Jones v. St. Clair County: Key Deposition Questions
Part of Documented Incident
Deputy Marc King OWI Arrest and Cover-Up
November 6, 2022
Overview
Analysis
Cross-Examination Issue Clusters
Key questions and issue clusters for legal proceedings or oversight hearings.
Cluster 1: Why No Recusal?
Core Question: Why did Mat King remain involved in a matter concerning his own brother?
Follow-up Questions:
“When were you first notified of your brother’s arrest?”
“At that moment, did you consider recusing yourself?”
“What, if any, policy required you to recuse yourself?”
“If no policy existed, why not?”
“Do you believe you could be impartial in a matter involving your brother?”
“If a citizen were in your position, would you expect them to step back?”
“What actions, if any, did you take after being notified?”
“Did you discuss the matter with anyone in your office?”
“Did you give any direction regarding how the matter should be handled?”
“Do you understand why the public might perceive this as a conflict of interest?”
Cluster 2: Why Deleted Texts?
Core Question: Why were text messages deleted, and what did they contain?
For Matthew Pohl :
“Did you have text message communications regarding the November 2022 arrest?”
“Do those messages still exist?”
“If not, what happened to them?”
“When were they deleted?”
“Why were they deleted?”
“Did anyone ask you to delete them?”
“Were you aware at the time that they might be relevant to legal proceedings?”
“What did the messages discuss?”
“Who were the messages with?”
“Do you understand that deleting evidence can create legal liability?”
For Damon Duva :
“You testified that text messages are ’no longer available.’ What does that mean?”
“Were they deleted?”
“By whom?”
“When?”
“What was discussed in those messages?”
“Did anyone instruct you to delete messages?”
Cluster 3: Why No Independent Investigation?
Core Question: Why was this matter not referred to an external agency?
Questions:
“Is it standard practice to investigate internally when an officer is arrested?”
“Are there circumstances that would trigger external investigation?”
“Would a family relationship to command staff be such a circumstance?”
“Why was Michigan State Police not contacted?”
“Why was a neighboring sheriff’s office not contacted?”
“Who made the decision to handle this internally?”
“Were any alternatives considered?”
“Do you have agreements with external agencies for such situations?”
“If you do, why weren’t they invoked?”
“Do you believe the internal handling was appropriate given the circumstances?”
Cluster 4: Pattern and Practice
Core Question: Is this an isolated incident or part of a pattern?
Questions:
“How many times has a Sheriff’s Office employee been arrested in the past 10 years?”
“In each case, how was the matter handled?”
“Were any referred to external agencies?”
“What is your policy for internal investigations?”
“Have other conflicts of interest arisen?”
“How were those handled?”
“Has evidence ever been deleted in other matters?”
Cluster 5: Consequences and Reform
Core Question: What happens now?
Questions:
“What consequences, if any, have resulted from these events?”
“Have any policies been changed as a result?”
“If not, why not?”
“Will you commit to implementing recusal policies?”
“Will you commit to evidence retention policies?”
“Will you commit to external investigation requirements?”
“What assurance can you provide that this won’t happen again?”
Strategic Notes
For each question cluster:
- Start broad, then narrow
- Get commitments on record
- Follow up on inconsistencies
- Document evasions or refusals
- Compare testimony to documents
Key documents to reference:
- Sheriff Mat King Deposition
- Captain Matthew Pohl Deposition (deleted texts admission)
- Deputy Duva Transcripts (missing messages admission)
- Any written policies (or lack thereof)