These are true and correct excerpts from Plaintiff Kim Cardinal Bajrdi's sworn certification filed on July 3, 2014.
The certification was filed as an exhibit in support of Plaintiffs' opposition to my Motion to Compel Plaintiffs To Produce Discovery Ordered on April 25, 2014 or Dismiss or Strike Complaint.
PLAINTIFF KIM CARDINAL BAJARDI
|Plaintiffs' EXHIBIT F- Kim Bajardi Certification|
At 4:25 PM on Wednesday, August 6, 2008, Sara Stojkovic was emailed "Recap for 411" of the Tuesday Hoboken Planning Board meeting.
At 4:36 PM Stokovic forwards the "recap" to Lane Bajardi and Kim Cardinal Bajardi.
At 4:56 PM Kim Cardinal replies to Lane Bajardi and Sara Stojkovic:
At 5:18 PM on August 6, 2008, Sara Stojkovic writes to Lane Bajardi and Kim Cardinal Bajardi about attorney "Michael Kates." The exchange continues between Cardinal and Stojkovic.
At 6:06 PM Kim Cardinal writes "the first order of business is to get to Nino and Russo... We need to protect the effort at the council level first. The public can find out later."
One more time?
Kim Cardinal Bajardi: "We need to protect the effort at the council level first... the public can find out later."
At 1:34 PM on Monday August 4, 2008 Beth Mason sends Lane Bajardi, Kim Cardinal, and Sara Stojokovic the text to a mailer for distribution in Dawn Zimmer's 4th Ward.
Note, there is no municipal election in 2008; this mailer is not in service of any particular Mason campaign.
At 3:16 PM Kim Cardinal replies to Beth Mason, Lane Bajaradi and Sara Stojkovic: "I love it.... We'll talk more about Dawn's emails later."