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. 3

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chance to finish your question. MS. HAMILTON: But you know what, if I want a

chance to finish my question or if I need the witness to wait, I'll -MR. HANNAFAN: so. MS. HAMILTON: you, Mike. MR. HANNAFAN: MS. HAMILTON: back? (WHEREUPON, the record was read by the reporter.) BY THE WITNESS: A. Did I keep a copy for myself? Yes. Then you won't get it. Could you read the question I don't want your help. Thank If you don't want my help, say

BY MS. HAMILTON: Q. A. Q. Did you provide a copy for anyone else? No. When did you first learn that the

statement in the letter might be inaccurate? A. I believe it was last February. I got a phone call from -Wait, wait. Bill, you've answered the I was

in Florida.

MR. CONWAY:

MR. HANNAFAN:

Dockets.Justia.com

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question.

She asked you when. You're getting into privileged

MR. CONWAY: issues here.

MR. HANNAFAN: to object -BY THE WITNESS: A.

You have to give him a chance

February of last year.

BY MS. HAMILTON: Q. And how did you -'06 or '05?

MR. HANNAFAN: BY THE WITNESS: A. '06.

MR. HANNAFAN: BY THE WITNESS: A.

This year?

This year. February of '06?

MR. HANNAFAN: BY THE WITNESS: A. Correct.

BY MS. HAMILTON: Q. How did you learn that? How? I'm concerned you're So is your

MR. CONWAY:

getting into a privileged area here.

question who did he have that conversation with? MS. HAMILTON: Right.

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MR. CONWAY:

Okay.

So that's the question,

who did you have a conversation with. BY THE WITNESS: A. I had a conversation -And just identify the person

MR. CONWAY: and -BY THE WITNESS: A.

Mr. Bergen and Mr. Conlon.

BY MS. HAMILTON: Q. What was said during the conversation? I'll object.

MR. CONWAY: BY THE WITNESS: A. What?

BY MS. HAMILTON: Q. What was said in the conversation? I'll object on the grounds of

MR. CONWAY: privilege.

MR. HANNAFAN:

He's making an objection on So I'm going to And if counsel

the grounds of privilege.

instruct you not to answer that.

for the EEOC disagrees, then they will have to seek a ruling from Judge Zagel. answer it now unless -THE WITNESS: I won't. You should not

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MR. HANNAFAN:

-- unless you're told

otherwise by -- possibly by the Court. BY MS. HAMILTON: Q. Other than any conversation in which

Mr. Conlon participated, did you and Mr. Bergen have any discussion regarding the letter? A. Q. No. Other than that conversation in

February with Mr. Bergen and Mr. Conlon, did you have any discussion with anyone about the letter other than your attorney, Mr. Hannafan? MR. HANNAFAN: BY THE WITNESS: A. No. That's yes or no.

BY MS. HAMILTON: Q. Why do you recall the circumstances

that led to the drafting of this letter? MR. CONWAY: THE WITNESS: MR. CONWAY: BY THE WITNESS: A. Basically, if you look at the bottom of Object to the form. Can I answer that? Yes.

the letter in the fine print -MR. HANNAFAN: Bottom left-hand corner.