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. 7

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EXHIBIT G

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retired? A. Q. No. Did you have any responsibility for

responding to inquiries from government agencies on behalf of Sidley & Austin? A. Q. No. Did anyone ever tell you that you could

not respond to inquiries from a government agency on behalf of Sidley & Austin? A. No. It's 5:00. We're going to go.

MR. HANNAFAN: MS. HAMILTON: finished. MR. HANNAFAN: MS. CONWAY:

Well, Mr. Hannafan, I'm not

Too bad. How much

What do you have left?

time do you have left? MS. HAMILTON: I do have some other issues To be honest with you,

that I need to cover.

Mike, I won't go more than seven hours, but I can't tell you exactly how much longer I'm going to go. MR. CONWAY: Well, I would appreciate it if You

you would tell me how much you need to cover.

can do it outside the presence of the witness if

Dockets.Justia.com

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you want. out.

Then maybe we can try to work something

MS. HAMILTON:

I'm not unwilling to work with

you, but I don't think I'm going to tell you what I need to cover. I'm not being unreasonable. If I'm

not even asking for more than seven hours. that was necessary, I certainly would.

But at

this point I'm just saying I am entitled to cover -MR. CONWAY: have left? MS. HAMILTON: exactly. As I said, I really can't say How much time do you think you

We have, you know -- I'll keep moving as

expeditiously as possible. MR. HANNAFAN: exhibits. like that? MS. HAMILTON: MR. HANNAFAN: MS. HAMILTON: MR. HANNAFAN: MS. HAMILTON: MR. HANNAFAN: There is. What rule is that? I'll get it for you. That's okay. It's in the local rules. You get seven hours even if we Is that what you're You've got quite a stack of

Is there a-seven hour rule or something

start at 5:00 in the evening?

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telling me?

You can go 5:00 until midnight? You get seven hours with any

MS. ELKIN: witness.

MR. HANNAFAN:

So if you start at 5:00, you

can go till midnight? MS. ELKIN: No, you just get seven hours

total, whether it's over one day, two days, or three days. THE WITNESS: MR. HANNAFAN: anything. I told you long ago that we were going to have to leave at 5:00. that's your problem. MS. HAMILTON: And I'm saying to you that I'm So if you're not done, How many hours have elapsed? Bill, you don't have to say

not finished, but I'm reserving the right to recall the witness if necessary. MS. ELKIN: leave. If you're going to leave, you can

But we're just going to reserve our right

for our full seven hours. MR. HANNAFAN: want. You can reserve anything you

I'm not agreeing to it, but you can reserve

anything you want. They want seven hours. What 90 percent

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of these documents have to do with their theory, I don't know. But she's going to use another hour,

because she wants seven hours, because they say that's what the rule says. So you're going to I mean, even if

take seven hours, aren't you?

it's a two-hour deposition, you want to take seven hours. I mean, that's the impression I'm getting

looking at the stack of documents you have to go through. So, nice meeting you all. We'll see you again. Maybe, maybe not. The time is

MS. HAMILTON: MR. HANNAFAN: 5:02.

(WHEREUPON, the deposition was adjourned sine die.)