eastern district of wisconsin milwaukee county, employee

Indeed, it was one of the central conclusions of the County’s own April 2002 Audit of the
Development and Adoption of the 2001-2004 Wage and Benefit Package (the “April 2002
Audit”) that Dobbert had failed to pass along the letter to County decisionmakers 47 :
In his deposition in July 2007, Jerome Heer (“Heer”), the Director of the County’s Department
of Audit, confirmed the conclusion of the April 2002 Audit that the County Board’s staff’s “first
indication of a cost associated with the backDROP benefit came as they gathered information for
an issue paper released in December of 2001.” Heer further had no evidence that County
supervisors had ever received the cost information in the January 16, 2001 letter. 48
For instance, DeBruin has repeatedly testified that the letter was never provided to the
County Board prior to the DC 48 contract. DeBruin testified about the significance of this
failure by Dobbert to pass on the letter:
47 PFF, 98.
48 PFF, 99-100.
Q. Now I want to go back and just complete the chronology that
you set forth in your timeline, Exhibit 108. Now I note that
you have an entry for January 16, 2001, a letter from Skelly
to Dobbert on backdrop costs, and following it is significant
because it showed that the strategy of no cost pension
enhancements was not accurate. Is that an accurate
assessment of your belief as to the significance of the failure
to cost the backdrop?
A. I wrote this, and that's my assessment of why it would be
significant to me as the finance chairman, because it would
have shown, it would have been proof that Mr. Dobbert's
assertions were not accurate, and then I would have,
QBACTIVE\6280487.1 23
Case 2:06-cv-00372-CNC Filed 06/09/2008 Page 23 of 52 Document 110