When did you first meet Tracy Evans?
2011, 2012.
We had mutual friends before working there, so …
OK, So you knew Tracy prior to his employment at Founders? 
We met a few times, yes. 
OK, are you aware Tracy is black?
What do you mean by that? 
Are you aware Tracy is African-American?   
I’m not sure of his lineage so I can’t answer that. 
Alright. Are you aware that Tracy is a man of color?
What do you mean by that? 
Do you know what a white person is versus a black person?
Can you clarify that for me?
No. Do you know — you don't know what it means for someone 
to be a white person or a black person? 
I'm asking for clarification.
You don’t need any. I can promise you that. We’ll keep the 
record as is. Someone’s skin color. A white —
So that’s what you’re referring to?
Yeah. Oh, yeah, yeah.
OK. Yes, I know the difference in skin tone.
Are you able to identify individuals by their skin color?
What do you mean identify?
I mean have you ever looked at Tracy Evans in your entire 
life? Have you? That’s a — that’s a genuine question.
Objection. Argumentative.
You can answer.
Yes.
And did you ever realize that Tracy’s skin color is black?
That’s not — I mean, is his skin different from mine? Yes.
How? 
What do you mean how? It’s a different color.
Correct. And what is the difference of that color?
It’s darker.
And that means?
Objection. Vague question.
I mean, we could — This could be a one-sentence answer, you 
know.
So by your — I guess your testimony is you have no idea if 
Tracy is a minority, if he’s African American?
I don’t know Tracy’s lineage, so I can’t speculate on 
whether he’s — if he’s from Africa or not.
What do you mean lineage, from Africa?
No. I mean, like, I don’t know his DNA.
Have you ever met black people who aren’t from Africa?
Excuse me?
Have you ever met a black person born in America?
Yes.
And you were able — Have you ever met a black person who 
didn’t tell you they were black? 
Can you rephrase that?
Is Barack Obama black?
Objection.
To your knowledge?
I’ve never met Barack Obama so I don’t —
So you don’t know if Barack Obama is black? What about 
Michael Jordan? Do you know if Michael Jordan is black?
Objection.
 I never met him.
So you don’t know? What about Kwame Kilpatrick?
Never met him.
To your knowledge, was Kwame Kilpatrick black?
I —
You don’t know?
I don’t know.
[From Computer Speaker] Is Barack Obama black?
[From Computer Speaker] ?
Objection.
[From Computer Speaker] To your knowledge?
[From Computer Speaker] I’ve never met Barack Obama so I 
don’t —?
Ok.
You dont know if Barack Obama is black, huh?
Yep. Mm Hmm. I'm finna get paid. 
Dumb Motherfucker.
[Mumbling] Student Loans
You gotta see this shit.
We finna get paid.
