eastern district of wisconsin milwaukee county, employee

The “attached letter” was a letter from Skelly of Mercer to Dobbert, dated October 3,
2000, which detailed the following costs for proposed pension enhancements:
Mercer’s letter to Dobbert detailed a $7,654,000 annual cost for proposed pension
enhancements. The pension enhancements listed in Mercer’s letter are the precise benefits for
which Dobbert had provided bullet-point descriptions in his memorandum, for the simple reason,
noted above, that those benefits were the only benefits included whose cost Mercer had been
asked to analyze at that time. Thus, Mercer’s October 3, 2000 letter to Dobbert does not
mention the BackDROP at all. 33
The premise of the Plaintiffs’ claim, however, is that Mercer, seeing the Dobbert
memorandum referencing a “minimal impact” for the BackDROP, juxtaposed with a reference to
cost analyses from “the actuary,” should have immediately realized that Dobbert was
misrepresenting the facts, and “spoken up” to inform the PSC members that Mercer had, in fact,
not been engaged to and, thus, had not yet performed any cost analysis for the BackDROP.
Thus, Lynne DeBruin (“DeBruin”), one of three County Board members on the PSC, testified :
33 PFF, 73-75
QBACTIVE\6280487.1 15
Case 2:06-cv-00372-CNC Filed 06/09/2008 Page 15 of 52 Document 110