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Teresa Baumann Deposition - Main Justice

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with Jay Macklin and Tom Anderson and Kimya Jones on November<br />

2, 2010?<br />

A. No.<br />

Q. Do you know what the note means that says "She's<br />

made it very plain that she needs it"?<br />

A. No.<br />

Q. How about "ALJ/EEO/MSPB"?<br />

A. I don't know what those notes would mean.<br />

Q. The next page says "PIP due by end of year or early<br />

January." Is that your note?<br />

A. Yes.<br />

Q. The next note says, "Don't need to rate her<br />

unsuccessful, but put her on PIP." Do you know what that<br />

means?<br />

A. That would have been advice that we don't need to<br />

rate her unsuccessful before we put her on a PIP.<br />

Q. Okay. The next note says "We don't want it to look<br />

like we're picking on her. Looks like management action<br />

after management action." Do you know whose statement that<br />

was?<br />

A. I believe this is all Kimya's advice.<br />

Q. Okay. The next page says "Typically take three<br />

steps before removal. Need to be consistent with GCO policy<br />

and practice. Can't turn current proposed suspension into<br />

removal." Was there talk about going from a proposed<br />

Gov. Appendix Page 146<br />

Case 5:12-cv-04029-RGK Document CASSADY 53-1 COURT Filed REPORTING 08/15/13 Page 32 of 35<br />

(515) 243-5154

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