Teresa Baumann Deposition - Main Justice

Teresa Baumann Deposition - Main Justice Teresa Baumann Deposition - Main Justice

mainjustice.com
from mainjustice.com More from this publisher
19.11.2014 Views

75 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Clark about this report? A. No. Q. What did you do, if anything, with this information from Rich Murphy? Did you report it to the GCO? A. I don't remember. Q. Did you believe at the time that Martha was planning on filing an age discrimination complaint -- March 11, 2010? A. I -- I don't know. I mean, L.A. L.A. #1 wouldn't necessarily know the lingo. I think I assumed that that meant that the memo that she had sent us was her complaint. Q. Had L.A. #1 job title or job classification changed any time in this -- the late 2009, early 2010 time frame? A. Yes. Q. From what to what? A. Paralegal to Legal Assistant. The more important information was the grade level change significantly. Q. Down? A. Yes. Q. From what to what? Do you recall? A. 11 or 12 -- GS 11 or 12, to GS 7. Q. Who made that decision? A. It was made based on a performance, or a -- Performance evaluation isn't the right word. She was assessed or audited. #1 Gov. Appendix Page 138 Case 5:12-cv-04029-RGK Document CASSADY 53-1 COURT Filed REPORTING 08/15/13 Page 24 of 35 (515) 243-5154

76 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A desk audit? A. Yeah. Q. So it was based on what her level of proficiency was? A. Right. MR. CARROLL: Okay. Before we take a break, another noon break, or our first noon break, I'm going to hand you some documents. (Deposition Exhibit 42 was marked for identification.) BY MR. CARROLL: Q. I should say, before you read this thing in detail, I just first want to know, do you know whose writing this is? A. Stephanie's. Q. Okay. Did she share these notes with you when they were made? A. No. Q. Okay. That's all I need on that. (Deposition Exhibit 43 was marked for identification.) BY MR. CARROLL: Q. Who is this one? A. Whose writing? Q. Yes. A. My own. Gov. Appendix Page 139 Case 5:12-cv-04029-RGK Document CASSADY 53-1 COURT Filed REPORTING 08/15/13 Page 25 of 35 (515) 243-5154

76<br />

1<br />

2<br />

3<br />

4<br />

5<br />

6<br />

7<br />

8<br />

9<br />

10<br />

11<br />

12<br />

13<br />

14<br />

15<br />

16<br />

17<br />

18<br />

19<br />

20<br />

21<br />

22<br />

23<br />

24<br />

25<br />

Q. A desk audit?<br />

A. Yeah.<br />

Q. So it was based on what her level of proficiency<br />

was?<br />

A. Right.<br />

MR. CARROLL: Okay. Before we take a break, another<br />

noon break, or our first noon break, I'm going to hand you<br />

some documents.<br />

(<strong>Deposition</strong> Exhibit 42 was<br />

marked for identification.)<br />

BY MR. CARROLL:<br />

Q. I should say, before you read this thing in detail,<br />

I just first want to know, do you know whose writing this is?<br />

A. Stephanie's.<br />

Q. Okay. Did she share these notes with you when they<br />

were made?<br />

A. No.<br />

Q. Okay. That's all I need on that.<br />

(<strong>Deposition</strong> Exhibit 43 was<br />

marked for identification.)<br />

BY MR. CARROLL:<br />

Q. Who is this one?<br />

A. Whose writing?<br />

Q. Yes.<br />

A. My own.<br />

Gov. Appendix Page 139<br />

Case 5:12-cv-04029-RGK Document CASSADY 53-1 COURT Filed REPORTING 08/15/13 Page 25 of 35<br />

(515) 243-5154

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!