One of Gardner’s staffers, after consulting with her, also told a judge that Tisaby had taken no notes during his interview of the woman, even though he had taken notes, and Gardner “was seated at his side during the entirety of the interview,” the indictment says.

Gardner only turned over her notes and Tisaby’s notes after defense lawyers obtained a video of Tisaby’s interview of the woman.

The indictment also says Tisaby lied about whether he searched his laptop for notes during a break in his deposition, and when he said he didn’t talk to Gardner during that lunch break. The two spoke seven times, including a conference call with Tisaby, Gardner and an investigator that lasted 16 minutes and another two that lasted 11 minutes and five minutes, the indictment says. The pair spoke for a total of 34 minutes, it says, and Gardner never corrected Tisaby’s lies about speaking with her during the second half of the deposition.

The indictment says Tisaby lied when he claimed that he hadn’t asked a single question of the woman, when he asked more than 150 detailed questions.