CR_Opposition to Bausch and Lomb_Motion2STRIKE_1stBrief_Filled9_2015

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Case: 15-11914 Page: 14 79, 80, 81, 82, PP. 228-31 (P. 19) This transcript deposition evidence should be taken in consideration for the sake of justice to come out and the web of many different and contradictory lies made by Appellee’s employees so, Appellant can prove ‘But-For Pre Text’ since Gordon’ testimony is important to probe bad intent at the time of the ‘insubordination’ incident. I. APPENDIX NO. 57, P. 199 (P. 13) “Appellant references page 9 of the transcript of Javier Callejas’s deposition. Although part of the Callejas deposition transcript is contained in the record below (Dkt. 88-2), that page is not in the record.” However, this page and citation demonstrate what Callejas duties and knowledge his HR job functions consisted of. J. APPENDIX NO. 69, P. 214-15 (P. 16) “Appellant references document bates numbered “CR F. 26 p. 274-275” (Job Posting) in the appendix. This document is one of the documents produced by Appellant in response to “Defendant’s Request to Produce” Appellee is also well aware of this crucial evidence since it was also used as evidence during the Florida Unemployment compensation proceeding claim and presented as well, by Appellant, to the EEOC. Finally, it is an essential key evidentiary document. K. APPENDIX NO. 72, P. 218-19 (P. 17) “Appellant references “DEF000462-463 Document responsive to Plaintiff First Request #17” in the appendix, and in the brief he states they were “Def’s sealed documents.” These are not in the record or in the Defendant’s sealed documents.” These e-mails interchanges were produced by the Appellee and its content show pre-text hence, they are to be considered as, evidence. L. APPENDIX NO. 73, P. 220 (P. 17) “Appellant references “DEF349 Sealed Exhibits Document responsive to Plaintiff’s First Request #1” in the Appendix. This document is not the record below or in the Defendant’s sealed documents”
Case: 15-11914 Page: 15 Same entry, double requested, as of letter C of Appellee’s Motion to Strike. CONCLUSION Appelle Bausch & Lomb’s Motion to strike valid evidence and swore given testimonies by appellee’s employees is without merit, admits that under certain circumstances an Appeal Court can permit a record to be supplemented on appeal, and seeks to hide the truth hence, it is a discretionary determination for this Court to deny The Defendant’s Motion to Strike or seek other remedies. DATED this 29 th day of December, 2015 Respectfully submitted by, ________________________________________________ Carlos Ramirez Pro Se Appellant
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CR_Opposition to Bausch and Lomb_Motion2STRIKE_1stBrief_Filled9_2015

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