Rep. Jason Nemes, the chair of the ad hoc impeachment committee in the Kentucky House, announced on Wednesday that there would be an “expert witness” before the committee on Thursday. The petitioners in the Cameron impeachment therefore filed the following motion:
Come the Petitioners in the Impeachment Proceedings against Rep. Robert Goforth and Attorney General Cameron, by counsel, and request the following relief from this Committee:
That counsel for Petitioners be permitted to ask questions of the witness appearing before the Committee today, and other witnesses moving forward; or, in the alternative, that the Committee ask the following questions of today’s witness and allow opportunity for the Petitioners or counsel to address questions to future witnesses before the Committee.
Should this Committee vote and determine that Petitioners’ counsel may not directly question the witness, the following questions are proposed for the Committee to ask:
- Was the motion to recuse Chairperson Nemes correctly handled by him, without input from the Committee
- Should the Impeachment Committee vote on the motion to recuse Jason Nemes
- Is there a Committee vote in the records on the motions previously addressed by the Committee
- Who voted on the motions before the Committee
- Should Nemes have a vote in the motion to recuse him for bias or conflict of interest
- Have you reviewed the documents in the record for any evidence of bias on the Chairperson’s part, or do you plan to do so? Do the documents provide evidence of bias or conflict of interest? Why or why not
- Are legislators considered statewide elected officials under Kentucky law
- Have impeachment actions been dismissed on jurisdictional grounds (rather than facial deficiencies) in the past. If so, state which by name/date
- Have you read the petitions and supporting documents
- Under Kentucky law, may a party designate a representative to speak for him
- What statute prohibits the Grand Jurors from designating their counsel as a spokesperson for them
- Have you reviewed the Grand Jurors’ designations held by their attorney for validity
- Is impeachment separate from any circuit court action, civil or criminal
- Who retained you as a witness
- Who signed your contract or letter of engagement or fee agreement
- What are you being paid to appear here today
- Who is paying you
- In impeachment proceedings, does Petitioner or counsel for the Petitioner get to speak/participate/question witnesses. If your answer is in the negative, cite to Kentucky law that denies that right
- Did you provide an oral or written opinion to anyone on the Committee or counsel for the Committee before appearing today? If so, please provide a copy
- Will you be providing a written summation or legal opinion as an expert witness following your appearance today
- For each opinion you give today, please give the state statute or regulation supporting your opinion and list any relevant caselaw in support
- As there is no Response from Rep. Goforth in the record, how can you determine his position on any of the issues detailed in that Petition or whether the Petition has merit
- Is it possible that there are any facts which may not be contained in the Petition which would change your opinion
- Why didn’t you ask to speak to Petitioners or their counsel
Respectfully submitted,
Anna Stewart Whites
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