. The Roads in the City-proposed remedy, yes.

11 Q. Okay. Do you know if there's a defined

12 neighborhood that actually -- or some sort of official

13 city definition that defines the areas of The Roads?

14 A. Not that I'm aware of.

15 Q. Do you know if there is some official city

16 definition that defines the neighborhood of

17 Shenandoah?

18 A. Not that I'm aware of.

19 Q. Are you aware of anything for any of the

20 neighborhoods that officially defines what the area of

21 any of the neighborhoods in the City of Miami are?

22 A. Not that I'm aware of.

23 MR. LEVESQUE: Why don't we take a short

24 five-minute break.

25 THE WITNESS: I was just thinking the same

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1 thing.

2 (Thereupon, a recess was had from

3 3:06 p.m. - 3:14 p.m.)

4 MR. LEVESQUE: We can go back on the

5 record.

6 BY MR. LEVESQUE:

7 Q. Mr. Johnson, I'm going to show you an

8 exhibit that we are going to mark as Document 77. I'm

9 sorry. Defendant's Document Number 77.

10 (Thereupon, City of Miami Commission

11 Districts Adopted June 14, 2023 were received as

12 Defendant's Exhibit 77 for identification.)

13 Q. Mr. Johnson, I will represent to you that

14 these are the plans that were attached to the

15 resolution that the City of Miami Commission adopted,

16 and it might be a visual representation of the

17 districts that might be a little bit easier to see

18 because in addition to the large blowup that's on the

19 first page, if you flip through you will see that

20 there are larger versions that permit you to better

21 ascertain some of the boundaries of the district. Do

22 you see that?

23 A. Yes.

24 Q. And in looking at District 3, would you

25 agree that at least for the southeastern part of the

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1 district it generally follows major roadways that

2 would include Bayshore Drive and Miami Avenue?

3 A. Bayshore Drive and Miami Avenue. It does

4 follow those, yes.

5 Q. And then for a portion of the -- the top

6 part of the foot it follows South Dixie Highway?

7 A. Oh, yes. Yes.

8 Q. And then at the northeastern part, once it

9 has the little jog over to Southwest 2nd Avenue, it

10 comes up and essentially follows the river all the way

11 up to Northwest 18th Avenue?

12 A. Yes.

13 Q. You would agree that the river would be a

14 natural geographic boundary?

15 A. Yeah.

16 Q. In looking at this map, and I know it

17 doesn't have the neighborhoods on there, does that

18 help you better ascertain whether The Roads is

19 entirely within District 3 or not?

20 A. No.

21 Q. Okay. Are you able to generally identify

22 where you live on this map?

23 A. Yes.

24 Q. If I could ask you -- I'm going to hand you

25 a pen. If I could ask you to mark on that map where

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1 you live and you can either put a little circle or dot

2 and circle it or however you'd like to indicate where

3 you live.

4 A. Okay.

5 Q. Okay. If you could show that to your

6 counsel too.

7 So at least as it appears do I understand

8 that you live west of Miami Avenue?

9 A. Yes.

10 Q. Mr. Johnson, I'm going to show you another

11 document that I'm pretty sure you've seen before and

12 this we're going to mark as Defendant's Document 2438.

13 (Thereupon, Declaration of Jared Johnson

14 was received as Defendant's Exhibit 2438

15 for identification.)

16 Q. Mr. Johnson, do you recognize that

17 district?

18 A. The district indicated on the declaration?

19 Q. I'm sorry. Do you recognize that document?

20 A. Yes, I do.

21 Q. And for some reason I have verbal problems

22 occasionally. It's never been diagnosed, but I might

23 substitute words inadvertently. If I do that, please

24 draw that to my attention.

25 A. That's okay.

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1 Q. So you have seen this declaration before?

2 A. Yes.

3 Q. Did you write this declaration?

4 A. In conjunction with my counsel.

5 Q. And I don't want to know anything about

6 what you discussed with your counsel, but I would like

7 to ask you about some of the statements in here. In

8 paragraph four, you state, "I want what is best for

9 Miami and my community here." What do you believe is

10 best for Miami and your community?

11 A. In the context of representation, wanting

12 to ensure that the residents of Miami feel empowered

13 to elect officials that have their interests as their

14 priority.

15 Q. And with a democratic process that

16 sometimes is divided, how do you translate that to

17 what is best for Miami and your community?

18 A. The core of democracy is the power of the

19 people and, you know, empowering people to have a

20 voice in their elected officials includes both the

21 votes they cast at the ballot box as well as ensuring

22 that the districts that they are members of are

23 indicated by them -- like the voters are able to

24 choose their districts and not commissioners choosing

25 their voters, I think, is the ideal.

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1 Q. Well, there would be a solution if that

2 were the case that would involve the district maps

3 having to be adopted by voter referendum, if that were

4 the case. Would you agree?

5 A. Not necessarily.

6 Q. Okay. Well, at least under the City's

7 current governance model, the city commissioners are

8 responsible for drawing the districts, correct?

9 A. Correct.

10 Q. And every single one of those commissioners

11 were elected to the city commission not even from

12 either of these maps. Do you have any dispute as to

13 the legitimacy of their holding office based upon

14 their election to the districts from 2013?

15 A. I wasn't a resident during 2013. I don't

16 have a lot of insight in terms of how those districts

17 were created at that time. My only perspective is

18 based on the maps that were presented by the City.

19 Q. In an ideal world an elected representative

20 will represent all of their constituents regardless of

21 how elections turn out, correct?

22 A. In an ideal world, yes.

23 Q. And some representatives are better at

24 trying to walk that line than others, would you agree?

25 A. Walk the line of --

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1 Q. Being a faithful public servant and

2 representing all of their constituents' interests?

3 A. Yes.

4 Q. And that's going to vary from elected

5 representative to elected representative?

6 A. Yes.

7 Q. And it's not necessarily going to be

8 dependent on party or political affiliation or

9 anything like that because you might have someone who

10 only pays attention to some of their constituents in

11 either party, in either race regardless of any of

12 those other factors. There's going to be a great deal

13 of variability. Would you agree with that?

14 A. Yes.

15 Q. In paragraph five, you state that "I

16 believe that the process of creating the map should

17 have been fairer, including to Black residents of

18 Miami." Can you explain that statement?

19 A. I believe that the existing process of

20 creating the map, which, you know, from my perspective

21 was racially gerrymandered, did not adequately

22 represent the voices of Black residents. My

23 assumption is that if Black residents' voices were

24 heard in the way in which I believe they should have

25 been, then we would not have had a racially

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1 gerrymandered map in the beginning. It would have

2 reflected something along the lines of what, you know,

3 we have put forth in the four maps that have been

4 crafted by the plaintiffs. And, again, there can be

5 nuances in terms of some of the boundaries within

6 those maps but, you know, the statement is essentially

7 saying that I don't believe that Black voices were

8 represented adequately in the drawing of the lines of

9 the map on the 2022, as well as the remedy in 2023.

10 Q. Okay. When you're referencing the Black

11 voices not being heard was that in relation to

12 District 3 or was it in relation to other districts?

13 A. Miami as a city. Not just District 3.

14 Q. Okay. And so how were Black voters -- I

15 guess, what were Black voters calling for in terms of

16 the drawing of the districts?

17 A. I think Black voters are consistent in

18 ensuring that districts aren't racially gerrymandered.

19 That's the core message from Black voters.

20 Q. Were you aware -- let me ask this.

21 District 5 -- District 5 is a district that, I think

22 the parties agree, is required by the Voting Rights

23 Act. District 5 is a district that is required to be

24 drawn to perform for the Black candidate of choice.

25 The preferred Black candidate. The Black preferred

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1 candidate. Would you agree with that statement?

2 A. I'm unaware of the statutes that govern the

3 creation of District 5.

4 Q. So whether the City or the plaintiffs in

5 drawing their maps deliberately considered race in the

6 drawing of District 5, as the voting rights required

7 of them, that's not anything that you have knowledge

8 of one way or another?

9 A. I do not.

10 Q. Are you critical of the way the City drew

11 District 5?

12 A. I have, at this point, no -- I look at

13 the -- you know, primarily the district that I'm in.

14 That's where my primary focus has been.

15 Q. Okay. And so going back to District 3,

16 what about the City's drawing of District 3 could have

17 been fairer to Black residents?

18 A. I believe the maps that we, as the

19 plaintiffs, put forth represent, you know, my input

20 and my perspective, as well as the perspective of

21 other plaintiffs. So I stand by the maps that we've

22 put forth in terms of that.

23 Q. And you referenced the input and the

24 perspective that you referenced. Are you aware of

25 whether the plaintiffs held community meetings to seek

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1 input on the map drawing process?

2 A. I am.

3 Q. Did you attend any of those meetings?

4 A. No.

5 Q. And I don't mean this to be punchy or

6 something but --

7 A. Sure.

8 Q. -- you're not an elected representative,

9 correct?

10 A. No.

11 Q. Have you ever thought about running for

12 office?

13 A. I have.

14 Q. Are any of the plaintiffs elected

15 representatives?

16 A. Not that I know of.

17 Q. Do you know who drew the plaintiffs' maps?

18 A. I don't believe one individual drew the

19 plaintiffs' maps.

20 Q. Do you know the individuals that would have

21 been involved with drawing the plaintiffs' maps?

22 A. Plaintiffs, as well as our counsel.

23 Q. Do you know if all of those meetings where

24 they had sessions drawing the maps, were they

25 recorded?

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1 A. I'm not aware.

2 Q. Were they noticed and made available to the

3 public so that everybody could understand what you

4 were doing and what you were discussing when you did

5 it?

6 A. I'm unaware.

7 Q. What could the City have done to be fairer

8 to Black residents in District 3 in drawing District

9 3?

10 A. I believe there could have been more

11 outreach to Black residents of the City to get

12 perspective. You know, prime example is the map that

13 the plaintiffs put forward, you know, and the City

14 came back with a map that was -- didn't seem like a

15 compromise. It seemed like a very similar map to what

16 was already being provided. So to me it is almost a

17 validation of my assumption of not taking Black voices

18 seriously into account as the lines are being drawn on

19 the map.

20 Q. Are you aware that during the first round

21 of redistricting the issue of District 4 going down

22 and taking a little cut of Coconut Grove was a big

23 point of contention?

24 A. I do recall, yes.

25 Q. Do you recall that there was an area of the

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1 west Grove that was included in District 4 that people

2 were not happy about?

3 A. I do recall, yes.

4 Q. What's your understanding of the racial

5 makeup of the west Grove?

6 A. My understanding is the west Grove is a

7 predominantly Black neighborhood.

8 Q. And that's one of the, say, few areas where

9 gentrification hasn't completely displaced the Black

10 population down there; is that correct?

11 A. I would -- I would say that's correct.

12 Q. And when the City redrew the lines in 2023,

13 you do see where they included that area of the

14 western Grove back into District 4 -- I'm sorry --

15 District 2, correct?

16 A. Correct. Yes.

17 Q. And so that road actually follows, I

18 believe at that point it might be US-1 or Dixie

19 Highway?

20 A. Dixie Highway.

21 Q. So that would be an area where at least the

22 second time around the City listened to the

23 constituents and they included that back in the west

24 Grove, correct?

25 A. I can't speak for the motivations as to the

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1 amendment of that section of the map, but that part

2 has changed relative to the original map. That's

3 correct.

4 Q. Do you think that was a change that the

5 City made for racial reasons?

6 A. Racial -- define racial reasons in this --

7 Q. Well, did they move it back in to racially

8 gerrymander the map?

9 A. The map holistically is racially

10 gerymandered.

11 Q. Explain that.

12 A. I already discussed it. We've talked about

13 data. We've talked about the preliminary injunction

14 which I know the court of appeals still has to decide

15 on but I think there's reason to believe that -- and

16 the statements that were also articulated by the

17 commissioners as well that are on record, holistically

18 indicate that there was racially gerrymandering

19 associated with the creation of this map -- of the

20 original map and this map being very similar with some

21 small adjustments still very much mirror the map that

22 was originally racially gerymandered.

23 Q. Have you gone back and watched or reviewed

24 any of the original city commission meetings?

25 A. No, I have not.

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1 Q. How are you aware of what was said at those

2 meetings?

3 A. Because I read statements from those

4 meetings.

5 Q. When you say you've read statements, where

6 did you read statements?

7 A. In Judge Moore's decision from the

8 preliminary injunction.

9 Q. So the basis for your understanding that

10 the City racially gerrymandered the map is reading

11 Judge Moore's opinion?

12 A. That's not the original because the opinion

13 happened after seeing that those statements are also

14 there as well that indicate the racial gerrymandering

15 based on conversations by commissioners themselves.

16 Q. I understand that but, I guess, did you

17 read the statements before Judge Moore's ruling?

18 A. I was aware of the statements.

19 Q. And how did you become aware of the

20 statements?

21 A. As a plaintiff and as part of Engage Miami.

22 Q. Okay. So was it from reading the amended

23 complaint?

24 A. I'm using the amended complaint to make my

25 argument. That's not the first time I understood that

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1 commissioners had made statements and the statements

2 are written down in Judge Moore's decision.

3 Q. I understand that they're written down and

4 I understand they're written in the amended complaint

5 but apart from -- and in the original complaint.

6 A. Yes.

7 Q. Apart from those three documents, where did

8 you --

9 A. Like I said, I had conversations with

10 people in Engage and the plaintiffs about those

11 comments as well.

12 Q. So your understanding of what was said and

13 what was meant is not actually from going back and

14 looking at the full transcript of the hearings. It's

15 from your conversations with your fellow plaintiffs,

16 it's from reading pleadings that have been filed in

17 this case?

18 A. Correct.

19 Q. As it relates to the 2023 plan, were you at

20 the June 14th meeting?

21 A. The June 14th commission meeting?

22 Q. Yes.

23 A. City of Miami? No.

24 Q. Did you view that meeting? Watch the

25 video?

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1 A. Watch the video, no.

2 Q. Did you read the transcript?

3 A. No.

4 Q. Is your understanding of what was said at

5 the June 14th meeting related to the 2023 map all

6 derived from either the pleadings, Judge Moore's

7 order, or your conversations with plaintiffs?

8 A. Yes.

9 Q. Paragraph six says, "As a resident of the

10 newly enacted city commission District 3, I am

11 concerned that Black residents like me have been

12 categorized and stripped from my district on the basis

13 of our race." When you say "stripped from my

14 district," what district are you being stripped from?

15 A. My assumption would be, you know, my

16 preference being in District 2 and being placed in a

17 District 3 was the context around that statement.

18 Q. Do you know if you get to pick your

19 district as a resident of Miami?

20 A. No.

21 Q. Would you agree that the only way to pick

22 your district is buy or rent a residence within that

23 district?

24 A. I'm sorry. What was the last part you

25 said?

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1 Q. Buy or rent a residence in that district.

2 A. Rent a residence. What's a rent a

3 residence?

4 Q. Rent. It's a verb. Buy or rent a

5 residence in the district.

6 A. Yes.

7 Q. So if you wanted to be in District 2, you

8 could rent an apartment in District 2?

9 A. I got it. I understand. Yeah.

10 Q. Now, you state that, "Black residents like

11 me have been categorized and stripped from my

12 district." What category did the city commission put

13 you in?

14 A. Black resident.

15 Q. Okay. And when they put you in District 3,

16 what were they trying to accomplish?

17 A. I believe by placing the boundaries around

18 District 3 that were indicated on the map that there

19 was racial intent behind the creation of that

20 district.

21 Q. I understand racial intent but what I'm

22 asking is, what were they trying to accomplish? Were

23 they trying to make District 2 less Black by putting

24 you in District 3 or were they trying to make District

25 3 more Black by putting you in District 3?

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1 A. I can't speak for the exact nuance of 2

2 versus 3. All I know, from my perspective, is that

3 because there was racial intent associated with the

4 creation of that district, which in my opinion dilutes

5 the power of Black voters in the City of Miami, that's

6 why the statement was provided in the declaration.

7 Q. Now you said something different that I'll

8 need to ask you about. You mentioned that it dilutes

9 the Black voting power in the districts. How does it

10 do that?

11 A. Racial gerrymandering by definition does

12 that.

13 Q. You're in District 3. Before the maps were

14 drawn, do I understand correctly that you were in

15 District 2?

16 A. I believe I was in District 3.

17 Q. So before the districts were drawn you were

18 still in District 3?

19 A. Correct.

20 Q. Other than District 2, is there any other

21 district that you would conceivably naturally fall

22 into?

23 A. No.

24 Q. Okay. Do you know what the Black voting

25 age population is in District 2?

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1 A. I do not.

2 Q. Do you know if you were included in

3 District 2 that there would be a significant boost to

4 the Black voting age population in District 2?

5 A. Can you repeat that? I'm sorry.

6 Q. Sure. Well, let me ask it this way. Do

7 you know if there is generally in the Brickell area

8 sufficient Black population that if they put them in

9 either District 3 or District 2 that they would change

10 the Black voting age performance for either of those

11 districts?

12 A. Off the top of my head I'm not aware

13 Q. And I think earlier you indicated that, at

14 least based upon your observation walking around

15 Brickell and living in the area, being familiar with

16 the general racial makeup, Hispanics and whites make

17 up the vast majority of the residents in that area,

18 correct?

19 A. Based on my observations, yes.

20 Q. It's fair to say that you in that area are

21 a minority living in Brickell?

22 A. Yes.

23 Q. Are you aware that the City of Miami has

24 approximately 70 percent -- 17 percent Black voting

25 age population within the city limits?

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1 A. I'd read a number but I couldn't recall but

2 that sounds...

3 Q. Are you aware that a vast majority of those

4 residents actually live in the geography that is

5 placed in District 5?

6 A. I am not aware of that, no.

7 Q. Are you aware that the City of Miami has

8 roughly a 70 percent voting age population for

9 Hispanics?

10 A. I was not aware of the exact number.

11 Q. Roughly 14 percent for white voting age

12 population within the city limits?

13 A. I wasn't aware of that number.

14 Q. So none of those numbers affect your view

15 of the racial makeup of how the district might

16 actually look if you actually had the numbers?

17 A. No.

18 Q. So at least as it relates to being

19 categorized and stripped from the district, you have

20 no understanding or no idea what the City might have

21 been trying to accomplish by doing that?

22 A. I know based on, again what I said earlier,

23 the intention of the City to racially gerrymander my

24 district as well as the districts beyond my district.

25 Q. When you say, "stripped from my district,"

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1 and you were in District 3 before, and you are in

2 District 3 now, can you explain like where are you

3 being stripped from?

4 A. Again, I think that for me in the

5 redistricting, because obviously over time

6 demographics change and whatnot, I believe that

7 personally I should have been in District 2. And by

8 being placed in District 3, you know, in the context

9 of the creation of the map more generally I believe

10 that it was done with racial intent.

11 Q. But your basis for understanding, you know,

12 the changes in demographics, that only picks up from

13 about 2021, right, when you moved here?

14 A. Sure.

15 Q. You haven't looked historically back as to,

16 you know, how those districts were configured, whether

17 they've always been configured that way or not,

18 correct?

19 A. Correct.

20 Q. In paragraph eight, you say, I am concerned

21 that the commission map splits my neighborhood,

22 Brickell, along racial lines between Districts 2 and

23 District 3. Going back to the maps that we were just

24 looking at, looking at District 3, which lines are

25 being drawn and what race is on the side of each line

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1 in terms of splitting Brickell there?

2 A. Can you repeat that question? I was

3 looking at --

4 Q. Sure. Let's start with which lines split

5 Brickell along racial lines.

6 A. I mean the line that -- the line that's in

7 Brickell. There's only one line.

8 Q. Is it just the fact that Brickell is split

9 that it's split along racial lines?

10 A. District 3 -- again, it's not just Brickell

11 but it's being in District 3 versus District 2. So

12 the split of Brickell, you know, where it is and then

13 creating a District 3 with that part of Brickell

14 within it, you know, is a racial gerrymander relative

15 to me being in District 2 and that line being there.

16 Q. But in your statement, though, you say that

17 splits my neighborhood, Brickell, along racial lines

18 between District 2 and District 3.

19 A. Right. Because district -- sorry.

20 Q. The way that I read that is that the City

21 is drawing a line and there are people on one side of

22 the line that are one race and people on the other

23 side of the line that are a different race and that

24 they're doing that deliberately to keep those races

25 separate. Is my understanding of what you mean by

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1 that statement correct or incorrect?

2 A. It's incorrect.

3 Q. Okay. Explain to me, then, what you mean

4 by that statement.

5 A. So District 2 and District 3 comprise not

6 just of Brickell but of other parts of the City of

7 Miami. So the statement is essentially saying that

8 within the Brickell neighborhood where the boundary

9 occurs, that within my part of Brickell plus District

10 3, is racially gerrymandered relative to the other

11 part of Brickell with the totality of District 2.

12 Q. What is your understanding of why the City

13 had to redraw the lines in the first place?

14 A. My understanding is that there is a

15 redistricting process that occurs on a specific

16 cadence.

17 Q. Is it something that they always have to do

18 or is it something that is required when there's a

19 particular event?

20 A. That I'm not sure of, if there's any

21 specific events. My understanding is that there is a

22 specific cadence that redistricting does take place.

23 I'm not exactly sure if there's any sort of ad hoc

24 event that would necessitate a redistricting.

25 Q. So when it comes to a government's

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1 obligation to draw new district lines, are you aware

2 that there are requirements under the Unites States

3 Constitution that require under the equal protection

4 clause that districts be redrawn after the census to

5 provide for the one person, one vote requirement?

6 A. I don't have a lot of understanding of the

7 law but I believe that that's the case to my

8 understanding.

9 Q. And the idea being that, theoretically, if

10 a city never redistricted and they had huge population

11 shifts, you might have one district with 20 people,

12 one district with 100 people, and the people with the

13 ten-person district their vote counts more than the

14 people with the hundred-person district. Does that

15 make sense?

16 A. That does make sense, yes.

17 Q. Are you aware after the 2020 census which

18 of the City's districts were overpopulated and which

19 of the City's districts were underpopulated?

20 A. I'm unsure of the districts that were under

21 and overpopulated.

22 Q. Would it surprise you if District 2 was the

23 only district that was overpopulated?

24 A. No.

25 Q. Why is that?

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1 A. Look at the skyline.

2 Q. There's a lot of building going on?

3 A. Yes.

4 Q. In paragraph nine, you say, "The border

5 between Districts 2 and 3 is just a block and a half

6 to the east of my apartment. In my view it is more

7 logical to keep all of my Brickell neighbors together

8 in one district because our neighborhood has

9 common issues of being an urban, dense,

10 transit-oriented, coastal neighborhood that can more

11 sensibly be served by a single commissioner." Would

12 you agree that on some level the lines have to go

13 somewhere?

14 A. Yes.

15 Q. And if there's a constraint of trying to

16 keep generally population equal amongst the districts,

17 some neighborhoods might have to be split?

18 A. Yes.

19 Q. Would you also agree that some

20 neighborhoods might actually benefit from having more

21 than one commissioner represent them?

22 A. There could be some benefits, yes.

23 Q. So if a neighborhood has two commissioners

24 that represent them and they're both zealous advocates

25 for them, that's two of the three votes they need to

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1 get a majority in the city commission, correct?

2 A. Potentially, yes.

3 Q. In paragraph ten, you say -- do you have

4 any reason to believe that that would not be the case

5 for Brickell?

6 A. To --

7 Q. Let me back up. Forget the mixing of two

8 different questions.

9 A. Sure.

10 Q. Going back to what we were discussing

11 before, do you have any reason to believe that if

12 Brickell is represented by two commissioners, in this

13 case a commissioner from District 3 and District 2,

14 that they wouldn't have at least one commissioner

15 zealously representing them?

16 A. If there are two commissioners that -- I

17 just want to make sure I understand the question. If

18 there's two commissioners that are representing

19 Brickell, do I assume that one of those commissioners

20 would be like zealously supporting --

21 Q. Do you have any reason to believe that at

22 least one of them would not be?

23 A. At least one of them would not be?

24 Q. Yes.

25 A. It's possible.

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1 Q. Possible but --

2 A. It's possible.

3 Q. And it's possible that both commissioners

4 could zealously represent them and Brickell might be

5 doing really well in terms of the needs that address

6 an urban, dense, transit-oriented coastal

7 neighborhood's particular problems?

8 A. Possible. Yes.

9 Q. In paragraph ten, you say, "I am also

10 concerned that District 3 is predominantly driven by

11 racial considerations that are not geared toward fair

12 representation for minority residents." Which

13 minority residents are you talking about?

14 A. In this case Black residents specifically.

15 Q. How would it make it more fair for Black

16 residents? I guess, what would be your solution to

17 the City's map? Is it the plaintiffs' maps?

18 A. Correct. Yes.

19 Q. In paragraph 11, you say, "I believe that

20 the racial classification of voters in the commission

21 map prevents fair representation on the city

22 commission." What do you mean by that statement?

23 A. As I said previously, racial gerrymandering

24 by definition dilutes the power of the racial groups

25 that they are gerrymandering. So in this case if

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1 there's a racial gerrymandering that is taking place,

2 which we believe that there is, then it follows that

3 we would not have a fair representation on the city

4 commission.

5 Q. Okay. When you're talking about dilution,

6 that means that one group of voters are being placed

7 into a particular district and they are making it such

8 that their voice, which would make a difference in the

9 other district, is being diluted. Do you agree with

10 that general definition?

11 A. Yes.

12 Q. So my question is, with the way the City

13 drew District 3, what district are the Black voters

14 being stripped from that they would have an impact on

15 that they're now being deprived of?

16 A. I'll go back to my answer. The maps that

17 we put together, you know, all four of those options

18 reflect our perspective of how Black power -- or Black

19 voting power, rather, would not be diluted.

20 Q. Mr. Johnson, I am now going to show you

21 Exhibit 8234.

22 (Thereupon, Plantiffs' Map 1 was received

23 as Defendant's Exhibit 8234 for identification.)

24 THE WITNESS: Thank you.

25 BY MR. LEVESQUE:

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1 Q. Mr. Johnson, do you recognize that

2 document?

3 A. Yes.

4 Q. Did you review and approve this document

5 before it was shared with the city commission?

6 A. I can't remember the timing, but I did

7 approve this document, yes.

8 Q. Did you have input into this document?

9 A. Provided my perspective, yes.

10 Q. Did you like the way they drew Brickell in

11 this map?

12 A. Yes.

13 Q. Do you see where they split the town of

14 Edgewater?

15 A. Yes.

16 Q. Would you agree that there are

17 neighborhoods that are not kept whole in this

18 district?

19 A. With the assumption that the boundaries of

20 Edgewater are represented by the text there, then,

21 yes, it does seem that -- at least for that

22 neighborhood there is some splitting of them.

23 Q. Are you aware that plaintiffs' maps unite

24 an area of West Miami that has never been joined in

25 single member districts?

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1 A. I'm not familiar with previous maps of

2 Miami so I'm unaware of that.

3 Q. I'm going to ask you to briefly take a look

4 at what we're going to mark as Defendant's Exhibit

5 2480.

6 (Thereupon, 1997 Plan was received

7 as Defendant's Exhibit 2480 for identification.)

8 Q. I'll represent to you that this is the

9 first redistricting plan that was originally drawn by

10 the city commission back in 1997.

11 A. Okay.

12 Q. And you can see in that area of western

13 Miami Flagami is split between District 1 and District

14 4. And even if you look back at the City's most

15 recent plan, that first page --

16 A. Yes.

17 Q. -- you see that that area of Flagami is

18 still split between District 1 and District 4.

19 A. Yes.

20 Q. Do you believe that community input is

21 important for a city commission to listen to?

22 A. Yes.

23 Q. Would you agree that a lot of times when

24 people come and speak before the City sometimes there

25 might be constituents who are advocating for things

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1 that are at odds?

2 A. Yes.

3 Q. Are you aware of anyone who came forward

4 and requested that Flagami should be united into one

5 district?

6 A. I can't recall.

7 Q. Do you know why in every version of the

8 plaintiffs' map they kept Flagami whole in one

9 district?

10 A. I can't recall the exact rationale for --

11 what is this, District 4?

12 Q. Yes.

13 A. For that specifically.

14 Q. Have you looked at or studied any of the

15 racial statistics for any of the plaintiffs' plans?

16 A. Yes. I believe the -- what I had mentioned

17 earlier that -- I still can't remember the expert's

18 name. I believe that same expert did evaluate the

19 demographical data with the maps that we had provided.

20 Q. Are you referring to Dr. Moy or Dr. Abott?

21 A. I believe it was Dr. Abott but I can't a

22 hundred percent recall the name.

23 Q. What is your understanding of the either --

24 for lack of a better term -- the goal or the

25 philosophy or the theory behind plaintiffs' Map 1?

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1 A. The philosophy is to, number one, keep

2 constrained geographical areas and then also not

3 racially gerrymandering the city.

4 Q. Are you aware that the city commission

5 publicly discussed the criteria that they wanted their

6 map drawer to follow?

7 A. I do recall -- let me ask a follow-up

8 question, just to make sure I'm understanding. In

9 regards to the remedy map -- the 2023 map?

10 Q. No.

11 A. The 2022?

12 Q. I'm referring to initially when the City

13 first started out on this little journey they passed a

14 resolution or adopted a resolution that specifically

15 directed the map drawer to consider certain criteria.

16 A. I can't recall.

17 Q. And is that you can't recall if they did it

18 or you can't recall --

19 A. No. I can't recall --

20 Q. -- the specific criteria?

21 A. Yeah. The specific criteria.

22 Q. All right. I'm going to show you what

23 we're going to mark as Defendant's Exhibit 8235.

24 (Thereupon, Plaintiffs' Map 2 was received

25 as Defendant's Exhibit 8235 for identification.)

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1 THE WITNESS: Thank you.

2 BY MR. LEVESQUE:

3 Q. Mr. Johnson, do you recognize that map?

4 A. Yes, I do.

5 Q. And in looking at that map, you would

6 recognize that there are still neighborhoods that are

7 being split, correct?

8 A. Yes.

9 Q. And, in fact, in this map Brickell gets

10 split, does it not?

11 A. It does, yes.

12 Q. And in this map are you in District 3?

13 A. Yes, I am.

14 Q. But they keep Coconut Grove whole, correct?

15 A. It does, yes.

16 Q. There were a lot of people that requested

17 that, correct?

18 A. Yes.

19 Q. In the community meetings what is your

20 understanding of how many community meetings that the

21 plaintiffs and others conducted related to getting

22 input on their plans?

23 A. I cannot recall the exact number. I

24 believe there was at least two or three.

25 Q. Are you aware of any that occurred in any

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1 of the three Hispanic super majority districts?

2 A. I am unaware.

3 Q. Are you aware of a reason why they wouldn't

4 have included meetings in any of the three Hispanic

5 districts?

6 A. I don't know.

7 Q. In drafting plaintiffs' plans, would you

8 agree that the most significantly revised districts

9 are the three Hispanic districts?

10 A. When you say the majority of the Hispanic

11 districts, are you saying Districts 1, 3, and 4?

12 Q. Yes.

13 A. Yes.

14 Q. And District 2 and District 5 are certainly

15 not exactly as they were and there are changes

16 throughout the plaintiffs' maps, I'll certainly

17 concede, but as we make our way to Map 4, they're

18 starting to look more and more like the original

19 districts. Would you agree?

20 A. The plaintiffs' Map 4?

21 Q. Yes. As we work through that process.

22 We're not there yet --

23 A. Okay. I want to make sure I didn't miss

24 anything.

25 Q. If you want to wait to answer that, just

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1 tell me. That'd be fine.

2 A. That would be -- yeah. That would be more

3 helpful if I can take a look.

4 Q. You at least recognize in this particular

5 map District 2 doesn't take Silver Bluff like it did

6 in plan one?

7 A. Correct. Yes.

8 Q. But it does come further down so that

9 District 5 and District 1 take up more of the coast,

10 correct?

11 A. Yes.

12 Q. In fact, are you aware of whether District

13 1 has ever run all the way to the coast?

14 A. 1997 does not have it running up to the

15 coast. That's the only other map that I would have

16 knowledge of.

17 Q. So at least as far as you're aware, you are

18 not aware of any other map that has it?

19 A. No. I'm not aware.

20 Q. Would you agree that some of the coastal

21 areas have very different issues than some of the more

22 inland communities?

23 A. Yes.

24 Q. Now I'm going to ask you, Mr. Johnson, if

25 you could look at plaintiffs' map 8236. I'm sorry;

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1 Defendant's Exhibit 8236.

2 (Thereupon, Plaintiffs' Map 3 was received

3 as Defendant's Exhibit 8236 for identification.)

4 THE WITNESS: Thank you.

5 Q. Do you recognize this map?

6 A. Yes.

7 Q. Do you know who or what group drew this

8 map?

9 A. Similar to the maps before, in

10 conjunction -- plaintiffs in conjunction with counsel.

11 Q. This particular map, do you know what

12 prompted it?

13 A. I can't recall the specific details.

14 Q. Do you recall whether there was a little

15 bit of consternation that was expressed because the

16 plaintiffs' first two maps did not include

17 historically Black Overtown in District 5?

18 A. I believe there was, to my recollection,

19 conversation around Overtown, keeping it in one

20 district.

21 Q. When you say there was a conversation, who

22 was a part of that conversation?

23 A. The plaintiffs. I can't recall the exact

24 members. The plaintiffs.

25 Q. Do you recall hearing anything about either

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1 members of the Black community that live in Overtown

2 or the commissioner of District 5 objecting to the way

3 the plaintiffs' maps 1 and 2 were drawn?

4 A. I vaguely remember a conversation that

5 cited the district's comments but I can't recall the

6 full nature of that conversation.

7 Q. And you see in this plan they still keep

8 Flagami whole?

9 A. Yes.

10 Q. And you have no idea why they did that?

11 A. Again, I can't recall the exact details

12 around Flagami being kept whole, no.

13 Q. Would it seem unusual to keep an area -- or

14 to draw an area into one district that has never been

15 that way and it's not being done for population

16 reasons?

17 MS. MCNAMARA: Objection to form. You can

18 answer.

19 THE WITNESS: No.

20 BY MR. LEVESQUE:

21 Q. I am now going to show you what we are

22 going to mark as Defendant's Exhibit 8237.

23 (Thereupon, Plaintiffs' Map 4 was

24 received as Defendant's Exhibit 8237 for

25 identification.)

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1 Q. Mr. Johnson, have you seen this document

2 before?

3 A. Yes.

4 Q. And this was presented to the Court as the

5 plaintiffs' preferred plan; is that correct?

6 A. Yes.

7 Q. Of the four plans that were proffered to

8 the Court as the preferred plan, which plan did you

9 prefer most?

10 A. Personal preference was map 1.

11 Q. Okay. What is your understanding of the

12 areas of Overtown?

13 A. My understanding -- clarify.

14 Q. Sure. Do you have any understanding of the

15 borders of Overtown, where they are?

16 A. I don't know the exact borders, no.

17 Q. And in this plan they still stuck you in

18 Brickell, didn't they?

19 A. Yes.

20 Q. District 3?

21 A. Yes.

22 Q. Would you agree that the configuration of

23 Districts 2 and 5 here are generally pretty similar to

24 Districts 2 and 5 in the 2013 plan?

25 A. I don't believe I have the 2013.

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1 Q. You don't. But I can fix that because I

2 think what you need is one more map.

3 A. One more map. I'll see maps in my sleep

4 now.

5 MR. LEVESQUE: We're going to mark this as

6 Defendant's Exhibit 2482.

7 (Thereupon, 2013 Plan was received as

8 Defendant's Exhibit 2482 for identification.)

9 Q. Okay. This is the 2013 plan. Comparing

10 the plaintiffs' map to the 2013 plan, would you agree,

11 and I'll stipulate they are not identical, but,

12 generally speaking, you've got two similar districts?

13 A. Yeah. Broadly speaking.

14 Q. Broadly speaking, District 5 and District

15 2, if you treat them as a whole, are pretty similar

16 with probably differences around the bottom, you know,

17 there in District 2 in Coconut Grove and north with

18 the Golden Pines area and then some of the way that

19 the downtown area is handled with District 1, District

20 5, and District 2 there, correct?

21 A. Yes.

22 Q. But what is not the same as the plaintiffs'

23 map and the 2013 plan is the configuration of the

24 Hispanic districts, correct?

25 A. Yes.

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1 Q. And, in fact, in every single one of the

2 plaintiffs' plans, whether it's plaintiffs' 1, 2, 3,

3 or 4, those three Hispanic districts are significantly

4 reworked; would you agree?

5 A. Yes. There is definitely a difference

6 between 2013 and Map 4 regarding those districts, yes.

7 Q. Is it your position that because of the

8 racial or ethnic makeup, that those districts had to

9 be redrawn that way?

10 A. Yes.

11 Q. Is it your position that when those

12 districts were redrawn, the racial and ethnic makeup

13 was going to be significantly different?

14 A. I'm sorry. Can you repeat that question?

15 Q. Is it your position that the racial and

16 ethnic makeup of plaintiffs' plans was intended to

17 alter Districts 1, 3, and 4?

18 A. The intention of the plaintiffs' plans is

19 to create five districts that are not racially

20 gerrymandered.

21 Q. The City's three districts all have super

22 majority Hispanic districts in both the 2022 plan and

23 the 2023 plan. Is it your position that because they

24 have super majority Hispanic districts they're

25 racially gerrymandered?

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1 A. Super majorities in and of themselves don't

2 a hundred percent indicate racial gerrymandering.

3 Q. How many -- you said not a hundred percent.

4 90 percent? How far does a super majority Hispanic

5 district get you for those three districts?

6 A. Racial gerrymandering is not just in the

7 context of super majority of Hispanic voters. It's

8 also statements that have been made and intentions

9 behind the creation of those districts as well.

10 Q. Would you agree that there were statements

11 made for the 2022 plan and there were statements made

12 for the 2023 plan?

13 A. Yes.

14 Q. They weren't the same. Would you agree

15 with that?

16 A. Verbatim weren't the same. Like there's

17 statements that were made before 2022 that aren't

18 verbally identical to 2023, but there are still

19 racially motivated statements in both -- preceding the

20 creation of both of those maps.

21 Q. As we sit here today, are you able to

22 identify any racially motivated statements that you

23 would point to as a basis for your claims for the 2023

24 plan?

25 A. I can't recall off the top of my head.

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1 MR. LEVESQUE: If we take about a

2 seven-minute break, I might be done.

3 MS. MCNAMARA: Okay. That works.

4 (Thereupon, a brief recess was had from

5 4:21 p.m. - 4:30 p.m..)

6 MR. LEVESQUE: We can go back on the

7 record. Mr. Johnson, I don't have any more

8 questions at this time.

9 THE WITNESS: Okay.

10 MS. MCNAMARA: I don't have very many

11 questions. But I have non-zero number of

12 questions.

13 CROSS-EXAMINATION

14 BY MS. MCNAMARA:

15 Q. So you testified earlier that you liked the

16 P1 map the most of all the maps for you personally.

17 A. Yes.

18 Q. And what about it do you like the most?

19 A. It's the only one that keeps me in my

20 preferred -- well, places me in my preferred district

21 of District 2.

22 Q. And that's District 2. Let's say they kept

23 all the districts the same but just redistributed the

24 numbers and so, let's say -- it doesn't matter but

25 we'll use P1. Let's say that we just decided in this

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1 map that the green district is actually D5 and maybe

2 the yellow district is D2, and the other three or

3 whatever, would the actual numbers attached to it

4 impact your view of what district you're in?

5 A. No.

6 Q. It's about the contents of the district,

7 not the label?

8 A. Correct. Yes.

9 Q. What else -- other than the fact that

10 Brickell where you live is unified in the plaintiffs'

11 Map 1 for District 2, what else do you like about it?

12 A. Well, I think, you know, as we talked about

13 in terms of the spirit of all four maps being not

14 intentionally -- or there's no intention of racial

15 gerrymandering at all and keeping those neighborhoods

16 together are also things that stand out.

17 Q. Now, let's just say hypothetically, instead

18 of living in Brickell that you live in Natoma Manors.

19 A. Uh-hum.

20 Q. Would you still think that P1 is the best

21 district for someone who lives in Natoma Manors --

22 P1's D2 -- I'll just -- I messed that up enough. I'll

23 restart.

24 A. It's okay.

25 Q. Let's say you lived in Natoma Manors --

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1 A. Yes.

2 Q. -- instead of in Brickell.

3 A. Okay.

4 Q. Would you still be happy with the way that

5 the districts are drawn such that Natoma Manors is

6 within District 2 along with all of Brickell and

7 everything else that's in District 2 on this P1 map?

8 A. I believe so, yes.

9 Q. Do you think, of the maps you've looked at,

10 that the Natoma Manors section of District 2 makes the

11 most sense in the P1 map or in one of the other maps,

12 however they're drawn? And you can look at all the

13 maps if you want.

14 A. And the question is -- to clarify, the

15 question was whether or not Natoma Manors makes sense

16 to be placed in District 2 in all the maps?

17 Q. Well, I mean, if you looked at all of these

18 maps --

19 A. Uh-hum.

20 Q. -- and you lived in Natoma Manors --

21 A. Right.

22 Q. -- which one would you think is the best

23 one -- and it's based on the fact that you're living

24 there and that's why you --

25 MR. LEVESQUE: Object to form.

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1 Q. -- that's why you prefer that one.

2 A. So which of the maps I would prefer to be

3 in -- would prefer if I lived in Natoma Manors? Is

4 that the question?

5 Q. Well, let me -- here's a shorter

6 question --

7 A. Sorry.

8 Q. -- that's probably easier.

9 A. Okay.

10 Q. If you lived in Natoma Manors rather than

11 Brickell --

12 A. Yeah.

13 Q. -- would P1 still be your preferred map out

14 of all the maps?

15 A. Speaking hypothetically, yes.

16 Q. Can you look at, I believe, it's D 77.

17 That's the 2023 map. Is Natoma Manors in District 3

18 in this map?

19 A. I have to make sure I remember where it

20 actually is. Hold on. It does not look to be. Maybe

21 I'm -- it's not labeled so maybe I'm --

22 Q. If I were to represent to you that the

23 bottom little foot of the green section that says like

24 Tigertail Avenue and Bayshore Drive --

25 A. Yeah. Yeah.

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1 Q. -- that that is Natoma Manors.

2 A. In this one it's District 3.

3 Q. Okay. So it looks to me as if both in

4 plaintiffs' Map 1 and in the 2023 map, that both your

5 residence in Brickell and Natoma Manors are in

6 District 3?

7 A. Correct. No. Sorry. It's 2.

8 Q. Let me rephrase that. Both your

9 neighborhood in Brickell -- your residence in

10 Brickell --

11 A. Yes.

12 Q. -- and Natoma Manors are in the same

13 district in both the 2023 map and in plaintiffs' Map

14 1?

15 A. Yes. Correct.

16 Q. Which district between the 2023 map and

17 plaintiffs' Map 1 do you think better represents

18 Natoma Manors and Brickell if you just considered them

19 and, I guess, the part that connects them?

20 A. Sure. I would say plaintiffs' Map 1. I'm

21 just trying to understand the question. I think I

22 understand it. I just --

23 Q. I'm thinking if I want to ask more

24 questions beyond that.

25 Do you think that the preference of

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1 districts depends on the location or on the person who

2 lives at that location for determining that person's

3 preference?

4 A. Does the preference for the district depend

5 on the location or --

6 Q. I can --

7 A. I just feel like I'm in a very hypothetical

8 space so it's really hard for me to, like, navigate

9 it.

10 Q. You said that if you lived in Natoma

11 Manors --

12 A. Yeah.

13 Q. -- you would most prefer the P1 that is in

14 District 2 which also happens to include where you

15 currently live in Brickell?

16 A. Yes. And I'm probably biased because I'm

17 currently living in Brickell so it's really hard for

18 me to...

19 Q. Do you think that any person randomly

20 picked who lived in Natoma Manors would feel the same

21 way or do you think that, depending on who the person

22 is who lives in Natoma Manors, they might have

23 different opinions about whether they liked P1 versus

24 the 2023?

25 MR. LEVESQUE: Object to form.

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1 THE WITNESS: It's possible that there may

2 be a difference of opinion there.

3 BY MS. MCNAMARA:

4 Q. But for you there wouldn't be?

5 MR. LEVESQUE: Object to form.

6 THE WITNESS: Based on the map as it

7 exists, the plaintiffs' Map 1, hypothetically, I

8 don't know if I would have an issue with this map

9 if I lived in Natoma Manors.

10 BY MS. MCNAMARA:

11 Q. Do you know anybody who lives in Natoma

12 Manors?

13 A. No, I don't.

14 MS. MCNAMARA: No further.

15 REDIRECT EXAMINATION

16 BY MR. LEVESQUE:

17 Q. Mr. Johnson, you were asked about which

18 version of the maps make the most sense to you.

19 A. Uh-hum.

20 Q. And you indicated plaintiffs' version --

21 plaintiffs' plan one made the most sense to you; is

22 that correct?

23 A. Made the most -- that's the preferred -- I

24 recall being asked the preferred map and I said, yes,

25 plaintiffs' Map 1.

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1 Q. But I think in the context of

2 identifying -- well, I think you also indicated that

3 plaintiffs' plan one would better represent Brickell

4 and Natoma Manors. Did I understand that correctly?

5 A. My recollection was, in response to the

6 question is, if I hypothetically were a resident of

7 Natoma Manors would I be comfortable with the way in

8 which plaintiffs' Map 1 was drawn and I,

9 hypothetically, said yes.

10 Q. What makes Brickell and Natoma Manors ideal

11 areas that should be united in one district?

12 A. What makes -- what makes Brickell and

13 Natoma Manors ideal to be --

14 Q. In the same district.

15 A. You know, I -- I don't have all the details

16 in terms of all the characteristics of Natoma Manors

17 and Brickell. Again, I know that the spirit of this

18 map was created to both create constrained

19 geographical areas as well as, you know, ensure that

20 these areas are not racially gerrymandered. So that

21 is the extent at which I understand and as long as

22 that is the intent of this map -- you know, being in

23 Natoma Manors with that being the intent of the map

24 being drawn illustrates the reason why I answered the

25 question the way I did.

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1 Q. And when you talk about the intent of the

2 map, one of the things that you've been critical of

3 the City are public statements about why they were

4 drawing the maps or public statements describing three

5 Hispanic districts, a Black district, and an Anglo

6 district?

7 A. Sure.

8 Q. You would agree that when the plaintiffs

9 drew their plans, the public wasn't present, there was

10 nobody recording --

11 A. Sure.

12 Q. -- nobody knows what the plaintiffs were

13 thinking --

14 A. Sure.

15 Q. -- and, at least at this point in time,

16 with one more day of discovery -- two more days of

17 discovery left, there's nobody that is testifying

18 about how they did anything when it comes to the

19 thought processes and what was considered --

20 A. Sure.

21 Q. -- for drawing the plaintiffs' plans?

22 Would you agree with that?

23 A. Yes.

24 MR. LEVESQUE: That's all.

25 MS. MCNAMARA: All right.

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1 MR. LEVESQUE: Read or waive?

2 MS. MCNAMARA: Read.

3 MR. LEVESQUE: And we'll take a copy.

4 THE COURT REPORTER: And, Ms. McNamara, do

5 you want a copy?

6 MS. MCNAMARA: I will want a copy.

7 THE COURT REPORTER: Okay. Thank you. We

8 are off the record.

9 (Thereupon, the taking of the

10 deposition was concluded at 4:42 p.m.

11 Signature and formalities were not waived.)

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1 CERTIFICATE OF OATH WITNESS

2 STATE OF FLORIDA )

COUNTY OF MIAMI-DADE )

3

4 I, the undersigned authority, certify that

5 JARED A. JOHNSON personally appeared before me on

6 October 18, 2023 and was duly sworn.

7 WITNESS my Hand and Official Seal this

8 2nd day of November, 2023.

9

10

11

 <%12689,Signature%>

12 BEATRIZ VALDES-PRIETO

 Notary Public - State of Florida

13 Commission No. HH 005266

 Expires 6-23-2024

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1 REPORTER'S DEPOSITION CERTIFICATE

2 STATE OF FLORIDA:

 SS.

3 COUNTY OF DADE:

4

 I, BEATRIZ VALDES-PRIETO, Florida Professional

5

Reporter and Notary Public in and for the State of

6

Florida at Large, do hereby certify that I was

7

authorized to and did stenographically report in

8

shorthand the deposition of Jared A. Johnson, a

9

witness called by the defendant in the above styled

10

cause; that the reading and signing of the deposition

11

were not waived by the witness; that the foregoing

12

pages, numbered from 1 to 93, inclusive, constitute a

13

true and complete record of my stenographic notes.

14

 I further certify that I am not a relative,

15

employee, attorney or counsel of any of the parties,

16

nor am I a relative or employee of any of the parties'

17

attorney or counsel connected with the action, nor

18

financially interested in the action.

19

 Dated this 2nd day of November, 2023.

20

21

22

 <%12689,Signature%>

23 BEATRIZ VALDES-PRIETO,

 Florida Professional Reporter

24

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1 VERITEXT LEGAL SOLUTIONS

 One Biscayne Tower

2 2 S. Biscayne Boulevard - Suite 2250

 Miami, Florida 33131

3

November 2, 2023

4

TO: Mr. Jared Johnson

5 c/o Caroline McNamara, Esq.

 ACLU

6 4343 West Flagler Street

 Suite 400

7 Miami, FL 33134

 cmcnamara@aclufl.org

8

Re: Grace, Inc., et al. vs. City of Miami

9 Deposition of: Jared A. Johnson

Taken: October 18, 2023

10 Veritext Job Number: 6162475

11 The above-referenced transcript is available

for review.

12 Mr. Johnson should read the testimony to

verify its accuracy. If there are any changes,

13 Mr. Johnson should note those with the reason on

the attached Errata Sheet.

14 Mr. Johnson should, please, date and sign the

Errata Sheet and e-mail to the deposing attorney

15 as well as to Veritext at Transcriptsfl@veritext.com and copies will be e-mailed to

16 all ordering parties.

 It is suggested that the completed errata be

17 returned 30 days from receipt of testimony, as

considered reasonable under Federal rules*;

18 however, there is no Florida statute to this

regard.

19 If the witness fails to do so, the transcript

may be used as if signed.

20

21 Yours,

22 Veritext Legal Solutions

23

24 *Federal Civil Procedure Rule 30(e)/Florida

25 Civil Procedure Rule 1.310(e).

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1 Re: Grace, Inc., et al. vs. City of Miami

Deposition of: Jared A. Johnson

2 Taken: October 18, 2023

3 E R R A T A S H E E T

4 PAGE____ LINE____ CHANGE_______________________

5 _______________________________________________

6 REASON___________________________________________

7

PAGE____ LINE____ CHANGE_______________________

8

_______________________________________________

9

REASON___________________________________________

10

11 PAGE____ LINE____ CHANGE_______________________

12 _______________________________________________

13 REASON___________________________________________

14 PAGE____ LINE____ CHANGE_______________________

15 _______________________________________________

16 REASON___________________________________________

17

PAGE____ LINE____ CHANGE_______________________

18

_______________________________________________

19

REASON___________________________________________

20

21 PAGE____ LINE____ CHANGE_______________________

22 _______________________________________________

23 REASON___________________________________________

24

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break 26:1

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claimed 27:8

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clause 66:4

clear 19:15

24:22

clearest 6:12

clients 9:18

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Federal Rules of Civil Procedure 

Rule 30

(e) Review By the Witness; Changes.

(1) Review; Statement of Changes. On request by the 

deponent or a party before the deposition is

completed, the deponent must be allowed 30 days 

after being notified by the officer that the

transcript or recording is available in which:

(A) to review the transcript or recording; and

(B) if there are changes in form or substance, to 

sign a statement listing the changes and the

reasons for making them.

(2) Changes Indicated in the Officer's Certificate.

The officer must note in the certificate prescribed 

by Rule 30(f)(1) whether a review was requested

and, if so, must attach any changes the deponent 

makes during the 30-day period.

DISCLAIMER: THE FOREGOING FEDERAL PROCEDURE RULES 

ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY.

THE ABOVE RULES ARE CURRENT AS OF APRIL 1,

2019. PLEASE REFER TO THE APPLICABLE FEDERAL RULES 

OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.

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