EEOC v. Sidley Austin Brown.

Filing 86

MOTION by Plaintiff Equal Employment Opportunity Commission to compel Deponent William White to Answer Questions Regarding his conversations with Sidley Management and for completion of his deposition (Attachments: # 1 Exhibit Exhibit A# 2 Exhibit Exhibit B# 3 Exhibit Exhibit C# 4 Exhibit Exhibit D# 5 Exhibit Exhibit E# 6 Exhibit Exhibit F# 7 Exhibit Exhibit G)(Hamilton, Deborah)

EEOC v. Sidley Austin Brown.

Doc. 86 Att. 2

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EXHIBIT B

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of the firm's retirement policy.

It was not

within the jurisdictions of my job. MS. HAMILTON: Could you mark this as White

Deposition Exhibit 14? BY MS. HAMILTON: Q. In 1999, what, if anything, have you

heard about what the firm's retirement policy was? A. I didn't hear anything about the

retirement policy. (WHEREUPON, a certain document was marked White Deposition Exhibit No. 14, for identification, as of 7/26/06.) BY MS. HAMILTON: Q. Mr. White, I'm going to ask you to take

a look at what's been marked as White Exhibit No. 14, SA 30831. A. Q. Is that your signature --

Yes. -- on the document? Whose initials appear on the document?

A. Q. A. Q.

Where?

Over --

The sort of middle to the -WBW;kmr? Yes.

Dockets.Justia.com

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A.

Those are my initials and my

secretary's initials. Q. A. Q. What was your secretary's name? Karen Reber, R-e-b-e-r. Do you recall the circumstances that

led you to write this letter? MR. CONWAY: BY THE WITNESS: A. Yes. Object to foundation.

BY MS. HAMILTON: Q. What led you to write this letter? Object to foundation --

MR. CONWAY: BY THE WITNESS: A.

This letter --- and form.

MR. CONWAY: BY THE WITNESS: A.

This letter was drafted by Mr. Delp,

who was then the current secretary of the Executive Committee, and I was asked to sign it. BY MS. HAMILTON: Q. A. Q. A. Who asked you to sign it? Pardon? Who asked you to sign it? Mr. Delp.

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Q.

What did Mr. Delp say to you when he

asked you to sign it? A. He asked me to sign it so he could put

it in his file in case there was a problem with his self-employment tax on his retirement payments. Q. At the time that you signed it, were

you aware that it was addressed to the Social Security Administration? A. Q. Yes. At the time that you signed it, did you

believe it to be a correct statement of policy? A. Q. A. Q. I had no reason to believe it wasn't. But did you believe it to be correct? Yes. At some later point in time, did you

develop the view that it was not correct? A. Based on, yeah, what I read in the

newspaper, it's not correct. Q. When you say what you read in the

newspaper, what are you referring to? A. In terms of -- I'm referring to the

newspaper article in the Tribune relating to my disqualification -- or to the disqualification of

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my attorney because of the adverse situation with Sidley's position. Q. A. Okay. At that point in time, you know, I

became aware of the fact that this was not the policy. Q. Or at least you became aware that

Sidley is now taking the position that is not the policy of the firm, correct? MR. CONWAY: answer. BY THE WITNESS: A. Yes. Object to form. Go ahead and

BY MS. HAMILTON: Q. Do you recall anything else that

Mr. Delp said to you when he asked you to sign the letter? A. Q. No. Did Mr. Delp present the draft to you

for your signature? A. but -Q. Do you know who actually wrote the I don't recall how it was given to me,

language contained in the letter?