eastern district of wisconsin milwaukee county, employee

6. The October 27, 2000 Pension Study Commission Hearing
The October 27, 2000 PSC hearing is the main focus of Plaintiffs’ case. The irony of
this focus is that, as the transcript of the hearing shows, there was literally no discussion
whatsoever of the BackDROP. 30
In preparation for the hearing, Dobbert had prepared a memorandum to the PSC
describing the pension enhancements that would come before them for consideration as part of
the Package. The memorandum consists largely of a series of bullet-points detailing key benefit
revisions to be included in the Package, including an increase to the multiplier for pension
benefits for employees hired after 1982; and a “retention bonus” for pre-1982 hires of 7.5% for
each year of service after January 1, 2001 to a maximum of 25%. 31
Then, in conclusion, the memorandum appends the following cryptic language, which
later became central to Dobbert’s criminal prosecution, and is again the focus of Plaintiffs’ case:
In the first sentence Dobbert first states that the BackDROP would have a “minimal impact.” In
the second sentence, Dobbert refers to an “attached letter” from “the actuary” for the “cost of
these benefit revisions,” without defining the antecedent for “these” – either the “back drop and
sick allowance pay out” benefits mentioned in the prior sentence, or the other, bullet-pointed
benefits that the body of the memorandum had described. 32
30 PFF, 69.
31 PFF, 70-71.
32 PFF, 72.
QBACTIVE\6280487.1 14
Case 2:06-cv-00372-CNC Filed 06/09/2008 Page 14 of 52 Document 110