QUESTIONS FOR THE DEFENSE!!!!

[Jason]

Here are my questions! Please excuse the formatting! It's all fucked
up!

I will provide each witness with a copy of my questions when I arrive
to Mission at 6:00pm!

Questions for Sam Holliday:

Are you faithful to the Rastafarian religion?

Yes. I live in accordance with the Rastafarian way of life.

Do you follow the I-Tal diet, which is an important tenant of the
Rastafarian religion?

Yes. I follow the I-Tal diet. It is an important part of my belief
system.

How long have you been a member of the Rastafarian Group at CSU?

Not long. My name doesn’t appear on the official school club rosters.

On November 8th, after you were informed of your suspension from CSU,
did you send Dean Unamon an email explaining the Rastafarian way of
life and your beliefs? (Exhibit 5)

Yes, I sent Dean Unamon that email after I went to meet with him at
his office.

In your email, did you state that Rastafarians abstain from consuming
alcohol and meat?

Yes, I included that information in my email to the Dean.

Do you drink alcohol or eat meat?

No.

Had you contemplated not taking your prescribed medications in favor
of alternative treatments while you were attending CSU?

Yes. I considered taking Astragalus plant, which has been said to
treat TB. I researched other alternative forms of treatment, such as
the Milk Diet, as well.

How did you find out about these alternative treatments for TB?

I researched alternative treatments on the internet with other
students.

In your testimony, you stated “I contemplated throwing my isoniazid
and other pills away, and even told some of my friends about my
intentions”. Is that true?

Yes.

Have you taken the medication prescribed to you to treat your TB since
December 20th?

No, I have not.

Can any of the witnesses for the prosecution confirm that you were
taking your prescribed medications during the time you attended CSU?

No. But, I swear I did!

Did Dean Unamon, in her official letter to you informing you of your
suspension, state anything regarding Rastafarianism or cite your
beliefs as a reason you were suspended?

No.

In her official letter to you informing you of your suspension, did
Dean Unamon state that you were permanently expelled from Copper State
University?

No, she did not.

As part of the claims which you are raising against the Defendant,
included in Paragraph 19, did you state that you have no other way to
plain, adequate, or complete remedy to speedily redress your
suspension besides legal action against Dean Unamon?

Yes, that is what I am claiming.

Could you not address the issue of your suspension by simply abiding
by the court-ordered treatment agreement which you, yourself, signed?

Yes, I could….but that would violate my religious beliefs.































Questions for Marion Leverage:

Is it true that Dean Unamon was the person who made you aware of the
job opening for CSU’s Vice President of Student Life?

Yes. He told me about the job.

Is it true that thanks to Dean Unamon’s blessings and assistance you
received an interview for that position?

Yes. Afam helped me get an interview for the job.

Did Dean Unamon, ultimately, allow the Rastafarian group to exist,
despite the fact that he had the authority to prohibit the group?

Yes…

Do you consider Rastafarianism a religion?

No, I don’t. I consider Rastafarianism as more of a political and
social movement.

How well do you know the Plaintiff, Mr. Samuel Holliday?

I don’t know him very well. He has not been a member of the
Rastafarian Group for that long.

In your testimony, when speaking about Mr. Holliday you said “he
didn’t seem very committed to the Rastafarian Movement. Is this
correct?

Yes. I said that in my testimony.

Have you ever witnessed Mr. Holliday behaving in a way which is not in
accordance with the Rastafarian way of life?

Yes.

What exactly have you seen Mr. Holliday do?

On one occasion, Sam arrived to a Rastafarian Group meeting carrying a
bag of chalupas from a local Mexican fast-food restaurant and appeared
to be drunk .

What did you do in response?

I asked Sam to leave the meeting because he was being very
disrespectful and belligerent.

On November 5th, did you meet with Bert Espinoza, the President of the
Arizona Board of Regents?

Yes.

During that meeting, did you tell Mr. Espinoza that you were
interested in becoming the Dean of Copper State University?

Yes, I told him I would be interested in filling the position.

As part of your official testimony, did you say “[Dean Unamon] is
going to pay for what she did to me. Just you wait and see.”

Yes.

Is that the reason you are testifying on the Plaintiff’s behalf
tonight?

No! That is a personal matter which has nothing to do with this case.









































Questions for Sydney Mendenhall:

Is it true that many college students who claim to be Rastafarians
lose interest in the movement rather quickly?

Yes. The Rastafarian movement seems to catch the interest of young
people who are in their experimental stages. Typically, young people
abandon the Rastafarian Movement when they learn how important the I-
Tal diet is to the faith.

Is it possible to tell if someone is a real Rastafarian?

No. It is impossible to tell if someone is actually a Rastafarian or
just pretending to be a Rastafarian.

Is there any reason why an individual would pretend to be a
Rastafarian?

Yes. Some people who profess to belong to the Rastafarian Movement do
so to justify conduct that otherwise would be prohibited, such as
smoking Marijuana.

Is it possible that the Plaintiff is pretending to be a Rastafarian to
justify his failure to comply with his court-ordered TB treatment
plan?

I am unaware of anything that leads me to believe that Sam Holliday is
falsely claiming to be a Rastafarian in order to avoid complying with
the state’s TB treatment plan.

To clarify: It is impossible to tell if someone is actually a
Rastafarian or pretending, correct?

That is correct.

Has the prosecution paid you to act as a witness for them?

Yes. The prosecution is paying me £1,500 for my services.

Have you ever participated in a trial as an expert witness before?

No.

Why did you choose to act as a witness for the Prosecution in this
case?

I am interested in beginning a career as an expert witness. I thought
this would be a good opportunity for me to gain experience and build
my resume so I may obtain more lucrative assignments in the future.










Questions for Dean Afam Unamon:

Can you please state your name and occupation?

My name is Afam Unamon. I am the Dean of Copper State University, and
have served in that position since 2006.

Did you sanction the existence of a Rastafarian Group at CSU, per
Marion Leverage’s request?

Yes. I did.

Has Marion Leverage started any other student groups at CSU?

Yes. Marion Leverage started and supported the PETA Group and NCIC
(“No Class in Class”) Group. Both of these groups have been very
disruptive and have proved to be inappropriate for an academic
environment. CSU’s PETA Group pickets the school dining hall every
Wednesday, and the NCIC wishes to hold all classes outdoors because
they believe it is a better learning environment.

Before the Rastafarian Group was created, were you aware of any
Rastafarians attending CSU?

No. I do not believe there were any Rastafarians at CSU before Marion
Leverage started the group.

Do you believe that Rastafarianism is a religion?

No. I believe Rastafarianism is more of a political and social
movement. I studied Rastafarianism at Harvard.

Have you ever spoken with any of the Rastafarians at CSU?

No, I have not. However, I see them at the local Taco Bell and
McDonalds quite often.

How did you come to learn that the Plaintiff had Tuberculosis?

On October 8th, Sam made an appointment with my secretary at my office
over the phone, but neglected to mention anything about TB to her.
When he arrived to the appointment, he was wearing a mask and casually
told me of his diagnosis. I felt very uncomfortable with the situation
and having not been told this information before he came to meet with
me. I would have preferred that Sam set up a phone appointment with me
or sent me an email prior to meeting me at my office.

During that meeting, what information did the Plaintiff provide to you
regarding his situation?

Sam informed me that he had voluntarily signed a court-ordered
treatment agreement with the state. His treatment agreement required
him to wear a mask at all times when outside of his residence, to take
his prescribed medication, and to submit to regular TB testing to
monitor his condition. Furthermore, Sam provided me with a copy of a
court-order approving his treatment program.

How did you feel when you were told the conditions of the Plaintiff’s
court-ordered treatment plan?

I, personally, did not feel as though the conditions of the court-
order were sufficient. However, by the time that Sam had informed me
of his diagnosis, Arizona’s TB Control Officer and the Court had
already signed off on the program, and I was never given the
opportunity to present CSU’s concerns about the situation.

Did you give Mr. Holliday permission to return to CSU during this
meeting?

Yes. I allowed Sam to return to CSU on the condition that he followed
his court-ordered treatment plan.

How did you come to find out that the Plaintiff, Mr. Holliday, was not
acting in compliance with his court-ordered treatment agreement?

I received several phone calls from students who reported to see Sam
not wearing his mask in the dorm showers. Additionally, I also
received several phone calls stating that Sam was not taking his
prescribed medication.

Did you make the decision to suspend Mr. Holliday after receiving that
information?

No, not initially. I always gave Sam the benefit of the doubt and
treated him in a fair and balanced manner. When I learned that he had
not worn his mask in the dorm showers, I personally cleaned the
showers in response.

When did you make the decision to suspend Mr. Holliday from CSU?

I made the decision to suspend Sam on November 5th after I received
Tyler Blunt’s text message which indicated that Sam was not wearing
his mask and in the direct company of other students at a party.

Did you ever take Mr. Holliday’s religious beliefs in consideration
when making the decision to suspend him?

When Sam complained to me about his suspension on November 8th, I
asked him to prove to me that he was a Rastafarian. As I expected, Sam
could not provide me with any definitive proof. He sent me an email
later that morning containing information about Rastafarianism which
looked as though it had been copied and pasted from Wikipedia.

Did you suspend the Plaintiff due to his religious beliefs?

No, absolutely not. My decision to suspend Sam is consistent with my
obligations to CSU’s students and faculty. Sam posed a threat to other
students by not abiding by his treatment agreement, and I have the
responsibility of minimizing that threat.











Questions for Tyler Blunt:

Can you please state your name and occupation?

My name is Tyler Blunt. I am a Sophomore at Copper State University in
Phoenix, Arizona.

What is your relationship with Dean Unamon?

Dean Unamon has been very kind to me ever since I arrived at CSU in
the fall of 2007. I didn’t have a penny to my name when I enrolled at
CSU, but the Dean was nice enough to offer me a dorm room in the
Copper Canyon Residence Hall. Since then, I have kept in touch with
the Dean regularly.

Has Dean Unamon ever expressed appreciation for diversity at CSU to
you?

Yes, he has. He said he appreciates CSU’s diverse faculty and student
body.

What is your relationship with the Plaintiff, Samuel Holliday?

I live in the dorm across the hall from Sam. We see each other quite
frequently.

Were you aware that the Plaintiff, Mr. Holliday, had Tuberculosis?

Yes, I was. On October 8th, the Department of Health visited the
Copper Canyon Residence Hall and knocked on my door. They informed me
that a student living in the dorm was diagnosed with TB. Of course,
that student turned out to be Sam.

Were you aware that the Plaintiff, Mr. Holliday, was required to
follow a court-ordered treatment plan to manage his Tuberculosis?

Sort of - yeah. I heard that Sam was required to take prescription
medication and wear a protective mask.

Given that you lived in such close proximity to Mr. Holliday, did Dean
Unamon ask you to report to him on Sam’s compliance with his treatment
program?

Yes, he asked me to inform him if I noticed that Sam was not abiding
by his treatment plan.

Have you ever observed the Plaintiff taking prescription medication?

No. I have never seen Sam with prescription medication or taking
prescription medication.

Did you ever witness an incident in which Mr. Holliday was not in
compliance with the requirements of his court-ordered treatment plan?

Yes, I have. On October 27th, Sam came to my door without his mask
on. He asked if I would like to a Halloween party down the hall. I was
reluctant to go, but Sam nearly dragged me down the hall with him to
the party. After we arrived, I suspected that the students there had
been drinking, and decided to go back to my room. As I was leaving the
party, Sam called me a “bummer”, or a “downer”, or something to that
effect.

What action did you take in response to that incident? (Exhibit 2)

I sent Dean Unamon a text message that night. The text message,
essentially, said “Sam is out with a lot of people and not wearing his
mask”.

Have you ever observed the Plaintiff engaging in any other suspicious
activity in relation to his court-ordered treatment plan?

Yes. Once, I was standing in the bathroom in the dorms. Sam walked in
with a bag of pills, then entered one of the stalls. I heard the
toilet flush, and when Sam emerged, the bag of pills was empty. I’m
assuming that the bag contained Sam’s TB medication.









































Questions for Tavan Belo Reaper, M.D:

Can you please state your name and occupation?

My name is Dr. Tavan Belo Reaper. I am the Tuberculosis Control
Officer for the Arizona Department of Health Services.

How is Tuberculosis spread and contracted?

Tuberculosis, or “TB”, is a contagious disease that is spread through
the air. TB germs, known as Bacilli, are spread into the air when an
individual diagnosed with TB coughs, sneezes, or even speaks. These
germs can stay in the air for a matter of hours, depending on the
environment. An individual must only inhale a small number of Bacilli
to become infected.

Are there different types of Tuberculosis?

Yes. There is a difference between latent TB infection and active TB
disease. Individuals who are diagnosed with latent TB infection are
not contagious, as the Bacilli lie dormant within their bodies. Those
who have developed the active TB disease can spread the disease to
others. The active TB disease can be contracted if an individual does
not properly manage latent TB infection by taking prescription
medications.

What protective measures can be taken to prevent the spread of
bacteria by an individual who is diagnosed with TB?

Personal respirator masks are an important line of defense against the
spread of TB. They are often confused with surgical masks, but are
fundamentally different. Personal respirators fit tightly around the
face and are designed to capture minute airborne infectious
particles. Furthermore, individuals diagnosed with TB should
rigorously take medication prescribed by their doctor. One form of
medication that is prescribed to treat TB is isoniazid.

Have alternative forms of treatment for TB, such as those mentioned by
the Plaintiff – the Astragalus plant and the Milk Diet – been proven
to be effective treatments of TB?

Individuals who forego traditional medical treatment for TB in favor
of alternative natural treatment are putting themselves and others at
great risk. Neither of these alternative forms of treatment have,
conclusively, been shown to treat TB.

Has the Arizona Department of Health Services been able to test Mr.
Holliday to discern if the alternative forms of treatment he has
sought have been effective?

Unfortunately, no. Mr. Holliday has refused to be tested further based
on religious grounds. The only test which Samuel has taken, to date,
has been a PPD, which only tells us that he has been infected with TB.
Until we are able to take a sputum smear test, we cannot determine if
Mr. Holliday has developed active TB disease or monitor his progress.
If Mr. Holliday refuses to take this test, we must assume that he is
still infectious until it has been proven otherwise.

In your professional opinion, was the Defendant justified in
suspending Mr. Holliday from CSU to prevent him from infecting other
students?

Yes. Holliday’s failure to comply with the treatment plan is selfish
and reckless, and I wholeheartedly support Dean Unamon’s swift and
decisive suspension of Holliday.