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Teresa Baumann Deposition - Main Justice

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always swipe?<br />

A. No.<br />

Q. If you walk in with two or three other people,<br />

somebody swipes, and everybody comes in; right?<br />

A. Right.<br />

Q. Were you aware of that fact when the door codes were<br />

pulled?<br />

A. Yes.<br />

Q. How were you going to control for the possibility<br />

that Martha might be coming in with other people?<br />

A. I think that was a problem we found, that the door<br />

code information wasn't all that useful, because it was only<br />

partial information.<br />

Q. In the next sentence in Exhibit 40, it says, "During<br />

my second week in the office, on January 25, 2010, USA Rose<br />

began retrieving data to determine if there was any truth to<br />

employees' reports that Ms. Fagg was often absent from the<br />

office." What does "often absent" mean?<br />

A. I suppose it means more than once or twice without<br />

permission.<br />

Q. Well, did you write this document?<br />

A. I did.<br />

Q. What did "often absent" mean when you wrote it?<br />

A. That it means more than three times a week.<br />

Q. And it was your understanding that Ms. Rose<br />

Gov. Appendix Page 129<br />

Case 5:12-cv-04029-RGK Document CASSADY 53-1 COURT Filed REPORTING 08/15/13 Page 15 of 35<br />

(515) 243-5154

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