Teresa Baumann Deposition - Main Justice
Teresa Baumann Deposition - Main Justice
Teresa Baumann Deposition - Main Justice
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Q. Whose is it?<br />
A. Mine.<br />
Q. Do you know what this memorializes?<br />
A. It's like a conversation that I had with Jay<br />
Macklin, Tom Anderson, and Kimya Jones, or perhaps I had -- I<br />
guess I don't know. It looks like Jay, Tom, and Kimya met,<br />
and someone was conveying the information from their meeting<br />
to me. I don't know if it would have been Stephanie or<br />
Kimya.<br />
Q. Are Jay, Tom, and Kimya management's lawyers?<br />
A. Yes.<br />
Q. Who sent several letters? Do you know? I'm at the<br />
top here (indicating)?<br />
A. I don't know.<br />
Q. Who made the FOIA request?<br />
A. I don't know.<br />
Q. The "Suggestion/Direction" says, "Make sure we look<br />
very reasonable, issue 14-day suspension now." Do you know<br />
what that was about?<br />
A. Well, something regarding the 14-day suspension, but<br />
I don't know.<br />
Q. Whose idea was it to "make sure that we" -- is that<br />
management -- "look very reasonable"?<br />
A. The "we" would be management, yes.<br />
Q. And so I'm clear, do you recall having a discussion<br />
Gov. Appendix Page 145<br />
Case 5:12-cv-04029-RGK Document CASSADY 53-1 COURT Filed REPORTING 08/15/13 Page 31 of 35<br />
(515) 243-5154
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