Evans’ Attorney, Jack Schulz: When did you first meet Tracy Evans?
Founders Manager Dominic Ryan: 2011, 2012. We had mutual friends before working there, so …
Schulz: OK, So you knew Tracy prior to his employment at Founders?
Ryan: We met a few times, yes.
Schulz: OK, are you aware Tracy is Black?
Ryan: What do you mean by that?
Schulz: Are you aware Tracy is African-American?
Ryan: I’m not sure of his lineage so I can’t answer that.
Schulz: Alright. Are you aware that Tracy is a man of color?
Ryan: What do you mean by that?
Schulz: No? Do you know … You don’t know what it means for someone to be a white person or a Black person?
Ryan: I’m asking for clarification.
Schulz: You don’t need any. I can promise you that. We’ll keep the record as is. Someone’s skin color. A white …
Ryan: So that’s what you’re referring to?
Schulz: Yeah. Oh, yeah, yeah.
Ryan: OK. Yes, I know the difference in skin tone.
Schulz: Are you able to identify individuals by their skin tone?
Ryan: What do you mean “identify”?
Schulz: I mean have you ever looked at Tracy Evans in your entire life? Have you? That’s a … that’s a genuine question.
Founders Attorney: Objection. Argumentative.
Founders Attorney: You can answer.
Schulz: And did you ever realize that Tracy’s skin [is] Black?
Ryan: That’s not … I mean, is his skin different from mine? Yes.
Ryan: What do you mean “how”? It’s a different color.
Schulz: And what is the difference of that color?
Ryan: It’s darker.
Schulz: And that means?
Founders Attorney: Objection. Vague question.
Schulz: I mean, we could … This could be a one-sentence answer, you know. So by your … I guess your testimony is you have no idea if Tracy is a minority, if he’s African-American?
Ryan: I don’t know Tracy’s lineage, so I can’t speculate on whether he’s … if he’s from Africa or not.
Schulz: What do you mean lineage, from Africa?
Ryan: No. I mean, like, I don’t know his DNA.
Schulz: Have you ever met Black people who aren’t from Africa?
Ryan: Excuse me?
Schulz: Have you ever met a Black person born in America?
Schulz: And you were able … Have you ever met a Black person who didn’t tell you they were Black?
Ryan: Can you rephrase that?
Schulz: Is Barack Obama Black?
Founders Attorney: Objection.
Schulz: To your knowledge?
Ryan: I’ve never met Barack Obama so I don’t …
Schulz: So you don’t know if Barack Obama is Black? What about Michael Jordan? Do you know if Michael Jordan is Black?
Founders Attorney: Objection
Ryan: I’ve never met him.
Schulz: So you don’t know him? What about Kwame Kilpatrick?
Ryan: Never met him.
Schulz: To your knowledge, was Kwame Kilpatrick Black?
Ryan: I …
Schulz: You don’t know?
Ryan: I don’t know.
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