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‘Diploma presented to INEC by Tinubu not like those issued in 1979’ — raw transcript of CSU’s deposition in court

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Editor’s note: This is the uncertified transcript of what transpired in court on Tuesday at the deposition of Carl Westberg, the deponent/witness of the Chicago State University, as obtained by TheCable. As a result, it is riddled with typographical errors which are usually corrected before a final version is released based on a court order. In summary, Westberg told the court that the diploma (also called certificate) President Bola Tinubu presented to INEC was not like the ones issued by the university in 1979 (but more like those produced in the 1990s).


1 IN THE MATTER OF

2 PLT.

3 V.

4 DFT.

5

6 DEPOSITION OF (CARL WESTBERG)

7 —————————————————–

8 The following transcript of proceedings, or any portion

9 thereof in the above-entitled matter, taken on the 3RD

10 day of October 2023 is being delivered UNEDITED as an

11 UNCERTIFIED DRAFT. PLEASE DO NOT QUOTE FROM THIS DRAFT

12 IN PLEADINGS OR ELSEWHERE. THE CERTIFIED TRANSCRIPT IS

13 THE ONLY OFFICIAL RECORD WHICH MAY BE RELIED UPON FOR

14 VERBATIM CITATIONS OF TESTIMONY. This transcript has

15 not been proofread. It is a draft transcript. NOT a

16 certified transcript. The transcript may contain

17 untranslates/misstrokes and reporter notes.

18 corrections will be made in the preparation of the

19 certified transcript resulting in difference in

20 content, page and line numbers, punctuation and

21 formatting.

22 **A FINAL TRANSCRIPT ORDER IS REQUIRED IN ORDER TO

23 RECEIVE A ROUGH DRAFT.**

24

UNCERTIFIED TRANSCRIPT

2

 

1 CARL WESTBERG

2 BY MS. LIU:

3 Q And hi, Mr. Westberg. I’m Angela Liu with

4 Dechert on behalf of applicants Atiku Abu car. I’m

5 present here today with my colleague, Alex Jermont and

6 Taylor sue Jewssky, who are joining us virtually as

7 well as my colleague nicole Carla a doe adieu in the

8 room. Would counsel likewise introduce yourselves.?

9 MR. HAYES: Michael Hayes for Chicago State

10 University the Respondent in this matter.

11 MR. HENDERSON: Good morning, Victor

12 Henderson, I’m on behalf of the Intervenor. Period of

13 time Bola Tinubu T-I-N-U-B-U. As is my colleague,

14 Mr. R O W EF A FO L A B I and he’s appearing virtual

15 and you see him on the screen.

16 Q Mr. Hayes, I believe you had something that

17 you would like to add to the record.

18 MR. HAYES: Yes. Thank you. Just as a

19 preliminary matter, we would like to note that

20 today’s deposition is under Rule 30(b)(6), on five

21 topics approved by the Court in this matter. And the

22 University witnesses prepared to address those topics

23 the University witness is not prepared to speak on the

24 University behalf on any other issues that is not

UNCERTIFIED TRANSCRIPT

3

 

1 related to the topics and we would urge for the

2 applicant and the intervenor to stay with the topics

3 that have been approved by the Court. Finally, I would

4 note by the agreement of the parties this deposition is

5 not being video recorded. We do have several persons

6 participating remotely, but it is our understanding and

7 I someone please speak up if this is not so, that no

8 one that is participating remotely is video recording

9 today’s deposition. Thank you.

10 MS. LIU: Thank you Mr. Hayes, and

11 Mr. Westberg, can you please state and spell your full

12 name for the record?

13 A Caleb Westberg.

14 Q And are you being represented by Mr. Hayes

15 today?

16 A Yes.

17 Q And are you being represented by any one else

18 in the room or on camera today?

19 A No.

20 Q Have you ever been deposed before?

21 A No.

22 Q With that I would like to go over some ground

23 rules for the deposition. First, you are under oath

24 today, do you understand?

UNCERTIFIED TRANSCRIPT

4

 

1 A Yes.

2 Q And it is important that there be a clear

3 record of today’s deposition. I’m going to be asking

4 you a series of questions and to ensure that there is a

5 clear transcript of your answer, please respond

6 verbally to all of my questions. And so there should

7 be no headshakes or head nods. Do you understand?

8 A Yes.

9 Q And so that the Court Reporter, can

10 accurately transcribe the deposition and let’s try not

11 to talk at the same time. Please let me finish my

12 question before you answer and I’ll let you finish your

13 answer before I ask my next question. Do you

14 understand?

15 A Yes.

16 Q If you don’t understand a question, let me

17 know and I’ll try to rephase it. If you don’t say

18 anything, I’ll assume you understood the question. Do

19 you understand?

20 A Yes.

21 Q And at times, Counsel may object to my

22 questions but unless, your counsel instruct you

23 otherwise, not to answer, you can answer the question,

24 when he has finished stating his objections download

UNCERTIFIED TRANSCRIPT

5

 

1 that.

2 A Yes.

3 Q Finally, if at any point you would like to

4 take a break, just let your counsel or me no and we

5 will accommodate you. The only exception if there is a

6 question pending and in instance, I’ll ask you to

7 answer the question before we take a break, do you

8 understand that?

9 A Yes.

10 Q And do you have any questions about the

11 procedures we will follow today?

12 A No.

13 Q Is there any reason you cannot testify

14 truthfully and accurately today everyone, no.

15 Q And just to make sure we are on the same

16 page, when I say CSU, I mean Chicago State University.

17 A Yes.

18 Q And when I say Mr. Tinubu, Mr. Bola Tinubu,

19 who is presently the President of Nigeria?

20 A Okay.

21 Q And when I say INEC, Independent National

22 Electoral Commission in the Nigeria, do you understand

23 that?

24 A Yes.

UNCERTIFIED TRANSCRIPT

6

 

1 Q So I would like to borrow your LinkedIn. I’m

2 handing what is marked as Exhibit 1.

3 (WHEREUPON Exhibit 1 was marked for

4 identification).

5 Q Do you recognize this as your LinkedIn

6 profile?

7 A Yes.

8 Q And I understand you graduated from the

9 University of California at Berkeley in 2012, is that

10 correct?

11 A That is correct.

12 Q And then you received a Master Degree in the

13 philosophy from the University of Chicago in 2013

14 right?

15 A That is correct.

16 Q You’ve been employed as the registrar by the

17 Chicago State University since November 2020, correct?

18 A October 2020.

19 Q Since October 2020.

20 Q And CSU is a public university?

21 A Correct.

22 Q And can you describe to me your job

23 responsibilities?

24 A The registrar managing all policies and

UNCERTIFIED TRANSCRIPT

7

 

1 procedures for the University so we oppose academic

2 affairs regulations and keep the day-to-day management

3 of the office functioning.

4 Q And that include maintaining record?

5 A Correct.

6 Q And does CSU registrar office maintain a

7 physical office?

8 A Yes.

9 Q And do you work out of that office?

10 A I do.

11 Q And how many employees work in the

12 registrar’s office.

13 A We are a team of eight at present.

14 Q And do the seven other individual report to

15 you.

16 A Yes.

17 Q And you work with all seven of those

18 individuals?

19 A That’s correct.

20 Q I’m going to hand you I’m going to mark this

21 as Exhibit 2.

22 (WHEREUPON Exhibit # was marked for

23 identification). Two.

24 Q I’m handing you what has been marked as

UNCERTIFIED TRANSCRIPT

8

 

1 Exhibit 2.

2 Q Mr. West bigger this is the subpoena for the

3 deposition which includes the topics of examinations

4 that Mr. Hayes refers to, is that correct?

5 A Yes.

6 Q And do you recognize this document?

7 A Yes.

8 Q Prior to today’s deposition did you review

9 the topics of the examination that are listed on the

10 pages four and five.

11 A Yes.

12 Q And are you appearing today as the corporate

13 designee as all of the topics on Pages 4 and 5 Of this

14 company?

15 A Yes.

16 Q And are you prepared to each topic of

17 examination on Pages 4 and 5 of the subpoena?

18 A Yes.

19 Q And do you understand as the designated

20 corporate representative of this deposition, my

21 questions are asking for the CSU knowledge and not your

22 percentage knowledge, do you understand that?

23 A Yes.

24 Q And how did you prepare to testify on the

UNCERTIFIED TRANSCRIPT

9

 

1 topics in the subpoena?

2 A We reviewed the student file, conferred will

3 legal affairs at the Chicago State as well as Michael

4 Hayes and reviewed the topic submitted.

5 Q You are concurring with Mr. Haze, how many

6 times did you meet with Mr. Haze?

7 A Somewhere between four or five times.

8 Q And when were these times?

9 A Within the last two months.

10 Q And how long was each meeting.

11 A At least an hour.

12 Q And were they in person?

13 A No, most today was in person most were

14 virtual.

15 Q Did you pleat with anyone else from

16 Mr. Haze’s office?

17 A No.

18 Q Did you speak with any other attorneys in

19 this room?

20 A No.

21 Q Did you speak with other attorneys of

22 Mr. Tinubu?

23 A No.

24 Q Did you speak with any employees of CSU in

UNCERTIFIED TRANSCRIPT

10

 

1 preparing for this deposition.

2 A Robin Hawkins in our legal affairs office.

3 Q And what Robin title?

4 A I don’t know her title —

5 Q And she is an attorney?

6 A Yes.

7 Q And when did you speak with the Robin?

8 A Within the last two weeks.

9 Q And for how long.

10 A About an hour each time. We’ve casted.

11 Q And what were the general topics of

12 conversations?

13 MR. HAYES: I would object on the basis of

14 privilege, Mr. Westberg, you can answer that question

15 generally, but do not disclose in that answer specific

16 conversations with Miss Hawkins who is an attorney for

17 the CSU. Generally, the subject matter, answer that

18 but, please don’t go beyond that.

19 A We discussed the case.

20 Q And did you speak with any formal employees

21 of the CSU in preparation for this deposition.

22 Q Did you speak to Mr. Tinubu or any

23 representatives of the Tinubu?

24 A no.

UNCERTIFIED TRANSCRIPT

11

 

1 Q And other than the individual that we spoke,

2 did you speak with any one else about today’s

3 deposition?

4 A no.

5 Q And you said that you reviewed the

6 student’s files. What are the document that you

7 reviewed in the preparation for the deposition?

8 A The once in the exhibit that we submitted.

9 Q And so that the document that you produced?

10 A Correct.

11 Q Did you review any other documents in

12 preparation for your deposition?

13 A No.

14 Q And did your counsel provide any of the

15 documents that you reviewed for your deposition?

16 A What do you mean?

17 Q Mr. Hayes didn’t give you the documents to

18 review for your deposition?

19 A No we’ve provided all the documents.

20 Q And how did you select these documents?

21 A They were what were requested.

22 Q Who selected them?

23 A I did.

24 Q And how did you, how did you sech for them?

UNCERTIFIED TRANSCRIPT

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1 A Physically in our office we keep student

2 record.

3 Q And they are physical student record?

4 A During that time period yes.

5 Q And electronic copies of those record?

6 A Not from that time period.

7 Q And did you do anything else to prepare?

8 A No.

9 Q I am going to mark this as Exhibit 3.

10 (WHEREUPON Exhibit # was marked for

11 identification). 3.

12 Q Before I hand you this exhibit, did do the

13 document produced yesterday constitute all the

14 documents about Mr. Tinubu.

15 A Yes.

16 Q I’m handing you what has been marked as

17 Exhibit 3, this is these are the responses to applicant

18 revised subpoena to produce documents. That include

19 the applicant’s request document requests. So have

20 you reviewed the document requests?

21 A Yes.

22 Q Have you reviewed the responses?

23 A Yes.

24 Q So I have some questions to ask about the

UNCERTIFIED TRANSCRIPT

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1 requests. 1st request Number 1 state, a true and

2 correct copy of any diploma for the Bachelor of

3 Science, degree issued by the CSU in 1979. And in

4 response it looks like you have’s been able to locate

5 documents that have now been Bates labeled, CSU, 0001

6 through CSU 0007. And so we’ll show outhouse

7 documents. Mr. Tinubu.

8 Q I’m handing what has been marked as

9 Exhibit 4.

10 Q Are diplomas that CSU produced yesterday in

11 response to the Number 1.

12 MR. HAYES: Angela, the exhibit goes beyond

13 the one in the Number 1, I would like to note for the

14 record that the Exhibit 4, knows from the SCS1, to.

15 CSU12 and the response to the one is referencing one

16 through seven.

17 MS. LIU: That is correct. I’m handing you

18 diploma that the CSU produced in response to request

19 Number 1 that and CSU have produced some other

20 documents in the response to request Number 1. And are

21 they true and correct copies of the CSU diploma?

22 A Yes.

23 Q And what is the basis for that?

24 A We have them in our possession. We produced

UNCERTIFIED TRANSCRIPT

14

 

1 these documents. They align with the student record

2 and the official transcript.

3 Q And are these documents maintained in the

4 physical copy form.

5 A We have those physically.

6 Q And you don’t have these document

7 electronically?

8 A Correct.

9 Q And how did you determine that the diplomas

10 from 1979, which are CSU which are Bates stamped CSU1,

11 allow did you determine that these were issued by the

12 CSU in 1979.

13 A Because they say they were.

14 Q Any other reason?

15 A No.

16 Q And where were they found?

17 A In our record room.

18 Q Where is the record room?

19 A Cook administration, building, building 128.

20 Q And if you don’t have the record in the

21 electronic form, what is the put off for keeping

22 documents manually.

23 Q Could?

24 A Could you rephrase that.

UNCERTIFIED TRANSCRIPT

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1 Q So you said that these documents are not in

2 electronic form correct?

3 A Correct.

4 Q So what is the date cut off for the keeping

5 the documents manually rather than digitally?

6 A Are you asking when did we start tracking

7 document digitally?

8 Q Yes?

9 A We moved to Elecian Banner in 1996.

10 Q And that is a software.

11 A Stupid Information Center. ELECIAN Banner.

12 Q And once again. What date was that?

13 A 1996.

14 Q And so documents prior to 1996, you would

15 have, you would not have an electronic form?

16 A Correct.

17 Q And four the diplomas after 1996, you have

18 those stored in the electronic form?

19 A No.

20 Q So at what point do you store diplomas in the

21 electronic form?

22 A We do not ever.

23 Q And did you I guess, why were these records

24 available?

UNCERTIFIED TRANSCRIPT

16

 

1 A While not able to determine that, the

2 speculation I have is that they were never picked up.

3 Q So you did not find Mr. Tinubu diploma that

4 was issued in 1979?

5 A Correct.

6 Q And turning to CSU, 0001 through 0007. These

7 diplomas have date in the 1979, correct.

8 A Correct.

9 Q And they all have seal with the Class B hand.

10 A Correct.

11 Q They all have the same five signatures,

12 correct?

13 A Correct.

14 Q And it looks like one of the signatures it is

15 from the Chairman of Board of Governors Leon Davis?

16 A Correct.

17 Q And another signature from Donald E. Walters

18 Secretary, correct?

19 A It appears so, yes.

20 Q And then Benjamin, Alexander President,

21 correct?

22 A Correct.

23 Q Looks like a Dean leer, Andrew F. Skull la?

24 A Something like that.

UNCERTIFIED TRANSCRIPT

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1 Q But look like Andrew who was a Dean, yes?

2 A Yes.

3 Q And a signature for a registrar James J her

4 reviews sa?

5 A Yes.

6 A I would note that the Dean is going to be

7 different on those because some of them are different

8 colleges.

9 Q So this we’re looking at CSU, 001 diploma, is

10 the Andrew because he is the Dean of Business and

11 Administration?

12 A Yes.

13 Q And is your understanding that the reason why

14 the Board of Govenors, sir is listed on the Diploma,

15 because there is no Board of Trustee in 1979?

16 A That’s correct.

17 Q And it is pretty school that the registrar

18 used to be on the diploma in 1979 as well?

19 A Sure.

20 Q Let’s turn to CSU8 through 10.

21 Q Now, these diplomas were issued by CSU in the

22 ’90s, correct?

23 A That is correct.

24 Q And how do you know when they are were

UNCERTIFIED TRANSCRIPT

18

 

1 issued?

2 A They say the year they were issued.

3 Q And you say that because each document states

4 when the diploma is granted.

5 A Correct.

6 Q And each of those date are in the 90s.

7 A Correct.

8 Q Could any of these diploma, considered drafts

9 or exemplar?

10 A I’m hot sure what the word exemplar means,

11 but none of those would be drafts.

12 Q And how do you know that?

13 A Because these are original diploma we had on

14 file.

15 Q And how can you be sure that they are

16 original?

17 A They are in H our possession, and have never

18 left our possession.

19 Q And why does CSU maintain copies of those di

20 memo mass and not others?

21 A As I mentioned before, we believe the student

22 did not pick them up.

23 Q And looking at these diplomas on the

24 left-hand side, you’ll see a signature from the chair

UNCERTIFIED TRANSCRIPT

19

 

1 of the Board, correct.

2 A Correct.

3 Q Do you know who that is.

4 A A little hard to read the signature to be

5 honest.

6 Q And then on the right it looks like Elenora,

7 D Daniel signs the diploma?

8 A Yes.

9 Q And she is the President in the ’90s.

10 A I believe so.

11 Q And under that signature, a Herbert Kwonly,

12 Science as the Dean of the university?

13 A As Dean of the college?

14 Q And we know he’s Dean of the College Of

15 business because there is Dean at the bottom of the

16 page here?

17 A Correct.

18 Q And the seal on the diploma the seal is a

19 triangle with two lines through, correct?

20 A That’s correct.

21 Q And the seal has the verbiage, 1867 under it?

22 A True.

23 Q And it has Chicago State University on top of

24 the seal, correct?

UNCERTIFIED TRANSCRIPT

20

 

1 A Yes.

2 Q And the seal has the word “responsibility”

3 under that?

4 A Yes.

5 Q And this seal is different than those that

6 were conferred in the Bates stamp CSU1 through seven

7 correct.

8 A Yes.

9 Q When did the seal change?

10 A I’m hot certain. Some point between 1979 and

11 the 90s.

12 Q You think it changed in the 90s?

13 A Possibly.

14 Q And if you look at CSU8 and then CSU9, it

15 looks like the font is a little different between the

16 two. Do you see that?

17 A I don’t see a difference to be honest?

18 Q If you look at the AD before 1989 and the AD

19 1998?

20 A Okay.

21 Q Do they look slightly different to you.

22 A You know necessary are scanned copies and it

23 is entirely possible that that difference is due to the

24 Xerox machine.

UNCERTIFIED TRANSCRIPT

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1 Q And if you go tooths Bates stardom CSU11.

2 And 12 these are two diplomas from 2003?

3 A Correct.

4 Q And they have two signature on those diploma

5 plas?

6 A Yes.

7 Q And one from the Luban chairperson and the

8 other Elnora D Daniel president of the university

9 correct?

10 A Correct.

11 Q And Dr. Lubin was the chairperson in the

12 2003?

13 A Yes.

14 Q Doctor Lubin, was Dr. Lubin the Chairman man

15 in the 2022.

16 A I do not know that off the top of my ahead.

17 Q And Elenora, Daniel the president in the

18 2003?

19 A Yes.

20 Q And Elenora Daniel is not the president in

21 the 2022 correct?

22 A Correct.

23 Q And you’ll see the seal on these diplomas

24 from 2003, are seals with a tree on them?

UNCERTIFIED TRANSCRIPT

22

 

1 A Uh-uh, yes.

2 Q And that seal is different from the previous

3 set of diplomas?

4 A That is correct.

5 Q So when did the seal change then?

6 A At some point between 1999 and 2,003.

7 Q And you don’t know which date?

8 A No I’m not certain.

9 Q Is the seal the same today?

10 A No.

11 Q And what is the seal now?

12 A Our current seal. It is a book, but it looks

13 a little like a tree.

14 Q And when did that change?

15 A I don’t know for certain, I believe that was

16 at some point in the 20 teens.

17 Q And going back to the Exhibit 3, you look at

18 the Request Number 2, the request is a true and correct

19 copy of the any diploma issued by the CSU in the 1979

20 to Mr. Tinubu. Do you see that?

21 A I do.

22 Q And CSU has determined that it does not have

23 a true and correct copy of too Bola Tinbuti in 1979?

24 A That is correct.

UNCERTIFIED TRANSCRIPT

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1 Q And how did the CSU determined that it did

2 not have a true and correct copy of this?

3 A We went through every diploma in our

4 possession.

5 Q And you went through every diploma in your

6 possession, given the importance of this matter.

7 A Yes.

8 Q And so CSU after going through every diplomas

9 was unable to find and authentic copy of any diploma

10 matured to Tinubu in the 1979?

11 A We did not find any diploma issued by 1979 to

12 Mr. Tinubu.

13 Q But you retained copies of the some diplomas

14 of some and not others?

15 A When we have a copy of the diploma, it is

16 because a student didn’t pick it up.

17 Q And you don’t have a copy of the

18 Mr. Tinubu’s, June 22, 1979 diploma or his June 27,

19 1979 diploma, correct.

20 A We have the June 27, 1979 diploma, is in our

21 possession.

22 Q The original June 27, 1978, diploma, is in

23 your possession it is a reordered copy.

24 A The one that you have, it is in one of your

UNCERTIFIED TRANSCRIPT

24

 

1 exhibits.

2 Q And the reordered copy is a re-created copy

3 that CSU re-created?

4 A It is a diploma reorder that matches what we

5 have in CSU11 and 12.

6 Q And why did you not produce the June 27

7 diploma yesterday.

8 A My impression was that you already had that.

9 MR. HAYES: Which request do you think it is

10 responsive to. I don’t read it as being requested

11 yesterday.

12 MS. LIU: True and correct. Copy of any

13 diploma for a Bachelor of Science Degree issued by the

14 CSU in 1979?

15 MR. HAYES: Please ask the witness, but the

16 June 27, diploma was not issued by the CSU in 1979. We

17 all know that.

18 THE WITNESS: What he says is correct.

19 MS. LIU: And she was June 27, 1979 diploma

20 in Mr. Tinubu’s files at CSU?

21 A We don’t keep diploma that in the student

22 files. We have a file cabinet that has diplomas.

23 Q And how long do you keep diplomas, please let

24 me know at CSU?

UNCERTIFIED TRANSCRIPT

25

 

1 A At present until student pick them up. .

2 Q So just to backing up, just so I understand

3 it, say someone today graduated from the 1979 and calls

4 the registrars office and want a copy of their diploma

5 you don’t have like a template for a degree from the

6 CSU in the 1979 in the registrar’s office that you

7 use?

8 A Correct.

9 Q And that person requesting a gloam from 1979

10 department receive a copy of the diploma from 1979,

11 correct?

12 A Correct.

13 Q Diploma.

14 Q Let’s go to Tab 4.

15 MS. LIU: Before I hand you another document.

16 I believe you testified that you produced the entire

17 student file?

18 A Correct.

19 Q Are there any other documents from the file

20 that have been withheld because you thought they were

21 not responsive?

22 A No.

23 Q Only the June 27th please let me know that,

24 correct?

UNCERTIFIED TRANSCRIPT

26

 

1 MR. HAYES: I object. As he testified

2 before, that diploma is not part of the Mr. Tinubu

3 file, when you say other documents with held from the

4 file that is not accurate, Mr. Westberg answer the

5 question if you can.

6 MS. LIU: I kindly ask Counsel from making

7 speaking objections and improperly coaching the

8 witness.

9 THE WITNESS: What was the question again?

10 MR. HAYES: I objected to the form of the

11 question.

12 A No.

13 Q But you did with localed the June 27, please

14 let me know because you thought it was not responsive?

15 MR. HENDERSON: Objection, miss character

16 rises his testimony.

17 THE WITNESS: We provided what was requested.

18 Q But you did not provide the June 27, 1979

19 diploma?

20 MR. HENDERSON: Same objection.

21 THE WITNESS: We did not provide that

22 yesterday.

23 MS. LIU: No, no, I’m going to hand you

24 another document. 5.

UNCERTIFIED TRANSCRIPT

27

 

1 (WHEREUPON Exhibit # was marked for

2 identification), five.

3 Q I am going to hand you what is marked as

4 Exhibit 5, entitled Undergrad rate, please let me know

5 that order replace placement form. And this is the

6 form that is posted on the CSU website for an undergrad

7 order or replacement form.

8 A Yes.

9 Q And do you recognize this document?

10 A Yes.

11 Q And do you people fill out this form in order

12 to order a replacement diploma?

13 A Yes.

14 Q And does everyone has to fill out this form?

15 A If they want to order a replacement diploma.

16 Q And it says full legal name at time of the

17 graduation, you take steps to verify that this person

18 went to CSU?

19 A Correct, yes.

20 Q And what steps do you take?

21 A We locate their record.

22 Q And how do you do that?

23 A Using the confidential information provided

24 that allows you to identify their identity and we do a

UNCERTIFIED TRANSCRIPT

28

 

1 record look up and verify what is on the record before

2 we produce a diploma reorder.

3 Q And how far back in time do those records go.

4 A What do you mean.

5 Q Do you have record from the every student in

6 the 70 be?

7 A If they were ha student with us, we keep a

8 student file on them.

9 Q And how far back do the records go?

10 A I have seen record as early as the 30s.

11 Q Does CSU have a policy or practice after how

12 long they keep the student record?

13 A We keep the student record into perpetuity.

14 Q And what does CSU keep for the student who

15 graduated in the 1979?

16 A At the very least we maintain an official

17 transcript.

18 Q So every, CSU student who graduate waded in

19 the 1979 would have an official transcript in their

20 files?

21 A That’s correct.

22 Q And where are these files kept?

23 A In our records room.

24 Q And are there any instance are record are not

UNCERTIFIED TRANSCRIPT

29

 

1 maintained for a student.

2 A No.

3 Q Do you keep any record of when former

4 students ask for the diplomas?

5 A No.

6 Q Did you have a record of when Mr. Tinubu

7 asked for the diploma?

8 A No.

9 Q Why don’t you keep a record?

10 A It is not consequential to the student file.

11 Q And how many questions for the diploma do you

12 get typically, in a month.

13 A 1. If one. Maybe none.

14 Q It is pretty, A typical, if someone request a

15 replacement dim please let me know?

16 A It could be a handful in a — this is not a

17 common, it is not that common.

18 Q And do you always verify that the someone

19 went to the University before I cannerring a

20 replacement diploma?

21 A Yes.

22 Q And by what mean base, do you do this, if we

23 talk about a student who attend 40 years ago.

24 MR. HENDERSON: Objection. Asked and

UNCERTIFIED TRANSCRIPT

30

 

1 answered.

2 THE WITNESS: I do answer this, we would look

3 up there record.

4 MR. HENDERSEN: On Exhibit 5, at the top of

5 the page, please note we only keep on file diploma up

6 to the two years. Please let me know you are correct?

7 A You are correct.

8 Q If someone graduated in the 2021, and asked

9 for the copy of their diploma from CSU, they would

10 receive a copy. Correct.

11 A I would provide the diploma if we had in our

12 possession, if not I would place an order.

13 Q But if someone graduated from the CSU in the

14 1979 you don’t have a copy of that 1979 diploma?

15 MR. HENDERSON: Objection asked and answered?

16 THE WITNESS: The only event that we have a

17 copy is if a student didn’t pick it up.

18 Q So do you keep documents that were reordered

19 only if they are not picked up?

20 A Correct.

21 Q So why do you have the June 27, diploma in

22 your files?

23 A While the University know that for certain,

24 my speculation, it was not picked up.

UNCERTIFIED TRANSCRIPT

31

 

1 Q And you’re speculating correct.

2 A Correct.

3 Q You don’t know that for certain?

4 A Correct.

5 Q And just process wise, you need to use a

6 different form diploma, if someone reorders a di memo

7 ma from the 1979 to today?

8 A It would appear like the di memo mass that we

9 issued in the 2023.

10 Q So correct me if I am wrong, all diploma are

11 signed by the current President and Board Chair?

12 A Correct.

13 Q And so if I graduated in the 1979 and Ifill

14 out this form for a replacement diploma that placement

15 diploma, would be signed by the current president and

16 board Saturday are chair?

17 A Yes, correct.

18 Q And any one else that you would see to expect

19 to see on the diploma as a signature?

20 A No.

21 Q And if it is a third party requesting a

22 diploma of a CSU graduate, do you always call the CSU

23 graduate of —

24 A We would not do that, we would not process

UNCERTIFIED TRANSCRIPT

32

 

1 that D if it was not from the student.

2 Q Every time?

3 A We would verify it is the student who is

4 requesting.

5 Q So you have never —

6 (WHEREUPON Exhibit # was marked for

7 identification), six.

8 Q I’m handing you what has been marked as

9 Exhibit 6, this purports to be a June 22, 1979 issued

10 to Mr. Bola Tinubu, and you can see it is stamped by

11 INEC on the diploma as well. Have you seen this

12 document before.

13 A In the proceedings of this case, yes.

14 Q You have never seen this document prior to

15 the proceedings in this case?

16 A Correct.

17 Q And I’ll submit to you that this diploma is

18 the diploma that Mr. Tinubu reported to the INEC, do

19 you have any reason to doubt that statement?

20 A No.

21 Q And this June 22, 1979 diploma I will refer

22 to as the INEC diploma for the simplicity sake for do

23 you understand?

24 A Yes.

UNCERTIFIED TRANSCRIPT

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1 Q And let’s take a look at the INEC diploma.

2 INEC diploma says that the diploma is granted on this

3 22nd day of June 1979. Correct.

4 A Yes.

5 Q And CSU didn’t have a Board of Trustees in

6 the 1979, did it.

7 A True.

8 Q So let’s look at the signature on the INEC

9 diploma. On the right it looks like one of the

10 signatures says Elenora Daniel, correct.

11 A Yes.

12 Q And Elenora Daniel was not the share or the

13 President of CSU in 1979, correct?

14 A Yes.

15 Q And she was the President from 1998 to the

16 2008, correct.

17 A As far as I’m aware.

18 Q For the other two signatures, the one on the

19 right, looks like her Herbert A Conley.

20 A It doesn’t state Dean under it, correct.

21 A It does appear that may be cut off from the

22 Xerox.

23 Q But it is not there?

24 A I do not see it on the paper.

UNCERTIFIED TRANSCRIPT

34

 

1 Q And Herbert A Conley, was not Dean in 1979,

2 correct?

3 A As far as I’m aware.

4 Q And the signature on the left who was that?

5 A Very hard to make out signatures I’m not sure

6 what the name is.

7 Q You don’t think this person was the Chairman

8 of the board in 1979?

9 A I didn’t say that.

10 Q Are you looking at a different document?

11 A I think this matches what we have for

12 Exhibit 10 and 11.

13 Q From the Bates stamp CSU so and CSU11.

14 Q And those diploma plas are from 1990, well,

15 it is not from CSU11. Correct.

16 A Pops you are correct.

17 MR. HAYES: Keep your voice up please.

18 THE WITNESS: 9 and 10.

19 Q So.

20 MS. LIU: And the date for included on the

21 diploma for CSU9 and 10, are 1998 and 1999

22 respectively, correct.

23 A Yes.

24 Q And so this person on the left-hand side of

UNCERTIFIED TRANSCRIPT

35

 

1 Exhibit 6 that signature he wasn’t the Chairman of the

2 Board in the 1979, correct.

3 A Correct.

4 Q And the seal on the Exhibit 6 doesn’t have,

5 it is the triangle with it lines through it?

6 A Yes.

7 Q And the seal doesn’t have the word

8 responsibility under it?

9 A Correct.

10 A Not on this copy, no.

11 Q And the seal does not have 1867 under it?

12 A Not on this copy.

13 Q And you are unaware of any diploma that

14 includes these three signature being issued by the CSU

15 correct.

16 A Correct.

17 Q And you are unaware from any diploma from

18 1979 that includes the triangle, seal having been

19 issued by the CSU, correct.

20 A Correct.

21 Q And you have’s never seen a diploma that

22 cut off the triangle seal in this manner?

23 A Correct.

24 Q You have never seen a diploma that cut off

UNCERTIFIED TRANSCRIPT

36

 

1 the signature of Herbert Conley, position like that?

2 A Correct.

3 Q And CSU doesn’t have a 1979 diploma that

4 contains the font CL signatures and wording apart from

5 the INEC diploma, correct.

6 A Correct.

7 Q And CSU doesn’t know of any diploma like the

8 INEC diploma being issued, correct.

9 A I believe that is what we produced that in

10 the request. Hold on. The once that are like it, are

11 CSU, eight, nine and 10.

12 MS. LIU: CSU8, 9 and 10, are dated in the

13 1999?

14 A You are correct.

15 Q Or from the 90s?

16 A Correct.

17 Q And Exhibit 6 is dated from 1979 crescent?

18 A It is dated 1979.

19 Q So CSU doesn’t know of any diplomas dated

20 1979 like the INEC diploma that has ever been issued

21 correct.

22 MS. LIU: It is a simple yes or no answer.

23 A Sure.

24 Q That’s correct.

UNCERTIFIED TRANSCRIPT

37

 

1 A Yes.

2 Q And has hoe bases so that it was issued by

3 the CCSU?

4 A Check audio.

5 A The student in the question graduated from

6 the university June 22, 1979, were not qualified to

7 verify whether this document is authentic, given that

8 it is not in our possession.

9 Q Have you ever seen a diploma purporting to

10 the be from the CSU but was actually a forgery?

11 A Yes.

12 Q Are you awe wear of any entities, create such

13 fake diplomas?

14 A Yes.

15 Q Can you give me some examples of that —

16 A Not I cannot provide a name of an entity,

17 that does such, however, you can Google this easily,

18 there are many companies that do this for folks.

19 Q And CSU has no record of issuing this INEC

20 diploma to the President Tinubu in 1979?

21 MR. HENDERSON: Objection. Asked and

22 answered?

23 A Correct.

24 Q And CSU has no record of I’s cannerring, INEC

UNCERTIFIED TRANSCRIPT

38

 

1 to President Tinubu?

2 MR. HENDERSON: Objection. Asked and

3 answered for a third time.

4 A Correct, we do not keep copies of the reorder

5 requests.

6 Q And CSU did not issue either the two diploma

7 to the President Tinubu in the 1979, correct?

8 A Can you rephrase that.

9 Q So CSU did not issue June 22, 1979 diploma as

10 well as the June 27, 1979 diploma to Mr. Tinubu in

11 1979?

12 MR. HENDERSON: Objection. Compound

13 question.

14 MS. LIU: Reframe from making.

15 MR. HENDERSON: Other than a speaking

16 objection, vague. And — question is not a speaking

17 objection.

18 MR. HAYES: You can answer the question Caleb

19 if you understand it.

20 A We issued a diploma to every. Students that

21 graduates. I think I’m a little confused by the

22 question, though.

23 Q I’ll rephrase it. So CSU did not the INEC

24 diploma to President Tinubu in 1979?

UNCERTIFIED TRANSCRIPT

39

 

1 MR. HENDERSON: Objection. Asked and

2 answered?

3 THE WITNESS: Not in 1979.

4 Q And did not issue a diploma dated June 27,

5 1979 to Mr. Tinubu in 1979?

6 A Correct.

7 Q Mr. Westberg, I’m hand you can you what is a

8 has been marked as Exhibit 7. It is a letter from CSU

9 dated June 27, 2022, do you recognize that document.

10 A I do.

11 Q This is a stock letter for anyone who

12 requested Mr. Tinubu’s record?

13 A Yes.

14 Q Did you draft this letter?

15 A I did.

16 Q Did anyone else help to prepare you in

17 drafting this letter?

18 A No.

19 Q And was CSU counsel involved at this point.

20 A I don’t recall.

21 Q Do you recall CSU outside counsel was

22 involved at this point?

23 A I don’t think so.

24 Q And no one else was anyone else involved in

UNCERTIFIED TRANSCRIPT

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1 drafting this letter?

2 A no. in about 20 years ago we received similar

3 requests and a past registrar named Lois Davis looked

4 into the matter and drafted a more or less, identical

5 letter at that time as well.

6 Q So 20 years ago, you received similar

7 requests about Mr. Tinubu’s record?

8 A That’s correct.

9 Q And Lois Davis was the registrar then?

10 A She was.

11 Q And she wrote a stock letter similar to this

12 in Exhibit 7?

13 A Yes.

14 Q And you don’t have a record of that in your

15 possession?

16 A Not no.

17 Q There is no record of Lois Davis’ letter in

18 the CSU’s possession?

19 A Yes, we have a copy of the letter.

20 Q And that is in Mr. Tinubu’s files?

21 A No.

22 Q Where would that be then?

23 A Somewhere in our office, probably in my

24 office at present.

UNCERTIFIED TRANSCRIPT

41

 

1 Q University like sitting on your desk or

2 where?

3 A When these matters arise and we have to do

4 checking on thing, we look up what we have available to

5 us and this was found.

6 Q So where was it found?

7 A 1 of my staff members brought it to me.

8 Q Was that in electronic form?

9 A Yes. A scanned copy.

10 Q And so you took miss Davis’ letter and just

11 made and identical letter in 2,022.

12 A After verification of the record to ensure

13 that was accurate.

14 Q And what did you do to verify?

15 A I looked up the student record.

16 Q Anything else.

17 A Nothing else.

18 Q Did you call Miss Davis?

19 A No.

20 Q Was the letter that is Exhibit 7 drafted at

21 the request of the Mr. Tinubu?

22 A No..

23 Q And do you know if the letter drafted by Lois

24 Davis was drafted at request of Mr. Tinubu?

UNCERTIFIED TRANSCRIPT

42

 

1 A I doubt it.

2 Q Why do you say that?

3 A I was not around when Lois Davis was

4 registrar so I can’t 100 percent say that, we as

5 registrar don’t usually, issue letters of student.

6 A We don’t generally do these kind of

7 typically, the student without being requesting a

8 letter like this.

9 Q And so was a hyperfile situation 20 years

10 ago.

11 A My understanding is that yes, I believe

12 bulletin who has been in the politics for a long time.

13 Q And in drafting Exhibit 7, was there and

14 uptick in the number of inquiry for Mr. Tinubu’s

15 record then?

16 A Yes.

17 Q And were you balding those inquiries?

18 A Yes.

19 Q Building.

20 Q And were they in to his diploma?

21 A Yes.

22 Q And about how many inquiries, did you get?

23 A 5 to 30 a day.

24 MR. HENDERSEN: Would you read that answer

UNCERTIFIED TRANSCRIPT

43

 

1 back.

2 Q And how would those inquires come to CSU?

3 A Via, e-mail.

4 Q And for each of necessary inquiries, you

5 would send this letter that is Exhibit 7?

6 A Correct.

7 Q And did you notify Mr. Tinubu each time?

8 A No.

9 Q And you knew it was a controversial matter,

10 but you did not notify him?

11 A The university was not under the impression

12 this was a controversial matter.

13 Q You knew it was an important matter though,

14 and you didn’t notify him then?

15 A Correct.

16 Q And the letter state please be advised that

17 the bola Tinubu attended Chicago State University from

18 the August 1977 to June 1979. He was awarded a

19 Bachelor of Science Degree in the Business

20 Administration with honor on June 22 terms and

21 conditions 1979. His major was accounting. Apart from

22 coping the information from Lois Davis’ letter, what

23 is the basis for the assertions in this letter.

24 A The student transcript.

UNCERTIFIED TRANSCRIPT

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1 Q Anything else.

2 A no.

3 Q Your assertions are rather than the are

4 aren’t based on personal knowledge though that

5 Mr. Tinubu applied, correct.

6 A No.

7 Q And were you told by someone that Mr. Tinubu

8 applied.

9 A No.

10 Q So CSU has no basis to conclude with the

11 certainty that the Bola Tinubu is the same Bola Tinubu

12 who is president, correct?

13 A We believe they are one in the same.

14 Q So CSU is simply, assuming that the Bola

15 Tinubu is the same person as the President?

16 MR. HENDERSON: Objection asked and answered?

17 THE WITNESS: That is correct.

18 Q And whom it may concern that CSU produced

19 yesterday doesn’t have your signature right?

20 A Can you show me what we are talking about.

21 Q Sure.

22 (WHEREUPON Exhibit # was marked for

23 identification) Exhibit 8.

24 Q I hand you what has been marked as the

UNCERTIFIED TRANSCRIPT

45

 

1 Exhibit 8.

2 A You are correct, their letter does not have

3 my signature.

4 Q And I’ll just put on the record that the

5 Exhibit 8 are the documents that are some of the

6 document that you produced that CSU produced yesterday.

7 A Yes.

8 Q And so to the to whom it may corn letter

9 doesn’t have yourating.

10 MR. HENDERSON: Can we talk about the Bates

11 stamp to make the record here?

12 A Would you let me know, Bates stamp CSU0015,

13 doesn’t have your signature right.

14 THE WITNESS: I don’t see the Bates stamp but

15 this letter here or this one does have and this one

16 does not have the signature. 0013 does not have my

17 signature.

18 MR. HAYES: Can we stop for a second. Can I

19 ask a question, the exhibit that you showed the witness

20 CSU0015, is not what we produced yesterday. It is

21 missing the Jamar or attached up in the corner. J Arc O

22 R R. I’m looking at what we’ve produced yesterday and

23 what we just handed the witness with the CSU number on

24 it and the documents are different.

UNCERTIFIED TRANSCRIPT

46

 

1 Q These document were what we received

2 yesterday, we can clear up from the maybe after the

3 break, but it is not necessary at this point?

4 MR. HENDERSON: I would object, if you are

5 going to ask questions about the document, I would are

6 like to refer to the Baites nal or if you are not going

7 to ask him question that is fine, if you are going to

8 ask let’s be on the same page either by exhibit or

9 Bates page.

10 MR. HAYES: I’m happy to talk to you during

11 the break about the parent discrepancy in the some of

12 the markings on the documents I agree we should move

13 ahead, I apologize.

14 Q And you are aware. That are you oh, you

15 aware that to whom it may conern, that was Nigerian has

16 your signature.

17 MR. HENDERSON: Either, what exhibit or Bates

18 page.

19 MS. LIU: I’m asking him a question you.

20 MR. HENDERSON: You are referring to a

21 document.

22 MS. LIU: I can depo to the Exhibit 7.

23 Exhibit 7 has your signature on it, correct.

24 A Yes.

UNCERTIFIED TRANSCRIPT

47

 

1 Q Are you aware that this letter with your

2 signature on it, was submitted in the Nigerian

3 litigation.

4 A I am now.

5 (WHEREUPON Exhibit # was marked for

6 identification), Exhibit 9.

7 Q Landing the witness what has been marked as

8 Exhibit 9. This is a subpoena issued by Mike

9 ENAHORO-EBAH. This is the subpoena issued by Mike

10 Enahoro-Ebah lawyer Mr. Kowals, K-O-W-A-L-S. And it is

11 a subpoena for the record pertaining to the admission

12 or pertaining to record, it is a subpoena for any and

13 all record pertaining to the admission of bola Ahmed

14 Tinubu. Do you recognize that.

15 A Yes.

16 Q You have seen this subpoena before?

17 A Yes.

18 Q Were you the one that gathered the

19 information for this subpoena?

20 MR. HAYES: I would object to this line of

21 questioning as not related to today’s topics of

22 today’s deposition, topic, one through five,

23 Mr. Westberg is not here on the University’s behalf

24 to address questions about that prior subpoena. I’m

UNCERTIFIED TRANSCRIPT

48

 

1 not going to instruct you not to answer, but

2 Mr. Westberg can answer question to the extent of his

3 personal knowledge and I ask you to stick to the topic

4 of the deposition today, this isn’t one of them.

5 MS. LIU: Topic Number 2, is CSU positions on

6 the authenticity of the eight document that are

7 included in the exhibits to the complaint in

8 Enahoro-Ebah versus, Tinubu.

9 MR. HAYES: I agree it is the authenticity of

10 the document that are attached to the subpoena. But

11 please go aid head I have stated my objection.

12 MS. LIU: Were you the one that gathered the

13 information for this subpoena.

14 A Yes.

15 Q Did anyone else help you?

16 A No.

17 Q And let’s turn back to the subpoena which is

18 Exhibit 2. The subpoena in this matter.

19 A Yes.

20 Q And attached to?

21 MR. HENDERSON: I am sorry. We are on

22 Exhibit 2 now.

23 MS. LIU: Yes, attached to that exhibit are

24 additional documents that were topics in the subpoena..

UNCERTIFIED TRANSCRIPT

49

 

1 A Yes.

2 Q And if you can turn to the page with the

3 handwritten Exhibit 7 on it, it is a letter from you to

4 Mr. Kowals dated September 22, 2022. Do you recognize

5 this letter?

6 A I do.

7 Q This letter was sent by CSU, that is correct.

8 A That is correct.

9 Q And you signed this letter?

10 A I did.

11 Q And it says, the enclosed documentation, is

12 all the record we have for Bola Tinubu. We do not have

13 the record of any documentation for a passport visa,

14 Social Security Card or driver’s license, initially, we

15 don’t have a record of now o tuition was paid during

16 their time of attendance.

17 Q Before sending along these documents to

18 Mr. Kowals, did you contact Mr. Tinubu?

19 A No.

20 Q Why not?

21 A I was not instructed to do so.

22 Q And who would have instructed you to do so?

23 A Our Legal Affairs Department.

24 Q Did the Legal Affairs Department tell you you

UNCERTIFIED TRANSCRIPT

50

 

1 could send one of these documents without contacting

2 Mr. Tinubu. Strike that. Par par this letter has more

3 information in it than the stock letter of information

4 that you sent before in Exhibit 7.

5 A You are correct.

6 Q And the remainder of the document attached to

7 this subpoena that is Exhibit 2, these were included in

8 the Enahoro-Ebah complaint with this letter.

9 A What are we referring to.

10 Q So the remainder of the documents attached to

11 the subpoena which is Exhibit 2?

12 A Oh, I see, yes.

13 Q And the remainder, did Mr. Enahoro-Ebah?

14 A Yes.

15 Q And looking at the documents with the written

16 Exhibit 9, the written Exhibit 10. And written

17 Exhibit 11, and written Exhibit 12 how did CSU

18 authenticate these documents before sending them to

19 Mr. Enahoro-Ebah.

20 A We located them in the student file.

21 Q And the written Exhibit 8, was that also in

22 the student file.

23 A no. this is in the file cabinet with

24 diplomas.

UNCERTIFIED TRANSCRIPT

51

 

1 Q So looking at these exhibits or at least

2 document, how is CSU cellular that they all concern the

3 same Bola Tinubu who is now president?

4 A Because of the transcript.

5 Q And that the only basis?

6 A That is the official record of the a student,

7 a diploma in the U.S. is considered a ceremonial

8 document.

9 Q Let’s look@ment handwritten nine which state

10 Chicago State University academic record at the top?

11 A Yes.

12 Q And you see in the upper right hand corner,

13 that the bitter date appearance to be 3/29/54 here.

14 A That is correct.

15 Q And you are aware that Mr. Tinubu also

16 submitted to the INEC that his H birthday is 3/29/52?

17 A I’m not aware of that.

18 Q How can you be sure that this is the same

19 Bola Tinubu who is now president?

20 A This is the part of the student official

21 record, we don’t have any reason to authenticate of our

22 student record. Authenticity of our student record.

23 Q But there is nothing in this document that

24 strike that.

UNCERTIFIED TRANSCRIPT

52

 

1 Q Exhibit 12, the handwritten Exhibit 12. Leer

2 it says, that the Bola A Tinubu is female.

3 MR. HENDERSON: What document are we looking

4 at?

5 MS. LIU: Handwritten Exhibit 12,.

6 MR. HAYES: At the back of Exhibit 2. Vic.

7 MR. HENDERSON: I want to make cellular we

8 are on the same page.

9 Q (By Ms. Liu) It has a heading of southwest

10 college.

11 Q And this document is in the student files?

12 A You are correct.

13 Q And this document says, Bola A Tinubu is

14 female?

15 MR. HENDERSON: We are talking about the

16 southwest college document?

17 THE WITNESS: It does indicate that.

18 Q So how are?

19 MS. LIU: So how did you sure that the Bola A

20 Tinubu who is female is the Bola Tinubu of Nigeria.

21 MR. HENDERSON: Objection foundation?

22 A We can attest this is part of the student

23 record, there was received by the just, this is what we

24 have in connection with the student record.

UNCERTIFIED TRANSCRIPT

53

 

1 Q So anything received by the university you

2 just awe assume is correct.

3 A no.

4 Q So you are notarial sure then that this Bola

5 Tinubu listed at female is the same Bola A Tinubu is

6 the president R president of my engineer ra?

7 MR. HENDERSON: Objection. Asked and

8 answered?

9 THE WITNESS: I’m not saying that.

10 Q (By Ms. Liu) Because you are not

11 cellular,?

12 A I’m not saying that, because we believe there

13 to be part of the student record, so while you know, I

14 can’t detest whether or not that was caught at the

15 time, this was submitted and received as part of the

16 student file.

17 Q So everything that is a part of the student

18 file is in your estimation, correct.

19 A I’m saying these are accurate document that

20 that are a part of the — they are accurately part of

21 the student file.

22 Q But you are not saying that the information

23 submitted in the documents is correct.

24 A I’m saying I’m able to verify that this is

UNCERTIFIED TRANSCRIPT

54

 

1 what is a part of the student file.

2 Q So you are saying that the student, this is

3 part of the student file correct but just because a

4 record is a part of the student file doesn’t mean that

5 the underlying information is correct right.

6 A You are correct.

7 Q So this document doesn’t mean that this is

8 the same Bola Tinubu that is the President of my

9 Nigeria?

10 MR. HENDERSON: Objection. Asked and

11 answered.

12 THE WITNESS: Chicago University doesn’t seek

13 to what is on the transcript, what I can say is this is

14 received by the Chicago State University and is a part

15 of the student file.

16 Q (By Mr. Hayes) We have been going for the

17 two hours, sometime soon, you can finish on that

18 document, I would request a five minute break.

19 Q (By Ms. Liu) So CSU doesn’t know for

20 certain what is in these documents is true correct.

21 MR. HENDERSON: Objection. Asked and

22 answered?

23 THE WITNESS: Nobody working at the

24 university was currently working at the university was

UNCERTIFIED TRANSCRIPT

55

 

1 around in the 1979, so I don’t have a way to tell you

2 what occurred with the southwest college transcript at

3 the time.

4 Q Can you read back the question.

5 MR. HENDERSON: Would you read back lis

6 answer please. Read back.

7 Q (By Ms. Liu) And just a few employer

8 questions before a break, just to make sure I’m

9 clear, none of these documents we just looked at

10 state that the individual is Bola Ahmed Tinubu

11 correct.

12 A I’m not certain that we have his middle name

13 spelled out on those documents no.

14 Q (By Mr. Henderson) Which document are you

15 talking about. The Southwest College one that we

16 went over.

17 Q (By Ms. Liu) Any of the documents attached

18 to the subpoena?

19 MR. HENDERSON: Okay. The Southwest College

20 Sabo la A Tinubu.

21 MS. LIU: Let me ask the question again, none

22 of these documents —

23 THE WITNESS: They do not state his full

24 middle name.

UNCERTIFIED TRANSCRIPT

56

 

1 Q (By Ms. Liu) Thank you.

2 MR. HENDERSON: For the record the Southwest

3 College one says Bola HTinubu and the document in the

4 court file and I’m not sure what this is,?

5 MS. LIU: Mr. Henderson, kennelly, are you

6 speaking a speaking objection.

7 MR. HENDERSEN: I’m going to clarify the

8 record. Less are Bola H on the document that is three

9 or four pages ahead of the Exhibit 11 and ahead of the

10 Exhibit 11. On Exhibit 10, it says Bola A Tinubu. On

11 Exhibit 10. On Exhibit and another one —

12 Q But none of those documents state Bola Ahmed

13 Tinubu.

14 A You are correct.

15 Q Awe 10, bore, can we take a comfort break.

16 Austin —

17 MS. LIU: Back on the record, Mr. Westburg, I

18 asked you previously how do you know that the Bola

19 Tinubu and in the student record is the same B Tinubu

20 that is now president. And I believe your testimony is

21 that the record is correct.

22 A I guess how do you know that it is the the

23 same person who is president.

24 A So when we do an analysis of the record we

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1 are looking at a lot of the documentation in, we are

2 looking at the official transcript. We’re looking at

3 thing like for example what is in here is the admission

4 to the student and the admissions application, all of

5 outhears things match that identity and so we have no

6 reason to doubt that what’s in the student record is

7 what we have.

8 Q I guess I would ask you this question. So

9 using my name, Angela Liu if there is a record of Angie

10 Liu in CSU files, how do you know this is the same

11 Angie Liu that is iting in the front of you right now.

12 MR. HENDERSON: Objection asked and answered.

13 A We would check your student file against your

14 personal information in the case of Bola Tinubu it is

15 the unusual name in the U.S. It is not a hard one to

16 verify.

17 Q Do you know if Bola Tinubu is a common name

18 in the fly engineer yeah?

19 A I’m not aware.

20 Q Nigeria.

21 Q And your aware of the discrepancy of his

22 birth date in the document appended to the subpoena and

23 what was submitted to the INEC?

24 A Can you reference where we’re looking at

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1 discrepancy,.

2 Q Handwritten Exhibit 9 says the date of birth

3 is 3/29/54?

4 A Against which document.

5 Q I can submit to you that the document that

6 was submitted to in the Mr. Tinubu’s affidavit of

7 particulars state that hi birthday is March 29, 1952. .

8 MR. HENDERSON: For the record can you

9 identity that document for us please.

10 MS. LIU: It is I can get that exhibit, are

11 you aware of any of the discrepancy in his bitter date

12 in in these document that were submitted to the INEC.

13 MR. HENDERSON: Same objection.

14 THE WITNESS: According to the record, I’m

15 not aware of any discrepancies.

16 MS. LIU: And you are aware of the

17 discrepancy in his gender?

18 A The university is not confused by this, we

19 issued a to Bola Tinubu and he applied as a male

20 student that is a part of the record.

21 Q So if you have a record of and Angela Liu in

22 CSU’s files, you are certain it is the same one in

23 front of you now?

24 MR. HENDERSON: Objection. Calls for

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1 speculation and complete hypothetical.

2 THE WITNESS: I would need to look at what

3 you submitted to me, to identify your identity.

4 Q Can you give me some examples of that?

5 A When we seek to verify identity, we are

6 seeking to the look at legal name, we are looking at

7 date of birth, we are looking to look at you know,

8 could be social security number — you know, there is a

9 variety of personal identification information that we

10 might look up.

11 Q Identifying information.

12 Q Okay, let’s go to and going back to that, I

13 guess did you verify strike that. Turning to

14 handwritten exhibit approximate, attached to the

15 subpoena which is Exhibit 2 in this case. This is a

16 diploma that is I’m sorry I ask that you turn to the

17 exhibit handwritten Exhibit 8. Which is the diploma

18 dated the 27th day of June, 1979.

19 A Yes.

20 Q Do you recognize this document.

21 A I do.

22 Q And this was one of the documents that were

23 included in the letter to Mr. Kowals?

24 A Yes. KO W A L S. Hold on. Oh, yes. .

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1 Q And there is issued with the Enahoro-Ebah

2 subpoena?

3 A This is date.

4 A Yes.

5 Q This is dated differently than the diploma

6 that is dated June 22, 1979?

7 A You are correct.

8 Q And was this because this one is dated

9 July 27, 1979, correct.

10 A Yes.

11 MR. HAYES: You meant to say June, Angela.

12 MS. LIU: Yeah, June 1979.

13 A Above that was the Mr. Hayes.

14 Q And this document was already in

15 Mr. Tinubu’s files when you were responding to the

16 Mr. Enahoro-Ebah for a subpoena?

17 A We had this in our diploma file cabinet.

18 Q Typically, you don’t keep diplomas longer

19 than it years?

20 A We only mail diplomas that students do not

21 pick up.

22 Q Do you ever send di memo mass out?

23 A We do mail diplomas as part of our business

24 operations. Some student request a pick up and some

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1 student do not. At other point in time, this is not

2 current, but a diploma may be, it used o be that the

3 diploma were sometimes held due to an outstanding

4 balance as well.

5 Q So this diploma could have been held because

6 of an outstanding balance?

7 A I doubt that, but I suppose it is possible.

8 Q So why would you have this diploma dated

9 June 27, 1979 and not the INEC diploma.

10 A I have this diploma because it was never pick

11 up, the INEC diploma we don’t have in our possession,

12 as it is not a current record of ours.

13 Q And you didn’t mail you think think to mail

14 that June 27, 1979 diploma?

15 A no. we do not mail any of our diplomas.

16 Q How long has this diploma been in your file?

17 A We would have to speculate around the same

18 time as the ones that match the signature and the seal.

19 Q And are you referring to the documents Bates

20 stamp CSU11 and CSU12?

21 A Correct.

22 MR. HAYES: Let her finish.

23 Q — Exhibit 2.

24 A I was referring to the Exhibit 4, 11 and 12.

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1 Q And if you could turn back to the document

2 requests that CSU responded to. Through the Exhibit 3.

3 Q And it state, CSU for the response to Number

4 request Number 3, CSU is also producing bait labeled at

5 CS11 and 12, prepared for the other student which match

6 the format of the Tinubu replacement diploma dated

7 June 1997. Is 1997 a typo.

8 A Yes.

9 Q Should it be the 1979?

10 A I believe so.

11 Q And then you are saying the CSU document

12 Bates stamped, CSU11 and 12, match the format of the

13 Tinubu diploma dated June 27, 1979 then correct.

14 A Yes.

15 Q And if I go back to the CSU11 and 12

16 documents so the documents Bates attached 11 and 12,

17 which are?

18 MR. HAYES: Exhibit 4.

19 MS. LIU: Part of Exhibit 4. These documents

20 are from 2,003 correct.

21 A Correct.

22 Q And just to make sure that it is clear for

23 the record, the response to request Number 3, which

24 state that the students’ name on this has been —

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1 sorry, which states, CSU is also producing Bates

2 labeled at CSU11 and CSU12, diplomas prepared foreother

3 students with their names redacted for the privacy,

4 which match the format of the Tinubu replacement

5 diploma dated June 27, 1997 that you means June 271979.

6 A That is correct.

7 MR. HAYES: I’ll state on the record as the

8 author that is my typo.

9 Q And CSU11 and 12, those Bates stamp document

10 are from 2,003 correct.

11 A Yes.

12 Q And there is not from 1979 correct.

13 A Correct.

14 Q And going back to the June 27, 1979 diploma

15 that is attached to Exhibit 2, you didn’t prepare this

16 diploma?

17 A No.

18 Q Do you know who prepared this diploma?

19 A No.

20 Q And your speculating that the diploma is in

21 the files because it wasn’t picked up.

22 A Correct.

23 Q So why would Mr. Tinubu in Nigeria row order

24 a diploma and not asked that it be sent to him.

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1 MR. HENDERSON: Objection. Foundation.

2 Calls for speculation.

3 A You may want to ask him.

4 Q (By Ms. Liu) You have any thought on that?

5 MR. HENDERSON: Same objection,.

6 A I can’t speculate on why a student behaves

7 the way they behave.

8 Q Does it sound plausible to you that

9 Mr. Tinubu in Nigeria would reorder a diploma and not

10 asked that it be sent to him.

11 MR. HENDERSON: Same objection?

12 THE WITNESS: Yes.

13 Q (By Ms. Liu) Liu this diploma dated

14 June 27, 1979 looks different than the INEC

15 diploma?

16 A You are correct.

17 Q The verbiage of top is different. Correct.

18 A Yes.

19 Q Because the seal with a tree on it, correct.

20 A Correct. I believe we answered these.

21 Q And it is signed by Eleanor Daniel who is

22 president of the University, correct.

23 MR. HENDERSON: Objection. Asked and

24 answered.

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1 THE WITNESS: Yes.

2 Q (By Ms. Liu) Liu she wasn’t the president

3 of the university in 79?

4 MR. HENDERSON: Same objection. Asked and

5 answered.

6 THE WITNESS: She is correct and that is

7 correct.

8 Q And she wasn’t the President in 2022,

9 correct?

10 A Correct.

11 Q Also signed by Niva Lubin by the Board of

12 Trustee, correct.

13 A Correct.

14 Q And Dr. Lubin wasn’t the Board of Trustee in

15 1979 hen-same objection, asked and answered?

16 THE WITNESS: Yes.

17 Q Dr. Lubin wasn’t chairman of the board of

18 trustees in 2022, correct?

19 A Correct.

20 Q Apart from the letter to Mr. Kowals. What

21 communications did you have with Mr. Enahoro-Ebah

22 lawyers?

23 A None.

24 Q Now, let’s move to some more documents.

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1 MR. HAYES: Can we take a slotter break and

2 get the right one.

3 (WHEREUPON Exhibit # was marked for

4 identification). 10..

5 MR. HENDERSON: This is being marked as 10.

6 MR. HAYES: Yes.

7 Q (By Ms. Liu) Liu I’ve just handed you

8 exhibit marked as 10 and these are documents that I

9 just received as the official copy of the CSU

10 produces relating to Mr. or. Previously I lad put

11 many the record Exhibit 8 which is the copy that we

12 received yesterday from CSU but Exhibit 10 is the

13 official copy from the CSU.

14 MR. HAYES: Can you confirm that for her

15 Caleb.

16 A Yes, that is correct.

17 Q So tress document in the Exhibit 10 were

18 produced in response to a document request asking for

19 true and correct copies of any CSU documents relating

20 to Mr. Tinubu that were certified by the Jamar C. Orr,

21 correct?

22 A Correct.

23 Q And Lamar or his associate, GC of CSU?

24 A He was.

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1 Q And does associate, GC — document?

2 A I’m not aware of that.

3 Q Are you aware of any other instance when

4 associate or when any documents are certified by CSU

5 counsel?

6 A No I’m not.

7 Q And what does certifying a document even

8 mean?

9 A My impression the recollection in this was

10 that he was request requested to do this.

11 Q And who requested him to do this.

12 A I think the W O L E A FO L B I.

13 Q Mr. Obvious Mr. Woleafolbi is Mr. Tinubu

14 lawyer here, correct?

15 A I believe so, yes.

16 Q And did you speak with Mr. Woleafolbi?

17 A No.

18 Q Do you know if Mr. Orr spoke with

19 Mr. Woleafolbi?

20 A I think they had an e-mail exchange.

21 Q Was it prior to certifying these documents?

22 A Yes.

23 Q And do you know what was discussed in that

24 e-mail exchange?

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1 A The request to certify the documents.

2 Q Have you seen their e-mail before?

3 A I don’t recall.

4 Q And did anyone at CSU certify the

5 certification?

6 A I don’t understand the question.

7 Q Did anyone at CSU know that Mr. Orr was

8 certifying those documents?

9 MR. HENDERSON: Objection. Foundation.

10 Vague.

11 A I believe Jason Carter was aware. Part of

12 General Counsel.

13 Q Do you know Jason Carter then approved their

14 certification.

15 A I’m not aware.

16 Q And looking at CSU13, the document Bates

17 stamped, C SU13. It’s states that on June 28, 2023, in

18 compliance with the family education right and prive va

19 act, on receipt of sign consent from Mr. Bola A. tinubu

20 diploma, Mr. Woleafolbi was provided the educational

21 record of Mr. Tinubu. Do you see that?

22 A I do see that.

23 Q And so your understanding is that

24 Mr. Woleafolbi e-mailed Mr. Orr asking for these

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1 documents, correct?

2 A I don’t know the question was made, it was

3 played, via, the form you have which is CSU14. .

4 Q (By Ms. Liu) Liu apart from the Jason

5 Carter, do you know of anyone else who was involved

6 in certifying these documents?

7 A No.

8 Q Did you help correctness document for

9 certification. Collect?

10 A Yes, they were from the student file.

11 Q Did Mr. Orr ask you to collect the document

12 for certification.

13 A He asked me to provide them which I did.

14 Q And so you went to the student file and you

15 provided the documents to Mr. Orr?

16 A Yes.

17 Q So that he could respond to

18 Mr. Woleafolbi’s request?

19 A Yes.

20 Q Did you know that Mr. Orr was going to

21 certify and provide them to Mr. Tinubu’s lawyers?

22 A I was aware that the request was made. I

23 don’t get involved in the legal affair to say, business

24 processes.

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1 Q So turning to the CSU14 the content to

2 release student educational record it looks like it is

3 for Bola, Ahmed Tinubu from Lagos Nigeria, correct.

4 A That is correct.

5 Q Asking for the grades, kick process?

6 A That is correct.

7 Q And Lagos, Nigeria.

8 Q And the record should be released to

9 Mr. Woleafolbi correct.

10 A Correct.

11 Q And there being released for legal

12 proceedings, is that correct.

13 A Correct.

14 Q And then it has a signature dated

15 286-20-23##, is that Mr. Tinubu signature?

16 MR. HENDERSON: Objection. Foundation.

17 Calls for speculation.

18 A It appears so yes.

19 Q And do you know what legal proceedings they

20 were being released for.

21 MR. HENDERSON: Same objection. Foundation.

22 Calls for speculation.

23 A I believe it was the state court case this

24 summer.

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1 Q Can you be more specific?

2 A I don’t recall what the state case was called

3 this summer, you probably have that.

4 Q And then moving to the CSU, 15, which is the

5 next page, this is a June 27, 2022, to whom it may

6 concern letter, it does not have your signature

7 included in this document correct.

8 A Correct.

9 Q And why does it not.

10 A The university deemed it kind to me to take

11 me off the document because of how many inquiries, we

12 were receiving and the amount of that I was coming into

13 the press.

14 Q And looking at these documents provided to

15 Mr. Orr, there are more documents provided here than

16 what you had previously seen in response to

17 Mr. Enahoro-Ebah subpoena correct.

18 MR. HAYES: Objection. Foundation.

19 THE WITNESS: I’m not aware of any

20 differences in the documents.

21 Q You would expect the same documents would be

22 produced here as in the Enahoro-Ebah spen that?

23 MR. HENDERSON: Objection. Foundation.

24 Calls for speculation.

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1 THE WITNESS: I believe so.

2 Q And all of these document certified by

3 Mr. Orr came from the CSU files.

4 A Correct.

5 Q Did any of those document come from the

6 Mr. Tinubu in the 2022, or 23?

7 THE WITNESS: The FERPA form. F ER PA.

8 Q And anything else.

9 A No.

10 Q FERPA.

11 Q What’s process to certify documents?

12 A That is a great question. I assume that was

13 a legal thing, I suspect you although about that than I

14 do.

15 Q Has CSU ever certified documents for anyone

16 else.

17 A Not that I’m aware.

18 Q And so and compensation was made for

19 Mr. Tinubu?

20 MR. HENDERSON: Objection. Foundation.

21 Calls for speculation,.

22 A I don’t know if it is an exception, but we

23 complied with the request.

24 Q But you have never seen it a certification

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1 process happen for someone else?

2 A No I believe this was made because it is more

3 of a Nigerian thing.

4 Q Employer of a Nigerian thing. So were these

5 documents pulled together for legal proceedings in the

6 fly engineer yeah?

7 MR. HENDERSON: Objection. Asked and

8 answered.

9 A I believe this was related to the west

10 pressing case. Oh I’m sorry, I apologize you are

11 talking about the FERPA, this was produced as a rul of

12 the FERPA request.

13 Q And the FERPA request state that the record

14 are being released for the purposes in legal

15 proceedings?

16 A Correct.

17 Q So are you aware of whether these documents

18 were requested to be certified for the Nigerian

19 proceedings.

20 A I believe they were requested by

21 Mr. Woleafolbi to be certified. I cannot say more than

22 that about why or why or for what.

23 Q And looks like these stamps in the corner

24 here, upper corner, of each of these documents says

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1 certify certified true copy, certified by the Jamar

2 Orr. Is this stamp and o-Fish stamp?

3 A I’m not aware if it is an official stamp. It

4 was what was requested.

5 Q So CSU representative today, you don’t know

6 if this is an official stamp of?

7 MR. HENDERSON: Objection, asked and

8 answered.

9 A I suppose as a matter of course given that we

10 were certifying the document, we could call it

11 official.

12 Q And why did Mr. Orr feel compel to stamp the

13 documents certified true copy?

14 A Because it was requested.

15 Q This isn’t part of any CSU practice correct?

16 A Correct.

17 Q Did Mr. Orr later departed from the CSU

18 several weeks after the certificate if I cake of these

19 documents correct?

20 A I believe so.

21 Q Was it related to the certification?

22 A Not that I’m aware of.

23 Q Do you know why Mr. Orr departed from the

24 CSU?

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1 A I have no clue.

2 MR. HAYES: State on the record it is not a

3 topic for the today’s deposition.

4 Q Turning to another exhibit. Is.

5 (WHEREUPON Exhibit # was marked for

6 identification) 11.

7 Q I’m handing you what has been marked as

8 Exhibit 11, which is look like your affidavit.

9 Q This document is your affidavit that was

10 submitted to Mr. Tinubu’s pleadings in this matter.

11 Do you recognize it?

12 A I do.

13 Q And did Mr. Tinubu’s counsel request for it

14 to be prepared?

15 A I don’t I’m not aware, I mean the request to

16 me came from our own legal counsel.

17 Q And do you know if Mr. Requested for it toen

18 prepared.

19 A I’m not aware Woleafolbi.

20 THE COURT: Mr. Tinubu counsel.

21 Q And you have’s signed their affidavit at

22 the bottom leer.

23 A I did.

24 Q And this signature looks different from the

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1 signature that is in H the Exhibit 7 which is the to

2 would you let me know it may concern letter?

3 A Correct. This is a wet signature, I did it in

4 the moment, the other signature is from a let’s say

5 more carefully composed signature that I’m able to

6 apply to the document the. They are both mine.

7 Q And carefully, composed, you have an

8 electronic signature?

9 A We are familiar with the professional you

10 might do a nicer signature that is the one I applied in

11 a more formal things like that. .

12 Q Mr. Tinubu counsel prepare this affidavit?

13 A I don’t believe so.

14 Q Diploma CSU counsel prepare it?

15 A I think so.

16 Q Did they draft it?

17 A I mean these were my statements.

18 Q So you drafted this affidavit?

19 A I think they helped me put in the format that

20 you see in front of you, with the writing here is my

21 own.

22 Q And so let’s go through the affidavit.

23 Paragraph 2, it state, Bola, Ahmed Tinubu and

24 paragraph, state, Bola Amed Tinubu graduated and was

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1 awarded a degree from the Chicago State University on

2 June 22, 1979. Awarded. What is the basis for the

3 assertion Bola Ahmed Tinubu graduated and was awarded a

4 degree from the Chicago State University on June 22,

5 1979.

6 MR. HAYES: Objection. Asked and answered.

7 Go ahead and answer the question, sir.

8 THE WITNESS: That is the official

9 transcript.

10 Q Any other basis?

11 A No.

12 Q So you are assuming from the official

13 transcript, how can you tell it is the same Bola Tinubu

14 president now?

15 MR. HENDERSON: Objection asked and answered.

16 MR. HAYES: Objection.

17 THE WITNESS: We did do that, giving the

18 wholistic review of the record, we believe it is the

19 president of my Nigeria.

20 Q Have you ever met Mr. Tinubu?

21 A no.

22 Q Has he visited CSU campus?

23 A no.

24 Q Does he donate to the CSU?

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1 A Not that I’m aware of.

2 Q Do so you have not seen Mr. Tinubu?

3 A I don’t see most of our student alumni.

4 Q Apart from the official transcript, they have

5 no other basis that the Bola Tinubu is the same Bola

6 that is now president of Nigeria?

7 A Chicago State University has the original

8 record of Bola Tinubu and we believe that to be true.

9 Q So let plea ask the question again, and it is

10 a simple yes or no, apart from these document that

11 we’ve just gone through, CSU has no other basis for

12 stating that the Bola A Tinubu that attended KCS. Is

13 the same?

14 MR. HENDERSON: Objection and answered,

15 harassing the student. Argumentative.

16 MS. LIU: I would Kindlily, ask counsel from

17 making speaking objections. I know you know how to.

18 MR. HENDERSON: You are speaking right now,.

19 Q (By Ms. Liu) Under the federal rules.

20 MR. HENDERSON: We go off the record for a

21 second. Argument.

22 MR. HAYES: Let’s go back on the record

23 please. Mr. Westburg, I object that asked and answered

24 and miss character rises your prior testimony, answer

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1 her question again, and I ask that it be the last time

2 it be asked.

3 A I apologize for what was the question again

4 at this stage.

5 A Apart from these document, we have no other

6 basis to comment on this student.

7 Q (By Ms. Liu) Liu response to

8 Mr. Henderson, colloquy during the bake, I’m more

9 than entitled to conduct this court order in

10 compliance with the federal rules and I’m not going

11 to be inTim dated other wise. I will continue?

12 MR. HENDERSON: For the record, in compliance

13 with the rules does are doesn’t allow you to ask the

14 question nine times, that is not in compliance with the

15 rules.

16 MR. HAYES: Let’s move along please.

17 Q Mr. Westberg, looking at Paragraph 2, how do

18 you know that Mr. Tinubu middle name is Ahmed. . It

19 was in the subpoena paperwork.

20 Q So none of the CSU documents say what his

21 middle name is correct.

22 A Not that I’m aware of.

23 Q So you have throw basis for stating that the

24 middle name of the student who attended CSU is Ahmed

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1 other than the Tinubu’s counsel told you.

2 MR. HENDERSON: Objection. Foundation.

3 MS. LIU: Without clear documentation of a

4 passport, I have is a, Social Security Number,

5 driver’s license, how can CSU no exactly, who Bola A

6 tin no.

7 MR. HAYES: Answer it one more time and I’ll

8 instruct to not answer further questions that are

9 identical that you asked before, please answer again

10 sir.

11 A The legal name Tinubu is sufficient for the

12 university to determine the student identity, the

13 middle name is not required for us to do that.

14 Q Going to the Paragraph 3 it state, Chicago

15 State University provided a diploma to Bola Ahmed

16 Tinubu and subsequently provided a certified or

17 official copy of that diploma both are valid and

18 authentic diploma of Chicago State University do you

19 see that?

20 A I do.

21 Q Now, is the diploma referred to as the one

22 provided to Bola, Ahmed Tinubu the INEC diploma?

23 A I’m mot able to comment on that, because the

24 INEC diploma is not in our possession, the reason for

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1 that statement is we provided a did them for all

2 student loans when they graduate.

3 Q Okay. And it says, and subsequently provided

4 a certified or official copy of that diploma. Which

5 diploma is that referencing. Is it the June 27

6 diploma.

7 A Yes.

8 Q In Exhibit 2 the example number is included

9 but it is in Exhibit 2. I think is example eight,

10 handwritten example eight.

11 Q And so when Chicago State University provided

12 a diploma to Bola Ahmed Tinubu you are say assuming

13 that when a person named bull Bola, Tinubu graduated in

14 the 1979 that CSU provided a diploma to that student

15 correct?

16 A Correct.

17 Q And so the diploma you refer to as the one

18 that the CSU provide to the Tinubu was the one that was

19 provided to that student in the 1979 correct.

20 A I’m sorry could you rephrase that.

21 Q So that diploma that you refer to in

22 Paragraph 3 that says, Chicago State University

23 provided a diploma to Bola Ahmed Tinubu you are

24 referring to that diploma asks at one that was provided

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1 to that student in the 1979?

2 A Correct.

3 Q Will.

4 Q And the diploma that was provided to the

5 student Tinubu in 1979 Kane be the one that president

6 submitted to the INEC because Dr. Daniel did not arrive

7 at CSU until later?

8 MR. HENDERSON: Objection. Calls for

9 speculation.

10 A That’s correct.

11 Q And then we just talked about the certified

12 or the official copy of the diploma is in reference to

13 the June 27 diploma in the Exhibit 2 correct.

14 A Correct.

15 Q And going back to Exhibit 5, which is the

16 diploma order form. The order form doesn’t say

17 anything about getting a certified or o-Fish copy does

18 it?

19 A Any diploma we issue is an official copy from

20 us.

21 Q So the diploma that was provided as the

22 official has the wrong date of graduation, correct?

23 A Correct.

24 Q And it is signed by two people who did not

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1 arrived at CSU until the late 1990s correct.

2 A Correct.

3 Q Auntly were gone by the early, 2,000’s?

4 A Some point in that time period yes. .

5 Q Going to the Paragraph four of your

6 affidavit. It states there are certain differences

7 between the diploma and the certified copy because all

8 the diploma are signed by the current president slash

9 co-chair, there is also differences in the font and

10 seal on the diploma versus the certified copy because

11 the university updated its font and seal after the

12 diploma was issued. So you say that all on the diploma

13 are sign by the current president and board chair,

14 correct?

15 A Correct.

16 Q And going to the Paragraph 5, it state that

17 the difference in the date of a word on the diploma

18 versus the certified copy is likely the result of human

19 error do you see that everyone I do.

20 Q And you use the term likely, are you

21 speculating here?

22 A I have to — I was not around at the time it

23 was produced.

24 Q So you don’t really know?

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1 A Correct.

2 A I correct.

3 Q Who typed in the date on the June 27 diploma?

4 A We are not aware.

5 Q And how is it that you don’t know. Or CSU

6 doesn’t no?

7 A I don’t have a staff member in my office that

8 was working at the time in my office in the 2,003.

9 Q So your testifying that this is an official

10 copy or certified copy but you don’t know who prepared

11 it correct.

12 A Correct.

13 Q Going to the Paragraph 6, it says,

14 institution, in the United States of America,

15 institutions of higher education, often consider the

16 diploma to be a ceremonial document. So some

17 institutions in the US do not consider diploma merely

18 ceremonial?

19 A In general in the U.S. the diploma are

20 ceremonial documents. In other countries it is a more

21 official document for us it is not.

22 Q Do you know whether Nigerian law consider

23 diploma to be primarily ceremonial?

24 A I’m not aware.

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1 Q And what is your understanding of Nigerian

2 law as to the submission of inauthentic document

3 submitted by the Candidate to the Nigerian election

4 authority?

5 A I’m unaware.

6 Q I would like to take a five minute break.

7 Q Mr. Westberg, forgive plea if I miss id this

8 did you say check public record to the Bola, Tinubu

9 went to the CSU and graduated in the 1979 is the same B

10 Tinubu who is now president.

11 A What do you marine about the public records.?

12 Q Forges available in the public?

13 A No I did not.

14 Q And do you know whether the FBI has ever

15 contacted CSU about whether Mr. Tinubu attended CSU?

16 A Not that I am aware.

17 Q I would like to pass the witness and leave

18 the deposition open for the further questions after the

19 other attorneys here. Are done. Thank you for your

20 time.

21 MR. HAYES: Do you have questions.

22 MR. HAYES: Hayes flout I don’t, why don’t

23 you go ahead. Please.

24 MR. HENDERSON: Cross-examination.

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1 MR. HENDERSON: Mr. Westberg my name is

2 Victor Henderson, I’m the attorney for President Tinubu

3 and I apologize if I ask some questions that may

4 overlap or some of the questions you have asked before

5 I would like to get a little clarity, you said that you

6 never plet Mr. Tinubu as far as you know, is that

7 accurate.

8 A Yes.

9 Q And you have never seen him in the

10 registrar’s office?

11 A Correct.

12 Q And he’s never heard about him being in the

13 registrary, is that correct?

14 A Correct.

15 Q Will.

16 Q You didn’t personally, prepare any diploma or

17 copies is that accurate?

18 A Yes.

19 Q Counsel asked you if you spoke with the Lois,

20 Davis, she was a prior registrar is that accurate?

21 A Yes.

22 Q And do you know ballpark how many registrars

23 were there between ’79 and you.

24 A Oh, I would have to guess, I would say at

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1 least six. But quite possibly employer.

2 Q And is it fair to say as benefit you know, as

3 representative ofment CSU, that some policies and

4 procedures have changed overtime as the registrar as

5 have changed?

6 A Oh, yes.

7 Q And so that is the one of the reasons you are

8 not in a position to speak to what happened example in

9 the 1979?

10 A Correct.

11 Q And you did not speak to miss Davis on any

12 level including as it relate to you using her letter as

13 a template; is that right?

14 A Correct.

15 Q Do you know if she is still alive?

16 A I believe she is.

17 Q Counsel spent time with you as it relates to

18 the Exhibit No. 6, do you remember?

19 A Yes.

20 Q And so you didn’t create Exhibit 6 is that

21 accurate?

22 A That is accurate.

23 Q And you don’t know whether miss Davis created

24 it correct?

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1 A Correct.

2 Q And did you tell us earlier, that when there

3 is a replacement diploma made or any diploma is that

4 done in house by CSU or sent offsite?

5 A At present it is sent offsite.

6 Q Do you know whether in the 79 it was sent

7 offsite or whether it was done in house?

8 A I would have to speculate, I suspect it was

9 done in-house.

10 Q But you are not certain?

11 A You.

12 A I’m not certain.

13 Q So you don’t know who created Exhibit No. 6

14 is that accurate?

15 A That is accurate.

16 Q And did you tell us earlier, that there was a

17 letter that you didn’t want to sign because you were

18 feeling harassed?

19 A No, what I was referencing at that time, the

20 institution met to discuss the situation different how

21 many inquiries we were receiving and it was deemed just

22 better to not have my name tied to it given the way

23 that I was being pulled into the media in this

24 instance.

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1 Q I want to turn your attention to the

2 Exhibit 11. And that’s your affidavit in particular I

3 would like to turn your attention to the paragraph five

4 and the difference in the date of the award on the

5 diploma versus the is likely of human error?

6 A Do you see that sense.

7 A Yes.

8 Q And the following sentence say, the

9 graduation date on a certified copy is typed in

10 manually by a person and can be inaccurate?

11 A I do.

12 Q Counsel spent a lot of time with you, asking

13 you about the male/female issue that was identified on

14 the southwest I guess community college transcript, do

15 you remember that?

16 A I do.

17 Q And when you went through your r?sum? with

18 us, you currently at CSU, before that you were at Ivy

19 Tech is that accurate?

20 A That is accurate.

21 Q And then you also spent time at UC Berkeley

22 as a research assistant?

23 A That is accurate also.

24 Q And spent time at Emmerson elementary?

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1 A Yes.

2 Q And Berkeley City college?

3 A Yes.

4 Q And there were human being al all tholes

5 places?

6 A Yes.

7 Q And as far as you know, in all those various

8 places did you observe people make mistakes from time

9 to time in terms of data entry?

10 A I couldn’t really, comment on that. I’m sure

11 that happened from time to time. Yes.

12 Q And I’m asking in the context you are

13 experience at CSU is that people make mistakes?

14 A Human error happens.

15 Q As evidences by what you said in your

16 affidavit correct.

17 A Correct.

18 Q And prior to this lawsuit, did you know

19 anybody about the first name Bola Bola?

20 A no.

21 Q And so you don’t know for example with the

22 transcript from the southwest whether whoever did the

23 entry, could have conservatively thought Bola was a

24 woman went in fact he’s a man?

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1 A Correct.

2 Q Let me hand you what I would like to mark as

3 (WHEREUPON Exhibit # was marked for

4 identification), 12.

5 Q I’m going to land what you the Court Reporter

6 Lagos marked as Exhibit 12, this is something that was

7 filed in the lawsuit. It is an affidavit from a

8 gentlemen and I’m going to spell the name. Olajide

9 Adeniji as best I know. It’s type, Olajide Adeniji.

10 Why don’t you take a minute to look at this affidavit

11 and after you had a chance to look at it, let me know

12 that you have done so.

13 A I’m familiar with this.

14 Q And so you have’s seen this affidavit prior

15 to today?

16 A I have.

17 Q And in this particular affidavit there is a

18 person I can’t, do you know whether that person is male

19 or fee female?

20 A I don’t recall this person’s sex or gender.

21 Q It is a fir and last name that is unfamiliar

22 to you, similar to the way that the Bola Tinubu was

23 unfamiliar to you?

24 A Yes.

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1 Q And the left-hand corner, it says in the

2 application of the Atiku Abubakar, A B U B a/k/a R.

3 A You see that.

4 Q Have you met that person?

5 A no.

6 Q Do you know if that person is male or feel?

7 A I here he is man, but I have not met him.

8 Q But you don’t note concern.

9 Q And this particular students was at CSU and

10 on compass at the same time that the Bola, Tinubu was

11 there?

12 A I do.

13 Q Did you have an opportunity to check the

14 record to see whether or not this person Oljide Adenji

15 actually went to CSU?

16 A Yes, I did.

17 Q And did that person go to the?

18 A Yes.

19 Q And was that person on the exam pass at the

20 same time as benefit you know president Tinubu was

21 there?

22 MS. LIU: Objection.

23 THE WITNESS: Yes.

24 Q And based on the record?

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1 A Yes,.

2 Q And the record have them being there at the

3 same time correct?

4 A That is correct.

5 Q And their document has the after are vent

6 saying that the president Tinubu is a man correct.

7 A I do see that.

8 Q Or at least it says, I’m family with the

9 Bola, Tinubu who is the president of my engineer ran

10 and you understand to be a man?

11 A Correct.

12 Q And it says in the paragraph four, oh, I ran

13 in the closely, contested race against B Tinubu for the

14 leadership of the counseling associate?

15 A I do.

16 Q And the major of Bola Tinubu at CSU appeared

17 to be accounting?

18 A Correct.

19 Q And the document let me take you to CSU 0019,

20 this is an Exhibit 10 and counsel went over this with

21 you. You see that.

22 A I see it.

23 Q And under, it says, Bola, honors lift do you

24 see that?

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1 A Where oh, yes, I see that.

2 Q And below honors list, and honors is since

3 you understand and at the university for the student

4 who do well correct.

5 A Yes.

6 Q And underneath principals of accounting do

7 you see that?

8 A I do.

9 Q And above it four or five lines above it it

10 says fundamentals of accounting?

11 A Yes.

12 Q And Southwest College this particular Bola

13 Tinubu was and accounting majors?

14 A Correct.

15 Q And then the Bola Tinubu at CSU, is also and

16 accounting major correct?

17 A Correct.

18 Q And you tommed counsel that there are any

19 number of things that you look at in a student’s

20 record to verify that in fact is the person that you

21 believe it to be.

22 MS. LIU: Objection.

23 MR. HENDERSON: Isn’t that what you told

24 counsel,.

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1 A I did.

2 Q And —

3 MR. HENDERSON: So for example on the 00149

4 Southwest College it list the address for the B Tinubu

5 as 7741 South Shore drive, do you see that.

6 A I do.

7 Q Are you familiar with the South Shore area?

8 A Somewhat.

9 Q You know it is not that far from CSU?

10 A Correct..

11 Q And then let me turn your attention to the

12 page CSU 0016 and in that same document. Look up in

13 the top left-hand corner. Do you see address that says

14 7424 South Shore drive?

15 A I do.

16 Q And so that is as based on your knowledge of

17 Chicago, just a few blocks from the earlier address?

18 A Correct.

19 Q And so those are the types of things that you

20 would be looking at to make sure that you are deal with

21 the same person when you look through the entire file

22 addresses, names, fields of study, those kinds of

23 thing?

24 A The university would have reviewed these

UNCERTIFIED TRANSCRIPT

96

 

1 materials when we received them.

2 Q And those are the types of thing that you

3 looked at to draw that the B Tinubu was in fact the B

4 Tinubu who is the president?

5 MS. LIU: Objection.

6 A That is the type of thing we would like at.

7 Q You would look at the whole record?

8 A Correct.

9 Q And then you draw a conclusion?

10 A Yes.

11 Q So when counsel asked you for example about

12 1954h versus, 1952, in term of a date of birth, that is

13 the type of information for example that could have

14 been acceptable for the humaner error?

15 A It could have been.

16 Q You don’t know?

17 A I don’t know.

18 Q Let me turn your attention to the CSU 025.

19 You with me?

20 A Yes.

21 Q And the very first Paragraph in this letter,

22 the very first Paragraph says, I am pleased to inform

23 you that you have been accepted as a transfer student

24 at Chicago State University for the fall trimester,

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1 1977 do you see that?

2 A I do.

3 Q And so the fact that CSU is indicating and

4 this is a certified true copy by the Jamar Orr that B

5 Tinubu is being accepted as transfer student that is

6 consistent with the fact that appears as if the B

7 Tinubu who is referred to on CSU 0019 was a transfer

8 student correct.

9 MS. LIU: Objection.

10 THE WITNESS: Wait a seek.

11 A Yes, the file indicates that the student was

12 a transfer student.

13 Q From a Community College or some other place?

14 A Correct.

15 Q And that is another indicia to you that the

16 person at Southwest College was the subsequently

17 admitted to the Chicago state?

18 A Correct.

19 Q And then on Page CSU, 0026, look at the top

20 left and it says, Bola H Tinubu do you see that?

21 A I do.

22 Q And where it says, major accounting do you

23 see that?

24 A I do.

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1 Q Again consistent with what was on the

2 Southwest College record?

3 A Correct.

4 Q Now, let plea point you to something else,

5 let you toggle back and forth between CSU 0019 and CSU,

6 zero of?

7 A Okay.

8 Q On the Southwest College document that

9 counsel referred to that has this particular B Tinubu

10 as a female do you see that?

11 A I do.

12 Q Then right next to it, is a social security

13 number do you see that?

14 A Yes.

15 Q And I don’t want to talk about the social

16 security number because I don’t know where it would

17 wind up, but you see the first three numbers do you Soo

18 he that?

19 A Yes, I do.

20 Q And those correspondence go to the CSU 0026

21 go to the 0026 for me,?

22 A I’m there.

23 Q The first three numbers are the same?

24 A All of the numbers are the same..

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1 Q Well, yes and the middle three numbers you

2 see that?

3 A Yes.

4 Q And then the last three numbers do you see

5 that?

6 A Yes.

7 Q So the social number and again I don’t want

8 to put it in the record on Southwest College which was

9 typed in is it similar to, the same as a social

10 security number on the CSU document?

11 A Correct.

12 Q That would be something else that you would

13 look at to determine that you are deal with the same

14 person correct?

15 A Yes.

16 Q And if your experience as a college add plin

17 Administrator, a social security number is a unique

18 identifier?

19 A It is.

20 Q (By Ms. Liu) Liu for the record, the

21 transcript is CSU 0016.?

22 MR. HENDERSON: That was not the one that I I

23 was looking at.

24 MS. LIU: Okay.

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1 MR. HAYES: He was questioning the witness on

2 CSU 19 and CSU 26 that have the same social security

3 numbers I believe.

4 MR. HENDERSON: Yes.

5 Q CSU 0019 which is the southwest college

6 Document which is part of the City Colleges of the

7 Chicago. And then the CSU 0026 which has that same

8 social security number which is a State University

9 document.

10 Q Mr. Westberg, you understand City college of

11 college is to be a separate institution from the

12 Chicago State University correct.

13 A Yes.

14 Q And you actually know the City colleges of

15 Chicago, in some to be a feared school for the CSU?

16 A It is.

17 Q And fourths who may read this transcript and

18 don’t know what a feeder school, in the June it is

19 people who finish at a community college and then

20 enroll in a four-year institution like Chicago State?

21 A Correct.

22 Q Now me turn your attention to the the

23 Exhibit 7. And this is a document that was signed by

24 you correct.

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1 A 1 second.

2 A Yes.

3 Q And you got the information that that’s

4 contains in the exhibit p from the student that you

5 been telling us about?

6 A Yes. student file.

7 Q Let plea focus on something that counsel did

8 not ask you about. And I want to go to the the second

9 full sentence which says, he, being Bola Tinubu, was

10 awarded a Bachelor of Science Degree in the business

11 administration with honors. Do you see tha?

12 A Yes.

13 Q Tell us what the significance of graduating

14 with honors at least in CSU?

15 A It is a GPA distinction.

16 Q And so people who graduated with honors have

17 higher GPAs?

18 A They do.

19 Q So is it fair to say that those are the more

20 accomplished students?

21 A I guess you could say that.

22 Q And based on your experience as both a

23 college Administrator and student is it fair to say

24 that some majors are harder than others; is that right.

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1 P- I think all of our programs are challenging to

2 student, but I’m sure that some present certain

3 rigorous that are than others.

4 Q And accounting is one of the more rigorous

5 majors?

6 A It is a rigorous majors.

7 Q And not only this have a rigorous major, he

8 also graduated with the honors?

9 A He did indeed.

10 Q Rigors.

11 Q And it is fair to say that the certain

12 students are employer motivated academically, than

13 others in your experience as with a college

14 Administrator and being in the college?

15 A Yes.

16 Q And in your experience the students who are

17 more motivated oftentimes go on to be prominent alumni

18 correct.

19 A That is speculative, but sure.

20 Q I’m asking based on your experience as being

21 a student and college Administrator, you have seen

22 scene that correct.

23 A I have.

24 Q And there B Tinubu that you are referring o

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103

 

1 about in the Exhibit 7, back in the 1979 graduating

2 with the honors, in a challenging major?

3 A Correct.

4 Q Honors.

5 Q And as far as you know, that is the person

6 who is now the President of Nigeria?

7 A Correct.

8 Q I don’t have any further questions.

9 MR. HAYES: I do have a couple of focus

10 questions and get out of your way.

11 MR. HAYES: Mr. Westberg, you just reviewed

12 the portion in the Exhibit 10 that is Bates number CSU

13 0019 the southwest college document right.

14 A Yes.

15 Q And that is the document where whoever filled

16 it out on the Southwest College, designated the Section

17 As Africa, female?

18 A Yes.

19 Q Were their materials submitted to Chicago

20 State in Mr. Tinubu’s record that indicate he was a

21 male.

22 A Yes.

23 Q Turn please to the CSU 0023. Let me know

24 when you are there.

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1 A Okay.

2 Q What is this document sir?

3 A This is the undergraduate admission

4 applications.

5 Q And this is this the document that appears to

6 have been completed by Mr. Tinubu himself?

7 A Ostensibly.

8 Q And what on this document does Mr. Tinubu

9 identify himself in terms of his sex?

10 A A male.

11 Q And when the university admitted Mr. Tinubu

12 turn to CSU 0025,. Is this the letter in

13 Mr. Tinubu’s student file informing him of his

14 admission?

15 A Yes.

16 Q And the salutation at the top what does that

17 identify in term of Mr. Tinubu sex?

18 A It says, Mr. Tinubu indicating male.

19 MR. HAYES: I don’t have any other questions.

20 Thank you.

21 Q (By Ms. Liu) Liu have a few questions. You

22 stated that you look at the information like South

23 Shore drive address, correct.

24 A Address is one of the proponents.

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1 Q And you don’t know for a fact that the

2 President Tinubu lived at South Shore Drive?

3 A Not personally.

4 Q And you don’t know President Tinubu’s Social

5 Security Number, correct.

6 A Not, what I have is submission in the record

7 which I believe to be his social security number.

8 Q But you don’t know that for a fact right?

9 A I’m saying that the record here is accurate

10 record.

11 Q That is not my question, you don’t know

12 President Tinubu social security correct.

13 A I believe we do.

14 Q And what is the basis for that?

15 A This H documentation.

16 Q That’s based on the assumption that in the

17 documentation, record is the same as President Tinubu

18 correct.

19 A Yes.

20 Q I’m hand handing you, and exhibit.

21 (WHEREUPON Exhibit # was marked for

22 identification) 13.

23 Q I’m hand you an exhibit marked 13.

24 Q There is a biography from the encyclopedia,

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1 Britannica.

2 Q And on the second page of this document, you

3 see here, that B Tinubu in full Bola Ahmed and I’ll

4 spell Adekunle Tinubu born March 29, 1952. . Do you

5 see that?

6 A I do.

7 Q And on the first page, it says in

8 highlighting this is fact checked by the editor of

9 encyclopedia, Britannica, do you see that,?

10 A I do.

11 Q I’m handing you exhibit that has been marked

12 Exhibit 14. H.

13 (WHEREUPON Exhibit # was marked for

14 identification). 14.

15 Q This is from the all progressive Congress,

16 official website. Which is Mr. President Tea Party

17 affiliated website, if you go to the Page 2, it states

18 President Bola Amed and then Adekunle. Also known as

19 Jagaban was born in Lagos on March — Lagos on October

20 29, 1952. . Do you see that?

21 A I do.

22 Q J A G A B A N.

23 Q And you can cithara there are discrepancy in

24 his H birth date versus the birthday and his H student

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107

 

1 record correct.

2 A Those are different dates.

3 Q And let’s go to back to the Exhibit 4. Sorry,

4 Exhibit 5. This is the CSU diploma request form. And

5 it request the last four digits of the social security

6 number correct.

7 A It December.

8 Q Did Mr. Tinubu ever provide this information

9 when requesting record from the CSU?

10 A I don’t have a copy of the diploma reorder

11 form so I would not I can’t comment on that.

12 Q So you have never seen —

13 THE WITNESS: You are asking about the

14 June 27, 1979 diploma I don’t have a copy of the

15 diploma record form associated with this record.

16 Q And so have you ever seen President Tinubu

17 sworn submission to the INEC?

18 A No.

19 Q You are not aware about the discrepancies,

20 between his birth date and nationality in the INEC and

21 the information in the CSU documents?

22 A I can’t comment on anything related to the

23 INEC.

24 Q So you are not aware?

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108

 

1 A I’m not aware.

2 Q (By Ms. Liu) No further questions.

3 MR. HENDERSON: Let me take you to the two

4 documents that Counsel just gave you. Exhibit 13 says

5 his date of birth and again you don’t have any

6 information one way or another to know whether 13 is

7 accurate or inaccurate.

8 A Correct.

9 Q You didn’t play any role in the creating 13?

10 A Correct.

11 Q He was born on operator 29, 1952 correct.

12 A It does say that.

13 Q En a then exhibit sh, again same questions,

14 you didn’t have any role in the creating Exhibit 14

15 correct.

16 A Correct.

17 Q So you don’t know whether 14 is accurate or

18 inaccurate?

19 A Correct.

20 Q And simultaneously on the 204, he was born on

21 March 29, 1952 to you cithara?

22 A Yes.

23 Q And 13 and 14 have him as being on operator

24 29, 1952?

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1 A Correct.

2 Q And now let plea turn your attention to the

3 CSU, 0016 and the exhibit 10. Look at the top right

4 hand corner you see date of birth?

5 A That also say March 19.

6 A Yes.

7 Q And it has 54 as opposed to the 52?

8 A Correct.

9 Q You didn’t play a role in creating this

10 document?

11 A Yes.

12 Q And you told us earlier, that you know from

13 time to time people makes honest mistakes?

14 A Correct.

15 Q (By Mr. Henderson) No further questions.

16 MR. HENDERSON: Mike thank you for your time.

17 MR. HAYES: It has.

18 MS. LIU: Off the record.

19

20

21

22

23

24

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