72 - Rep. Ilhan Omar Depo

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5 In the Matter of the Complaint of
Rep. Steve Drazkowski regarding the
6 Neighbors for Ilhan (Omar) Committee
7 -----------------------------------------------------
8
9 The DEPOSITION of ILHAN OMAR, taken by Kassie
10 Lahti Beebe, Court Reporter, a Notary Public in and
11 for the County of Wright, State of Minnesota, taken
12 on the 19th day of December, 2018, at the offices of
13 the Minnesota Campaign Finance & Public Disclosure
14 Board, 190 Centennial Office Building, 658 Cedar
15 Street, St. Paul, Minnesota, commencing at
16 approximately 11:00 a.m.
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Kirby Kennedy & Associates

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1 A P P E A R A N C E S
2 APPEARING FOR AND ON BEHALF OF THE MINNESOTA CAMPAIGN
FINANCE & PUBLIC DISCLOSURE BOARD:
3
JEFF SIGURDSON, EXECUTIVE DIRECTOR
4 MEGAN ENGELHARDT, ASSISTANT EXECUTIVE DIRECTOR
MINNESOTA CAMPAIGN FINANCE & PUBLIC
5 DISCLOSURE BOARD
190 Centennial Office Building
6 658 Cedar Street
St. Paul, Minnesota 55155-1603
7
jeff.sigurdson@state.mn.us
8 megan.engelhardt@state.mn.us
9 APPEARING FOR AND ON BEHALF OF THE WITNESS:
10 K. DAVIS SENSEMAN, ATTORNEY AT LAW
DAVIS LAW OFFICE
11 400 South Fourth Street
Suite 401
12 Minneapolis, Minnesota 55415
13 davis@davismeansbusiness.com
14
15
16 *The Original is in the possession of the
Minnesota Campaign Finance & Public
17 Disclosure Board.*
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20 * * *
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25

(952)922-1955
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1 I N D E X
2 ILHAN OMAR PAGE
3 Examination by Ms. Engelhardt ................... 4
4 Examination by Mr. Sigurdson .................... 41
5
6
7 * * *
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10 E X H I B I T S
11 NUMBER DESCRIPTION PAGE MARKED
12 1 2/1/16 Report 4
2 7/27/17 Report 4
13 3 10/25/17 Transaction Summary 4
4 2/2/18 Report 4
14 5 Register of Actions 4
6 Affidavit of Carla C. Kjellberg 4
15 7 8/16/16 Email 4
8 8/31/16 Email 4
16 9 9/15/16 Email 4
10 3/30/17 Email 4
17 11 8/22/16 Letter 4
12 Unity Rally Document 4
18 13 Human Rights Awards Document 4
14 Leadership Summit 2017 Document 4
19 15 Keynote Speaker Document 4
16 Meet Ilhan Omar Document 4
20 17 2017 ANSWFL Gala Document 4
18 Financial Disclosure Report 4
21
22
23 * * *
24
25

(952)922-1955
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1 (Whereupon Exhibit Numbers 1-18 were

2 marked for identification by the court
3 reporter.)
4 P R O C E E D I N G S
5
6 MS. ENGELHARDT:
7 Q So, again, my name is Megan Engelhardt and
8 I'm the assistant executive director of the Campaign
9 Finance and Public Disclosure Board, and Jeff
10 Sigurdson, the executive director, and we're here to
11 do the deposition regarding the investigation about
12 expenditures made by your committee, Neighbors for
13 Ilhan (Omar) Committee, from 2016 and 2017. And as
14 the candidate we wanted to talk to you about this
15 matter. Have you ever had your deposition taken
16 before?
17 A No.
18 Q Okay. So here's kind of the ground rules
19 about depositions.
20 A Okay.
21 Q Kassie is going to need us to not talk over
22 each other.
23 A Um-hmm.
24 Q Which is hard, so we'll all try not to do
25 it. And we need to answer verbally, we can't nod

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1 because she can't take that down. Oh, and we need to

2 have you sworn in.
3 ILHAN OMAR,
4 after having been duly sworn, was examined and
5 testified on her oath as follows:
6
7 EXAMINATION
8 BY MS. ENGELHARDT:
9 Q Okay. And then if there's any questions
10 you don't understand or you want to take a break, be
11 sure to let me know and we can take a break. I don't
12 want you to answer a question if you don't understand
13 what I'm talking about. So I can reword it, so just
14 be sure. Take your time thinking about an answer,
15 and we'll hopefully not drive Kassie too crazy with
16 our nods and our uh-huhs and our um-hmms and all of
17 that.
18 Okay, all right. So I'm just going to
19 start with a little general background. So you
20 decided to run -- why don't you tell me about when
21 you decided to run for Minnesota House of
22 Representatives?
23 A Sometime in 2015.
24 Q Okay. And you formed a committee?
25 A Yes.

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1 Q Okay. Did you form the committee or did

2 you have somebody else working with you on it?
3 A Somebody else. Yeah, there was a kitchen
4 cabinet.
5 Q Okay. Why don't you tell me about how you
6 formed your campaign in 2015?
7 A Seems so long ago. There was a group of us
8 who decided we wanted to challenge the incumbent, and
9 lots of conversations, and then a few friends signed
10 up to be the chair and treasurer and campaign
11 manager. Then we got going.
12 Q Okay. Had you any experience with any
13 other campaigns or committees before this?
14 A Yes.
15 Q In what way?
16 A I managed a few campaigns.
17 Q Were you involved as a treasurer in the
18 financial part?
19 A No, no, no.
20 Q So you've never worked in the financial
21 part of running a campaign?
22 A Not really.
23 Q Okay. Did you decide how the bills were
24 going to be paid as a committee?
25 A I don't remember us having a conversation

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1 about that.
2 Q Okay.
3 A Everything happened a little, like,
4 chaotic.
5 Q Okay, all right. So did you -- we spoke to
6 Liz Loeb and she kind of gave us an outline for
7 how --
8 A She'll have better memory of how things
9 worked than I would.
10 Q Okay. Did you ever see bills or invoices
11 or anything like that?
12 A Not often.
13 Q So your committee wasn't set up where bills
14 needed to be seen by you before they were paid or
15 anything like that?
16 A No. Once in a while if no one else could
17 sign a paycheck or something, I might help.
18 Q Okay, all right. And do you know who
19 approved any sort of -- when expenditures were made,
20 who approved them?
21 A My understanding would be that one of the
22 campaign managers.
23 Q Okay.
24 A And maybe the treasurer.
25 Q Okay. Did anybody from your --

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1 A It was fairly fluid.

2 Q Okay. Did anybody from your campaign or
3 you, yourself, did you attend any compliance training
4 or anything like that?
5 A I came to one a long time ago. I
6 had -- was involved with a campaign -- not a
7 campaign, but like a PAC, like a collection
8 committee, and I came and maybe stayed a little bit,
9 and then had to go pick up the kids so I didn't
10 really go through it.
11 Q Okay. Did you ever ask anybody to do -- to
12 go to that training for your committee?
13 A I imagine there was, like, invitations to
14 go to that. I'm not sure if any of them did go.
15 Q Okay.
16 A I wouldn't be surprised if they did.
17 Q Okay.
18 A It's quite possible.
19 Q Let's talk a little bit, let's fast forward
20 to 2016.
21 A Um-hmm.
22 Q And specifically in July and August there
23 was -- and the term that we've been referring to and
24 what refers to in the emails is a crisis. So why
25 don't you tell us a little bit about that?

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1 A What do you want to know?

2 Q Fair enough, okay.
3 A There's a lot to tell. What exactly do you
4 want to know?
5 Q Well, from the exhibits -- and we can talk
6 about -- let's pull this one out. There's an email
7 from Lena Gardner on Tuesday, August 16th. That kind
8 of is the email that starts what you called the
9 crisis management team.
10 A Um-hmm.
11 Q So, essentially, what I'm kind of trying to
12 get at is, how did this committee get formed, this
13 crisis management committee?
14 A So there was a crisis. I was annoyed by
15 the crisis, and friends and associates felt like that
16 was not the reaction to have to the crisis. It
17 needed to be handled and worked on and they wanted to
18 figure it out. And Lena was the only one I had some
19 relationship with, and so she was mainly helpful in
20 finding folks to help figure it all out.
21 Q So just to be clear, the crisis was a
22 newspaper article -- well, not a newspaper -- a blog
23 post related to your immigration status and your
24 marriages?
25 A Um-hmm.

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1 Q Was there anything else?

2 A That was a good summary of it.
3 Q Okay. And at what point did you become
4 represented by counsel for this crisis?
5 A I would say within days, maybe.
6 Q Okay. And who did you first -- because we
7 have two names, one is Carla Kjellberg, who we've met
8 with, and the other is Jean Brandl. Can you tell me
9 a little bit about your relationship with
10 Jean Brandl?
11 A Jean is someone I knew from, like,
12 immigration stuff.
13 Q Okay. Did you retain her to represent you
14 or the committee?
15 A I don't know if I would use those words.
16 Q What words would you use?
17 A I asked for her to, like, talk to my comms
18 people, to like tell them to breathe.
19 Q Okay. So how long did you work with
20 Jean Brandl?
21 A I think it was like maybe one phone call.
22 Q Okay. I think she is the person that
23 received -- and Davis has already pulled this out for
24 you -- she's the person that received the letter from
25 Andy Luger.

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1 MR. SIGURDSON: Do you have an

2 exhibit number?
3 THE WITNESS: Yeah, there was a --
4 MS. ENGELHARDT: Eleven.
5 Exhibit 11, sorry.
6 THE WITNESS: There was -- are we
7 referring to these people as bloggers?
8 MS. SENSEMAN: Yeah, yeah.
9 THE WITNESS: Okay. There was a
10 blogger, I think his name was Scott Johnson, who sent
11 us an email, and Jean was the only lawyer that I had a
12 number for. We -- right after the primary election, I
13 left town the day -- that night, and so I wasn't like
14 here in the city to talk to people. So I called Jean
15 about this email that we had gotten, and she said I'll
16 just respond to the --
17 MS. ENGELHARDT:
18 Q What was the --
19 A -- blogger.
20 Q Sorry, I talked over you.
21 A No, an email that was inquiring about these
22 things.
23 Q Okay.
24 A That was in the other blog.
25 Q Oh, okay. So a different blogger?

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1 A Yes.
2 MS. SENSEMAN: And this blogger had
3 said, like, there is an investigation, the U.S.
4 Attorney's Office is doing an investigation, which is
5 why Jean reached out to get this letter, because
6 proving it negative was somewhat difficult.
7 THE WITNESS: Um-hmm. No, so -- so
8 in -- in that response, Jean didn't know that the
9 blogger was going to post her response, and so he
10 posted her response. And in the first few articles
11 that ran, had her email response to him telling him
12 she didn't have a response, I think, is what the email
13 was. And so when the -- the news people were
14 contacting Andy Luger, there was a -- a news reporter
15 in Minneapolis in one of the main media outlets who
16 ran a fake story that the attorney general was
17 investigating. And my understanding was that the
18 attorney general reached out to call Jean to say that,
19 and then she probably asked him to put it in an email.
21 Q To say that they were not investigating?
22 A Yeah, um-hmm.
23 Q That the article was wrong?
24 A Yeah. Yes, and I think this is why he sent
25 her this email referencing a phone call.

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1 Q Okay. Did you ever pay Jean for her

2 services?
3 A No.
4 Q Okay. So this was more of a volunteer,
5 pro bono matter for her?
6 A Yes.
7 Q Okay. And then when did you get involved
8 with Carla Kjellberg?
9 A So Lena and others, I think, might have
10 talked to Jean and she was busy.
11 Q Okay.
12 A And then I think somebody -- again, I
13 wasn't really, like, in a day-to-day conversation on
14 this, but I think somebody said to contact Carla.
15 Q Did you know Carla before that?
16 A I don't think I met Carla before that.
17 Q Okay.
18 A I can't remember.
19 Q Okay. And when you say you weren't really
20 involved with this, can you tell me why you weren't
21 involved with it?
22 A I wasn't involved with, like, calling
23 around or talking to people about who they were
24 calling.
25 Q Okay.

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1 A Yeah.
2 Q So was this kind of something you just
3 passed on to campaign staff to deal with, this
4 crisis?
5 A This was very personal for me, so I was
6 just having my personal reactions.
7 Q That seems fair. So when you met with
8 Carla -- and let me find the exhibit number because
9 we have the affidavit from Carla, that's Exhibit
10 Number 6.
11 MS. SENSEMAN: Here it is.
13 Q So let's take a look at this. This is
14 something Davis sent to us and it has the affidavit
15 from Carla, and it sounds like -- if you look to the
16 Exhibit 1 of her affidavit, which is page 2, it looks
17 like you met with her in August of 2016, August 16th?
18 A Um-hmm.
19 Q And when we spoke with Carla, she explained
20 there were two kind of reasons why you were meeting
21 with her.
22 A Um-hmm.
23 Q One was that so she could represent you in
24 this marital dissolution, the divorce.
25 A Um-hmm.

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1 Q And the other was part of the crisis

2 management.
3 A Um-hmm.
4 Q Is that a correct statement?
5 A I don't think we talked about the
6 dissolving of the marriage in those meetings.
7 Q Okay. What do you think you were talking
8 about?
9 A We were talking about, like, how she could
10 help us figuring out what everything else could mean.
11 Q What do you mean, everything else could
12 mean?
13 A I mean people were accusing me of not being
14 married. They were accusing me of other, more
15 drastic things, so. It's not illegal to be married.
16 Q So --
17 A Being married isn't a crisis.
18 Q No being married is not a crisis.
19 A Sometimes.
20 MS. ENGELHARDT: Oh, sorry.
21 MR. SIGURDSON: It's my role.
23 Q Okay. Well, let me back up --
24 A Yeah. I mean, it was -- we had very short
25 meetings and they were more like to give her

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1 permission to talk to people on my behalf and to look

2 at things and sign paperwork for her to represent me.
3 Q Have you seen this whole packet, this
4 affidavit, before?
5 A Yeah.
6 MS. SENSEMAN: Yeah. Yeah, you saw
7 that.
8 THE WITNESS: Long ago, long ago.
10 Q It was long ago. So let me just back up,
11 and maybe Davis has already explained this to you or
12 maybe you've taken a look at Ms. Kjellberg's
13 deposition. Have you?
14 MS. SENSEMAN: No, we haven't gotten
15 a copy of that.
16 MS. ENGELHARDT: Oh.
17 MR. SIGURDSON: It's a little
18 strange in that we were billed for that.
19 MS. SENSEMAN: No, you were billed
20 for the Liz Loeb one. I mean, you might have been
21 billed directly for the other one.
22 THE WITNESS: Who's Carla?
23 MS. SENSEMAN: Carla?
24 Ms. Kjellberg. That's how you pronounce her last
25 name.

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1 MS. ENGELHARDT: I'll call her

2 Carla.
3 THE WITNESS: I was like, I don't
4 know who that is.
5 MS. SENSEMAN: That's Carla.
6 MS. ENGELHARDT: I'll forward it to
7 you. I'm sorry.
9 Q So when you talked to Carla --
10 A Yeah, you've got to use first names. I
11 don't pay attention to last names at all. It's a
12 really sad, cultural thing.
13 Q That's fine. Carla is -- typically as a
14 lawyer we try to use Ms. and Mrs., but I like it.
15 We'll go with Carla.
16 A Yeah, yeah.
17 Q So when Carla met with us, she explained
18 that -- and if your recollection doesn't match up,
19 that's fine, just let me know if that's wrong. She
20 explained that you were meeting to discuss, okay, we
21 need to start the process for doing the dissolution.
22 And that's what you retained her for?
23 A Um-hmm.
24 Q Was the dissolution?
25 A Um-hmm.

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1 Q Because if you take a look at the bills

2 they're all labeled divorce.
3 A Um-hmm.
4 Q And they start in August and there are
5 conferences. And then like, for example, on the
6 bottom it says Frederick & Rosen, $1,500.
7 A Um-hmm.
8 Q And then the next page has a statement from
9 Frederick & Rosen.
10 A Um-hmm.
11 Q And if you go to the next statement she
12 sent you at the end of September, then that one has
13 the De León & Nestor, immigration work, $750.
14 A Um-hmm.
15 Q Okay. Now if you go to -- it's Exhibit 3
16 of Carla's affidavit, which we've marked as
17 Exhibit 6. It's a little confusing with all the
18 numbers.
19 A Um-hmm.
20 Q This is a bill you received May 31, 2017?
21 A Um-hmm.
22 Q Okay. And then it shows that, the second
23 page of it, shows that on December 15, 2016, there
24 was a payment of $2,250?
25 A Um-hmm.

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1 Q Does that seem familiar to you?

2 A Um-hmm.
3 Q Okay. So looking back, let's talk first --
4 A So in our first meeting, like, all of these
5 people were in the room.
6 Q The first meeting with Carla?
7 A Yeah. And so she might have -- but my
8 brain was on like the pieces everybody was doing and
9 what that, like, meant for the whole thing.
10 Q Okay. At the time that you met with her --
11 A This is very different than, like, the
12 space I was in in October.
13 Q Okay. When you met with Carla, did she
14 explain that she was going to retain these other
15 people to do work for you?
16 A Um-hmm.
17 Q And can you tell me what she said, if you
18 remember?
19 A We did not talk about specific people.
20 Q Okay.
21 A But she did mention that she -- she asked
22 if it was okay to include other people as she saw fit
23 to try to get answers to help us -- a better way to
24 communicate what was happening.
25 Q So did she say to you, I'm going to look to

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1 hire an immigration person and an accountant? Or did

2 she just say, can I hire who I want?
3 A Yes, I think for me that was my
4 understanding. There might be pieces I need to look
5 at. Can I hire people on your behalf?
6 Q But she didn't specifically say immigration
7 or accountants?
8 A Not to my recollection.
9 Q Okay. So you didn't know that there was
10 going to be specific work performed by -- let's start
11 with De León & Nestor, that's the immigration
12 lawyers. Bruce Nestor, does that name sound
13 familiar?
14 A Um-hmm.
15 Q Okay. He's the attorney that handled some
16 of the immigration work?
17 A Um-hmm.
18 Q Obtaining documents?
19 A Um-hmm.
20 Q Okay. So she didn't say to you, can I hire
21 Bruce Nestor?
22 A No.
23 Q Okay. Do you recall when you knew that she
24 had retained Bruce Nestor?
25 A There were lawyery questions he had that I

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1 needed to answer.
2 Q Lawyery questions, I like it. Okay. Did
3 you get this -- let's flip to page 2 of this exhibit.
4 Did you personally get this bill from Kjellberg Law
5 Office in August?
6 A I can't recall.
7 Q Okay.
8 A I'm not sure who paid the bill.
9 Q Did you --
10 A Did she recall who paid the bill?
11 Q Well, yes. Nobody paid this bill until
12 December.
13 A Um-hmm.
14 Q The December payment -- December 15th
15 payment for $2,250 covered Frederick & Rosen's $1,500
16 and $750 for Bruce Nestor, De León & Nestor.
17 A Um-hmm.
18 Q So you don't recall paying that at all?
19 A I don't.
20 Q So you wouldn't know if the check for
21 $2,250 came from you personally or from the
22 committee?
23 A I gave her a check for the divorce work
24 when she was filing for the divorce.
25 Q Okay. And that would have been in May of

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1 2017?
2 A Is that what it says? Is this it?
3 Q Yeah.
4 A Okay, then yes.
5 Q Okay. And so can you flip to page 2 of
6 that where it says, the $2,250 advance payment?
7 A Um-hmm.
8 Q Do you see that?
9 A Um-hmm.
10 Q So you don't know who wrote that check to
11 her?
12 A I don't recall. I mean, all of these dates
13 and everything is, like, literally a blur.
14 Q Okay. Let's talk for a few minutes about
16 A Um-hmm.
17 Q So as I explained, we've already
18 interviewed Carla, and Davis was there, and we asked
19 her some questions about what the purpose was of
21 A Um-hmm.
22 Q Actually, let me stop. Let me back up. So
23 the purpose that she had for De León & Nestor was
24 that they were going to obtain immigration documents,
25 your file, so that they could see what was in the

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1 public record that is possibly where some of these

2 sources were coming from, bloggers. Is that your
3 understanding?
4 A So it was more like to figure out how to
5 deal. So I don't -- I don't know what they were,
6 like, looking for.
7 Q Okay. When we talked to Carla about --
8 A She'd have a better understanding of it.
9 Q Okay.
10 A The purposes of these inquiries were for.
11 Q When we talked to Carla about Frederick &
12 Rosen, which is the $1,500 payment that she made to
13 them, and then you paid back or the committee paid
14 back in December, she told us that that was
15 attorney-client privilege and that prevented her from
16 telling us what the purpose of the public accountant
17 was. So I'm hoping, and maybe you want to talk to
18 Davis about this, that you can tell us what Frederick
19 & Rosen did you for you?
20 A She handled this. I have no -- there was
21 no -- I wouldn't assume extra paperwork. I would
22 have to talk to him about.
23 Q Okay. Can you flip back to Exhibit 1 of --
24 that's the page. That's perfect.
25 A Um-hmm.

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1 Q So this is a statement from Frederick &

2 Rosen, Limited.
3 A Um-hmm.
4 Q And this is what Carla provided to us?
5 A Um-hmm.
6 Q And it says non-retainer services, and it
7 says Hirsi Omar 2015 and 2014, $1,500.
8 A Um-hmm.
9 Q Does that give you any indication of what
10 Frederick & Rosen did for you?
11 A Not really.
12 Q Okay, all right. We'll have to circle back
13 to this.
14 MS. SENSEMAN: Yeah. I mean, I can
15 tell you that from what I saw from reviewing things
16 that I don't think there is attorney-client privilege.
17 It appeared that they were obtaining tax records, the
18 same way that the -- and reviewing tax records, the
19 same way that the immigration folks were obtaining
20 immigration files. That's what I can gather from what
21 I've seen.
22 MS. ENGELHARDT: Okay.
24 Q But you didn't have any knowledge of what
25 they were specifically doing for you at this point?

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1 You weren't talking to Frederick & Rosen, or did you

2 provide them documents?
3 A I don't think I provided them documents.
4 Q Okay.
5 MS. SENSEMAN: No, I think they were
6 obtaining things directly from the IRS.
7 THE WITNESS: Um-hmm.
8 MS. ENGELHARDT: Okay.
9 THE WITNESS: So in this case,
10 right, there was a lot that was being insinuated,
11 criminally, and I think what she was doing in helping
12 was trying to figure out if there were any -- like how
13 to move forward, if there were any truths to this
14 stuff.
15 To me, I feel like there wasn't
16 enough -- or to my benefit, not communicating too
17 much of it to me because she needed to know
18 independently. There was a lot of frustration that
19 any of these things were not disclosed to any of the
20 campaign staff when I decided to run for office. And
21 so I think everybody who was doing this wanted to put
22 a research file together that had the benefit of
23 making sure that there weren't any other dark things
24 in my closet that I might not have told them about.

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1 Q So would you say that you personally got

2 any benefit from the work that Bruce Nestor or the
3 accounting firm Frederick & Rosen did for you?
4 A No, no. It was all for the benefit of,
5 like, the campaign and making sure it survived and I
6 continued to get elected.
7 Q Okay. So let me summarize a little bit and
8 you correct me if I'm wrong. Okay?
9 A Okay.
10 Q So what you seem to be saying is Carla and
11 the rest of the campaign wanted to kind of
12 independently gather some information about you?
13 A Yeah. There's a process that naturally
14 happens when somebody decides to run for office.
15 Oftentimes, like, people will sit down with you and
16 they say tell me everything. Like, what could we be
17 prepared for? And when you have candidates that
18 could be become high profile like myself, then you
19 actually, like, hire a research firm or people who
20 have done that for similar people that fit into that
21 category to look at things that could potentially be
22 damaging for a campaign and its principal.
23 So because our initial starts were not
24 traditional, or nothing about our campaign was
25 traditional, we didn't do -- or I didn't do any of

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1 the background work that needed to get done. And

2 there was a feeling, I think, among our campaign and
3 advisors and people who, you know, were donors and
4 investors that they didn't -- it wasn't enough for
5 them to now just talk to me.
6 Q They wanted to see something else?
7 A They wanted to make sure that they had
8 somebody who had similar experience of dealing with a
9 candidate like me who could, you know, without
10 spending too much time, get them quick answers so
11 that they knew whether it made sense for them to
12 continue helping me or not.
13 Q Okay.
14 A So they -- I mean, for me, you know, it was
15 the normal questions, like, what's your Social
16 Security? That was almost the extent of the
17 conversations I was involved with, really, when all
18 of this was being taken care of.
19 Q Okay. I mean, I'll -- let me just explain
20 why I wanted to talk about this one. When I looked
21 at this exhibit, and I think, Davis, we've talked
22 about this, it looks like this accounting firm did
23 your taxes for 2015 and 2014.
24 A No, they were only known to me after this.
25 Q So you --

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1 A No.
2 Q So this is not personal work that they did
3 for you?
4 A No, no.
5 Q Okay.
6 A No, no.
7 Q Okay. It was basically to create your own
8 hit file, it sounds like?
9 A Yes.
10 MS. SENSEMAN: Yes. Actually, not
11 even your own hit file. The campaign's hit file.
12 THE WITNESS: Yes, yes.
14 Q Okay.
15 A I mean, Bruce and Tom were not previously
16 known to me.
17 Q Okay.
18 A I do know them quite well now, but they
19 were not previously known to me.
20 MR. SENSEMAN: At this point I have
21 an interjecting question.
22 THE WITNESS: Yeah.
23 MR. SIGURDSON: On the tax forms
24 Carla Kjellberg indicated that there were some issues
25 resolved, and she indicated there were some issues

(952)922-1955
Page 29
1 resolved by the accounting firm. Do you know if there

2 were amendments filed to your taxes based on the work
3 of the accounting firm?
4 THE WITNESS: I don't think so.
5 MR. SIGURDSON: Okay.
6 THE WITNESS: I think issues
7 resolved for her would probably mean that they were no
8 longer an issue.
9 MS. ENGELHARDT: But you
10 didn't -- personally didn't have to do any amendments,
11 you don't think.
12 THE WITNESS: I don't recall doing
13 any.
14 MS. ENGELHARDT: And maybe -- I
15 mean, once I send the deposition to you, I think I
16 remember asking Carla if there was some personal
17 aspect.
18 MS. SENSEMAN: Yeah. I mean, I
19 can't remember exactly how she answered that one, but
20 it also wasn't clear --
21 THE WITNESS: I do have personal
22 checks I paid to him afterwards.
23 MS. SENSEMAN: To Rosen?
25 MS. SENSEMAN: Yes, because you had

(952)922-1955
Page 30
1 used him in the future, now?

2 THE WITNESS: Yes.
3 MS. SENSEMAN: The past, not the
4 future. The future after this date.
6 Q So he's now your accountant?
7 A Yes. So everything that was -- was good
8 about this, was that they also became personal usages
9 as -- as people in my life after this introduction.
10 So she did end up eventually doing my divorce.
11 Q Yes.
12 A And Tom is now my accountant.
13 Q Okay.
14 MR. SIGURDSON: Can we talk about
15 this email? I'm just trying to get a time frame.
16 What exhibit is this? I'm not sure.
17 MS. ENGELHARDT: That exhibit is 7.
19 Representative Omar, if you look at number 7 which is
20 an email from Lena Gardner from August 16, 2016,
21 basically to everybody. I think it's to Carla
22 Kjellberg and Michael Howard, Ben Goldfarb, who we
23 talked to about, with Ms. Kjellberg about the roles of
24 all these individuals. This was basically the crisis
25 management team and this was on August 16th.

(952)922-1955
Page 31

2 MR. SIGURDSON: And I'm just going
3 to see if you agree with my understanding of what
4 happened, and if I have something incorrect, please
5 let me know.
7 MR. SIGURDSON: More or less right
8 after the primary election, there was a far-right
9 website that published an article questioning your
10 immigration status. Shortly after that, there was a
11 Power Line blog that's based in Minnesota --
12 THE WITNESS: That's this Scott
13 Johnson.
14 MR. SIGURDSON: It referenced the
15 far right side. And based on that, it then became a
16 story in Minnesota, and there were a series of emails
17 that were provided to us through discovery that show
18 that there were individuals involved in your campaign
19 who were alarmed. This was clearly an issue that
20 needed to be addressed.
22 MR. SIGURDSON: And in the end, it
23 results in this crisis management team that we see
24 here described. The reason why it is useful in the
25 email to you -- email to us, excuse me, is that it

(952)922-1955
Page 32
1 outlines everyone's role.

3 MR. SIGURDSON: And one of the parts
4 of the email says, Carla, Carla Kjellberg, is serving
5 as our legal advisor on our statements and strategy
6 for the campaign and for Ilhan personally.
8 MR. SIGURDSON: So I'm assuming by
9 the 16th it's determined that she's going to be
10 working on the two issues that we've talked about,
11 obtaining the file from immigration and dealing with
12 the accounting firm. And then I don't know if it was
13 seen as part of the crisis team or just so its people
14 are aware on the crisis team that she would be working
15 with you on the divorce issue as well. Is that a good
16 summary of how authority is being divided up on the
17 crisis team?
18 THE WITNESS: I think it's laid out
19 so if there were times that Carla couldn't talk to
20 them, that that would be to make sure that they gave
21 her an opportunity to talk to me.
22 MR. SIGURDSON: Okay. Then it goes
23 on to say that you would be ultimate decider on
24 messaging and strategy, this team will act in an
25 advisory capacity for presenting options and helping

(952)922-1955
Page 33
1 support and execute the implementing of those plans.

3 MR. SIGURDSON: Now, eventually
4 Ms. Kjellberg gets the documents that you see being
5 billed, the immigration file and also the -- I guess
6 we agreed they were tax forms from those two years.
7 Did those records end up being turned over to you, the
8 immigration file and the tax records?
9 THE WITNESS: No.
10 MR. SIGURDSON: To your knowledge,
11 then, are they still with Ms. Kjellberg, or are they
12 with the committee, or do you know where they're at?
13 THE WITNESS: They might be with the
14 people who have them.
15 MS. SENSEMAN: I think they might
16 be. I believe Carla never got the immigration file
17 because it was very late March of the following year
18 when that finally came back.
19 MR. SIGURDSON: Right. But it had
20 to have gone somewhere. Do we know --
21 MS. SENSEMAN: I don't believe it's
22 with the campaign.
24 THE WITNESS: I think they might
25 have just reviewed to see if there was anything that's

(952)922-1955
Page 34
1 alarming.
2 MR. SIGURDSON: It would
3 be interesting to see --
4 THE WITNESS: The immigration
5 documents --
6 MS. SENSEMAN: To figure out where
7 they ended up.
8 THE WITNESS: Yeah. Immigration
9 documents he would have looked at would be immigration
10 documents that I would also have.
11 MR. SIGURDSON: Since the committee
12 ends up paying for those services of obtaining that
13 file --
14 MS. SENSEMAN: Um-hmm.
15 MR. SIGURDSON: -- it would be
16 useful for us to verify that the committee has access
17 to those records and how eventually they are disposed
18 of.
19 MS. SENSEMAN: Sure, okay.
21 Q But you have those documents from when you
22 went through the immigration process?
23 A Um-hmm.
24 Q Correct?
25 A Yes.

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Page 35
1 Q Okay. So you didn't need another copy, you

2 already had it?
3 A No, no, I don't need it. I have much more
4 than what she would have gotten from them.
5 Q Okay.
6 A But they wanted to know it for themselves.
7 MR. SIGURDSON: And then --
8 THE WITNESS: My father's still
9 alive, so I have an old man's storage of documents.
10 MS. SENSEMAN: We can't necessarily
11 get them, but they are somewhere.
12 THE WITNESS: Yes.
13 MR. SIGURDSON: Okay. And so all of
14 this, again, referring back to that email where by now
15 the crisis group committee has been formed and
16 everyone has their roles by the 16th. On the 22nd,
17 Mr. Luger, who's the United States Attorney, responds
18 by letter that he is not conducting an investigation
19 of your status at all. At that point, was that the
20 end of activity for that committee from your
21 standpoint, or did they continue to be active through
22 the general election?
23 THE WITNESS: No, not really. I
24 think within a couple of days we had an opportunity to
25 put statements out with some clarity for the team to

(952)922-1955
Page 36
1 feel comfortable with. So this helped make it not

2 news anymore. And so their closing was just to make
3 sure that the final stuff would come in from, like,
4 everyone else. And once, you know, this was not news,
5 then I guess we're busy again.
6 MR. SIGURDSON: Sure. Just one
7 final question on this portion, relating back, again,
8 to services done by the accounting firm. We certainly
9 understand from looking at the media articles from
10 that time period the questions about immigration
11 status. Was there a particular question that the tax
12 records were going to be used for that? I wasn't able
13 to identify.
14 THE WITNESS: I was accused of being
15 married to two people, so tax filings I'm guessing
16 were a huge part of that.
18 MS. SENSEMAN: And a lot of the
19 allegations online kind of had a
20 throw-it-against-the-wall type of -- you know, it
21 would say, if this is true, here are the laws that
22 would be broken. And some of them did refer to, like,
23 tax forms and, I mean, it went on and on.
24 THE WITNESS: Um-hmm. Which makes
25 sense that she just had him look at the last two

(952)922-1955
Page 37
1 filings of, like, the two prior years.

2 MR. SIGURDSON: Are you done? Did
3 you have any other questions on that?
4 MS. ENGELHARDT: I'm done with the
5 2016 expenditures.
6 THE WITNESS: But I would say for
7 like those two --
8 MS. ENGELHARDT: I take that back.
9 THE WITNESS: The simplicity of it,
10 right, was to -- you know, there's all this stuff
11 that's being said about my immigration. So if you
12 don't want to, like, trust my word, then you
13 just -- you ask an immigration person to look at it
14 to, like, verify all of that. So I can't even
15 remember if he actually produced anything, but he
16 might have just been, like, we looked at it and she
17 has nothing to worry about. You guys are going to be
18 fine. Ilhan isn't being deported.
19 And then there is like the impropriety
20 that is being implied with, like, if she's, like,
21 living with a person and she's legally married to
22 someone else, then she might have, like, wrongly
23 filed her taxes and that could be a problem. To say,
24 hey, can you look at the last two forms for us to let
25 us know if this is something we need to worry about?

(952)922-1955
Page 38
1 And so --
2 MS. SENSEMAN: And it was --
3 THE WITNESS: It makes sense to me
4 in her reasoning.
5 MS. SENSEMAN: As Carla mentioned in
6 her deposition, like, it was a week, but it seemed
7 like -- you know, when you go from the 16th to the
8 22nd, it was really only a week of heightened --
9 THE WITNESS: And we were all
10 mentally and physically like exhausted, because the
11 election was on the 9th, which is Tuesday. The story
12 broke out on Friday. And so --
13 MS. SENSEMAN: But, yeah, it is
14 amazing that it happened in one week, and then after
15 the 22nd it was like, oh.
16 MR. SIGURDSON: What my, I suppose
17 follow-up question is -- and you can think about this
18 if it's not something you want to answer at the
19 moment -- we clearly have gone beyond where
20 Ms. Kjellberg was comfortable talking about those
21 issues. Can we consider that waived just so that we
22 can have her basically address the same questions we
23 asked before, just to have a consistent story?
24 MS. SENSEMAN: Yeah, just to confirm
25 the -- yeah.

(952)922-1955
Page 39
1 MR. SIGURDSON: Okay. I'm sorry,

2 back to you.
4 Q So I just want to -- so Exhibits 1, 2, 3,
5 and 4 are your campaign finance reports. It doesn't
6 sound like from what you've talked to me so far about
7 is that you had any real involvement in putting these
8 reports together. Is that true?
9 A Yes, very.
10 Q So just so we're looking at Exhibit -- this
11 is Exhibit 2, and it's the year-end report for 2016.
12 A Which one am I looking at?
13 Q So you're going to want to look at --
14 MS. SENSEMAN: One more back. This
15 one right?
16 MS. ENGELHARDT: Yep.
17 MS. SENSEMAN: Okay.
19 Q The year-end report for 2016. And this is
20 the one that has the payment to Carla on it, to
21 Kjellberg law firm, and that is on -- I should have
22 marked the page.
23 MS. SENSEMAN: It's back. I'm not
24 really familiar with this campaign report. Is it not
25 on this one? Is it on the next one?

(952)922-1955
Page 40
1 MS. ENGELHARDT: No, it should be on

2 this one.
3 MR. SIGURDSON: It's on page 20.
4 The one that says non-campaign disbursements.
5 MS. SENSEMAN: Oh. Is it like the
6 last page?
7 MR. SIGURDSON: Second -- almost.
8 Go forward just a little bit.
9 MS. SENSEMAN: Oh, is it a separate
10 section?
11 MR. SIGURDSON: Right. It's not
12 campaign disbursements. There you go. You're there.
13 The one on that one.
14 MS. SENSEMAN: This hand?
15 MR. SIGURDSON: Um-hmm.
16 MS. SENSEMAN: No, that one's --
17 MR. SIGURDSON: Here, I tell you
18 what. Why don't you use mine?
19 MS. SENSEMAN: Okay, there it is.
20 11/20/16.
21 MS. ENGELHARDT: No, looking at
22 this, this is not --
23 MS. SENSEMAN: Not the right one,
24 right? There was another one after this?
25 MS. ENGELHARDT: It skipped all the

(952)922-1955
Page 41
1 even ones when I --

2 MS. SENSEMAN: Oh, that makes sense.
3 MS. ENGELHARDT: I don't know how
4 that happened. Clearly, I can't run a copy machine.
5 MS. SENSEMAN: It's fine.
7 Q Okay. But this payment was on the 2016
8 report, but you didn't -- you don't have any
9 knowledge of when it was paid to the committee or
10 when it was owed?
11 MR. SIGURDSON: To the vendor.
13 Q To the vendor at all?
14 A No, I didn't --
15 Q Okay, all right.
16 MS. ENGELHARDT: Now I'm done.
17 BY MR. SIGURDSON:
18 Q Well, I'm going to shift topics a little
19 bit. As you know there was a second complaint filed
20 dealing with travel expenditures in 2017. I'd like
21 to walk through some of those to make sure that we
22 have a full understanding of what we were thinking of
23 with those various events first. I'm going to --
24 THE WITNESS: Is this one of those
25 places that has coffee?

(952)922-1955
Page 42
1 MS. SENSEMAN: No.

2 MS. ENGELHARDT: No. That's why I
3 carry this giant one around. There is a vending
4 machine upstairs.
5 THE WITNESS: Does it have coffee?
6 MS. ENGELHARDT: I don't know.
7 MS. SENSEMAN: I don't think it
8 does.
9 MS. ENGELHARDT: I don't think so.
10 The state does not want you drinking coffee. We have
11 to pay for our own.
12 THE WITNESS: There's one place at
13 our office, too, in the Transportation Building.
15 Q Well, having lost full control of this
16 conversation, I'll try again. Let's go to some of
17 the non-campaign disbursements in 2017.
18 A Okay.
19 Q The first one I want to talk about --
20 A What are you having me look at?
21 Q We can probably use these where you
22 describe the events. And I may not be -- well, in
23 fact I know I'm not frankly in the chronological
24 order, but I'm going to deal with the non-campaign
25 ones first. The first one meaning the first letter,

(952)922-1955
Page 43
1 the one in Chicago for the National Immigrant Justice

2 Center on June 6, 2017. And I don't know which
3 exhibit that is --
4 MS. ENGELHARDT: I'm just looking
5 for it. 13.
6 BY MR. SIGURDSON:
7 Q Exhibit 13. And you were the keynote
8 speaker at this event; is that correct?
9 A Yeah, the recipient of the award.
10 Q And you were also the recipient of Gina and
11 Joseph Harmatz Award. Can you tell me a little bit
12 about the award? I'm not familiar.
13 A I'm not familiar with it also.
14 Q Okay.
15 A It's a human rights award.
16 Q And this was basically a luncheon; is that
17 correct? So it was a one-day event?
18 A It was a one-day event.
19 Q And so did you fly back on the same date,
20 do you recall?
21 A I do not recall.
22 Q Okay. I notice that the --
23 A I'm constantly jet-lagged so I don't know.
24 This is ancient time we're talking about in my life.
25 Q Do you recall --

(952)922-1955
Page 44
1 A Because I flew in in the middle of the

2 night last night to be here.
3 MS. ENGELHARDT: She does need
4 coffee.
5 THE WITNESS: You're asking me what
6 I did. It's like June of a year ago, I have no clue.
7 BY MR. SIGURDSON:
8 Q Do you recall how you were notified that
9 you were going to be receiving the award and were
10 asked then to come make a presentation? Or a speech,
11 I should say.
12 A All right. Let me refresh my memory. This
13 is Chicago, right?
14 MS. SENSEMAN: Yes, yep.
15 THE WITNESS: So there was -- this
16 was -- the travel ban had happened the 26th of
17 January, which would have been two weeks after we got
18 sworn in, and everything kind of went upside down and
19 there was, you know, a strange community that really
20 that was kind of built around the country of folks who
21 worked on immigration things and lawmakers and people
22 like myself who have heritage of two countries that
23 are on the travel ban.
24 So I worked a lot on -- on this issue, and
25 there -- this organization and I were doing some

(952)922-1955
Page 45
1 collaborative work. There's a bill that I have that

2 gets Minnesota to become a sanctuary state. There
3 was a bill also going through the Illinois
4 legislative process around the same thing, so there
5 was like a lot of work and so my assumption is this
6 is how this came about.
7 MR. SIGURDSON: And do you happen to
8 have an email or an indication of when they notified
9 you of when you were going to receive the award? I'm
10 just trying to get a time frame on it.
11 MS. SENSEMAN: We couldn't find one.
13 MS. SENSEMAN: I think Connor looked
14 through those.
17 Q Representative, do you happen to be a
18 member of the National Immigrant Justice Center?
19 A No.
20 Q And so just from, again, looking on the
21 exhibit on the awards, you're certainly listed as the
22 award winner and there's a nice biography. It also
23 spends a lot of time talking about how to be a
24 sponsor for the organization. From your viewpoint,
25 was this also -- or from your understanding, I

(952)922-1955
Page 46
1 suppose, was this also a fundraising event for the

2 National Immigrant Justice Center?
3 A I don't remember if there was fundraising
4 done. I remember Mayor -- what's his name, Emanuel?
5 MS. SENSEMAN: Rahm Emanuel.
6 THE WITNESS: Rahm Emanuel spoke
7 right before I did. There was a young woman who was
8 undocumented from Somalia who introduced me, gave me
9 award. I remember there were -- there was a
10 recognition of the first respondents to the airports.
12 Q And so basically, again, this was a
13 luncheon, there was the presentations. To the best
14 you recall, did you do any other activities with the
15 institute -- excuse me, the justice center, or any
16 other activities, political or otherwise, in Chicago
17 after the event was over?
18 A I took pictures.
19 Q Okay. And you've already said that you
20 don't recall if you returned on that same date. The
21 reason I --
22 A I don't think I was there for a long time.
23 Q And I notice that the report doesn't have
24 any lodging or meal expenses for the trip to Chicago,
25 so?

(952)922-1955
Page 47
1 A Yeah. So it might have been one of those

2 awful arrangements.
3 Q Going on to the next one --
4 A There's nothing worse than that.
5 Q And, again, I realize this isn't quite the
6 right order. The next one we're looking at is the
7 Youth [sic] Elected Officials Conference in San
8 Francisco, and --
9 MS. ENGELHARDT: I don't think we
10 have an exhibit for that one.
11 MS. SENSEMAN: Yeah, you might not
12 because it was -- the conference thing --
13 MS. ENGELHARDT: It was huge.
14 MS. SENSEMAN: Yeah, it was big, and
15 now I don't even know that it's available online.
16 MR. SIGURDSON: Actually, we do have
17 a copy, but you're right, it's about 90 pages long and
18 I just didn't see the point.
20 Q So let me just remind you. It was from
21 July 12th through the 14th in San Francisco, and, at
22 least from my examination of the agenda and schedule,
23 it didn't appear that you made any presentations,
24 speeches, or appeared on any other working panels.
25 Is that your recollection as well?

(952)922-1955
Page 48
1 A Yes.
2 Q Okay. Do you recall how you found out --
3 THE WITNESS: Where is this on my
4 file?
5 MS. SENSEMAN: Right here. Delta.
6 BY MR. SIGURDSON:
7 Q Do you recall how you were invited or
8 nominated? I notice from the process there are
9 certain criteria. To attend you have to be a certain
10 age group and there is a nomination process --
11 A I was not at this conference.
12 MS. SENSEMAN: That one in
13 San Francisco?
14 THE WITNESS: No, mine was in April.
15 MS. SENSEMAN: When was this one?
16 Oh, wait. There might be -- hold on. Was it this
17 one? Was it that one?
18 THE WITNESS: Finish your question,
19 sorry.
21 Q Sure. Well, I do know that the Young
22 Elected Officials Conference do have a lot of policy
23 seminars as well. It could have been one in April.
24 They have a number listed on their website. We
25 assumed, perhaps incorrectly, that it was the main

(952)922-1955
Page 49
1 elected officials --
2 A If I remember correctly, and I --
3 MS. SENSEMAN: Yeah, that's April.
4 THE WITNESS: I might be -- it's
5 messing with my brain -- was that there was one in, I
6 think, New York and it was a working policy table on,
7 like, criminal justice -- criminal justice reform. A
8 lot of this sanctuary stuff to deal with this crazy --
9 BY MR. SIGURDSON:
10 Q Okay. Were you a presenter at that
11 conference, do you recall?
12 A It was like a round table. It was working
13 group, so there was no real, like, presenters. It
14 was like electives coming together to kind of dump
15 our brain and figure out what legislation we were
16 working on, what was working in a particular state,
17 and how we get our policies and in getting some
18 supporting documents and ways to --
19 Q So it was kind of -- I'm not trying to put
20 words in your mouth -- but did you view it as a way
21 to supports your efforts here in Minnesota? Because
22 you had already mentioned you had legislation for --
23 A Yes, yes, yes.
24 Q Okay. Do you recall --
25 A Yes. And Minnesota, like, we have -- we

(952)922-1955
Page 50
1 don't -- you know, Minnesota isn't like a point of

2 entry. Our airports aren't point of entries. We
3 haven't had a -- like the work was not as
4 sophisticated as it is in some of the other states
5 like New York or California or Illinois. And so most
6 of, like, our ability to propose real things and to
7 get people working on real things as a legislator
8 relied on having the opportunity to have networks.
9 Q Okay. Do you recall how you became aware
10 of this working group? Were you invited to attend?
11 A So when you are under the age, I think, of
12 40, and you're elected, it's kind of like the NCIS or
13 something or like the state -- the state exchange
14 program for progressive legislators. It's -- you are
15 sort of looped in. I don't think there's like a
16 formal invitation thing.
17 Q So you were just notified that this was
18 going to occur and you decided to attend because --
19 A Yeah. There was like -- it's like a list
20 of like different debriefs or things like that that
21 happen throughout the year, and people who are
22 working on those specific things can loop themselves
23 in.
24 Q And in terms of the Youth Elected Officials
25 [sic], which is an organization --

(952)922-1955
Page 51
1 A Young Elected.
2 Q You're right, I'm sorry. I said youth.
3 A We're not youth, as my daughter reminds me.
4 You can be young, but just don't be youth. That's
5 embarrassing, mom.
6 Q At least in 2017, that's the only event
7 that you attended for that organization; is that --
8 A Sure. I have no way of keeping a list of
9 the events.
10 Q You don't recall, okay. Well, hopefully
11 I've got the right city on the next one. On
12 July 23rd in Washington, D.C., there was the Girl Up
13 conference, which is exhibit --
14 MS. ENGELHARDT: 14.
16 Q -- 14, and here you were a featured speaker
17 and you gave a speech. Do you recall how and when
18 you were invited to make a presentation at this
19 conference?
20 A I don't get the invitations myself
21 so -- they go to a poor staffer that I have.
22 Q Committee staff or legislative staff?
23 A My legislative staffer.
24 MS. SENSEMAN: And we looked for
25 that, as well.

(952)922-1955
Page 52
1 THE WITNESS: And he also staffs two

2 extremely busy people. But, yeah, so I don't know
3 when the invitations -- when the invitations come or
4 how we decide to accept them.
5 MS. SENSEMAN: I hope you didn't
6 give that speech at 1:55 a.m. That's a typo.
7 THE WITNESS: That would be perfect
8 time, actually. That's how my work schedule should
9 be. It says 1:55 a.m.
10 MS. ENGELHARDT: I know, it was
11 funny.
12 THE WITNESS: Okay.
14 Q Assuming it should be 1:55 p.m., I did note
15 that -- and frankly it was a fairly short speech,
16 about 15 minutes. Was there any other role that you
17 had at the conference that you can recall besides
18 making that speech?
19 A I did a sit-down interview with a young
20 woman from Chile, I think.
21 Q Here's where I'd sort of like to give you
22 sort of an open-ended question. Part of the issue
23 the board looks at is when you list a cost as a
24 non-campaign disbursement, as a cost for serving in
25 office, you know, the question is how does it relate

(952)922-1955
Page 53
1 to your serving in office. From your viewpoint, how

2 was this helping you as a role as a representative or
3 filling the role of a representative for the State of
4 Minnesota?
5 A Good that you ask. Few of my bills were
6 around girl and women issues. I had two bills to get
7 rid of the statute of limitation for sexual violence.
8 I had done some bills that were around allowing or
9 giving young women the opportunity to finish college
10 and pay for child care. And so -- so there is a lot
11 of, really, a continuation. I didn't do any event
12 that didn't have legislative fulfillment of -- of the
13 work that I was doing as a legislator.
14 Q This is --
15 A At least in my definition of what that was.
16 Q On this one particular trip, there were
17 meal and hotel costs for the night following
18 the -- well, the same day as the presentation for
19 July 23rd. Do you recall if there was any other
20 activities you attended after the Girl Up conference
21 was over in Washington D.C.?
22 A What are the dates for those?
23 Q July 23rd, wasn't it?
24 MS. SENSEMAN: Yeah, July 23rd.
25 MS. ENGELHARDT: Except it looks

(952)922-1955
Page 54
1 like the summit is July 16th to the 19th.

2 MS. SENSEMAN: Yeah, and I'm not a
3 hundred percent sure. I think these might have been
4 recorded when they cleared the bank.
6 MS. SENSEMAN: I think that's how
7 they were recorded.
8 MR. SIGURDSON: So which date does
9 the program say?
10 MS. ENGELHARDT: The program
11 deposition -- or the Exhibit 14 says the event was the
12 16th to the 19th of July.
13 MS. SENSEMAN: I think those are
14 just when they cleared the bank.
15 THE WITNESS: Yeah. I don't look so
16 I don't know.
17 MR. SIGURDSON: Okay. Well,
18 perhaps --
19 THE WITNESS: What and why the dates
20 are the way that they are -- yeah.
22 Q You don't recall any other events that you
23 attended in Washington, D.C., after that conference
24 was over, or at least after that day of events was
25 over for the conference?

(952)922-1955
Page 55
1 A There was a -- there was a lot. There

2 were -- there was a lot of stuff I did. I gave my
3 speech. I did like a Q and A thing on stage.
4 MS. SENSEMAN: This one?
5 THE WITNESS: Is that it?
6 MS. SENSEMAN: I don't know.
7 THE WITNESS: Yeah. So there were a
8 couple things. I don't know if we did them all the
9 same day.
11 Q Maybe to clarify my question, did you do
12 any activities outside of the Girl Up UN conference?
13 I mean, did you have any meetings with, I don't know,
14 elected officials in Washington or with any other
15 groups while you were in the city?
16 A Oh, goodness, that I wouldn't be able to
17 recall.
18 Q Okay.
19 A That's like you asking me what did you eat
20 or, like, what hotel did you stay at? That would
21 have things blurred in my brain.
22 Q The next trip we're looking at --
23 A The only reason I actually remember giving
24 the speech at that place was because there was that
25 girl from Chile who I had very similar upbringings

(952)922-1955
Page 56
1 with. That's how I remember that trip, actually.

2 Q It's still on YouTube, for what it's worth.
3 A Oh, okay. I don't watch myself, so.
4 Q The next one is a trip I'm looking at is
5 the trip to Fort Myers, Florida, on November 10th of
6 '17. I believe it's '17. This is --
7 MS. SENSEMAN: Let me make sure
8 we're there. One second.
9 MR. SIGURDSON: So this would be
10 Exhibit 16. And I don't know if you gave them a copy
11 of that.
12 MS. ENGELHARDT: I did.
13 MS. SENSEMAN: Yeah. Which one is
14 it? Oh, this? This.
15 MR. SIGURDSON: Right.
17 Q You gave a presentation -- you were a
18 speaker at an event for the Democratic Party of
19 Lee County, this is in Fort Myers, Florida, on
20 November 10th, and then on the very next day on
21 November 11th you're the keynote speaker at the --
22 A Go ahead, sorry.
23 Q Then on the very next day --
24 A People just have the weirdest pictures on
25 things.

(952)922-1955
Page 57
1 Q Then on number 17 is the announcement about

2 the presentation by the Southwest -- no, excuse me,
3 the African Network of Southwest Florida where you
4 were the -- again, the lead speaker at their event.
5 So on the 11th, the very following day, also in
6 Fort Myers.
7 MS. SENSEMAN: So here's a
8 question --
9 THE WITNESS: No. What was your
10 question?
12 Q My question is, do you recall the sequence
13 of events here? Were you invited to speak for the
14 party unit first or for the Southwest Florida's --
15 that gala event first?
16 A Oh, the African thing.
17 Q Um-hmm.
18 MS. SENSEMAN: This one first?
19 THE WITNESS: Yes.
20 MS. SENSEMAN: Yeah.
22 Q Okay. Do you have any recollection as to
23 how the Democratic Party of Lee County then sort of
24 piggybacked on your visit to Florida? You were down
25 there apparently for that to be the lead speaker.

(952)922-1955
Page 58
1 Somehow they found out and they asked you to attend

2 an event the day prior to that?
3 A Yeah, I wouldn't know. I don't know how
4 they found out.
5 Q Okay. Do you recall making a presentation
6 for them or a speech for them?
7 A No, no. What I recall is meeting the
8 person who was hosting me at this place, but that's
9 where I'm like, where is this from? After I had
10 arrived.
11 Q Okay. So it's even possible that you
12 didn't do the presentation on the 10th?
13 A I did not. I don't -- there was no --
14 MS. SENSEMAN: So it looks like
15 there was a meet and greet.
16 THE WITNESS: Yeah, I arrived and my
17 host was --
18 MS. SENSEMAN: -- there.
19 THE WITNESS: At this location.
20 MS. SENSEMAN: It was a surprise
21 meet and greet?
22 THE WITNESS: Yeah, and there was
23 some people, a handful, six, seven people. Mostly
24 older folks.

(952)922-1955
Page 59
1 Q From your standpoint -- again, I'm not

2 trying to put words in your mouth --
3 A Yeah.
4 Q -- it was sort of the same event? I mean,
5 it was all part of the presentation on the 11th? I
6 mean, you were flying in the day before you made the
7 speech on the 11th and this just sort of happened?
8 A Yes, yes, yes. I certainly -- yeah. I
9 don't ever visit party units anywhere, really.
10 MS. SENSEMAN: Surprise.
13 Q One thing I noted just simply from the
14 report, now there is an itemization threshold of
15 reports, if it's under $200 it's not going to be
16 listed.
17 A Um-hmm.
18 Q But while you flew clearly in on the 10th
19 and your speech for the African network was on the
20 11th, there isn't any hotel or meal expenditures. Do
21 you recall, did you -- were there none that your
22 committee paid for? Do you recall if they paid for
23 those, or?
24 A My husband was with me so maybe he paid for
25 it. I don't remember. That's a good question.

(952)922-1955
Page 60
1 Q Okay. But to your knowledge, at least, the

2 committee didn't pay for it?
3 A Yeah, I don't think -- no, no. You mean
4 like us? My campaign?
5 MS. SENSEMAN: Um-hmm.
6 BY MR. SIGURDSON:
7 Q Yeah.
8 A Yeah, no, no. And I don't even remember if
9 they even paid for --
10 Q And this is just sort of similar to the
11 other questions. Are you a member of the African
12 Network of Southwest Florida?
13 A No.
14 Q Okay. Again, it appears to be a
15 fundraising event so I'm just trying to understand
16 your relationship. They asked you to make a
17 presentation. From their website, I know this is one
18 of their annual ways of raising funds. But from your
19 perspective, again, sort of the open-ended question I
20 had with the UN Girls Up event, how did this relate,
21 again, to your role as a legislator?
22 A So we have like a setup in our office that
23 if there are, like, people who are inviting us to
24 speak to the legislative work that I'm doing and what
25 it means for us to be active in that way, then that I

(952)922-1955
Page 61
1 go and so I -- that would have been the acceptance

2 decision, and the decision to go would have been done
3 by them in fulfilling that category of that -- you
4 know, whether -- because every time I would go, we
5 would run it by -- what do they call it?
6 MS. SENSEMAN: House Ethics.
8 BY MR. SIGURDSON:
9 Q Really? Well, tell me about that. That's
10 news to me. So did they look at these trips and
11 think they were appropriate?
12 A Yeah. I've never taken a single trip
13 without checking in and making sure, like, everything
14 was proper. Even with my -- the school speech stuff,
15 like, everything I always ran by. Or they always
16 gave me an opinion that said, sure, this looks fine.
17 Or at least that was my understanding that that's
18 what my staff was doing before they would commit me
19 to doing anything.
20 Q Oh. So it was the staff's responsibility?
21 A Yes.
22 Q To check with the Ethics?
23 A Yes.
24 Q For the legislature, to make sure it was
25 appropriate?

(952)922-1955
Page 62
1 A Yes.
2 MR. SIGURDSON: This is a formal
3 request, can you see if there's any emails that her
4 legislative staff have confirming that, or?
5 THE WITNESS: I don't think he'd
6 email.
7 MS. SENSEMAN: I bet he called.
8 MR. SIGURDSON: If there aren't
9 emails, then I think that's someone we are going to
10 want to talk to, because that is important to
11 understand the thought process going into accepting
12 invitations to things.
13 MS. SENSEMAN: Okay.
15 Q One thing that did stand out as somewhat
16 different about this trip -- and this is just a
17 question -- but I did notice from your federal
18 statement that you were paid an honorarium to speak
19 at this event. Do you recall that?
20 A That is quite possible.
21 Q I believe it's $800 listed there.
22 A Okay.
23 Q Okay. Do you recall if there were any
24 other activities that you did? I realize that you
25 were surprised about the party event, but do you

(952)922-1955
Page 63
1 recall any other events that you did in Florida

2 during this trip?
3 A No, no. I was also surprised. It was
4 supposed to be like a conference and it wasn't really
5 a conference. That was the surprise.
6 Q Okay.
7 A I had some breakfast with some college
8 students.
9 Q Okay. But no other events that come to
10 mind?
11 A Uh-uh.
12 Q Okay. The last non-campaign cost is the
13 European Young Leadership conference. And, again, I
14 didn't print off that agenda because it was close to
15 200 pages long. But this was in September --
16 A Yeah, it felt like that. I was sick, it
17 was torture.
18 Q It was in Estonia and -- at least the
19 conference. I don't know if you were there for all
20 of the conference, but the conference started on
21 September 18th and ended on the 23rd, of 2017.
22 Again, tell me about the process about how you became
23 aware of the conference. To your knowledge, were you
24 invited to speak?
25 A Yeah, yeah, yeah. So what is -- with the

(952)922-1955
Page 64
1 Young European Leaders, it's like similar to the

2 Young Electives network, so they kind of just, like,
3 put you in the network because you fit the category
4 of the people who belong in the network. It's like
5 nobody asks for permission or you don't like ask. I
6 think it's a nomination actually. Somebody nominates
7 you because you fit in that -- yeah, because the
8 Young Electives is also nomination because I did just
9 nominate a friend. And so they have a category of
10 like leaders from like thought leaders from like
11 media, and then they have like a group of -- what are
12 they called -- like people who like work in creating
13 like policy, but not policymakers -- you know, like
14 the people who are like chief of staffs and that kind
15 of stuff. And then they have like the actual
16 electives, the people who get to make the
17 legislation. And it is to bring all of that
18 together, to move an agenda and to be able to
19 legislate effectively from a place of like having all
20 the things that you need in order to get work done.
21 Q There's a pretty wide range of agenda of
22 subjects that we're going to be referring to. Do you
23 recall any in particular that piqued your interest
24 enough to go to Europe for --
25 A You don't have the agenda?

(952)922-1955
Page 65
1 MS. SENSEMAN: No, we don't have the

2 agenda. It's huge.
3 THE WITNESS: I don't remember. I
4 mean, the bulk of -- so the conference that they do is
5 to help, like, have constructive debates on like
6 things. So one of these, like, big debates was mass
7 migration, and how do you effectively create
8 immigration policies that make it easy for people to
9 come into countries, how do you create policies that
10 are effective when people are in those countries so
11 that they are able to lead a new and hopeful life, and
12 then how do you create policies that help with, like,
13 the safety, like help with safety and assimilation of
14 these immigrants once they come in. And so generally
15 the whole thing for me was very interesting and
16 appealing as that is really like the bulk of the work
17 and the conversations I'm in and have been in since I
18 had my unfortunate election be the same night as the
19 conference.
21 Q You said it was a long conference. Were
22 you there for the bulk of it, at least?
23 A I was there for the whole thing.
24 Q That finishes the non-campaign ones. The
25 one conference, or trip, I should say, I want to talk

(952)922-1955
Page 66
1 about is campaign expenditure and this is the one to

2 Boston. And in the response that we received as to
3 why that was the purpose of that trip, it references
4 a Facebook invitation that was in response to the
5 possibility that there was going to be a white
6 supremacy march in the Boston Commons, and it was
7 asking people to do a power demonstration, I guess I
8 would characterize it, and have speakers present at
9 that event.
10 THE WITNESS: I have to use the
11 bathroom. Do you want to hold that thought?
12 MR. SIGURDSON: Sure.
13 (A break was taken from 12:36 p.m.
14 until 12:44 p.m.)
16 Q Just to resume, the last piece of travel
17 I'd like to talk about, again, is the trip to Boston
18 on August 19th, this is for the Boston counterprotest
19 and resistance rally. In explaining the event, it
20 was pointed out that there was a Facebook invitation
21 and this is -- in providing an invitation to come and
22 have resistance against the white supremacy march
23 that was thought was going to occur at that time.
24 And what I'm trying to understand is, were you
25 personally invited to attend and speak at that event?

(952)922-1955
Page 67
1 Or were you responding to the general call of arms

2 asking people to show up at that event?
3 A I had written an op-ed in Time magazine. I
4 think my op-ed was published maybe three days after
5 the -- I think like on the 17th. And it's -- it's my
6 understanding that we got an invitation or a request,
7 and -- yeah, the decision was made that we join and
8 bring an uplifting voice to that big rally that was
9 happening there, the counterrally.
10 Q Okay.
11 A And it was going to be like an organized
12 counterrally.
13 Q Now, from media accounts, my understanding
14 is, is that in some ways the event kind of sputtered
15 out?
16 A It did.
17 Q There was no --
18 A I did not make it.
19 Q Okay. So you did not speak at the rally?
20 A No. We were on the way. We were in the
21 car and could not get in, and then the police -- it
22 was -- it was bad.
23 Q Okay. Now --
24 A And, yeah, the decision was made that it
25 didn't -- it didn't make sense for us to continue to

(952)922-1955
Page 68
1 try. There were no real formal speeches that were

2 honored for that.
3 Q Now, the other thing we're looking to
4 Boston is Exhibit Number 12.
5 A Um-hmm.
6 MS. SENSEMAN: Is that this?
7 MR. SIGURDSON: Right.
9 BY MR. SIGURDSON:
10 Q There was another event that you did
11 attend.
12 A Um-hmm.
13 Q This is the campaign rally for a candidate
14 for Boston city council, Ms. Jibril. I may not be
15 pronouncing that correctly, I apologize if that's not
16 even close. And that was on August the 19th, and
17 that was posted -- the next page on the exhibit is
18 talking about it was posted on August the 8th, and
19 then the third page of the exhibit is a newspaper
20 article talking about your appearance at the rally.
21 A Um-hmm.
22 Q That, I'm assuming, would not have gone
23 through your legislative aide. Was that directly to
24 your campaign? Or do you know Ms. Jibril, or?
25 A So there was a conversation that my team on

(952)922-1955
Page 69
1 the campaign sides, like, there's a lot of us that

2 remained involved and somebody mentioned it to one of
3 our like East African leads that I might be going to
4 Boston and he knew that there was this woman running,
5 and he had reached out to see if she'd have dinner
6 with me or like she might want to get like advice.
7 And then before I knew it and approved, there was a
8 Facebook event that the campaign put up on social
9 media, and there were a lot of people that were not
10 happy that I would appear with her. But I knew how
11 mean members of my community were to me when I ran
12 for office. I didn't want to let her down, even
13 though I didn't agree to go in the first place. I
14 ended up showing up.
15 Q Okay. So you didn't know Ms. Jibril prior
16 to --
17 A No, and I still don't know Ms. Jibril.
18 Q Okay. I'm sorry. This is what you said,
19 but I'm just trying to make sure I understand it so
20 I'm sort of repeating this back to you to see if I
21 captured this. You were initially going to Boston
22 for the counterprotest?
23 A Um-hmm.
24 Q A campaign member became aware of the trip
25 and was also aware of this candidate's campaign in

(952)922-1955
Page 70
1 Boston and basically made a coordinated --

2 A Yeah. She was the only other Somali woman
3 that was trying to do the same thing, and he thought
4 that he should reach out to her and see if -- if she
5 wanted to meet because I was coming to town. And she
6 got, you know, too excited and like put an event
7 together, which happens a lot in our community.
8 Certainly happens to me a lot. And so when -- then
9 when people started saying I shouldn't go, I thought
10 that it would actually make more sense that I should
11 go because one of the things that you do in paving a
12 trail right is you don't let other people suffer the
13 pain you suffered.
14 Q In the end, that was the one speech that
15 you made in Boston. Did you end up making any other
16 presentations?
17 A No, no. I left after -- I was supposed to
18 come back. I think I left after the event. I think
19 we were on a late-night plane coming back.
20 Q Okay.
21 MR. SIGURDSON: Well, that comes to
22 the end of the questions I had on the travel. Did you
23 have any that I missed?
24 MS. ENGELHARDT: No.
25 MR. SIGURDSON: Okay. We really

(952)922-1955
Page 71
1 appreciate your time and the information that you've

2 provided us. This helps us a lot. We do want to, I
3 think, if there is a staffer who can help us
4 understand the process of accepting trips, that would
5 be very useful.
6 MS. SENSEMAN: Yep. Do you want
7 them to come in for like a formal --
8 MR. SIGURDSON: Yes.
9 MS. SENSEMAN: Okay. I'll figure
10 out who that was, exactly who that was.
11 MR. SIGURDSON: And I don't know. I
12 think we're getting very close here, and again, thank
13 you for your time. We know you have a very busy
14 schedule.
15 (Deposition concluded at 12:51 p.m.)
16
17
18
19
20
21
22
23
24
25

(952)922-1955
Page 72
1 STATE OF MINNESOTA)
)
2 COUNTY OF WRIGHT )
3 Be it known that I took the deposition of
ILHAN OMAR, on the 19th day of December, 2018, at the
4 office of the Minnesota Campaign Finance & Public
Disclosure Board, 190 Centennial Office Building,
5 658 Cedar Street, St. Paul, Minnesota;
6 That I was then and there a Notary Public in
and for the County of Wright, State of Minnesota, and
7 that by virtue thereof, I was duly authorized to
administer an oath;
8
That the witness before testifying was by me
9 duly sworn to testify the whole truth and nothing but
the truth relative to said cause;
10
That the testimony of said witness was recorded
11 in stenotype by myself and transcribed into
typewriting under my direction, and that the
12 deposition is a true record of the testimony given by
the witness to the best of my ability;
13
That the cost of the original transcript has
14 been charged to the party noticing the deposition
unless otherwise agreed upon by Counsel, and that
15 copies have been made available to all parties at the
same cost, unless otherwise agreed upon by Counsel;
16
That I am not related to any of the parties
17 hereto nor interested in the outcome of the action;
18 That the reading and signing of the deposition
by the witness and the Notice of Filing were waived.
19
Witness my hand and seal this 26th day of
20 December, 2018.
21
22
23 ___________________________
KASSIE LAHTI BEEBE
24 Court Reporter
25

(952)922-1955

72 - Rep. Ilhan Omar Depo

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Page 1

Kirby Kennedy & Associates

Kirby Kennedy & Associates

Kirby Kennedy & Associates

1 (Whereupon Exhibit Numbers 1-18 were

Kirby Kennedy & Associates

1 because she can't take that down. Oh, and we need to

Kirby Kennedy & Associates

1 Q Okay. Did you form the committee or did

Kirby Kennedy & Associates

Kirby Kennedy & Associates

1 A It was fairly fluid.

Kirby Kennedy & Associates

1 A What do you want to know?

Kirby Kennedy & Associates

1 Q Was there anything else?

Kirby Kennedy & Associates

1 MR. SIGURDSON: Do you have an

Kirby Kennedy & Associates

Kirby Kennedy & Associates

1 Q Okay. Did you ever pay Jean for her

Kirby Kennedy & Associates

Kirby Kennedy & Associates

1 Q And the other was part of the crisis

Kirby Kennedy & Associates

1 permission to talk to people on my behalf and to look

Kirby Kennedy & Associates

1 MS. ENGELHARDT: I'll call her

Kirby Kennedy & Associates

1 Q Because if you take a look at the bills

Kirby Kennedy & Associates

1 Q Does that seem familiar to you?

Kirby Kennedy & Associates

1 hire an immigration person and an accountant? Or did

Kirby Kennedy & Associates

Kirby Kennedy & Associates

Kirby Kennedy & Associates

1 public record that is possibly where some of these

Kirby Kennedy & Associates

1 Q So this is a statement from Frederick &

Kirby Kennedy & Associates

1 You weren't talking to Frederick & Rosen, or did you

Kirby Kennedy & Associates

1 Q So would you say that you personally got

Kirby Kennedy & Associates

1 the background work that needed to get done. And

Kirby Kennedy & Associates

Kirby Kennedy & Associates

1 resolved by the accounting firm. Do you know if there

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1 used him in the future, now?

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1 THE WITNESS: Um-hmm.

Kirby Kennedy & Associates

1 outlines everyone's role.

Kirby Kennedy & Associates

1 support and execute the implementing of those plans.

Kirby Kennedy & Associates

Kirby Kennedy & Associates

1 Q Okay. So you didn't need another copy, you

Kirby Kennedy & Associates

1 feel comfortable with. So this helped make it not

Kirby Kennedy & Associates