1 IN THE UNITED STATES DISTRICT COURT

 FOR THE SOUTHERN DISTRICT OF FLORIDA

2

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

3

4 GRACE, INC., et al.,

5 Plaintiffs,

6 -vs7 CITY OF MIAMI,

8 Defendant.

 ____________________________________/

9

10 DEPOSITION OF: CLARICE COOPER

11 DATE: Monday, October 9, 2023

12 TIME: 9:00 a.m. - 12:30 p.m.

13

 PLACE: GRAY ROBINSON, P.A.

14 333 SE 2nd Avenue

 Suite 3200

15 Miami, Florida 33131

16

17 STENOGRAPHICALLY

 REPORTED BY: VANESSA OBAS, RPR

18

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1 A P P E A R A N C E S:

2

3

 CHRISTOPHER J. MERKEN, ESQUIRE

4 OF: DECHERT LLP

 929 Arch Street

5 Philadelphia, Pennsylvania 19104

 christopher.merken@dechert.com

6

 -and7

8 CAROLINE ANDREWS MCNAMARA, ESQUIRE

 OF: ACLU OF FLORIDA

9 4343 W Flagler Street

 Suite 400

10 Miami, Florida 33134

 cmcnamara@aclufl.org

11 APPEARING ON BEHALF OF THE PLAINTIFF(s)

12

13 GEORGE T. LEVESQUE, ESQUIRE

 OF: GRAY ROBINSON, P.A.

14 301 S Bronough Street

 Suite 600

15 Tallahassee, Florida 32301

 george.levesque@gray-robinson.com

16 APPEARING ON BEHALF OF THE DEFENDANT

17

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 - - -

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1

 I N D E X

2

 PAGE

3

TESTIMONY OF CLARICE COOPER

4

DIRECT EXAMINATION BY MR. LEVESQUE 5

5 CROSS-EXAMINATION BY MR. MERKEN 103

6 CERTIFICATE OF OATH 107

CERTIFICATE OF REPORTER 108

7 ERRATA SHEET 109

Read & Sign Letter to Witness 110

8

9

10 ------

11 S T I P U L A T I O N S

12 It is hereby stipulated and agreed by and between

13 the counsel for the respective parties and the deponent

14 that the reading and signing of the deposition

15 transcript be reserved.

16 ------

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1 E X H I B I T S

2

 DESCRIPTION PAGE

3

Defendant's Exhibit Number 24-80 1997 Plan 24

4 Defendant's Exhibit Number 24-81 2003 26

 Districts

5 Defendant's Exhibit Number 24-82 2013 Plan 27

Defendant's Exhibit Number 24-83 2022 City 29

6 Commission

 Plan

7 Defendant's Exhibit Number 82-24 2023 City 49

 Plan

8 Defendant's Exhibit Number 82-34 Map 1 58

Defendant's Exhibit Number 82-35 Map 2 60

9 Defendant's Exhibit Number 82-36 Map 3 63

Defendant's Exhibit Number 82-37 Map 4 69

10 Defendant's Exhibit Number 24-37 Affidavit 80

Defendant's Exhibit Number 24-13 February 7th 92

11 , 2022,

 transcript

12 of the Miami

 City

13 Commission

Defendant's Exhibit Number 24-14 February 25 94

14 th, 2022,

 transcript

15 of the Miami

 City

16 Commission

Defendant's Exhibit Number 24-16 March 11th, 96

17 2022,

 transcript

18 of the Miami

 City

19 Commission

 meeting

20

21

22 ------

23

24

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1 P R O C E E D I N G S

2 *********

3 THE COURT REPORTER: Please raise your right

4 hand.

5 Do you solemnly swear or affirm that the

6 testimony you're about to give in this cause is the

7 truth, the whole truth, and nothing but the truth?

8 THE WITNESS: I do.

9 THEREUPON

10 CLARICE COOPER

11 was called as a witness and, having first been duly

12 sworn, testified as follows:

13 THE COURT REPORTER: Thank you.

14 DIRECT EXAMINATION

15 BY MR. LEVESQUE:

16 Q. Good morning, Ms. Cooper. My name is George

17 Levesque. I represent the City of Miami in this case.

18 Obviously, you're a plaintiff.

19 Before we get started, have you ever been

20 deposed before?

21 A. No.

22 Q. Okay. Have you ever testified in court before?

23 A. No.

24 Q. Okay. What I'm going to do is I'm going to go

25 over some of the ground rules. So far, you've been

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1 doing great.

2 One of the things that's happening while we're

3 talking this morning is the court reporter is taking

4 down everything we say. Occasionally, they can get like

5 a head nod or a headshake, but what will really help her

6 transcribe what we're saying, if you answer audibly.

7 So if there's a "yes" or a "no," I might sit

8 here and look at you and see you nodding your head or

9 shaking your head and understand exactly what you mean,

10 but if I say, "Is that a 'yes'?" I'm not doing it to be

11 rude.

12 A. Uh-huh.

13 Q. I'm just trying to make sure we get it for the

14 record.

15 And I'm probably not going to be the best at

16 it. Your counsel probably will be more alert to it

17 because sometimes I just get lost in the conversation.

18 I also tend to talk low and sometimes I talk

19 fast. So if there's ever a time where you don't

20 understand what I said or didn't understand my question,

21 please ask me to repeat it. If you answer the question

22 that I asked, I'm going to assume that you understood

23 the question. Is that fair?

24 A. Yes.

25 Q. Okay. And you understand that you're under

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1 oath?

2 A. Yes.

3 Q. Are you under any medication that would impair

4 your ability to testify this morning?

5 A. No.

6 Q. And this is not intended to be the Spanish

7 Inquisition. If at any point you need to take a break,

8 please let me know. We've got bathrooms right around

9 the corner. But one of the things that I will ask is,

10 if there's a question pending, let's go ahead and answer

11 that question and then we can take a break. This way,

12 the record is clean.

13 At different times I may ask a question that

14 might be poorly worded or a question that your counsel

15 doesn't like. Go ahead and let him get his objection on

16 the record, and then I might ask you to answer the

17 question. I might have a colloquy with your counsel to

18 ask him, you know, about his objection to maybe clarify

19 my question for you.

20 At different times he may instruct you not to

21 answer. I can't give you legal advice, but generally I

22 would advise that people follow the advice of their

23 counsel.

24 What did you do to prepare for this deposition?

25 A. Reread notes.

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1 Q. Okay. And when you say "reread notes," what

2 notes were you referring to?

3 A. The complaint that was filed.

4 Q. Okay. And there have been three versions of

5 complaints that have been filed. There was the initial

6 complaint, the first amended complaint, and the

7 supplemental complaint.

8 Which complaints did you review?

9 A. Probably the latter.

10 Q. Okay.

11 A. The latter.

12 Q. Okay. Would that be the supplemental

13 complaint?

14 A. Yes.

15 THE COURT REPORTER: I'm sorry. Before we

16 start, may I take appearances for the record?

17 MR. LEVESQUE: Oh, yes.

18 George Levesque on behalf of the City of Miami.

19 MR. MERKEN: Christopher Merken on behalf of

20 Ms. Cooper and the plaintiffs.

21 MS. MCNAMARA: Caroline McNamara on behalf of

22 Ms. Cooper and the plaintiffs.

23 THE COURT REPORTER: Okay. Thank you.

24 BY MR. LEVESQUE:

25 Q. Other than the complaint, did you look at any

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1 other documents?

2 A. No.

3 Q. Other than your attorneys, did you speak to

4 anyone else about this deposition?

5 A. No.

6 Q. And I know you're not supposed to ask a woman

7 her age, but can you let us know when you were born --

8 your birthday.

9 A. .

10 Q. And where were you born?

11 A. Miami, Florida.

12 Q. And are you a lifelong resident of Miami?

13 A. Yes, I am.

14 Q. So you've seen a lot of changes over the years,

15 then?

16 A. Yes.

17 Q. But what is your highest level of education?

18 A. Bachelor's degree.

19 Q. And where is that from?

20 A. Howard University in Washington, D.C.

21 Q. And what is your degree in?

22 A. Political science.

23 Q. Okay. And are you married?

24 A. No.

25 Q. Have you ever been married?

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1 A. No.

2 Q. Any children?

3 A. No.

4 Q. Are you currently employed?

5 A. No. Retired.

6 Q. Where did you retire from?

7 A. "Miami Herald."

8 Q. Okay. And what did you do at the "Miami

9 Herald"?

10 A. I was account executive in the advertising

11 division.

12 Q. And how long were you employed at the "Miami

13 Herald"?

14 A. 29 years.

15 Q. Okay. And when did you retire?

16 A. 2013.

17 Q. Have you ever been arrested?

18 A. No.

19 Q. Have you ever been charged with a crime?

20 A. No.

21 Q. Have you ever been a plaintiff in a lawsuit

22 before?

23 A. In an administrative complaint, I have.

24 Q. And what was that administrative complaint

25 relating to?

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1 A. The trolley barn on the corner of where I live

2 in Coconut Grove.

3 Q. And can you provide a little more information

4 about that.

5 A. That was for the residents in my neighborhood,

6 including myself. We objected to the construction of a

7 trolley barn. We were in the city of Miami. The City

8 of Coral Gables wanted to put the trolley barn in our

9 neighborhood, and we objected to it because of all of

10 the negative ramifications that it was going to cause.

11 So I was asked -- there were other lawsuits as

12 well. I was asked to file an administrative complaint

13 with the department of transportation.

14 Q. Okay. And how did that administrative

15 complaint resolve?

16 A. We didn't get the trolley barn there anymore.

17 Q. Okay. So you were successful, then?

18 A. Yes.

19 Q. Okay.

20 MR. MERKEN: Ms. Cooper, just if you can wait

21 for him to finish his question --

22 THE WITNESS: Oh.

23 MR. MERKEN: -- completely, just so that the

24 court reporter has the --

25 THE WITNESS: Okay. I'm sorry.

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1 MR. MERKEN: I just wanted to -- I just wanted

2 to make sure.

3 MR. LEVESQUE: And, Ms. Court Reporter, I'll do

4 my best not to speak over her.

5 THE COURT REPORTER: Sure.

6 BY MR. LEVESQUE:

7 Q. Were there any other lawsuits that you were

8 involved with as a plaintiff?

9 A. No.

10 Q. What about as a defendant?

11 A. No.

12 Q. And what is your current address?

13 A. 3735 Oak Avenue, Miami, Florida 33133-4806.

14 Q. And how long have you resided at that address?

15 A. Since 1981.

16 Q. And in relation to the current 2023 enacted

17 plan -- and I'm talking about the plan that the City

18 passed earlier this year -- I'll refer to that as the

19 "2023 plan" -- what district do you reside in, in that

20 plan?

21 A. District 2.

22 Q. Okay. And in the 2022 plan that the Court also

23 preliminarily enjoined that the City passed back in

24 March 2022, what district did you reside in, in that

25 plan?

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1 A. District 2.

2 Q. And in the 2013 plan that was in force from

3 2013 through 2022, what district did you reside in?

4 A. District 2.

5 Q. And have you resided in District 2 ever since

6 the City first drew districts?

7 A. Yes.

8 Q. So that would start with the 1997 plan?

9 A. (Witness nodding.)

10 Q. Proceeding to the 2023 plan?

11 A. Yes.

12 Q. Do you have any plans to move in the near

13 future?

14 A. No.

15 Q. And where are you registered to vote?

16 A. Precinct?

17 Q. Oh, no. Just the -- the area that you're --

18 are you registered to vote in the city of Miami?

19 A. Yes.

20 Q. Are you registered to vote at the 3735 Oak

21 Avenue address?

22 A. Yes.

23 Q. Is that the address that's reflected on your

24 driver's license?

25 A. Yes.

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1 Q. And are you registered under Caroline Cooper?

2 A. Clarice.

3 Q. Clarice. I apologize.

4 A. That's okay.

5 Yes.

6 Q. We're talking to Ms. Donaldson this

7 afternoon --

8 A. I know.

9 Q. -- and if the names are similar --

10 A. Right.

11 Q. Have you ever been registered to vote under a

12 different name?

13 A. No.

14 Q. Okay. Ms. Cooper, I am going to show you a

15 document. And I don't know if I'm going to mark it as

16 an exhibit yet or not, but I'm going to give you a

17 moment to look at that document.

18 MR. LEVESQUE: We can go off the record while

19 she looks at the document.

20 THE COURT REPORTER: Sure.

21 (A discussion was held off the record.)

22 MR. LEVESQUE: Back on record.

23 BY MR. LEVESQUE:

24 Q. Ms. Cooper, have you had the opportunity to

25 review that document?

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1 A. Yes.

2 Q. Have you seen that document before?

3 A. Yes.

4 Q. Did you see that document before it was filed

5 with the court?

6 A. No.

7 Q. If I could refer you to page 5, paragraph 25.

8 And there, in that sentence, it says "Plaintiff

9 Clarice Cooper is a Black resident of the West Grove in

10 District 2."

11 Do you agree with that statement?

12 A. Yes.

13 Q. It references "the West Grove".

14 What is the West Grove to you?

15 A. Well, the City of Miami's police department has

16 five districts in which they identify how they're going

17 to command those areas, and we happened to be in Coconut

18 Grove, and then the Coconut Grove district is broken

19 down into different districts, and we happened to be in

20 the West Grove district. And that was something that

21 was -- a designation that was given maybe about 20 years

22 ago or so. And the area became to be known as West

23 Grove.

24 Q. And let me ask you about that.

25 There's -- and you'll have to bear with me

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1 because I'm not from Miami. But you mentioned the West

2 Grove and other parts of Coconut Grove. What are the

3 other parts of Coconut Grove that you would recognize?

4 A. South Grove, Center Grove, North Grove.

5 Q. Any other parts?

6 A. There's a part that goes towards Mercy

7 Hospital.

8 Q. And that's different than West, South, Center,

9 and North?

10 A. Right.

11 Q. Okay.

12 A. Yes.

13 Q. Are there any parts of The Grove that you would

14 recognize? Other than West Grove, South Grove --

15 A. No.

16 Q. -- Center Grove, North, and the part that goes

17 to the Mercy Hospital?

18 A. Well, the Center part being -- including the

19 commercial area -- primarily commercial area, which we

20 call "The Village".

21 Q. Okay. And those five areas that you just

22 described, are those the five districts -- like, police

23 districts that you referenced?

24 A. Primarily, yes.

25 Q. Okay. You would agree that there are probably

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1 other ways that The Grove could be broken up as well,

2 wouldn't you?

3 A. Yes.

4 Q. And would you also agree that the boundaries of

5 what constitutes Coconut Grove as a whole are not

6 exactly clear?

7 A. They're clear. To me, they are clear, yes.

8 Q. Okay. So you know exactly where Coconut Grove

9 starts and where it stops in terms of its borders?

10 A. Yes.

11 Q. Okay. Can you describe what those boundaries

12 are?

13 A. Those are with the North US 1.

14 Q. Okay.

15 A. The west -- and this is a crude -- a crude

16 boundary, Le Jeune Road -- Le Jeune Road in some parts,

17 Douglas Road in other parts. Depends on how far north

18 or south you are. Biscayne Bay to the south in some

19 parts. In other parts, it's actual named streets where

20 it combines with -- or colludes [sic] with the city of

21 Coral Gables, and that would be going towards the -- the

22 west. Like, Douglas Road, that area.

23 And then as far as the east, I would say US 1

24 in the area where Vizcaya is, Bay Heights. As I say,

25 these are crudely designed.

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1 Q. Uh-huh.

2 Now, you mentioned Vizcaya and Bay Heights.

3 A. Uh-huh.

4 Q. Are those within Coconut Grove or are those --

5 A. Uh-huh.

6 Q. -- the boundaries?

7 A. That's within Coconut Grove.

8 Q. Okay. And those boundaries that you just

9 described, do those also correlate to the five city

10 police district boundaries that would be there in terms

11 of the -- the outer boundaries?

12 A. Yes.

13 Q. Are you aware of whether there are any other

14 ways that someone might define The Grove, either by

15 community redevelopment districts or any other type of

16 taxing district or any other type of, like, neighborhood

17 classification?

18 A. Yes.

19 Q. Okay. What are some of the other ones that

20 you're aware of?

21 A. Community redevelopment districts. Opportunity

22 zones. Target urban areas.

23 Q. And do those borders for, like, a community

24 redevelopment district or opportunity zone or a target

25 urban area match exactly the descriptions that you just

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1 laid out?

2 A. Not for the entire Coconut Grove.

3 Q. Okay.

4 A. Just in certain parts of it.

5 Q. Okay. And, Ms. Cooper, if I could ask you to

6 flip to page 6, paragraph 30.

7 And in that paragraph, it asserts that you were

8 placed in District 2 where you are not the predominant

9 racial group.

10 Do you see where it says that?

11 A. Yes.

12 Q. What is the predominant racial group in

13 District 2?

14 A. Caucasian, white American.

15 Q. And when you identify Caucasian as the

16 predominant group, what are you basing that on?

17 A. White non-Hispanic.

18 Q. Okay. White non-Hispanic.

19 And what are you basing that on?

20 A. Knowing the neighborhoods and who resides in

21 those neighborhoods.

22 Q. Have you looked at any demographic statistics

23 for that area, either for the 2022 plan or the 2023

24 plan?

25 A. Not in detail, no.

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1 Q. Okay. Do you recall seeing whether white

2 non-Hispanics make up a majority of residents in that

3 district?

4 A. No.

5 Q. Do you recall any -- seeing any statistics that

6 Hispanic voters would make up a majority in that

7 district?

8 A. No.

9 Q. Do you know what percentage of Black residents

10 would be comprised in that district?

11 A. I can make an estimate.

12 Q. Okay.

13 A. Would that be okay?

14 Q. Sure.

15 A. About 25 percent.

16 Q. And that estimate of 25 percent, what is that

17 based on?

18 A. The area where I reside in West Grove.

19 Q. Now, you've resided in that area since -- was

20 it 1981?

21 A. Since 1950. I've always lived in Coconut

22 Grove.

23 Q. Okay.

24 A. So 73 years.

25 Q. Okay. Since you've been alive, has Coconut

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1 Grove gone through any level of gentrification?

2 A. Yes.

3 Q. Okay. How long has it been going -- undergoing

4 gentrification?

5 A. 15 years, roughly.

6 Q. Going back to that first amended complaint, it

7 says "The enacted plan sends the message that their

8 commissioner's job is to represent the predominant

9 group; not them."

10 If I understand that statement correctly -- and

11 you can let me know if my paraphrase is accurate -- it's

12 saying that you, as a resident of District 2, feel like

13 the way the City drew the maps, it was intended to

14 represent white non-Hispanic voters. Is that an

15 accurate reflection of what that statement is intended

16 to convey?

17 A. Yes.

18 Q. And is that the way that you feel about the

19 district that you live in, in the 2023 plan?

20 A. Yes.

21 Q. If you could draw District 2, how would you

22 draw District 2?

23 A. Pretty much the same way it was before the

24 change -- before the commission made the change where

25 US 1 was our boundary. Because we're mostly like a

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1 coastal -- a coastal district. Make US 1 the boundary,

2 and then we end it at the bay.

3 Q. Okay. You can set the first amendment aside.

4 Ms. Cooper, I am going to show you another

5 document. I don't know if I'm going to mark this one

6 either. But I will give you the opportunity to look at

7 that.

8 MR. LEVESQUE: And we can go off the record

9 while she reviews it.

10 (A discussion was held off the record.)

11 MR. LEVESQUE: Back on record.

12 BY MR. LEVESQUE:

13 Q. Ms. Cooper, have you had the opportunity to

14 review that document?

15 A. Yes.

16 Q. Is that the supplemental complaint that you

17 reviewed in preparation for your deposition?

18 A. Yes. Yes.

19 Q. If I could ask you to flip to page 3.

20 And before I ask you that, did you see that

21 document before it was filed?

22 A. No.

23 Q. Have you discussed that document with anyone

24 other than your attorneys?

25 A. No. No.

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1 Q. And in paragraph 16, it makes a similar

2 allegation related to you being placed in a district

3 where you are not the predominant racial group. Based

4 upon the current population of the city of Miami, do you

5 think it's possible to be -- for you to be placed in a

6 district where you are with the predominant racial

7 group?

8 A. Yes. I think so, yes.

9 Q. Okay. And how would that district be drawn?

10 A. That would depend on a move that's underway

11 about getting more districts in the city of Miami, other

12 than the five that we have now.

13 Q. Okay. So the way that you might achieve that,

14 if I understand it correctly, is you would increase the

15 number of districts in the city from five to some higher

16 number --

17 A. Yes.

18 Q. -- to create smaller districts?

19 A. Yes.

20 Q. And you said there's a plan underway to

21 accomplish that. Do you know who's spearheading that

22 plan?

23 A. No. That's just in talks, really. It's talks.

24 Q. Other than drawing -- increasing the number of

25 districts and drawing smaller districts, are you aware

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1 of any way that you might be placed in a district where

2 you would be a part of the predominant group?

3 A. No.

4 Q. You would agree that it probably wouldn't make

5 sense to link the West Grove up with District 5;

6 correct?

7 A. No.

8 Q. And I'm sorry. No, that you --

9 A. No.

10 Q. No, you wouldn't agree or, no, that wouldn't

11 make sense?

12 A. It wouldn't make sense, no.

13 Q. Okay. And that's not something you're seeking

14 to do in this litigation, is it?

15 A. No.

16 Q. Okay. I think we can set that one aside.

17 (Defendant's Exhibit Number 24-80, 1997 Plan,

18 was marked for Identification.)

19 MR. LEVESQUE: And this is one that I will mark

20 as Defendant's Exhibit 24-80. And we're marking

21 them based upon the docket entry.

22 BY MR. LEVESQUE:

23 Q. Ms. Cooper, have you seen configuration of

24 those districts before that are reflected in that 1997

25 plan?

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1 A. Yes.

2 Q. And does that reflect, to the best of your

3 knowledge, the way the districts looked when the City

4 transitioned from citywide elections to district

5 elections?

6 A. Yes.

7 Q. And in that picture, Coconut Grove is all in

8 District 2; correct?

9 A. Yes.

10 Q. Prior to 1997, what's your understanding of how

11 city commissioners were elected?

12 A. It was citywide, at large.

13 Q. Do you know what the impetus for moving to

14 district elections was?

15 A. Primarily to have better representation for the

16 citizenry in the different districts.

17 Q. And when you're referencing "the citizenry in

18 the different districts," was that for all citizenry?

19 A. All citizenry.

20 Q. Were you an advocate during that time for

21 moving to single-member districts?

22 A. Yes, I was.

23 Q. Do you remember if you advocated for a certain

24 number of districts?

25 A. No.

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1 Q. What are the things that you did as part of

2 your advocacy back during that time to encourage city

3 commissioners to move to single-member districts?

4 A. Other than making sure neighbors and friends

5 and family members were registered to vote and that they

6 were more in tune with what was going on with city

7 politics and county, statewide, federal, and that that

8 was resolved.

9 Q. And do you recall what the outcome of the first

10 elections under those districts were?

11 A. Yes.

12 Q. Okay. And with those first elections, they

13 elected three Hispanic commissioners; correct?

14 A. Yes.

15 Q. And they elected a Black commissioner?

16 A. Yes.

17 Q. And they elected a white commissioner?

18 A. Yes.

19 (Defendant's Exhibit Number 24-81, 2003

20 Districts, was marked for Identification.)

21 BY MR. LEVESQUE:

22 Q. Ms. Cooper, I am going to show you another

23 exhibit that we're going to mark Defendant's

24 Exhibit 24-81.

25 MR. MERKEN: Thank you.

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1 BY MR. LEVESQUE:

2 Q. Ms. Cooper, looking at that picture, does that

3 appear to be the districts as they were drawn in 2003?

4 A. Yes.

5 Q. And do you recall the general outcome of

6 elections that were held under those districts?

7 A. Yes.

8 Q. And those districts elected three Hispanic

9 commissioners; is that correct?

10 A. Yes.

11 Q. And one Black commissioner?

12 A. Yes.

13 Q. And one white commissioner?

14 A. Yes.

15 Q. And in the 2003 plan, your district was

16 District 2?

17 A. Yes.

18 Q. And that's the white district?

19 A. Yes.

20 Q. Did you have a problem being drawn in a

21 district that was a white district for either the 1997

22 plan or the 2003 plan?

23 A. No.

24 (Defendant's Exhibit Number 24-82, 2013 Plan,

25 was marked for Identification.)

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1 BY MR. LEVESQUE:

2 Q. Okay. Ms. Cooper, I'm going to show you what

3 we're going to mark as Defendant's Exhibit 24-82.

4 Now, Ms. Cooper, what I've shown you is what

5 I'll represent to you is the 2013 plan for which

6 elections from 2013 through 2021 were conducted.

7 Does that configuration of districts look

8 familiar to you?

9 A. Yes.

10 Q. And your district in that map is still

11 District 2; correct?

12 A. Yes.

13 Q. And District 2 was still a district that would

14 perform for a white representative?

15 A. Yes.

16 Q. And Districts 1, 3, and 4 would still perform

17 for Hispanic candidates?

18 A. Yes.

19 Q. And District 5 would perform for a Black

20 candidate?

21 A. Yes.

22 Q. And were you okay being placed in a white

23 district in that plan?

24 A. Yes.

25 Q. Do you know the last commissioner to be elected

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1 from that district?

2 A. District 2?

3 Q. District 2.

4 A. (Witness nodding.)

5 Q. And who was the last commissioner to be elected

6 from District 2 in that plan?

7 A. Since -- up until what time?

8 Q. The last one elected before we transition to a

9 new map.

10 A. Ken Russell.

11 Q. Ken Russell?

12 And do you know if he's white or Japanese

13 American or somewhere in between both?

14 A. He's white.

15 Q. Okay.

16 A. Even though he is Japanese American as well,

17 yeah.

18 Q. Okay.

19 A. And he also speaks Spanish, so --

20 Q. He's got a leg up on me.

21 A. Yeah. Right.

22 (Defendant's Exhibit Number 24-83, 2022 City

23 Commission Plan, was marked for Identification.)

24 BY MR. LEVESQUE:

25 Q. Now, I'm going to show you what we're going to

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1 mark as Defendant's Exhibit 24-83.

2 MR. MERKEN: Thank you.

3 BY MR. LEVESQUE:

4 Q. And, Ms. Cooper, do you recognize this plan?

5 A. Yes.

6 Q. Is this the plan that the city commission

7 passed in 2022?

8 A. Yes.

9 Q. And in this plan, you still reside in

10 District 2; correct?

11 A. Yes.

12 Q. Are you aware if any elections have been held

13 under that particular plan?

14 A. No.

15 Q. Who's the current commissioner for District 2?

16 A. Sabina Covo.

17 Q. And she replaced Commissioner Russell; correct?

18 A. Yes.

19 Q. Do you know if she was elected from this

20 district?

21 A. Yes.

22 Q. And Commissioner Covo is Hispanic; correct?

23 A. Yes.

24 Q. And so at least under this plan, the only

25 election that has occurred elected a Hispanic

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1 representative; not a white representative; correct?

2 A. Yes.

3 Q. Do you have a problem residing in that

4 District 2?

5 A. The way it is now?

6 Q. In that -- in that particular plan, yes.

7 A. Yes, I do.

8 Q. Okay. What are your objections to that

9 District 2?

10 A. That we have District 4 and District 3 loops

11 down into what was formerly District 2.

12 Q. And District 4 is a district that's represented

13 by a Hispanic commissioner; is that correct?

14 A. Yes. Manolo Reyes.

15 Q. And District 3 is also represented by a

16 Hispanic commissioner?

17 A. Yes. Joe Carollo.

18 Q. Now, what is your understanding of the

19 reasons -- let me back up.

20 What is your understanding of why the city

21 commission needed to redistrict in 2022?

22 A. My understanding is it had a lot to do with the

23 results of the census.

24 Q. And --

25 A. And equally proportioning voters -- the

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1 citizens into the five districts.

2 Q. Because of the population growth in the city --

3 A. Yes.

4 Q. -- the districts became out of balance. Would

5 you agree with that?

6 A. Yes.

7 Q. And District 2 was overpopulated. Would you

8 agree with that?

9 A. Yes.

10 Q. And so District 2 needed to get rid of

11 population to give to the other districts; correct?

12 A. Yes.

13 Q. Is it --

14 Now, in the 2022 plan, one of the areas where

15 the city commission did that was at the bottom, in this

16 little area right here where there's sort of a triangle

17 is what I'll call it --

18 A. Right.

19 Q. -- using US 1 as the long border.

20 Is that part of the West Grove?

21 A. No.

22 Q. What part of The Grove is that?

23 A. That borders Bird Road [sic] and 27th Avenue.

24 It's still Coconut Grove.

25 Q. In terms of the five areas of The Grove that we

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1 talked about, what area of The Grove would that

2 particular triangle fit in?

3 A. Probably North Grove.

4 No, let me -- let me change that. West Grove.

5 Q. You --

6 A. That would be West Grove because it's west of

7 27th Avenue.

8 Q. And moving east on that map, there is what some

9 have referred to as a little "foot" that District 3

10 intrudes into.

11 A. Uh-huh.

12 Q. Do you know why that foot was drawn there?

13 A. Yes.

14 Q. And what's the reason that foot was drawn

15 there?

16 A. So that Joe Carollo's property would be

17 included in that -- in that district.

18 Q. And you would agree including Commissioner

19 Carollo's property in the district, for whatever reason

20 that might be, has nothing to do with racial reasons for

21 drawing the district that way; correct?

22 A. I don't know.

23 Q. Okay. Why wouldn't you know that?

24 A. I'm sorry. I'm sorry.

25 Well, okay. Yes. Yeah. So I'll say yes --

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1 Q. Okay.

2 A. -- to that.

3 Q. And just so we're clear for the record, what

4 are you saying yes -- yes to?

5 A. That I think it was racially motivated.

6 Q. It was racially motivated?

7 A. Yeah, I think so.

8 Q. And why was it racially motivated?

9 A. It was sort of like diluting the influence of

10 District 2.

11 Q. And how did it dilute the influence of

12 District 2?

13 A. Well, in our -- in Coconut Grove, we -- long

14 term, we've -- throughout The Grove, we've depended on

15 each other for support for anything that we wanted to

16 project as far as improvements in our areas.

17 And I think having that district broken up like

18 that, that was taken away from any support we were going

19 to have, any backup leverage that we would have for The

20 Grove at large. Especially what we were trying to get

21 done in the West Grove.

22 Q. Well, let me ask about that.

23 That area of The Grove that is in the foot, is

24 that a fairly affluent area of The Grove?

25 A. Yes.

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1 Q. Would they have the same type of needs that

2 areas of the West Grove would have?

3 MR. MERKEN: Objection. Speculation.

4 BY MR. LEVESQUE:

5 Q. If you know.

6 MR. MERKEN: You can answer.

7 THE WITNESS: I can answer?

8 No.

9 BY MR. LEVESQUE:

10 Q. What are some of the type of needs that the

11 residents of the West Grove need?

12 A. We need adequate housing, affordable housing,

13 more police patrolling, better infrastructure, better

14 job opportunities, rebuilding our economic development

15 structure. We had a once-vibrant commercial corridor,

16 which has, like, tanked, and we're trying to get that

17 back to what it was before. So we have some serious

18 issues.

19 Q. And that area of the foot, when we classify the

20 different parts of The Grove, what part of The Grove

21 would that be?

22 A. That would be -- well, just like it says,

23 Natoma -- Natoma Park, Bay Heights area --

24 Q. Okay.

25 A. -- they are flushed a little bit to the north

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1 part of -- what we consider North Grove.

2 Q. Okay.

3 A. Because, see, that's near where the museum used

4 to be, the science museum, which has moved downtown, but

5 they're across from Victoria -- Vizcaya.

6 Q. Okay.

7 A. And the Mercy Hospital area.

8 Q. And so those areas, they've already got pretty

9 good infracture?

10 A. Yes.

11 Q. They probably don't have quite the same issue

12 in terms of needing good-paying jobs? Housing?

13 A. (Witness nodding.)

14 Q. Going back to the little triangle that we

15 talked about in that area of West Grove, do you feel

16 that incursion of District 4 into District 2 was drawn

17 for racial reasons?

18 A. Yes.

19 Q. And what's your basis for believing that?

20 A. Again, that was taking away population from

21 West Grove and also throwing it into another district

22 and enhancing that district's ability to get more

23 resources.

24 Q. Are you aware of whether the commissioners in

25 District 4 and District 3 have invested in particular

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1 areas of their districts that they've been in for a

2 little while?

3 A. Yes.

4 Q. Do you have any basis for believing that the

5 commissioners of District 4 and District 3 wouldn't

6 invest in your communities that were added in that 2022

7 plan?

8 A. I have doubts.

9 Q. Okay. And what's -- what are your doubts and

10 what causes them?

11 A. Promises that have been made that haven't been

12 fulfilled.

13 Q. Is there anything else?

14 A. You're asking for my honest opinion; right?

15 Q. Yes, ma'am.

16 A. Yes. Okay.

17 Q. I don't mean to be pretentious about it, but

18 you are under oath. So I'm hoping that I'm getting the

19 truth from you.

20 A. Okay. What was your question again? I'm

21 sorry.

22 Q. You know, I've forgotten.

23 MR. LEVESQUE: If you could repeat it.

24 THE COURT REPORTER: Sure.

25 (Thereupon, the question was read back by the

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1 reporter as above recorded.)

2 THE WITNESS: It's based a lot on those

3 commissioners' backgrounds.

4 BY MR. LEVESQUE:

5 Q. Okay.

6 A. And I feel that they would be more willing to

7 entertain the interests of people of their backgrounds

8 more so than of my background.

9 Q. Okay. Ms. Cooper, I tend to be a little

10 direct, so I'm going to see if I can say what you are

11 being very diplomatic about saying.

12 Do you have concerns about whether a Hispanic

13 commissioner could adequately represent you and meet

14 your needs as a Black resident?

15 A. Yes.

16 Q. Okay. Has that changed with Commissioner Covo,

17 who is a Hispanic representative?

18 A. Yes.

19 Q. Now, looking at that configuration of

20 District 2, we've talked about the little triangle.

21 We've talked about the foot.

22 Is there anything else about that district that

23 we haven't discussed that you would find objectionable?

24 A. In the Coconut Grove area, the entire district?

25 Q. The entire district.

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1 A. Well, it's the fact that those two areas were

2 added and they weren't there before. And I just find it

3 hard to understand as to why they're there now.

4 Q. Uh-huh.

5 For this particular plan, do you believe the

6 commission drew the district to perform for a white

7 candidate or a Hispanic candidate?

8 A. Hispanic.

9 Q. Do you think it would be appropriate for the

10 city commission to draw it for a white candidate?

11 A. No.

12 Q. Do you think it would be appropriate for the

13 city commission to draw it for a Hispanic candidate?

14 A. No.

15 Q. Do you think it would be appropriate for the

16 City to just have a coastal district?

17 A. You mean as it was before?

18 Q. Well, just as a coastal district generally. In

19 whatever configuration it is, they're drawing it as a

20 coastal district because those residents have different

21 needs than those that live inland?

22 A. Yes.

23 Q. Now, it's your belief that the district that's

24 reflected in this map was drawn to favor Hispanic

25 candidates. Did I understand that correctly?

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1 A. Yes.

2 Q. What do you base that on?

3 A. Well, just the current demographics. The

4 Hispanic population exceeds the other populations --

5 dominant populations, which would be Black and white

6 non-Hispanic, and the more influence that would give

7 that population as far as the city government is

8 concerned.

9 Q. You would agree that the city of Miami is a

10 majority Hispanic city?

11 A. Yes.

12 Q. In fact, you could probably describe it as a

13 supermajority Hispanic city; correct?

14 A. Yes.

15 Q. And so as a result of having Hispanics as a

16 larger percentage of the overall population, they're

17 probably going to have greater representation. Wouldn't

18 you agree?

19 A. Yes.

20 Q. And then that naturally means that if you're

21 part of those smaller racial groups, whether it be

22 Black, Caucasian non-Hispanic or white non-Hispanic,

23 American Indian, or some other -- Japanese American,

24 you're going to have less proportional representation in

25 terms of racial influence, if that's what's motivating

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1 you. Wouldn't you agree with that?

2 A. Yes.

3 Q. Do you have any opinions or any objections to

4 the other districts that are reflected in this map?

5 A. Well, I was -- had some concerns. Of course,

6 I'm not as familiar with the other districts as I am my

7 own as I've only lived in Coconut Grove my entire life.

8 But I am somewhat familiar with the other areas. And I

9 was also worried about the diluting of influence of

10 Black residents in other parts of the city.

11 Q. Okay. And when you refer to "the diluting of

12 the influence of Black residents in the other parts of

13 the city," would that be the Black residents in

14 District 5?

15 A. Yes.

16 Q. Now, Ms. Cooper, are you a member of GRACE?

17 A. Yes, I am.

18 Q. And what does GRACE stand for? That's an

19 acronym; right?

20 A. Yes. Grove Rights and Community Equity,

21 Incorporated.

22 Q. And what is GRACE?

23 A. We're an organization that was established in

24 2019. Established for the sole purpose of protecting

25 the economic interests of people in Coconut Grove --

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1 West Coconut Grove, to be specific. And at this point,

2 we go by three names, Coconut Grove: West Grove,

3 Village West, Little Bahamas of Coconut Grove.

4 Q. And when you say, "We go by three names" --

5 A. In Coconut Grove, where I live.

6 Q. Coconut Grove?

7 A. Yeah.

8 Q. Okay. Okay.

9 So when somebody says "West Grove" or -- and I

10 was writing fast.

11 A. Village West.

12 Q. Village West.

13 A. Or Little Bahamas of Coconut Grove.

14 Q. So that would all refer to the same general

15 geographic area?

16 A. Yes.

17 Q. Okay. And how did that group get started?

18 A. Actually, it was an initiative of the Coconut

19 Grove Ministerial Alliance.

20 Q. What is the Coconut Grove Ministerial Alliance?

21 A. That's an organization that's been in existence

22 since -- in the '50s, I'm sure. Because I remember that

23 when it got started, ministers from the different

24 churches in that neighborhood. And they were

25 interested, as other groups were, in providing -- having

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1 a collective body to represent most or all of the

2 organizations in our neighborhood.

3 Q. Okay. And you mentioned ministers from

4 different churches. What type of churches were those?

5 A. Different denominations. You have Episcopal.

6 AME, African Methodist Episcopalian. Oh, you have

7 Baptist, Missionary Baptist, Church of Christ -- just

8 about 10 or 12 churches that's involved.

9 Q. Were they primarily Black denomination

10 churches?

11 A. Yes.

12 Q. Okay. And were they also the Coconut Grove

13 Ministerial Alliance? Was that also sort of like a

14 quasi-civil rights organization as well?

15 A. You can say that because the foundation of the

16 civil rights movement globally and nationally was based

17 in the churches.

18 Q. Uh-huh. Okay.

19 A. And then the churches were established during

20 the segregation era. So primarily Black -- Black

21 ministers. Black parishioners in the Black

22 neighborhoods.

23 Q. Now, what was your involvement in the creation

24 of GRACE?

25 A. Well, the organization that I'm involved in,

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1 Coconut Grove Village West Homeowners and Tenants

2 Association, we're also a foremost group in Coconut

3 Grove that was established in 1954, and they were trying

4 to bring in some of these lead organizations that had

5 been around forever to take part in the efforts of

6 GRACE.

7 Q. And who reached out to you to be a part of

8 GRACE?

9 A. Some members of the Ministerial Alliance.

10 Q. Okay. And who were those members?

11 A. The chair of the Ministerial Alliance.

12 Q. And what is his or her name?

13 A. Apostle John Chambers.

14 Q. And is he your minister?

15 A. No.

16 Q. And since its creation in 2019, do you hold any

17 titles with GRACE?

18 A. Yes.

19 Q. What are your -- what are the titles that

20 you've held?

21 A. Treasurer -- board member and treasurer.

22 Q. And have you been treasurer and board member

23 since inception?

24 A. Yes.

25 Q. How many board members does GRACE have?

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1 A. Presently, eight.

2 Q. Eight?

3 A. Yes.

4 Q. And do all eight of them live in the area of

5 the West Grove?

6 A. No.

7 Q. Do most of them live in the area of the West

8 Grove?

9 A. Half.

10 Q. Half?

11 What are the sources of GRACE's funding?

12 A. We've obtained grants from different sources.

13 Q. Are those government grants or are those

14 private-issued grants?

15 A. They're private.

16 Q. And what are some of the organizations that

17 have given you a grant?

18 A. One is Allegheny. Allegheny Foundation.

19 Q. Is that spelled --

20 A. Just like the Allegheny area, region.

21 Q. Okay. A-L-L-E-G-H-E-N-Y?

22 A. -G-H-E-N-Y.

23 Q. Okay. Feels good that I spelled it just as

24 good as you.

25 A. And also FIU, Florida International University.

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1 Q. Are there any other grant organizations that

2 you receive funds from?

3 A. (Witness shaking head.)

4 MR. LEVESQUE: I'll tell you what. Why don't

5 we take a short five-minute break, if that works?

6 MR. MERKEN: Okay.

7 (Thereupon, a recess was taken in the

8 deposition, after which the deposition continued as

9 follows:)

10 MR. LEVESQUE: Okay. Back on the record.

11 BY MR. LEVESQUE:

12 Q. Earlier, you had mentioned that you had your

13 doubts about whether the current commissioner,

14 Commissioner Covo, would adequately represent your

15 interests in District 2. What is your basis for that

16 belief?

17 A. That I had doubts about her --

18 Q. Whether she would represent your interests as a

19 Black resident in District 2.

20 A. I guess because I didn't have that much

21 knowledge about her at the time.

22 Q. Okay. Has there been anything in the interim,

23 since she's taken office, that you would point to as

24 something that has raised concerns in your mind about

25 whether she would adequately represent your interests?

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1 A. No.

2 Q. Would you agree that District 2 is probably one

3 of the more diverse districts in the city of Miami?

4 A. Yes.

5 Q. It's diverse ethnically?

6 A. Ethnically and racially.

7 Q. Economically?

8 A. Economically, yes.

9 Q. And so whoever's elected to that district,

10 whether they're Hispanic, white, or even Black, they've

11 got their work cut out for them because they've got a

12 very diverse district. Wouldn't you agree?

13 A. Yes.

14 Q. And sometimes those interests, whether they're

15 racial, ethnic, or economic, they're competing interests

16 of all of those different groups, aren't they?

17 A. Yes.

18 Q. And, ultimately, it's left up to the

19 commissioner who's representing those interests to do

20 the best job they can. Wouldn't you agree with that?

21 A. Yes.

22 Q. For District 2, how do you think Commissioner

23 Covo has done?

24 A. She's doing an adequate job.

25 Q. Okay.

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1 A. Yes. She understands the issues.

2 Q. For Commissioner Russell, how did you think he

3 performed in the role?

4 A. Admirably.

5 Q. Do you know how long Commissioner Russell was

6 in that position?

7 A. Yeah. He served one full term and

8 three-quarters of another term -- second term.

9 Q. Do you know if that was his first time holding

10 public office?

11 A. Yes, it was.

12 Q. Do you know if this is Commissioner Covo's

13 first time holding public office?

14 A. Yes, it is.

15 Q. And you were a resident of the district at the

16 time Commissioner Russell first came into office;

17 correct?

18 A. Yes.

19 Q. And when he first came into office, do you feel

20 he was performing admirably from day one, or was there a

21 ramp-up period?

22 A. Yes.

23 Q. And I apologize. My question was --

24 A. Yes.

25 Q. -- probably a poor question.

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1 Was that yes, he was performing --

2 A. Yes, he --

3 Q. -- admirably from day one, or --

4 A. Yes.

5 Q. -- yes, there was a ramp-up period?

6 Yes, there was a ramp-up period?

7 A. Yes.

8 Q. Oh.

9 A. Well, from the start.

10 Q. Okay. From the start he performed admirably?

11 A. Right.

12 (Defendant's Exhibit Number 82-24, 2023 City

13 Plan, was marked for Identification.)

14 BY MR. LEVESQUE:

15 Q. Okay. Ms. Cooper, I am now going to show you

16 what we're going to mark as Defendant's Exhibit 82-24.

17 Do you recognize that as the City's plan that

18 they enacted in 2023?

19 A. Yes.

20 Q. And you would agree that in that plan, they

21 removed that little triangle that we first talked about

22 when we were looking at the 2022 plan; correct?

23 A. Yes.

24 Q. Was that a plan that -- or was that a move that

25 you supported?

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1 A. No.

2 Q. You did not support moving that area of the

3 West Grove --

4 A. Oh, yes.

5 Q. -- back into District 2?

6 A. Yes.

7 Q. Okay. So, again, just so we're clear for the

8 record, the little triangle that would have been just to

9 the west of where it says "North Grove," that was put

10 back into District 2, you would support that move;

11 correct?

12 A. Uh-huh.

13 MR. MERKEN: Can you give an --

14 THE WITNESS: Yes. I'm sorry. Yes.

15 BY MR. LEVESQUE:

16 Q. Okay. And then there's still that little foot

17 area that picks up Commissioner Carollo's house;

18 correct?

19 A. Yes.

20 Q. And do you believe Commissioner Carollo is

21 being included -- his house is being included in that

22 district for racial reasons?

23 A. Yes.

24 Q. Okay. And what are the racial reasons?

25 A. To get more Hispanic representation.

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1 Q. Is that more Hispanic representation in

2 District 3, or is it more Hispanic representation in

3 District 2?

4 A. In 3.

5 Q. Do you know what the Hispanic representation in

6 District 3 is in that plan -- what percentage?

7 A. No. But it's high.

8 Q. In fact, it's high in District 1, 3, and 4;

9 correct?

10 A. Uh-huh, yes.

11 Q. Those are all supermajority Hispanic districts?

12 A. Yes.

13 Q. So I guess what is the effect of increasing the

14 Hispanic representation in District 3, in your mind?

15 And that's a poor question. Let me go back and

16 sort of set that up a little differently.

17 You indicated that you thought that area was

18 added to District 3 to increase the Hispanic percentage

19 in District 3.

20 A. Yes.

21 Q. Would you agree that doing that would have the

22 effect of potentially decreasing the Hispanic

23 representation in District 2?

24 A. Not necessarily, no.

25 Q. Not necessarily?

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1 A. No.

2 Q. What effect do you believe those changes had on

3 District 2?

4 A. That the influence of District 2, especially in

5 Coconut Grove -- that our influence was diminished.

6 Q. And why was your influence in Coconut Grove

7 diminished?

8 A. Because we were losing some of the residents

9 that we had previously, and considering some of the

10 issues that we had before us, we needed all the support

11 we can get from other residents of Coconut Grove -- or

12 from our district.

13 Q. You would agree that the city commission is a

14 representative body?

15 A. Representative of whom? All of us?

16 Q. The electors. People vote for them. The

17 people that they vote for represent their interests.

18 A. Yes.

19 Q. They might represent certain segments of their

20 electorate better than others. Is that your belief?

21 A. Yes.

22 Q. But in the grand sense of representation, each

23 district gets one commissioner that represents their

24 interests; correct?

25 A. Yes.

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1 Q. In this map, The Grove is split between two

2 commissioners; correct?

3 A. Yes.

4 Q. Commissioner Covo would be one and Commissioner

5 Carollo --

6 A. Carollo.

7 Q. -- would be the other; is that correct?

8 A. Yeah, but I'm still thinking that Reyes has

9 representation there, too. It's a little sliver over

10 here. Let me see here.

11 Yeah, just north of the highway and west of

12 37th Avenue.

13 Q. I'd like to ask you to circle on your map

14 there --

15 A. The area that I'm talking about?

16 Q. Yes, ma'am.

17 A. Okay. There.

18 Q. Okay. And in looking at that area, I see what

19 I believe is a railroad track and --

20 A. Yeah, that's the Metrorail alignment.

21 Q. Okay. Do you know if that is following US 1

22 there or not?

23 A. Yeah, US 1 is -- yeah, US 1. Yeah.

24 Q. Okay.

25 A. And this is an area over here that Manolo Reyes

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1 picked up as to why he's partially in Coconut Grove --

2 Q. Okay.

3 A. -- or what used to be District 2.

4 Q. Now, that area that you circled there, is that

5 considered part of Coconut Grove even though it's on the

6 other side of US 1?

7 A. Well, I wouldn't consider it Coconut Grove. A

8 lot of people do because of the history -- because, see,

9 you're talking about Coral Gables over here, and there

10 are a lot of Black residents there historically. And so

11 the communities were interconnected. As a matter of

12 fact, a lot of people don't even know which city they

13 live in, whether it's Miami or Coconut Grove. But he

14 does have representation of this, which was formerly

15 District 2.

16 Q. Okay. And you mentioned people being confused

17 about which city they live in --

18 A. Uh-huh.

19 Q. -- and it not being very clear.

20 Is that the only area where there's confusion

21 about whether it's part of The Grove or not?

22 A. This little -- that's the corridor right in

23 here.

24 Q. Okay.

25 A. And even down in South Grove, some people I

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1 think I've talked to are confused about where they live.

2 Because, see, they're crude -- have real crude

3 boundaries here.

4 Q. Okay. But the city's boundary isn't very crude

5 at all. I mean, the city's boundary stops --

6 A. Right.

7 Q. -- right there on the western edge.

8 On that map, could I ask you to roughly mark --

9 I'll give you your pen back.

10 Could I ask you to roughly mark where you

11 reside on that map. And if you could put an X.

12 A. Okay.

13 Q. And I understand the roads are going to be

14 small, but we can kind of ballpark it.

15 Okay. All right. Thank you.

16 Would it be fair to say that your concerns with

17 District 2 primarily relate to the southern portion of

18 the district that involves Coconut Grove?

19 A. Yes.

20 Q. And so do you have any specific objections to

21 the way the City drew the northern part of the district?

22 A. Yes.

23 Q. Okay. What are your objections to what -- to

24 the way the City drew the northern part of the district?

25 A. Well, going to the east part with Natoma Manors

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1 and Bay Heights --

2 Q. Uh-huh.

3 A. -- those were areas that were taken away from

4 District 2. And as I said, as far as the diluting of

5 the influence of Coconut Grove -- because that's all

6 considered Coconut Grove -- that made a difference in --

7 in the makeup of District 2.

8 Q. Okay. How did those changes affect the makeup

9 of District 2?

10 A. Took away a substantial number of residents,

11 because those are heavily developed areas. Like, a lot

12 of residences. They're single-family homes and

13 otherwise, yeah.

14 Q. Okay.

15 A. And these people closely identify with

16 District 2 and Coconut Grove.

17 Q. Okay.

18 A. And that -- you know, our whole district. And

19 the commission -- the commissioner who represented us.

20 Q. When you say they took away residents, did they

21 take away residents of a particular race, or was it just

22 the reduction --

23 A. Just the residents that were --

24 Q. -- just the reduction of residents, the number?

25 A. Yes.

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1 Q. Okay. And we discussed it earlier, but you

2 were aware that District 2 was overpopulated, so they

3 needed --

4 A. Uh-huh.

5 Q. -- to get rid of residents; right?

6 A. Uh-huh.

7 Q. And that had to happen somewhere; correct?

8 MR. MERKEN: I just wanted to make sure that

9 there was a "yes."

10 THE WITNESS: Yes.

11 MR. LEVESQUE: And did you get the affirmative

12 response to the previous --

13 THE WITNESS: Yes.

14 THE COURT REPORTER: I did.

15 BY MR. LEVESQUE:

16 Q. And one of the things that you also mentioned

17 was -- with your concerns with the map, maybe more

18 broadly, is the potential dilution of the Black voting

19 power in District 5. Did I understand that correctly?

20 A. Yes.

21 Q. Okay. Do you feel either the '22 plan -- 2022

22 plan or the 2023 plan diluted the voting power of Black

23 voters?

24 A. No.

25 Q. So at least in drawing District 5, you felt the

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1 city commission did a reasonably decent job in ensuring

2 that District 5 complied with the Voting Rights Act?

3 A. Yes.

4 (Defendant's Exhibit Number 82-34, Map 1, was

5 marked for Identification.)

6 MR. LEVESQUE: Okay. We're going to mark this

7 next exhibit as Defendant's Exhibit 82-34.

8 BY MR. LEVESQUE:

9 Q. And, Ms. Cooper, have you seen this document

10 before?

11 A. Yes.

12 Q. Do you recall if you saw this document before

13 or after it was filed with the court?

14 A. Probably before.

15 Q. Okay. Did you approve this document?

16 A. Personally?

17 Q. Yes, ma'am.

18 A. No.

19 Q. Are there things about this map that you

20 disagree with?

21 A. Yes.

22 Q. What are the things about this map that you

23 disagree with?

24 A. Well, going back to the Overtown area, which

25 has been predominantly African American or Black, or

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1 whatever, that was truncated and included other areas

2 that didn't really make any sense to me as the way the

3 layout of the city is in that part of the city.

4 Q. Okay. Are there any other districts in this

5 map that do not make sense to you?

6 A. Well, all of them, really. Every one.

7 Compared to how they were drawn before.

8 Q. Okay. Is it fair to say you don't like the

9 configurations of the districts in this map?

10 A. No. No, I don't.

11 Q. You're still in District 2, though; correct?

12 A. Yes.

13 Q. And do you know the -- the likely race that a

14 candidate from District 2 would be -- a successful

15 candidate from District 2 would be?

16 A. As far as their racial background?

17 Q. Yes, ma'am.

18 A. Yes.

19 Q. What would that be?

20 A. Starting in 5, up in the yellow portion, that

21 would probably be Black. It swing in the Overtown,

22 Omni, downtown Allapattah area. That could either be

23 Black or Hispanic.

24 3, which is the purple, that would definitely

25 be Hispanic. Flag- -- Flagami, Grapeland Heights,

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1 Auburndale, that would be Hispanic.

2 And it's a swing also here with the Silver

3 Bluff, Coconut Grove, Brickell. That would either be

4 white non-Hispanic or Hispanic.

5 Q. So in that map, your likely representative

6 would either be white non-Hispanic or Hispanic based

7 upon your understanding of the racial makeup of --

8 A. Yes.

9 Q. -- District 2; is that correct?

10 A. Yes.

11 Q. Other than your attorneys, have you discussed

12 the -- plaintiffs' Map 1 with anyone?

13 A. No.

14 (Defendant's Exhibit Number 82-35, Map 2, was

15 marked for Identification.)

16 MR. LEVESQUE: I'm going to mark this as

17 Defendant's Exhibit 82-35.

18 MR. MERKEN: Thank you.

19 BY MR. LEVESQUE:

20 Q. And what I've shown you as plaintiffs' Map 2,

21 have you seen this document before?

22 A. Yes.

23 Q. Did you review this document before it was

24 filed with the court?

25 A. No.

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1 Q. Did you ever approve this document?

2 A. No.

3 Q. Do you like the configuration of these

4 districts?

5 A. Yes.

6 Q. And in this map, you're still in District 2;

7 correct?

8 A. Yes.

9 Q. And in this map, District 2 is pretty similar

10 to the current district, is it not?

11 And let me clarify that question. In this

12 version of plaintiffs' Map -- plaintiffs' Map 2,

13 District 2 is similar to the way it was drawn in 2013.

14 Would you agree with that?

15 A. Yes.

16 Q. It's still a coastal district; correct?

17 A. Yes, still coastal.

18 Q. And in this map, Coconut Grove is kept whole

19 except for that little sliver that we've talked about;

20 correct?

21 A. Yes.

22 Q. So you don't have a problem with the little

23 sliver not being in Coconut Grove in this map, do you?

24 A. No.

25 Q. Okay. Is there a reason why there would be a

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1 problem with that little sliver not being included in

2 the 2023 plan but okay to not be included in the --

3 plaintiffs' Map 2?

4 A. Well, I wouldn't have any objection because

5 that area's primarily industrial.

6 Q. Okay. So going back to the 2023 plan that

7 we've discussed, you wouldn't have a problem -- you

8 don't really have a problem with the City not including

9 that little industrial sliver in District 2, do you?

10 A. No.

11 Q. For District 5, do you know if that district

12 diminished -- strike that.

13 Do you know if that district decreased the

14 percentage of Black voting-age population or Black

15 citizen voting-age population in that district from the

16 2013 plan?

17 A. Yes, it did. For that district, yes.

18 Q. Okay. Do you know if for that district,

19 District 5, whether that included all of Overtown or

20 whether Overtown was split in that district?

21 A. Overtown was split.

22 Q. Are you a member of either the Miami-Dade NAACP

23 or the South Miami-Dade NAACP?

24 A. No. No.

25 Q. Neither organization?

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1 A. No. I have national membership, but not --

2 Q. Not with any of the local affiliates?

3 A. No.

4 (Defendant's Exhibit Number 82-36, Map 3, was

5 marked for Identification.)

6 BY MR. LEVESQUE:

7 Q. Ms. Cooper, I am going to show you what we're

8 marking as Defendant's Exhibit 82-36.

9 And this is Plaintiffs' Map 3. Have you seen

10 this map before?

11 A. Yes.

12 Q. Do you recall if you saw this map before it was

13 filed with the court?

14 A. No.

15 Q. Have you ever been asked to approve this map?

16 A. No.

17 Q. Then, you would agree that this map still

18 splits Overtown?

19 A. Yes.

20 Q. Is this configuration of District 2 acceptable

21 to you?

22 A. Yes.

23 Q. Is it fair to say that your primary concerns

24 with District 2 are what I'll refer to as the southern

25 portions of the district that involve Coconut Grove?

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1 A. Yes.

2 Q. Do you have opinions about how the northern

3 part of the district, from Brickell up to Edgewater,

4 should be configured?

5 A. Yes.

6 Q. And how should those be configured?

7 A. I still think the Morningside, Upper East Side

8 area should be contained more into District 2.

9 Q. Populationwise, do you know if it's possible to

10 include the Morningside areas in District 2, if it's

11 configured in this matter?

12 A. I think that may have been affected because of

13 the change in the population from the census.

14 Q. Because District 2 was overpopulated?

15 A. Yes.

16 Q. And they needed to get rid of that population

17 and give it to another district?

18 A. Yes.

19 Q. Do you know if any of the changes that were

20 made in plaintiffs' Plan 1, 2, or 3 were drawn with the

21 intent to favor a particular race?

22 A. No.

23 Q. No, you don't know?

24 A. Rephrase the question. I'm sorry.

25 Q. Sure.

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1 Let's start with District 5 and Plan 1.

2 Do you believe that was drawn with the aim of

3 electing a Black candidate?

4 A. Yes.

5 Q. District 1 in Map 1, do you believe that was

6 drawn with the aim of electing a Black or Hispanic

7 candidate?

8 A. Same map we're talking about? Map 1?

9 Q. Map 1.

10 A. Yeah. Yes.

11 Q. And for District 3, do you believe that was

12 drawn with the aim of electing a Hispanic candidate?

13 A. Same map?

14 Q. Same Map 1.

15 A. "District 3," you said?

16 Q. Yes, ma'am.

17 A. Yes. Yes.

18 Q. And for Map 1, District 4, that was also drawn

19 with the aim of electing a Hispanic candidate; correct?

20 A. Yes.

21 Q. Let's talk about Map 2, then.

22 Do you believe -- well, before we go to Map 2,

23 District 2, do you believe that was drawn with the aim

24 of electing a candidate of a particular race?

25 A. Yes.

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1 Q. And what race do you believe that was drawn to

2 be?

3 A. White non-Hispanic or Hispanic.

4 Q. And what's your basis for that?

5 A. Just what I perceive as the racial makeup of

6 that district, as I know it.

7 Q. Okay. All right. Let's talk about Map 2,

8 then. And we're only talking about Map 2, but we'll

9 kind of run through the same questions.

10 For District 1, do you believe that was drawn

11 with the aim of electing a Hispanic candidate?

12 A. No.

13 Q. Okay. Do you believe that was drawn with the

14 aim of electing a candidate of a particular race or

15 ethnicity?

16 A. Yes.

17 Q. And what race or ethnicity was that drawn with

18 the aim to --

19 A. Black.

20 Q. Black?

21 A. Black.

22 Q. And for District 2 in that district -- I'm

23 sorry. For District 2 in that Map 2, what race was

24 District 2 designed to elect?

25 A. White non-Hispanic or Hispanic.

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1 Q. And District 3, what race was that designed

2 to -- or what race was that district designed to elect?

3 A. Hispanic.

4 Q. Is that the same for District 4 as well?

5 A. Yes.

6 Q. And District 5 was drawn to elect a Black

7 candidate?

8 A. Primarily, yes. But Hispanic as well. I would

9 say that that's a swing area, too.

10 Q. Okay. So plaintiffs' Map 2 could swing Black

11 or Hispanic, in your opinion?

12 A. Yes.

13 Q. Do you know if it was drawn to be a swing

14 district?

15 A. Yes.

16 Q. And let me just kind of -- my question was "Did

17 you know?" Let me ask the follow-up question.

18 Was it drawn to be a swing district?

19 A. I don't know.

20 Q. Well, now you've confused me, Ms. Cooper.

21 A. I'm sorry. I'm sorry.

22 Q. That's okay. We're here to --

23 A. I'm sorry.

24 Q. -- sort those things out.

25 I asked if you knew whether it was drawn, and

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1 you said, "Yes." And then when I asked you if it was

2 drawn, you said, "I don't know."

3 A. Yeah. Well -- okay. I feel that it was drawn

4 to be that way --

5 Q. Okay.

6 A. -- as a swing district because of the racial

7 makeup of those areas.

8 Q. Okay. And that helps me out tremendously.

9 So now we can go back to Map 3. And we'll run

10 through the questions for this.

11 For District 1, do you believe District 1 was

12 drawn to elect a particular race or ethnicity?

13 A. Yes.

14 Q. And what race or ethnicity was District 1 drawn

15 to elect?

16 A. Hispanic.

17 Q. Hispanic?

18 For District 2, what race or ethnicity in Map 3

19 was that drawn to elect?

20 A. White non-Hispanic or Hispanic.

21 Q. And for District 3, what race or ethnicity was

22 that drawn to elect?

23 A. Hispanic.

24 Q. And the same question for District 4.

25 A. Hispanic.

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1 Q. And District 5?

2 A. Black.

3 Q. Okay. For District -- well, hold that

4 question.

5 (Defendant's Exhibit Number 82-37, Map 4, was

6 marked for Identification.)

7 BY MR. LEVESQUE:

8 Q. I am now going to show you what we'll mark as

9 Defendant's Exhibit 82-37.

10 MR. MERKEN: Thank you.

11 BY MR. LEVESQUE:

12 Q. Ms. Cooper, have you seen this map before?

13 A. Yes.

14 Q. And did you see it before it was filed with the

15 court on July 6th, 2023?

16 A. Yes.

17 Q. Did you approve this map for filing with the

18 court?

19 A. Personally?

20 Q. Yes, ma'am.

21 A. Was I asked personally?

22 Q. Yes, ma'am.

23 A. For my opinion on it?

24 Q. Yes, ma'am.

25 A. I'm sure I gave my opinion.

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1 Q. Okay.

2 A. And I approved it.

3 Q. And in this map, District 1, what race or

4 ethnicity is that likely to elect, in your opinion?

5 A. Black.

6 Q. And do you believe it was drawn to elect a

7 Black representative?

8 A. Yes.

9 Q. And District 2 is substantially similar to

10 District 3. Do you believe that was also designed to

11 elect a white non-Hispanic representative or a Hispanic

12 representative?

13 MR. MERKEN: Objection.

14 THE WITNESS: These are over in Districts 2 and

15 3. But in District 3, probably Hispanic, I'm

16 saying, because those demographics have changed.

17 BY MR. LEVESQUE:

18 Q. Okay. But we're talking about District 2.

19 A. Oh, District 2? Okay.

20 Q. What race or ethnicity do you believe that was

21 designed to elect?

22 A. White non-Hispanic or Hispanic.

23 Q. And I have the attention span of a gnat, so --

24 I know you said what you thought District 3 was. What

25 race or ethnicity do you believe District 3 was designed

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1 to elect?

2 A. Primarily Hispanic.

3 Q. And then for District 4?

4 A. Hispanic.

5 Q. And then, finally, District 5?

6 A. 5 or 4?

7 Q. 5.

8 A. Black.

9 Q. And that version of plaintiffs' Map 4, do you

10 know if that splits Overtown at all?

11 A. No, I don't think it's split.

12 Q. Are you familiar with the borders of Overtown?

13 A. Somewhat.

14 Q. Are there areas of the borders where people

15 might consider Overtown -- strike that question.

16 Are there areas of that area that some people

17 might consider part of Overtown and others might not

18 depending on whether they're working off of community

19 redevelopment --

20 A. Yes.

21 Q. -- district definition --

22 MR. MERKEN: Objection. Objection.

23 Speculation.

24 BY MR. LEVESQUE:

25 Q. Are the areas of what is considered Overtown

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1 crystal clear in your mind?

2 A. Yes.

3 Q. Okay. And why are they crystal clear in your

4 mind?

5 A. Because of my familiarity with that area.

6 Q. Okay. And do you base your familiarity just on

7 walking around?

8 A. Yeah. Well, actually, it's more than that,

9 but --

10 Q. Okay. What other things would you base your

11 familiarity on?

12 A. Well, going back 60, 70 years ago, there were a

13 lot of business services, restaurants, entertainment

14 value that that area had that we partook of from all

15 over -- all over the city -- all over the county,

16 actually, and just being familiar with the people who

17 live there and where their homes were before they were

18 eroded by the expressways that came through, 95, 836, as

19 you know.

20 Q. Uh-huh.

21 A. And just -- just based on that.

22 Q. And you mentioned the areas that were eroded by

23 the expressways, like I-95. What was the effect that

24 that expressway had on that area?

25 A. Mass displacement of the residents.

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1 Q. Okay. And it also cut the residents who were

2 on the west side of I-95 off from those on the east

3 side; correct?

4 A. Yes.

5 Q. Is Overtown one of those areas where there's

6 significant gentrification?

7 A. That's evolving, but, yeah, a lot of changes.

8 It's like a lot of people wouldn't identify it anymore

9 who have been away for a period of time.

10 Q. And there's significant gentrification in some

11 of those areas, like in the southern parts of Little

12 Haiti; correct?

13 A. Yes.

14 Q. And that's something that you're aware of just

15 from being a 72-year resident of Miami-Dade; right?

16 A. Yes.

17 Q. Since I've put your name on the record, you're

18 aging very well, by the way.

19 A. Thank you.

20 Q. I hope I'm so lucky.

21 You mentioned that District 1 was drawn to --

22 and Map 4 was drawn to elect a Black candidate. Do you

23 believe that was drawn to displace the currently

24 suspended commissioner, Commissioner

25 Diaz de la Portilla?

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1 A. No.

2 Q. Commissioner Diaz de la Portilla is a Hispanic

3 representative; correct?

4 A. Yes.

5 Q. If it was drawn to elect a Black

6 representative, is he going to have a hard time winning

7 in that district?

8 MR. MERKEN: Objection. Speculation.

9 BY MR. LEVESQUE:

10 Q. You can answer if you have an opinion.

11 THE WITNESS: I can go ahead?

12 MR. MERKEN: Yes.

13 THE WITNESS: Okay.

14 No, I don't think he would have a hard time.

15 BY MR. LEVESQUE:

16 Q. You don't think he would have a hard time

17 winning in that district?

18 A. No.

19 Q. Even though it was drawn to elect a Black

20 representative?

21 A. Well, he's still on the ballot.

22 Q. I understand he's on the ballot for the current

23 map.

24 A. Uh-huh.

25 Q. But if the map looked like this, hypothetically

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1 speaking, and it was drawn to elect a Black candidate,

2 do you think he's going to do as well if he was on the

3 ballot in that particular configuration?

4 A. It's hard to say, but I think he will.

5 Q. Now, in nearly all -- actually, strike that.

6 In all of plaintiffs' maps that we just

7 reviewed -- 1, 2, 3, and 4 -- they all draw the western

8 part of the city that incurred -- includes the Flagami

9 area in a single district, District 4.

10 Do you know why that was done?

11 A. Just for District 4?

12 Q. Yes, ma'am.

13 A. To keep that representation intact because

14 that's primarily how it was drawn before.

15 Q. If I could ask you to look back at the 1997

16 plan.

17 A. Yeah. Let me -- that's what I was referring

18 to, yeah.

19 Q. And comparing plaintiffs' Map 4 with the 1997

20 plan, you can see in the 1997 plan that that area,

21 Flagami, is split between --

22 A. Yes.

23 Q. -- District 1 and District 4; correct?

24 A. Yes.

25 Q. And if you look at the 2003 plan, some minor

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1 border changes, but the area is still split between --

2 A. Uh-huh.

3 Q. -- District 1 and 4; correct?

4 A. Yes.

5 Q. And then 2013 plan, again, some minor changes

6 but still split between District 1 and 4; correct?

7 A. Yes.

8 Q. And then in each of the '22 -- 2022 plan and

9 the 2023 plan, that area, Flagami, is still split

10 between District 1 and District 4; correct?

11 A. Yes.

12 Q. Okay. So in all of the prior versions of

13 District -- of the district map for District 2, from

14 1997 to 2013, Coconut Grove is kept whole; correct?

15 A. Yes.

16 Q. Now, for all four of the plaintiffs' plans,

17 none of them keep that area, Flagami, the same as it's

18 been drawn from 1997 through the present.

19 A. Uh-huh.

20 Q. Is there a reason why Coconut Grove should be

21 kept the way that it's been drawn since 1997 but Flagami

22 should not be kept the way that it's been drawn since

23 1997?

24 A. Tough question. Well, I think a lot of it has

25 to do with the demographics. The demographic changes in

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1 that area. Like, Grapeland Heights, from what it had

2 become, seems to be more in tune with Flagami, what that

3 is now as well.

4 Q. Okay. Can you explain that a little bit more.

5 A. Okay. In the previous maps, before the

6 plaintiffs' maps, when the Flagami area was divided into

7 two, you see where Grapeland Heights and Allapattah was,

8 in that one district, District 1, there have been some

9 significant changes racially in those areas since those

10 maps were -- were drawn.

11 Q. Okay.

12 A. Like, more Hispanics.

13 Q. Okay. So Grapeland Heights, in your

14 understanding, is becoming more Hispanic?

15 A. Yeah.

16 Q. Okay. And District 1 is currently a Hispanic

17 district; correct?

18 A. Well, that area from way back was -- was white

19 non-Hispanic, and they had an area called "Railroad Shop

20 Addition" that had Black residents there. And they were

21 forced to leave that area, but sometime in the late '50s

22 and '60s, that became like a primarily Black area, and

23 there's still been like an influx of Hispanics that have

24 come in there.

25 Because that's even shifted. Like a lot of

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1 these areas, like Little Haiti, that wasn't always

2 Little Haiti; that was like Lemon City. So we've seen a

3 lot of demographic changes, even within some of these

4 later models here.

5 Q. Okay. And there's a lot there.

6 A. Yeah, I know. I'm sorry. I'm sorry.

7 Q. I was holding on the best that I could to

8 follow it.

9 So when you were talking about some of those

10 areas, let's kind of slow down. Grapeland Heights is an

11 area that has historically been linked with District 1;

12 correct?

13 A. Yes.

14 Q. And it's your understanding that Grapeland

15 Heights is becoming more Hispanic; correct?

16 A. Yes.

17 Q. And then if you look at the plans from 1997

18 through the current, District 1 elects the Hispanic

19 representative; correct?

20 A. Yes.

21 Q. In all of plaintiffs' maps, Grapeland Heights

22 seems to be included not in District 1 but in

23 District 4.

24 Do I understand that correctly?

25 A. Yes.

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1 Q. Is there a reason why you would you move those

2 Hispanic residents from District 1 and put them in

3 District 4?

4 A. There are probably some other concerns there

5 that are probably bigger than the racial makeup of the

6 area.

7 Q. Okay. What are some of those concerns?

8 A. The proximity to the airport, to that Melreese

9 golf course. Some of those issues like that.

10 Q. Okay. Would it be fair to say that when it

11 comes to Grapeland Heights, Grapeland Heights could be

12 included in either District 1 or District 4 for

13 nonracial reasons?

14 A. Yes.

15 Q. And let me kind of go back to my original

16 question, then.

17 In all of plaintiffs' maps, they split -- or

18 strike that.

19 They combine Flagami into a single district,

20 District 4. Do you know why that was done?

21 A. No.

22 Q. You attended some of the city commission

23 meetings; correct?

24 A. Yes.

25 Q. Did you hear anyone from any of those areas

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1 saying, "Please put Flagami in a single district"?

2 A. Not that I can recall, no.

3 (Defendant's Exhibit Number 24-37, Affidavit,

4 was marked for Identification.)

5 BY MR. LEVESQUE:

6 Q. Ms. Cooper, I am going to show you what we're

7 going to mark as Defendant's Exhibit 24-37.

8 MR. MERKEN: Thank you.

9 BY MR. LEVESQUE:

10 Q. Ms. Cooper, have you seen this document before?

11 A. Yes.

12 Q. In paragraph 3, you indicate that you're

13 president of the Coconut Grove Village West Homeowners

14 and Tenants Association?

15 A. Yes.

16 Q. Is that the association that you referenced

17 earlier that was part of the social organization network

18 that was affiliated with the Alliance of Black

19 Ministers -- I know that's not what they're called, but

20 the Coconut Grove Ministerial Alliance --

21 A. No.

22 Q. Okay.

23 A. A separate organization.

24 Q. Okay. Is the Coconut Grove Village West

25 Homeowners and Tenants Association in any way affiliated

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1 with GRACE?

2 A. Yes.

3 Q. What is their affiliation?

4 A. We're one of the organizational members.

5 Q. And let me ask about that.

6 Does GRACE have individual members and

7 organizational members?

8 A. Yes.

9 Q. Do you know if GRACE keeps a member registry?

10 A. Yes.

11 Q. Do you know if GRACE did an analysis of its

12 members to figure out which districts its members live

13 in?

14 A. No.

15 Q. And is that, no, you don't know, or, no, they

16 didn't do an analysis?

17 A. No, an analysis was not done.

18 Q. In paragraph 4, you say, "I care deeply about

19 my community and I want what is best for Miami, the West

20 Grove, and Coconut Grove."

21 The way that I read that sentence is there are

22 subsets that you're referencing in each of those.

23 A. Yes.

24 Q. You've got Miami as a whole. You've got the

25 West Grove next. And then you've got Coconut Grove.

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1 A. Yes.

2 Q. So there are areas with distinct identities.

3 Wouldn't you agree?

4 A. Yes.

5 Q. I believe you testified earlier the needs that

6 are experienced in the West Grove are not necessarily

7 the same needs that are experienced in the rest of the

8 areas of Coconut Grove; correct?

9 A. Yes.

10 Q. Paragraph 5, you say that "The process of

11 creating the map should have been fairer, including to

12 Black residents of Miami."

13 How was the process that the City used in

14 drawing the 2022 plan unfair?

15 A. As I stated before, I think that when The Grove

16 was shown to be split into three different groups, that

17 that was going to even diminish our leverage as far as

18 getting what we wanted to happen as improvements for

19 West Grove.

20 Q. Did the Black residents of The Grove -- Coconut

21 Grove as an entirety -- primarily live in the West

22 Grove?

23 A. Yes.

24 Q. You would agree that that concern, then,

25 wouldn't apply to areas like the North Grove or the

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1 other Grove areas other than the West Grove that do not

2 have as many Black residents; correct?

3 A. Yes.

4 Q. In paragraph 6, you say, "As a resident of the

5 newly enacted city commissioner -- commission

6 District 2, I am concerned that Black residents, like

7 me, have been artificially stripped from my district on

8 the basis of our race."

9 I want to pack that down a little bit.

10 When you say artificially stripped from your

11 district, which district are you referring to?

12 A. The District 2.

13 Q. Okay. But in every plan you're in District 2;

14 correct?

15 A. Yes.

16 Q. So whether it's any of the plaintiffs' plans or

17 any of the City's plans, you live in District 2

18 regardless?

19 A. Yes.

20 Q. Do you think you should have been in a

21 different district?

22 A. No.

23 Q. Okay. Is that an accurate statement, then, in

24 terms of being artificially stripped from your district,

25 if you've resided in District 2 and continue to reside

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1 in District 2?

2 A. Well, initially, when these plans were in

3 formation, of course, there was some talk about where I

4 am being put into District 4, because I live right

5 underneath the Bird Road and US 1 and also Day Avenue.

6 They were talking about making that a boundary and even

7 below that. Not as far down as Grand, because I live

8 off of -- just north of Grand Avenue. But they were

9 talking about bringing it down further, which it would

10 have taken me out of District 2.

11 Q. Okay. Well, let me kind of pause.

12 First, I showed you your declaration. You've

13 seen this before; correct?

14 A. Uh-huh.

15 Q. Did you draft it?

16 A. Not entirely, no.

17 Q. Okay. This was filed with the court on

18 February 10th, and it looks like you executed it on

19 February 1st, 2023.

20 A. Uh-huh.

21 Q. At that time, the '22 -- 2022 plan would have

22 been in effect.

23 A. Uh-huh.

24 Q. So the 2022 plan didn't strip you from your

25 district, did it?

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1 A. No, not that I -- no, not me personally.

2 Q. And I guess where it says "I'm concerned that

3 Black residents, like me, have been artificially

4 stripped from my district on the basis of our race," to

5 be clear, there might have been other people that that

6 happened to, but that didn't happen to you?

7 A. No.

8 Q. In paragraph 7, it says "Because of the way the

9 map was drawn and the reasons the commission gave for

10 drawing it."

11 What are the ways that the map was drawn, and

12 what are the reasons the commission gave for drawing it

13 that you're referencing there?

14 MR. MERKEN: Objection to form.

15 MR. LEVESQUE: And your counsel had a fairly

16 well-timed and well-taken objection. I'm assuming

17 it's because it's a compound question. So let me

18 break that up.

19 BY MR. LEVESQUE:

20 Q. In that -- you say "Because of the way the map

21 was drawn."

22 What are the ways that the map was drawn that

23 you object to?

24 A. That it took away some of the neighborhoods in

25 Coconut Grove in District 2. And as I stated before, I

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1 was concerned about that taking away the influence of

2 anything that was going to happen for any Coconut Grove

3 property owners or residents. And then they did

4 remove -- as shown on the current maps, that they did

5 remove some areas of District 2 that were in Coconut

6 Grove.

7 Q. But some of those areas, it has less to do with

8 race, because those are some pretty white or Hispanic

9 areas, and more to do with just diminishing the voice of

10 Coconut Grove; correct?

11 A. Yes.

12 Q. In that paragraph, you also say "Because of the

13 reasons the commission gave for drawing the map that it

14 drew."

15 In this case, you're referencing the 2022 map.

16 What are some of the reasons the commission gave for

17 drawing the map the way it drew the map?

18 A. It still had to do with the census and how they

19 were going to try to redistribute the population and to

20 put them into different districts as they were being

21 drawn.

22 Q. Okay. Were they discussing it in terms of

23 race, or were they discussing in terms of the

24 neighborhood, or were they discussing it in a wide

25 variety of ways?

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1 A. Just wide variety.

2 Q. In paragraph 8, you say, "Coconut Grove is a

3 cohesive neighborhood with particular interests."

4 What are the particular interests that you're

5 referring to in terms of it being a cohesive

6 neighborhood?

7 A. Well, most Coconut Grove-ites, which I've been

8 all my life, were concerned about preserving our legacy.

9 Those of us who have ancestors who came from different

10 parts of the country and also the Bahamas and elsewhere.

11 And as time went on, that was being fragmented, and we

12 were trying to keep that all together regardless of our

13 race or where we live as part of The Grove. And as I

14 said, our influence about being there and our interests

15 not being protected.

16 Q. Okay.

17 A. And even though city hall is in Coconut Grove,

18 you know, that's just the place where it is.

19 Q. Okay. Well, in which district? Articulate it

20 there in terms of the cohesive interest.

21 It sounds like that has less to do with race

22 and more to do with just sort of preserving the nature,

23 the character of The Grove as a whole; correct?

24 A. Yes, but race plays a part of it, too. See, we

25 still rely on the other parts of Coconut Grove. We --

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1 everybody helps each other out, all the different

2 communities. Like, me living in West Grove, I've been

3 approached by people from North Grove or Center Grove

4 for anything that they want to have placed before the

5 City or the County.

6 Q. Okay. And when you say -- you referenced race

7 but then talked about people approaching you.

8 Are people that are approaching you for your

9 support the same race as you or are they different

10 races?

11 A. No, different races.

12 Q. Okay. So there's -- it sounds like -- and if

13 this is a fair characterization, let me know.

14 It sounds like there's more racial cooperation,

15 from your perspective, in District 2?

16 A. Yes.

17 Q. As it relates to Coconut Grove?

18 A. Yes.

19 Q. But on the same hand, there's also different

20 interests in terms of what you've got going on in West

21 Grove and what you've got going on in the rest of The

22 Grove?

23 A. Yes.

24 Q. In paragraph 9 -- and, again, you're talking

25 about the 2022 plan.

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1 You say, "I'm deeply worried that the

2 commission ignored the outcry from the public,

3 particularly Black residents of the West Grove who

4 opposed splitting our community."

5 You would agree that the Black portions of the

6 West Grove were, in fact, included back in District 2 in

7 the --

8 A. Uh-huh.

9 Q. -- 2023 plan; correct?

10 A. Yes.

11 Q. And that was a good move by the City

12 independent --

13 A. Yes.

14 Q. In that paragraph, you assert that "The

15 commission chose to divide Coconut Grove for racial

16 reasons to separate cohesive communities along racial

17 lines and achieve their preferred racial balance for the

18 map."

19 Let's look back at that 2023 plan, which would

20 be Defendant's Exhibit 82-24.

21 Now, I think you testified earlier that in

22 addition to creating that little foot in District 3 that

23 goes down into The Grove, that that change was also

24 potentially intended to increase the Hispanic population

25 in District 3?

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1 A. Yes.

2 Q. Did I get that correct?

3 A. Yes.

4 Q. Do you know what effect that had on whether it

5 boosted or diminished the Hispanic population in

6 District 2?

7 A. Diminished. Because, see, that would be going

8 into District 3 at that point.

9 Q. Okay. So if it's diminishing the population in

10 District 2 to make it less Hispanic, does that make

11 District 2 more white?

12 A. Not necessarily, no.

13 Q. Okay. Looking at the plaintiffs' plans, do you

14 know if they have a higher white voting-age population

15 than any of the City's plans?

16 A. It was Map 4 or any of the maps?

17 Q. Any of plaintiffs' maps. Do you know if any of

18 their maps for District 2 have a higher white voting-age

19 population than -- we'll start with the 2023 plan.

20 A. Which map was that, sir? I'm sorry.

21 Q. I'm referring to -- I'm asking you to compare

22 that plan --

23 A. Oh, okay.

24 Q. -- with any of the plaintiffs' maps. And we're

25 looking at District 2.

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1 And do you know if District 2 -- in any of the

2 plaintiffs' maps, if the white voting-age population is

3 higher or lower than what is depicted in the 2023 plan?

4 And, Ms. Cooper, it's not intended to be a

5 test.

6 A. Okay.

7 Q. "I don't know" is a perfectly acceptable answer

8 if it's the truthful answer.

9 A. "If it was their intention," you said? Can you

10 repeat the question. I'm sorry.

11 Q. Actually, I'm just asking you if you know one

12 way or another whether District 2 in any of the

13 plaintiffs' plans has a whiter population than the

14 population that's represented in the City's

15 2023 District 2.

16 A. No. No.

17 Q. No? No, you don't know?

18 A. No, I don't know.

19 Q. Would it surprise you if it was?

20 A. Possibly, yes. It would.

21 MR. LEVESQUE: I'll tell you what. Can we take

22 a ten-minute break? I think I might be almost done.

23 I'm not going to represent that I'm done, but I'm

24 almost. If I can have like ten minutes to just

25 organize, I might be able to get us out.

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1 THE WITNESS: Yeah.

2 MR. MERKEN: Can we use the room next door?

3 MR. LEVESQUE: Yes, absolutely.

4 (Thereupon, a recess was taken in the

5 deposition, after which the deposition continued as

6 follows:)

7 MR. LEVESQUE: Back on the record.

8 (Defendant's Exhibit Number 24-13,

9 February 7th, 2022, transcript of the Miami City

10 Commission, was marked for Identification.)

11 BY MR. LEVESQUE:

12 Q. Ms. Cooper, I am going to show you what I'm

13 going to mark as Defendant's Exhibit 24-13.

14 MR. MERKEN: Could we have a copy, please.

15 MR. LEVESQUE: Sure.

16 MR. MERKEN: Thank you.

17 MR. LEVESQUE: The only difference is I've got

18 a cover page on hers for clarity.

19 MR. MERKEN: Okay.

20 BY MR. LEVESQUE:

21 Q. And, Ms. Cooper, I will represent to you that

22 this is a transcript of the February 7th, 2022, Miami

23 City Commission meeting that you spoke at, and,

24 specifically, this is a transcript of the statements

25 that you made to the city commission.

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1 Have you seen this transcript before?

2 A. No.

3 Q. Okay. In looking at the transcript, do you

4 believe this accurately reflects what you told the

5 commission?

6 A. Yes.

7 Q. And at the bottom of page 25, line 20 --

8 beginning on line 20, the first sentence there says you

9 "... told the commission removal of any part of the

10 Coconut Grove Village West from District 2 to be in and

11 next to an adjoining district will place in jeopardy the

12 painstaking strides for improvements and revitalization

13 that has been made towards regarding the West Grove

14 Community Redevelopment Agency."

15 So as I read that statement, the primary areas

16 you were concerned with at that February 7th meeting was

17 what the commission was proposing to do with that area

18 of Coconut Grove Village West; correct?

19 A. Yes.

20 Q. And you were also -- if you flip to page 26,

21 you were also concerned that there was not enough

22 opportunity for people to hear and consider what was

23 going on, and you suggested that they should have more

24 meetings; isn't that true?

25 A. Yes.

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1 Q. And, in fact, they did have more meetings,

2 didn't they?

3 A. Yes.

4 Q. So they listened to you. You were an effective

5 advocate.

6 A. Yep.

7 Q. And you also requested that they withhold

8 deliberation on the topic until the rest of the Coconut

9 Grove residents have been fully apprised.

10 A. Yes.

11 Q. And that wasn't the only commission meeting

12 that you spoke at, was it?

13 A. I would have to check my calendar. I believe

14 there may have been one or two others.

15 Q. Okay. And do you recall if they were before or

16 after February 7th?

17 A. Of last year?

18 Q. Yes, ma'am.

19 A. I have to look at my calendar.

20 (Defendant's Exhibit Number 24-14,

21 February 25th, 2022, transcript of the Miami City

22 Commission, was marked for Identification.)

23 BY MR. LEVESQUE:

24 Q. Okay. I am going to show you Defendant's

25 Exhibit 24-14.

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1 MR. MERKEN: Thank you.

2 BY MR. LEVESQUE:

3 Q. I'll represent to you that that is a transcript

4 of the February 25th, 2022, morning session of the Miami

5 City Commission meeting that you presented to the

6 commission.

7 Does that transcript look like it accurately

8 reflects your statement to the commission?

9 A. Yes.

10 Q. And in that commission meeting, you indicated

11 that you were here on behalf of the Coconut Grove

12 Village West Homeowners and Tenants Association.

13 Did the association have a vote to designate

14 you as its representative for that meeting?

15 A. Yes.

16 Q. Are there minutes whereby they made that --

17 that designation as recorded?

18 A. Well, what we usually do is prepare a statement

19 and submit it to the board, and they vote on it.

20 Q. Okay.

21 A. And that would be strictly for presentation

22 before any electorate body of people.

23 Q. And how many members of the board are on the

24 Coconut Grove Village West Homeowners and Tenants

25 Association?

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1 A. We have ten members.

2 Q. And are they all residents of the West Grove?

3 A. Yes, except one person.

4 Q. Does that one person still live in Coconut

5 Grove?

6 A. He was born and raised in Coconut Grove.

7 Q. Okay. Where does he reside now?

8 A. City of South Miami.

9 Q. So he no longer resides within the city limits,

10 then?

11 A. No.

12 Q. And at least in terms of the city processes,

13 after that first meeting where you said, "Please hold

14 more meetings," they held more meetings, and you were

15 able to present your views to the city commission at

16 that meeting as well; correct?

17 A. Yes.

18 (Defendant's Exhibit Number 24-16, March 11th,

19 2022, transcript of the Miami City Commission

20 meeting, was marked for Identification.)

21 BY MR. LEVESQUE:

22 Q. I'm going to show you what we're going to mark

23 as Defendant's Exhibit 24-16.

24 MR. MERKEN: Thank you.

25

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1 BY MR. LEVESQUE:

2 Q. Ms. Cooper, I'll represent that this is a

3 transcript of the March 11th morning session --

4 March 11th, 2022, morning session of the city

5 commission, and a transcription of your statements to

6 the commission.

7 In looking at that document, does that appear

8 to be an accurate recording or transcription of your

9 statement to the commission?

10 A. Yes.

11 Q. And on line 11, you reference "Commissioner

12 Russell has offered an alternative, which I think needs

13 to be looked at because it does keep The Grove together

14 and that's what we're all here about."

15 Do you recall what happened with Commissioner

16 Russell's alternative proposal?

17 A. It was voted down by his other commissioners.

18 Q. Okay. So at least in regards to that

19 particular question, Commissioner Russell wasn't able to

20 persuade two other commissioners to go along with him;

21 correct?

22 A. Exactly, yes.

23 Q. Do you know -- do you recall what the vote was

24 for that, whether it was a 3-2 vote or a 4-1 vote?

25 A. Probably 4-1.

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1 Q. Now, on line 16, you reference what are called

2 "NCD 2 revisions."

3 What are NCD 2 revisions?

4 A. Well, Miami 21, which is the zoning code for

5 the city of Miami, has within its body several

6 neighborhood conservation districts for different

7 neighborhoods. And we have two in Coconut Grove. NCD

8 2, as we refer to it as, it's for the West Grove

9 specifically and our "island district," as it's called,

10 where we try to maintain our architectural integrity, if

11 you will, towards the Bahamian vernacular.

12 And in NCD 3 it's a little different because it

13 covers the larger Coconut Grove area. And we have been

14 in the process of trying to get revisions to that code

15 to protect us from the gentrification and also the

16 influx of the overdevelopment in The Grove, especially

17 with the -- what we call "sugar cubes," "white boxes."

18 You may have seen those in The Grove and throughout the

19 city of Miami.

20 Q. And so the sugar --

21 A. They're called sugar -- they're white boxes.

22 They take up the whole lot.

23 Q. Okay. So to put it in layman's terms, someone

24 will buy a lot -- or buy a house, tear it down, and

25 put -- put up an all-white house where the structure

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1 takes up the bulk of the lot?

2 A. Right.

3 Q. And both the geographic areas of NCD 2 and the

4 geographic areas of the West Grove CRA that you also

5 mentioned, those are all within the West Grove; correct?

6 A. Yes.

7 Q. And both of those areas in the 2023 plan, the

8 City added back into District 2; correct?

9 A. Yes.

10 Q. And if we could go back to your declaration,

11 Document 24-37. And in the last paragraph of -- or the

12 last sentence of page 9 -- I apologize.

13 On page 2, in the last sentence of paragraph 9,

14 you state that "It greatly concerns me that the

15 commission chose to divide Coconut Grove for racial

16 reasons, to separate cohesive communities on racial

17 lines and achieve their preferred racial balance for the

18 map."

19 What do you believe the commission's preferred

20 racial balance for the map is?

21 A. Well, to just not give any significant amount

22 of representation to the Black community, West Grove in

23 particular.

24 Q. And what do you mean by that?

25 A. Well, with the truncation of the Coconut Grove

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1 community in District 2, as we were, we figured that --

2 as I said before, that that was going to take away from

3 some of the support that we were going to have available

4 to us from other parts of Coconut Grove and to try to

5 get accomplished some of the goals that we have set for

6 our community.

7 Q. And I apologize. I'm having a hard time --

8 A. It's okay.

9 Q. I'm having a hard time tracking -- let's go

10 back to your final statement there, that you felt that

11 the City was drawing a line -- district lines to achieve

12 their preferred racial balance for the map.

13 What do you believe the City's preferred racial

14 balance to the map is?

15 A. To make it more Hispanic.

16 Q. Okay. You recognize the City still drew a

17 Black district; correct?

18 A. Excuse me?

19 Q. You recognize the City still drew a Black

20 district, District 5; correct?

21 A. It boiled down to that initially. I thought

22 that was also a part of their design too, not to even

23 have a Black district with the -- what was happening

24 with Overtown and that other surrounding area.

25 Q. Well, at any time were they talking about

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1 keeping Overtown out of District 5?

2 A. I don't -- I'm not really sure about that.

3 Q. Okay.

4 A. But it appeared from the different maps that

5 had been submitted that they -- that that was a concern.

6 But, of course, we were mainly concerned about what

7 happened in our neighborhood, West Grove.

8 Q. But in the 2023 plan, you personally were in a

9 white district; correct?

10 A. Uh-huh.

11 Q. Do you feel that you would be better

12 represented by a white representative than a Hispanic

13 representative?

14 A. Not necessarily, no.

15 Q. Okay. Was it something about the current

16 representatives that currently held District 4 and

17 District 3 that you had concerns with?

18 A. Yes.

19 Q. Were you aware that Commissioner Carollo was

20 terminated out of office?

21 A. Yes.

22 Q. And, obviously, you don't know who's going to

23 replace Commissioner Carollo yet, do you?

24 A. No.

25 Q. Would it be fair to say that it's possible for

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1 a Hispanic to be elected to District 3 that could care

2 for the interests of those in Coconut Grove that are in

3 this district?

4 A. They could or could not? "Could," you said?

5 Q. Could.

6 A. Could?

7 Q. Could.

8 A. Could? Yes. Because the names are already on

9 the ballot, so --

10 Q. Well, Commissioner Carollo in District 3 is up

11 for election in 2025.

12 A. No, not at this time, no. But there's been

13 talk about him -- that he's running.

14 Q. Who have you heard talked about to running for

15 his seat in 2025?

16 A. That, I can't recall.

17 Q. But you do recall that whoever that might be,

18 they might have an interest in protecting the Grove-ites

19 that live in District 3?

20 A. (Witness nodding.)

21 Q. Is that a "yes"?

22 A. Yes.

23 MR. LEVESQUE: Ms. Cooper, I don't have any

24 more questions. Your counsel might have a few

25 follow-up. And depending on what he asks, I might

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1 have some follow-ups after that.

2 CROSS-EXAMINATION

3 BY MR. MERKEN:

4 Q. Ms. Cooper, you testified earlier regarding a

5 number of court filings made by the plaintiffs in this

6 case.

7 Do you remember that?

8 A. Yes.

9 Q. Were you part of the process of preparing court

10 filings in this case?

11 A. No.

12 Q. Was your input included in court filings in

13 this process?

14 A. I'm not sure. No.

15 Q. You also recall you testified about the

16 plaintiffs' purpose in drawing P-1, P-2, P-3, and P-4,

17 specifically the intentions with those maps.

18 Do you recall that testimony?

19 A. Yes.

20 Q. What was your basis for testifying about the

21 intention in plaintiffs' Proposed Maps 1, 2, 3, and 4?

22 A. Well, to keep it fair as far as the

23 proportioning of the -- the residents in those

24 districts.

25 Q. Was part of that -- strike that.

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1 Ms. Cooper, is your testimony about the intent

2 of plaintiffs' four proposed remedial maps based on

3 things that occurred before the maps were drawn or based

4 on your review of them today?

5 A. Probably my review of them today.

6 MR. MERKEN: Okay. No further questions.

7 REDIRECT EXAMINATION

8 BY MR. LEVESQUE:

9 Q. Ms. Cooper, you just mentioned that -- and I

10 might get this wrong, but part of the maps were --

11 plaintiffs' maps were intended to keep a fair

12 proportion.

13 What did you mean by "a fair proportion"? Was

14 that -- let me just stop there.

15 A. Well, since everything, the redistricting all

16 had to do with the census, and they were trying to

17 fulfill the requirement, I guess, of keeping, like, The

18 Grove being over -- the District 2 being overpopulated

19 to make it more accurate as far as representation by

20 different groups of people.

21 Q. So when you were referring to fairer

22 population -- I'm sorry, fairer proportions --

23 A. Proportions.

24 Q. -- you're referring to the process of drawing

25 districts that are generally equal in size?

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1 A. Yes.

2 Q. So the fairer proportion that you're talking

3 about has nothing to do with race. It has to do with

4 making sure that District 2 has roughly the same number

5 of residents as Districts 1 through 4; is that correct?

6 A. Yes.

7 Q. Okay. And is it your understanding that

8 plaintiffs' Maps 1 through 4 do that better than the

9 City's maps?

10 A. I think so, yes.

11 Q. Okay. And if the numbers bear that out, the

12 numbers are going to be what the numbers are; correct?

13 A. Right, yes.

14 Q. And so when you were referencing "fairer

15 proportion," it has nothing to do with race there, does

16 it?

17 A. Well, from whose standpoint?

18 Q. Well, from your standpoint.

19 A. From my standpoint? Okay. Yes.

20 Q. When you were talking about the plaintiffs'

21 maps having --

22 A. Yeah, right. Yeah.

23 Q. -- a fairer proportion, you were only referring

24 to the equal population part. You weren't referring to

25 a fairer proportioned district based upon race; correct?

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1 A. Well, I think that the racial element is to be

2 considered there, yes.

3 Q. Okay. So in your -- in your opinion, it would

4 be okay to consider race in drawing the districts?

5 A. Yes.

6 Q. And would you agree that whether it's the

7 City's map or any of the plaintiffs' maps, that they all

8 provide generally three Hispanic districts, one Black

9 district, and one -- what I'll call a coastal district

10 that doesn't have a racial majority?

11 A. Yes.

12 Q. You would agree with that?

13 A. Yes.

14 MR. LEVESQUE: I have no further questions.

15 MR. MERKEN: I think we're done.

16 MR. LEVESQUE: Okay. Thank you, ma'am.

17 Thank you, Ms. Cooper. I hope it was at least

18 better than going to the dentist.

19 We're off the record.

20 Read? Waive?

21 MR. MERKEN: Read.

22 (Thereupon, the deposition was concluded at

23 12:30 p.m.)

24

25

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1 CERTIFICATE OF OATH

2

3 STATE OF FLORIDA:

4 COUNTY OF MIAMI-DADE:

5

6 I, VANESSA OBAS, RPR, Notary Public, State of

7 Florida, do hereby certify that CLARICE COOPER

8 personally appeared before me on October 9, 2023 and was

9 duly sworn and produced her driver's license as

10 identification.

11

12 Signed this 23rd day of October, 2023.

13

14

15

16

 <%22726,Signature%>

17 _______________________________

 VANESSA OBAS, RPR

18 Notary Public, State of Florida

 My Commission No.: HH 428338

19 Expires: September 13, 2027

20

21

22

23

24

25

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1 CERTIFICATE OF REPORTER

2

3 STATE OF FLORIDA:

4 COUNTY OF MIAMI-DADE:

5

6 I, VANESSA OBAS, RPR, Notary Public, State of

7 Florida, certify that I was authorized to and did

8 stenographically report the deposition of CLARICE

9 COOPER; that a review of the transcript was requested;

10 and that the foregoing transcript, pages 5 through 106,

11 is a true and accurate record of my stenographic notes.

12

13 I further certify that I am not a relative,

14 employee, or attorney, or counsel of any of the parties,

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

16 attorneys or counsel connected with the action, nor am I

17 financially interested in the action.

18

19 DATED this 23rd day of October, 2023.

20

21

22

23 <%22726,Signature%>

 __________________________________

24 VANESSA OBAS, RPR

25

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1 ERRATA SHEET

2 DO NOT WRITE ON TRANSCRIPT-ENTER CHANGES HERE

3 IN RE: GRACE, INC., et al. v. CITY OF MIAMI

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

4 DATE: October 9, 2023

 DEPONENT: CLARICE COOPER

5

6 PAGE NO. LINE NO. CORRECTION & REASON

7 _______ _______ _______________________________

8 _______ _______ _______________________________

9 _______ _______ _______________________________

10 _______ _______ _______________________________

11 _______ _______ _______________________________

12 _______ _______ _______________________________

13 _______ _______ _______________________________

14 _______ _______ _______________________________

15 _______ _______ _______________________________

16 _______ _______ _______________________________

17 _______ _______ _______________________________

18 _______ _______ _______________________________

19 _______ _______ _______________________________

20 _______ _______ _______________________________

21 _______ _______ _______________________________

22 Under penalties of perjury, I declare that I have read

 the foregoing document and that the facts stated in it

23 are true.”

24

 ______________________________________________________

25 DATE CLARICE COOPER

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1 October 26, 2023

2 CLARICE COOPER

 c/o DECHERT LLP

3 929 Arch Street

 Philadelphia, Pennsylvania 19104

4 christopher.merken@dechert.com

5 In Re: October 9, 2023, Deposition of CLARICE COOPER

6 Dear CLARICE COOPER:

7 The above-referenced transcript is available for review.

8 You should read the testimony to verify its accuracy.

 If there are any changes, you should note those with the

9 reason on the attached Errata Sheet.

10 You should, please, date and sign the Errata Sheet and

 e-mail to the deposing attorney as well as to Veritext

11 at transcripts-fl@veritext.com and copies will be

 emailed to all ordering parties.

12

 It is suggested that the completed errata be returned 30

13 days from receipt of testimony, as considered reasonable

 under Federal rules*, however, there is no Florida

14 statute to this regard.

15 If the witness fails to do so, the transcript may be

 used as if signed.

16

 Yours,

17

 Veritext Legal Solutions

18

19

20

 Waiver:

21

 I,______________, hereby waive the reading and signing

22 of my deposition transcript.

23 ________________________ ____________

 Deponent Signature Date

24

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

25 Procedure Rule 1.310(e)

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&

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24-81 4:4 26:19

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ability 7:4 36:22

able 91:25 96:15

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basing 19:16,19

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belief 39:23

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board 44:21,22

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boxes 98:17,21

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causes 37:10

census 31:23

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center 16:4,8,16

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certain 19:4

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certificate 3:6,6

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chair 44:11

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changed 38:16

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73:7 76:1,5,25

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110:8

character 87:23

characterization

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charged 10:19

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check 94:13

children 10:2

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christ 43:7

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city's 49:17 55:4

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citywide 25:4,12

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clarice 1:10 3:3

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clarify 7:18

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classification

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clean 7:12

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closely 56:15

cmcnamara

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coastal 22:1,1

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coconut 11:2

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code 98:4,14

cohesive 87:3,5

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collective 43:1

colloquy 7:17

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come 77:24

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command 15:17

commercial

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commission 4:6

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79:22 83:5 85:9

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commission's

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commissioner

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29:5 30:15,17

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33:18 38:13,16

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configurations

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confusion 54:20

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coral 11:8 17:21

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correction

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correlate 18:9

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depicted 91:3

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descriptions

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diminish 82:17

diminished 52:5

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district 1:1,1

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18:16,24 19:8

19:13 20:3,7,10

21:12,19,21,22

22:1 23:2,6,9

24:1,5 25:4,8,14

27:15,16,18,21

27:21 28:10,11

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29:1,2,3,6 30:10

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79:20 80:1 83:6

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101:1,9,16,17

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104:18 105:4,25

106:9,9

district's 36:22

districts 4:4

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hold 44:16 69:3

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llp 2:4 110:2

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mentioned 16:1

18:2 43:3 46:12

54:16 57:16

72:22 73:21

99:5 104:9

mercy 16:6,17

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merken 2:3 3:5

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message 21:7

methodist 43:6

metrorail 53:20

miami 1:7,15

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9:12 10:7,8,12

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miami's 15:15

mind 46:24

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minister 44:14

ministerial

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ministers 42:23

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minor 75:25

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minute 46:5

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minutes 91:24

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missionary 43:7

models 78:4

moment 14:17

monday 1:11

morning 5:16

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morningside

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motivated 34:5

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motivating

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move 13:12

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moved 36:4

movement

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museum 36:3,4

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n 2:1 3:1,11 5:1

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naacp 62:22,23

name 5:16

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names 14:9 42:2

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national 63:1

nationally 43:16

natoma 35:23

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naturally 40:20

nature 87:22

ncd 98:2,3,7,12

99:3

near 13:12 36:3

nearly 75:5

necessarily

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need 7:7 35:11

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needed 31:21

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needing 36:12

needs 35:1,10

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negative 11:10

neighborhood

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42:24 43:2

86:24 87:3,6

98:6 101:7

neighborhoods

19:20,21 43:22

85:24 98:7

neighbors 26:4

neither 62:25

network 80:17

new 29:9

newly 83:5

nod 6:5

nodding 6:8

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102:20

non 19:17,18

20:2 21:14 40:6

40:22,22 60:4,6

66:3,25 68:20

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nonracial 79:13

north 16:4,9,16

17:13,17 33:3

35:25 36:1 50:9

53:11 82:25

84:8 88:3

northern 55:21

55:24 64:2

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notary 107:6,18

108:6

note 110:8

notes 7:25 8:1,2

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number 4:3,4,5

4:5,7,8,8,9,9,10

4:10,13,16

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numbers 105:11

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o

o 3:11 5:1 110:2

oak 12:13 13:20

oath 3:6 7:1

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obas 1:17 107:6

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object 85:23

objected 11:6,9

objection 7:15

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objectionable

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objections 31:8

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obtained 45:12

obviously 5:18

101:22

occasionally 6:4

occurred 30:25

104:3

october 1:11

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offered 97:12

office 46:23

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oh 8:17 11:22

13:17 43:6 49:8

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okay 5:22,24

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omni 59:22

once 35:15

ones 18:19

opinion 37:14

67:11 69:23,25

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106:3

opinions 41:3

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opportunities

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opportunity

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22:6,13 93:22

opposed 89:4

ordering 110:11

organization

41:23 42:21

43:14,25 62:25

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organizational

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organizations

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46:1

organize 91:25

original 79:15

outcome 26:9

27:5

outcry 89:2

outer 18:11

overall 40:16

overdevelopm...

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overpopulated

32:7 57:2 64:14

104:18

overtown 58:24

59:21 62:19,20

62:21 63:18

71:10,12,15,17

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100:24 101:1

own 41:7

owners 86:3

p

p 2:1,1 3:11 5:1

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p.a. 1:13 2:13

p.m. 1:12

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pack 83:9

page 3:2 4:2

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pages 108:10

painstaking

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paragraph 15:7

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paraphrase

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parishioners

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park 35:23

part 16:6,16,18

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36:1 40:21 44:5

44:7 54:5,21

55:21,24,25

59:3 64:3 71:17

75:8 80:17

87:13,24 93:9

100:22 103:9,25

104:10 105:24

partially 54:1

particular

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36:25 39:5

56:21 64:21

65:24 66:14

68:12 75:3 87:3

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particularly

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parties 3:13

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partook 72:14

parts 16:2,3,5

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35:20 41:10,12

73:11 87:10,25

100:4

passed 12:18,23

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patrolling 35:13

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pen 55:9

penalties 109:22

pending 7:10

pennsylvania

2:5 110:3

people 7:22 38:7

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72:16 73:8 85:5

88:3,7,8 93:22

95:22 104:20

perceive 66:5

percent 20:15

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percentage 20:9

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62:14

perfectly 91:7

perform 28:14

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performed 48:3

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performing

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period 48:21

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perjury 109:22

person 96:3,4

personally

58:16 69:19,21

85:1 101:8

107:8

perspective

88:15

persuade 97:20

philadelphia

2:5 110:3

picked 54:1

picks 50:17

picture 25:7

27:2

place 1:13 87:18

93:11

placed 19:8 23:2

23:5 24:1 28:22

88:4

plaintiff 2:11

5:18 10:21 12:8

15:8

plaintiffs 1:5

8:20,22 60:12

60:20 61:12,12

62:3 63:9 64:20

67:10 71:9 75:6

75:19 76:16

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79:17 83:16

90:13,17,24

91:2,13 103:5

103:16,21 104:2

104:11 105:8,20

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plan 4:3,5,6,7

12:17,17,19,20

12:22,25 13:2,8

13:10 19:23,24

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27:15,22,22,24

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39:5 49:13,17

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90:19,22 91:3

99:7 101:8

plans 13:12

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83:16,17 84:2

90:13,15 91:13

plays 87:24

please 5:3 6:21

7:8 80:1 92:14

96:13 110:10

point 7:7 42:1

46:23 90:8

police 15:15

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35:13

political 9:22

politics 26:7

poor 48:25

51:15

poorly 7:14

population 23:4

32:2,11 36:20

40:4,7,16 62:14

62:15 64:13,16

86:19 89:24

90:5,9,14,19

91:2,13,14

104:22 105:24

populations

40:4,5

populationwise

64:9

portilla 73:25

74:2

portion 55:17

59:20

portions 63:25

89:5

position 48:6

possible 23:5

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possibly 91:20

potential 57:18

potentially

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power 57:19,22

precinct 13:16

predominant

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predominantly

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preferred 89:17

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preparation

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present 76:18

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presentation

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president 80:13

pretentious

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previously 52:9

primarily 16:19

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primary 63:23

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prior 25:10

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probably 6:15

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24:4 33:3 36:11

40:12,17 47:2

48:25 58:14

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79:4,5 97:25

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problem 27:20

31:3 61:22 62:1

62:7,8

procedure

110:24,25

proceeding

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process 82:10

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103:9,13 104:24

processes 96:12

produced 107:9

project 34:16

promises 37:11

property 33:16

33:19 86:3

proportion

104:12,13 105:2

105:15,23

proportional

40:24

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proportioned

105:25

proportioning

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proportions

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proposal 97:16

proposed

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proposing 93:17

protect 98:15

protected 87:15

protecting

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provide 11:3

106:8

providing 42:25

proximity 79:8

public 48:10,13

89:2 107:6,18

108:6

purple 59:24

purpose 41:24

103:16

put 11:8 50:9

55:11 73:17

79:2 80:1 84:4

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q

quarters 48:8

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question 6:20

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questions 66:9

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quite 36:11

r

r 2:1 5:1

race 56:21

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70:3,20,25 83:8

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races 88:10,11

racial 19:9,12

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59:16 60:7 66:5

68:6 79:5 88:14

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racially 34:5,6,8

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railroad 53:19

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raise 5:3

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ramifications

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reading 3:14

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really 6:5 23:23

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reason 33:14,19

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reasonable

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reasons 31:19

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rebuilding

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receipt 110:13

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recognize 16:3

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record 6:14

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46:10 50:8

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recorded 38:1

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recording 97:8

redevelopment

18:15,21,24

71:19 93:14

redirect 104:7

redistribute

86:19

redistrict 31:21

redistricting

104:15

reduction 56:22

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refer 12:18 15:7

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reference 97:11

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registry 81:9

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relative 108:13

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remember

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representation

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representative

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representatives

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resides 19:20

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resolve 11:15

resolved 26:8

resources 36:23

respective 3:13

response 57:12

rest 82:7 88:21

94:8

restaurants

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result 40:15

results 31:23

retire 10:6,15

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returned 110:12

review 8:8

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rights 41:20

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road 17:16,16

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roads 55:13

robinson 1:13

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robinson.com

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role 48:3

room 92:2

roughly 21:5

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rpr 1:17 107:6

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rude 6:11

rule 110:24,25

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run 66:9 68:9

running 102:13

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russell 29:10,11

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russell's 97:16

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science 9:22

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show 14:14 22:4

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showed 84:12

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sic 17:20 32:23

side 54:6 64:7

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sign 3:7 110:10

signature

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signed 107:12

110:15

significant 73:6

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silver 60:2

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sir 90:20

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slow 78:10

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108:9,10 109:2

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transcription

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FLORIDA RULES OF CIVIL PROCEDURE

Rule 1.310

(e) Witness Review. If the testimony is

transcribed, the transcript shall be furnished to

the witness for examination and shall be read to or 

by the witness unless the examination and reading

are waived by the witness and by the parties. Any

changes in form or substance that the witness wants 

to make shall be listed in writing by the officer

with a statement of the reasons given by the

witness for making the changes. The changes shall 

be attached to the transcript. It shall then be

signed by the witness unless the parties waived the 

signing or the witness is ill, cannot be found, or 

refuses to sign. If the transcript is not signed by 

the witness within a reasonable time after it is

furnished to the witness, the officer shall sign 

the transcript and state on the transcript the

waiver, illness, absence of the witness, or refusal 

to sign with any reasons given therefor. The

deposition may then be used as fully as though 

signed unless the court holds that the reasons

given for the refusal to sign require rejection of

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the deposition wholly or partly, on motion under 

rule 1.330(d)(4).

DISCLAIMER: THE FOREGOING CIVIL PROCEDURE RULES 

ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY.

THE ABOVE RULES ARE CURRENT AS OF APRIL 1,

2019. PLEASE REFER TO THE APPLICABLE STATE RULES 

OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.

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documents as submitted by the court reporter and/or 

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amended, with respect to Personally Identifiable 

Information (PII). Physical transcripts and exhibits 

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controls. Electronic files of documents are stored

in encrypted form and are transmitted in an encrypted 

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