EEOC v. Blockbuster Inc.

Filing 105

RESPONSE in Opposition re 100 MOTION for Summary Judgment and Brief in Support of Summary Judgment filed by EEOC. Replies due by 4/19/2010. (Attachments: # 1 Exhibit Exb. 1, # 2 Exhibit Exb. 2, # 3 Exhibit Exb. 3, # 4 Exhibit Exb. 4, # 5 Exhibit Exb. 5, # 6 Exhibit Exb. 6, # 7 Exhibit Exb. 7, # 8 Exhibit Exb. 8, # 9 Exhibit Exb. 9, # 10 Exhibit Exb. 10, # 11 Exhibit Exb. 11, # 12 Exhibit Exb. 12, # 13 Exhibit Exb. 13, # 14 Exhibit Exb. 14, # 15 Exhibit Exb. 15, # 16 Exhibit Exb. 16, # 17 Exhibit Exb. 17, # 18 Exhibit Exb. 18, # 19 Exhibit Exb. 19, # 20 Exhibit Exb. 20, # 21 Exhibit Exb. 21, # 22 Exhibit Exb. 22, # 23 Exhibit Exb. 23, # 24 Exhibit Exb. 24, # 25 Exhibit Exb. 25, # 26 Exhibit Exb. 27, # 27 Exhibit Exb. 28, # 28 Exhibit Exb. 29)(Phillips, Ronald)

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

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EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

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Plaintiff,
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v.
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BLOCKBUSTER, INC.,
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Defendant.

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) Case No. 8:07-CV-02612
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****************************************
DEPOSITION OF
JUNE MARIE DAVIS
SEPTEMBER 17, 2008
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On the 17th day of September, 2008, at 1:09 p.m.,

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the oral deposition of the above-named witness was taken

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at the instance of the Plaintiff before Lezley Cull,

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Certified Shorthand Reporter in and for the State of

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Texas, at the offices of Morgan, Lewis & Bockius, LLP,

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1717 Main Street, Suite 3200, in the City of Dallas,

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County of Dallas, State of Texas, pursuant to Notice and

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the agreement hereinafter set forth.

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What was the -- what topics were discussed on
the sexual harassment training at Venturi?
A. What constitutes sexual harassment and how to
handle if -- if someone comes to you with an allegation
of sexual harassment, how to handle that, what steps to
be taken.
Q. And what steps -- what steps were you told
that needed to be taken if someone came to you with a
claim of sexual harassment?
A. Have a one-on-one with the associate who made
the allegation, hear their side of the story, find out
what other parties are involved. If the parties were
employees of my organization, I would talk to them. But
if they were employees of another -- of a customer, then
that customer would handle it.
Q. And if they were employees of a customer, were
you instructed to be involved in any way in the
investigation of that complaint?
A. Initially to set up the meetings. But after
those happened, no, I was not very much involved.
Q. And were you given any reason why you should
not be involved in those meetings?
A. Not that I recall.
Q. Now, that training was given to you while you
were at Venturi?

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A. Yes.
Q. And I think you said you took it, what,
yearly -A. Yes.
Q. -- beginning in 2004?
A. Yes. Whatever year CBS acquired Venturi is
when we started that every year.
Q. How long were you employed at Venturi?
A. Almost ten years.
Q. When did you begin?
A. September of 1997.
Q. And what position were you employed in in
September of 1997?
A. Staffing manager.
Q. And what were your responsibilities and duties
as a staffing manager?
A. Oversee the other staffing representatives,
take job orders from clients, find associates for the
jobs, and maintain contact with the clients and
associates to ensure that they were all satisfied.
Q. And what was the business of Venturi when you
joined in September 1997?
A. Office clerical and some light industrial.
Q. When you mean office clerical and some light
industrial, what did it do with respect to those

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categories?
A. Like secretarial placements, data entry,
customer service, accounting, warehouse.
Q. And when did you leave Venturi?
A. In September of 2007.
Q. And why did you leave Venturi?
A. Better opportunity.
Q. And where did you go once you left Venturi?
A. Pro Staff.
Q. And is that where you are employed today?
A. Correct.
Q. And what's your position at Pro Staff?
A. Talent manager.
Q. And what are your duties and responsibilities
as a talent manager?
A. Recruit employees to meet the needs of our
clients and employee development.
Q. Did you hold any other positions at Venturi
other than staffing manager?
A. Yes. I left Venturi for a brief period of
time and went to another company for seven months and
then was rehired at Venturi to handle the Blockbuster
account. And my title then was on-site project manager.
Q. When did you leave Venturi temporarily?
A. I believe it was in May of 2000 maybe -- of

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2000, yes.
Q. And why did you leave Venturi at that time?
A. I had a better opportunity.
Q. And where did you go?
A. To All Medical Personnel.
Q. And what did you do at All Medical Personnel?
A. I was a regional director overseeing the
recruiting and the recruiters in the medical field.
Q. Now, you said that you stayed there for about
seven months?
A. Uh-huh.
Q. Why did you leave All Medical?
A. Venturi had approached me about coming back to
work as they had been on the Blockbuster corporate
account downtown. So I interviewed for that position
and was hired to handle Blockbuster. I was on-site at
Blockbuster to handle their corporate staffing needs.
Q. And when you say you were on-site at
Blockbuster, you were physically at Blockbuster's
corporate offices here in Dallas?
A. Correct.
Q. And that would have been in 2000 when you came
back, May of 2000?
A. It was February of 2001 when I went to
Blockbuster.

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Q. So when did you come back to Venturi?
A. February of 2001.
Q. And what were your responsibilities when you
came back in February 2001 as on-site project manager
for Blockbuster?
A. To handle any temporary requisitions that
Blockbuster needed filled, to recruit the people, assign
the people, and work with the managers to make sure that
they were satisfied with the work that was being done.
Q. And was that all for Blockbuster's corporate
office?
A. Yes.
Q. And how long did you remain an on-site project
manager for Blockbuster's corporate office?
A. I think it was September 2007 -- no. Wait,
wait. I'm sorry.
September 2005.
Q. And then what happened in September of 2005?
A. Venturi/CBS cancelled the contract with
Blockbuster and I was reassigned as a branch manager for
Venturi.
Q. And what were your duties and responsibilities
as a branch manager?
A. To oversee the operations managers and ensure
that we recruited, retained, and took care of our

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client's temporary needs.
Q. And where were you physically located as
Venturi's branch manager?
A. In Addison, Texas.
Q. Now, during the period between February 2001
and September of 2005, was there some point in time
where you became responsible for things at Blockbuster
beyond the corporate office?
A. Yes.
Q. When did that happen?
A. I don't recall the exact dates. But we
started getting requisitions for regional assistants in
cities throughout the country. I would -- 2003, I'm
thinking, but I can't say for sure. So I worked with
other staffing companies if Venturi and CBS didn't have
an office there to ensure those jobs were filled.
Q. And when you say you worked with other
staffing companies, were you responsible for identifying
and locating those staffing companies in situations
where Venturi did not have an office?
A. Yes, I was.
Q. And how did you go about locating staffing
companies to use in locations where Venturi did not have
an office?
A. Typically, I would ask associates that I knew

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internal with the company if they had any
recommendations of anyone they had worked with. If I
could get referrals that way, then I would talk to them.
If not, then I would go on-line to the American Staffing
Association website and look and see what staffing firms
were registered there. And then I would just start
calling and talking to them.
Q. And when you would call and talk to them, what
type of information would you be asking about or
requesting?
A. How long they had been in business, what type
of staff they provided, what kind of testing they
provided. And then I would outline for them the terms
of the contract that we had with Blockbuster which we
expected them to adhere to. And then if it was a -- so
it was mainly by phone and e-mail. And then if it was
identified we would work together, we established -signed a partnership agreement with those firms.
Q. Would you ask them for references for
companies that they had worked with or provided staffing
with before?
A. Not on every single case, but sometimes we
did.
Q. And why would you ask sometimes and not ask
other times?

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A. If we had a referral from someone who had
worked with them before, we may not have asked. Because
in our industry, there's a lot of people who know each
other and move around. So that was usually our best way
to find other firms.
Q. Did you do any checking of public records of
any kind to determine, for example, if there were any
lawsuits pending against a staffing company?
A. No.
Q. Did you check to see if there were any, for
example, tax liens or things of that nature pending
against the company?
A. No.
Q. Did you check out -- would you check out any
of the principals in the company to see -- to learn
anything about their backgrounds?
A. No.
Q. At some point in time between February 2001
and September of 2005 when you were working as a
Blockbuster on-site project manager, were you asked to
place people in positions other than -- I think you
mentioned you started being requested to place people in
regional offices.
A. Right.
Q. Were you requested to do any other types of

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A. She's not with Venturi.
Q. Do you know where she's located?
A. She's a teacher in Dallas.
Q. Did you ever visit the Gaithersburg
facility -- Blockbuster's Gaithersburg facility?
A. No.
Q. Who was your primary contact there? Was it
Linc Barrett?
A. With Blockbuster, yes, Linc, yes.
Q. How often -- let's say between December of '04
and August of '05, how often did you interact with
Mr. Barrett?
A. Initially, probably several times a week. And
once the relationship started working, maybe every two
weeks to a month.
Q. And what types of things were you interacting
with him about?
A. Just their head count, how the process was
going. It was a new facility. Was he pleased with the
staff that he got and was he pleased with the service
that he was receiving from Express Personnel.
Q. And I guess you said initially, it was several
times a week.
For how long of a period of time did you meet
with him -- or talk with him -- I'm sorry -- talk with

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him several times a week?
A. I don't know for sure.
Q. And then it went to how many times a week,
approximately?
A. Well, then it went to probably every few
weeks.
Q. And do you recall when it went to every few
weeks?
A. No. Once the distribution got up and running,
but I couldn't tell you exactly, no, ma'am.
Q. During the time that you were talking to
Mr. Barrett several times a week, were there any
problems that he identified in terms of the staff that
were being placed at the facility?
A. There were sometimes occasional problems with
any staffing that maybe the person -- I can't say
specifically what the situation is, no.
Q. Did you have any interaction with the staff
that was placed at the facility by Express? Did you
ever talk with any of them, meet with any of them?
A. No.
Q. Did you interact with any other Blockbuster
employees during the period of November 2004 to
September 2005 related to the Gaithersburg facility?
A. Yes.

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Q. Who else did you interact with?
A. Scott Collen, Leonard Robinson occasionally.
But Scott was the main -- he was the regional manager
over that facility.
Q. And who was Leonard Robinson?
A. He was also a regional manager. He was not
over that facility. But at times, I think he helped out
there.
Q. And what types of things would cause you to
interact with Scott Collen?
A. To make sure that he felt like the staff he
was getting was good. And if there was any specific
problems, we would bring it to his attention.
Q. Now, during the course of December -- November
2004 to September 2005, who were you interacting with,
if anybody, at Express?
A. Cinnie Brown.
Q. And how often would you talk with Ms. Brown or
e-mail with Ms. Brown?
A. We received daily e-mails, and phone
conversations maybe every week to two weeks.
Q. Did you have any interaction with Mr. Lenear
once the partnership agreement was signed?
A. Occasionally.
Q. And what would cause you to interact with

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Mr. Lenear?
A. If Cinnie was not available.
Q. Do you recall how many times you interacted
with him during this same period of November 2004 to
September 2005?
A. No.
Q. And would you interact with him on the same
types of issues that you interacted with Cinnie Brown on
or would they be different issues?
A. I had a more close relationship with her. So
him, I -- unless there was a real problem that needed to
be addressed, I really -- I don't recall.
Q. Did you ever have any concerns about
Cinnie Brown?
A. None.
Q. Did you ever have any concerns about
Mr. Lenear?
A. No.
Q. Now, you indicated I guess that you would have
daily e-mails with Cinnie Brown.
A. Correct.
Q. Generally, what would those e-mails be about?
A. About the staff that was working. We needed a
daily head count report, how many people were working
each day. And if there were changes in the personnel,

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Q. How often did you talk with Mr. Collen during
the period of November 2004 to September 2005?
A. Probably about every two weeks.
Q. And what types of things would you talk about
with Mr. Collen when you talked with him every two
weeks?
A. We would talk about all his distribution
centers that he was over, how -- you know, how they were
being productive, how it was working for Blockbuster,
and the partnerships that we had established, how he was
feeling about the relationships with the staffing
providers.
Q. Did Mr. Collen ever express any concern about
Express Personnel?
A. No.
Q. Ms. Davis, at some point in time, did you
learn that there were complaints by workers that had
been placed at the facility by Express Personnel?
A. Yes.
Q. What types of complaints?
A. They were working a lot of hours, there were
some sexual innuendos made by several of the leads and
managers.
Can you restate the question?
MS. SPEIGHTS: Can you just read it back

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for me?

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A. Yes. Probably in the summer.
May I get some water?
Q. Sure, absolutely.
A. Okay.
Q. In terms of the complaints about what I would
call the improper touching, when did you first hear
about those complaints?
A. I don't remember specifically.
Q. The DVD issue, do you recall when you heard
about that?
A. Yes.
Q. And the sexual innuendos that you said may be
made by leads and mangers, what managers are you
referring to?
A. There was one that went by the name of Taj,
T-a-j. I think his name was Thomas Jefferson, I
believe. And there were a few comments about the DC
manager, Linc Barrett.
Q. Now, you also mentioned leads.
Which leads?
A. Taj was one of the leads.
Q. And you heard about sexual innuendo coming
from Lincoln Barrett, as well?
A. From Linc Barrett, yes.
Q. And when did you first hear about those

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complaints?
A. Sometime in 2005, but I can't recall exactly.
Q. Was it closer to the beginning of 2005 or
closer to the end of the relationship?
A. Probably around the middle, maybe in the -- it
seems like maybe the spring.
Q. And the issue of working a lot of hours, when
did you hear about that?
A. That was -- I don't have records. I'm
thinking probably the summer is when it got very busy.
Q. When you heard about the -- did you do
anything when you heard about the complaints of sexual
innuendo around you think maybe the spring of 2005?
A. Yes.
Q. What did you do?
A. I spoke to Scott Collen about it.
Q. And what did you tell him?
A. What the allegations were. And I -- I don't
remember specifically who said what to whom.
Q. And did Mr. Collen say anything or do anything
in response to your telling him about these complaints?
A. I think he told me just to keep my ears open
and if I heard anything else, to let him know.
Q. And did you ever get back to Mr. Collen
concerning these types of complaints of sexual innuendo

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THE REPORTER: Sure.
(Record read.)
A. They worked them hard, you know, a lot of
overtime. Some of them worked 60-plus hours a week.
And there was some -- some rumblings of some
inappropriate language being used.
Q. (BY MS. SPEIGHTS) Anything else?
A. There was an allegation by one of them that
one of the other employees had messed with her stacks of
DVDs, but I really don't recall all the specifics.
Q. Did you ever hear any complaints that the
leads had improperly touched some of the workers?
A. Yes.
Q. Did you ever hear any complaints that some of
the workers thought they were being discriminated
against because of their race or national origin?
A. I heard that towards the very end of the
agreement. I heard that they felt like they weren't
being treated fairly, but I never heard anything about
origin or race involved.
Q. Not until near the end of the -- this period?
A. Right.
Q. And we're talking about -- near the end, we're
talking about closer to, what, September 2005?

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after that first contact with him?
A. Yes.
Q. When did you get back in touch with him?
A. I don't remember the date.
Q. And why did you get back in touch with him?
A. Because it had escalated where other people
were making other complaints and it seemed like there
could be some problems with the supervisor -- the
manager and the lead.
Q. And do you recall when you contacted
Mr. Collen about that issue again?
A. Not exactly, no.
Q. Now, how did you learn about the complaints?
A. From Cinnie Brown.
Q. And do you have any knowledge as to when
Ms. Brown first learned about the complaints about
sexual -- the sexual innuendo complaints?
A. I don't remember the date.
Q. And how did Ms. Brown learn about the
complaints, do you know?
A. From the associates. People would quit and
tell her things that they felt like was inappropriate.
Q. Now, do you recall any of the names of the
staff workers who made complaints of sexual innuendo?
A. I remember the name Say Wing. I couldn't

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really tell you the other -- somebody Gonzales. I just
don't recall their names.
Q. Other than speaking to Mr. Collen about these
complaints of sexual innuendo, did you do anything else
about those complaints?
A. I remember initially, I contacted Blockbuster
HR and spoke to Jennifer Hilman.
Q. Jennifer who?
A. I believe her last name was H-i-l-m-a-n.
Q. And when did you speak to Jennifer Hilman?
A. Sometime in all that process. I can't tell
you exactly. But she basically referred me to talk to
Mr. Collen.
Q. So would it have been around the same time
that you -- that you spoke to Mr. Collen about the
complaints?
A. Probably a week before maybe, a few days
before.
Q. The improper touching, what did you do, if
anything, when you heard about complaints of improper
touching?
A. Just notified Scott Barrett -- I mean,
Scott Collen.
Q. Do you recall when you notified Mr. Collen of
those complaints?

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A. No.
Q. Did you talk with Blockbuster HR about those
complaints?
A. That's Jennifer Hilman I spoke to.
Q. Now, would that have been a separate call to
Ms. Hilman -- a call separate from your call to her
about the sexual innuendo?
A. I don't recall.
Q. Do you recall how many times you spoke to
Ms. Hilman about complaints from workers at this center?
A. No.
Q. Do you recall how many times you spoke to
Mr. Collen about complaints at the center?
A. A number of times, but I couldn't tell you how
many.
Q. Ms. Davis, I think you mentioned that you only
used agencies like Express Personnel to staff
Blockbuster facilities when you didn't have an office in
the area that you needed to staff; is that right?
A. Yes.
Q. So there were distribution centers where
Venturi staffed -A. Yes.
Q. -- workers?
A. Yes.

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Q. When Venturi places workers -- or hires people
to put in these temporary positions at the Blockbuster
facilities, does Venturi talk to them about EEO, Equal
Employment Opportunity?
A. It's in the handbook. And we had an EEO
policy, harassment policy. And they would read and sign
off on all of those.
Q. And were they given any type of training or
orientation on Equal Employment Opportunity when they
joined Venturi?
A. No.
Q. Did Venturi have in place methods for the
workers that were placed at the facilities, staff
workers, to complain about Equal Employment Opportunity
or sexual harassment?
A. Yes.
Q. And what was in place for the workers to make
those complaints?
A. That they would notify the -- they would -the workers would notify me as the project manager of
any issues. We had a very open door policy.
Q. And then what would happen after they notified
you?
A. Then I would talk to the distribution center
manager.

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Q. And was there a procedure in place at Venturi
for investigating -A. Yes.
Q. -- the complaints of those workers?
A. Yes.
Q. And what was that procedure?
A. To sit down one on one and talk with the
worker individually. If the workers were Venturi, the
Venturi people would talk to them. If they were
Blockbuster employees, we would not speak with the
Blockbuster employees.
Q. And did Venturi have a procedure in place or
policy in place for notifying Blockbuster about equal
opportunity complaints or sexual harassment complaints
when they were made by workers who were at the
facilities?
A. There was not a specific procedure, no.
Q. And if the complaining party was a Venturi
employee and an investigation was conducted, would a
Blockbuster employee also participate in those
investigations?
A. Not with Venturi, but with Blockbuster.
Q. What do you mean by "not with Venturi"?
A. We would not ever speak to the Blockbuster
employees. That would be -- Blockbuster would deal with

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them.
Q. And what about the Venturi employees, would
Blockbuster speak with Venturi employees if there was a
sexual -- during the course of an investigation of
sexual harassment, for example?
MR. PHILLIPS: Object to the foundation.
MS. MOORE: I'm going to object to the
form.
I'm not sure she's following you.
Q. (BY MS. SPEIGHTS) You can answer.
A. Would you repeat the question?
Q. Yes.
In those instances where Venturi was actually
providing the workers for a Blockbuster facility, if a
Venturi employee had a claim of sexual harassment or
discrimination and an investigation was conducted, who
conducted the investigation?
A. Venturi conducted the investigation with the
Venturi employees and Blockbuster conducted the
investigation on the Blockbuster employees.
(Exhibit No. 2 marked.)
Q. (BY MS. SPEIGHTS) Ms. Davis, do you recall a
staff person at the Blockbuster facility by the name of
Michelle Despertt?
A. I've heard the name, but I couldn't tell you

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what happened with her.
Q. Were you involved in any investigation of any
complaints by Michelle Despertt?
A. Not -- not specifically myself.
Q. Do you recognize Davis Exhibit 2?
A. Yes.
Q. What is it?
A. What was the question?
Q. What is Exhibit 2?
A. It's an e-mail that I sent to Scott Collen
with Blockbuster stating that Cinnie Brown is going to
talk to her associates after hours.
Q. Do you know why Ms. Brown was going to talk
with her associates after -- after hours at this point
in time?
A. Because they were complaining about the
working conditions, that they were working so many hours
and some of the inappropriate comments that had been
made to them.
Q. Now, at this point in time, March 8, 2005, had
you talked with Mr. Collen about any complaints of
employees prior to this e-mail?
A. Yes. I think that's what generated the
e-mail.
Q. When did you talk with him?

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A. Prior to March 8th, but I don't recall the
date.
Q. Do you recall how -- how much before
March 8th, 2005 you spoke with him about that?
A. No.
Q. It says here that Ms. Brown was going to give
a report back on Friday.
Did she give a report back to you on Friday?
A. I don't recall. This has been three years
ago, so I don't recall. She was usually very good at
doing what she said she was going to do. But I don't
remember.
Q. You don't recall anything about her getting
back to you shortly after -A. She did, but I can't tell you if it was on
Friday.
MS. MOORE: You're doing great.
THE WITNESS: Sorry.
MS. MOORE: But you -- she's trying to
think of her questions and form them and say them. And
it's hard as a lawyer to do that. So let her finish
them and then you answer her.
THE WITNESS: All right.
Q. (BY MS. SPEIGHTS) Even if she didn't get back
to you on Friday, do you recall if she got back to you

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MS. SPEIGHTS: If you could mark this as
Davis 4.
THE REPORTER: Okay.
(Exhibit No. 4 marked.)
Q. (BY MS. SPEIGHTS) Ms. Davis, have you had a
chance to look at Davis Exhibit 4?
A. Yes.
Q. Can you tell me what Davis Exhibit 4 is?
A. It's a follow-up e-mail from myself to
Cinnie Brown, responding to her e-mail.
Q. And the e-mail that's in the middle from
June Davis to Cinnie Brown, that's an e-mail from you,
correct?
A. At the top?
Q. No. In the middle. At the bottom of that
first page.
A. This was from Cinnie Brown to me. That's the
same as this one right here (indicating).
Q. That's the second page, correct?
MS. MOORE: On the bottom of this
(indicating).
MS. SPEIGHTS: Maybe I'm looking at the
wrong -- what's the Bates number at the bottom of that?
MS. MOORE: 3.
MS. SPEIGHTS: Hold on a minute.

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discuss the situation and that they're both going to get
a written warning at a bare minimum.
How did you know that Linc and Taj were going
to be getting a written warning?
A. Because Scott Collen told me he would be.
Q. And did he tell you why he was giving him a
written warning?
A. Because of the allegations that people
continuously made. There were people who were at this
facility before all this came about that had been
released that made allegations that, you know, it wasn't
very professional. I can't tell you specifically. But
it had been ongoing, some complaints about that
facility.
Q. The complaints that were made about that
facility before the March 2005 complaints, did you bring
those to the attention of Mr. Collen?
A. Yes.
Q. And what types of complaints were you bringing
to his attention before March of 2005?
A. Inappropriate language, some sexual innuendos.
Q. And how did you bring those to his attention?
A. Either by phone or face to face.
Q. Where would you meet with Mr. Collen face to
face?

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A. At his office.
Q. And when was the first time you met with him
and told him that there was inappropriate comments going
on at the facility?
A. I don't recall.
Q. But it's your testimony that it was prior to
March of -- prior to March of 2005?
A. Yes.
Q. Did you provide him with anything in writing
prior to March of 2005 concerning complaints of
inappropriate comments at the facility?
A. Not that I recall.
Q. So was the March of 2005 e-mail that we looked
at to Mr. Collen from you, was that the first thing that
you provided in writing to Mr. Collen about issues going
on at the facility?
A. I don't recall.
Q. The last paragraph here says, I'll update you
as I hear more, same on your end, okay?
Did you provide any further updates to
Ms. Brown?
A. I would imagine yes, but I don't recall. I
know Mr. Collen made several trips out there. We
communicated, but I don't recall specifically dates.
(Exhibit No. 5 marked.)

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A. But the e-mail at the bottom is the same as
the one on Exhibit 3.
Q. (BY MS. SPEIGHTS) Okay. Hold on for a
minute. I gave you the wrong one. Hold on. We're
going to get to that one.
MS. SPEIGHTS: Let's go off the record
for a minute.
(Off the record.)
Q. (BY MS. SPEIGHTS) In the second paragraph, it
says, Scott Collen is making a trip to Gaithersburg
tomorrow.
Do you know why Mr. Collen was making a trip
out to Gaithersburg at that point in time?
A. To follow up on some of the comments that had
been made by the temporary staff about the leads and
manager.
Q. Now, you say in the first paragraph, It seems
like your temps are okay with the working environment.
Why did you believe that they were okay with
the working environment at that point in time?
A. Based upon her e-mail from March 15th saying
that everybody said everything was going well except one
person said they got yelled at.
Q. You also mentioned in the second paragraph
that Scott's going to talk to both Linc and Taj to

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