Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 2 of 33 PageID #:998 Page 1 IN THE UNITED STATES BISTRICT CQURT OF ILLINOIS EASTERN U.S. CCMMISSIGN, WW MM ?leintiff, No. ll-ovw??54 vs. mm.? SGURCE ONE ETAFFING, ENC., Qefendent. WM mum The deposition of JENNIFER 8020, called by the Plaintiff for exemieation taken pursuant to the Federal Rules of Civil Procedure of the United States District Courts pertaining to the taking of depositions, taken before Valerie Calahria, CSR, RPR, a notary public within and for the County of Cook and State of Illinois, taken at 500 West Madison Street, Suite 2000, Chicago, on June 26, 2013, at 10:15 e.m. Se: velerie e. ?elebtie, 03R, RFR Thempsen Court Reporters, Inc (312) 421w33?? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 3 of 33 PageID #:999 Pege 2 EQUAL BY: MR. AARGN EGG wegt Me?isaa Styeet, S?icage, Illi?GiS 69?61 312.353.2?13 Suite 2000 appeaze? an behalf ef the Flaintiff; FOREMAE FRIEDMAN, PA BY: MR. ELLEQT S. WICZER MR. EGG Skekie Eeulevard, Suite 35% Ellinois 60862 849.4850 ewiczer@fflegal.com appeared on behalf 0f the Defendant. ALSO PRESENT: legal intern law Clerk ?aryam Arfeen, Richard Matt, Braulio Justo *ki?rk Court Regartere, Ina i312) ?21w33?? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 4 of 33 PageID #:1000 M.) 1.Page 25 A. Of 2010. MR. If we een take 3 quick break. I went te quiet eewn eer neighbers. MR. WICZER: ery. MR. Off the recerd. (Diseussien had eff the tecerd.} MR. We can g0 beck en the tecezd. BY MR. Q. Se it?s my understanding that durimg your first meeting with Seett Reedy, Jese Morales, and Helen Robles abeut a month into your employment you didn't really talk about the 01d form very much, correct? A. Correct. Q. But then thete was a subsequent meeting that only had you, Mr. Reedy, and Mr. Wiczer whete you did talk about the old form? A. Yes. Q. Te the best ef gee: what was seie during that meeting? A. What was said? Q. yes. A. Just I was asked if I knew anythi?g abeut what was geing on and.l gaid net really Themgsen Ceurt Repertete, ?ne {312} 421*337? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 5 of 33 PageID #:1001 *4 LO- a ?31Fa} gm; in} Page 26 baoausa it was before me other than if I had hoard any chatter about it batwaah the other employees at that time from them because they were thsra longer than myself, if I had heard anything and that we were instructed to not talk about the old form and that we wars instructed to w~ if a client did call and asked for male or female wa wore to keep that on the down low, as it was said, and to fill the order for tha hast body possible. Q. When you say "on the down low," what did you understand that to mean? A. That we were supposed to take direction from the client and only send them that specified person or specified male or female, that if that's what the client wanted that that's what we were supposed to do, but we were not to put it on the employee request form. Q. So you were not to document the w? A. Correct. Q. Let me finish my quastion. You were not to docsweht the empioyer?s A. Yes. Q. ?ho gave you that instigatioh? A. Helen Robles. Thompson Court Reporters, Ema {312) ?21w33?7 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 6 of 33 PageID #:1002 Page 27 Q. was Helen else at thie meeting? A. Re. This was a conversation before regarding that meeting. Q. Let me get the time. A. I'm sorry. Q. hen me get the time line. So who instruete? you to keep the A. In the staff meeting that was held, we were told to, a5 per the client's order, put down beetmabled body but to keep in mind that that's what they wanted. Q. Is this the first meeting or when was this? A. This was the second meeting. Q. Was this after your discussion with Scent and Helen? A. No, before. Q. 30 Helen Robles told you mm was there anyone else at thin meeting? A. The second meeting? Roeles teie you Q. The meeting where eheet :he eliee: A. It wee Joee Morales. myself, and Eelen. Se helee inetrueted you :0 ts did ?w/Nmn Thompeen Seuft Reportete, ?ne {312} ?21m3377 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 7 of 33 PageID #:1003 p527.? Page 28 she say keep it on the dawn 10w? MR. WICZER: Objeatien, leading. TEE N0. She said just keep in mind that if the ciient ?ees ask fer male 0r female that we set pat it me the sheet. 33 MR. Q. What else did she say that you can yememher? A. Regarding that? Ta just do as the client asked. Q. Was there any discussien of this at the meeting that you had with Mr. Wiczer and Mr. Reedy? A. Regarding the form? Q. Yes. A. I was told I can't speak for anyone else because it was a private meeting. I was told to net say anything as far as the old form being used, whether or not it was being used. we were told ts say that the new request form was being used, that practices were able?bcdied person be sent even thaugh we knew sutside of that meeting that that wasn?t happening. Q. 31a yea seise seas seneers ts Ea. Case: 1:11-cv-06754 Documen1#: 104-4 Filed: 07/11/13 Page 8 of 33 PagelD #:1004 gm)? {?Fage 29 Ha, I wag afraid; Q. Why wara gag A. I cani? have la?t my jab. didn?t want t9 Rage my jab; if that Was-anything that csml? hava caat ma my jahe Q. whan yam wage tald mat ?g discugg the what aid f?rm, did yam und?rgtand that ta meen? A, mi; eel-1; abmi? it. 3; didn't underatan? why u??ileaft?te?hajwther staff maeting was bald as ta ?hfe '?h?e?Ii?eaid that the E??c baa been yart of a ca?vergati??, I ?nd?xstcod withaut it fully being explaineused. Q. Were yam aver instxucted by Saurca One that aggigning of sex wag illagai?? I A. N01 E??n thoug? think t?ay knew, it I Q. whai ??at they k??w thai? a, about the famala in ?a?text:?f haw ?ar? 33:5111m II. I I Q. yam gash Q?bleg Q: w?i? Qii&%r Thamggaa Saar: Eng 4322; ezzeag?? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 9 of 33 PageID #:1005 Page 30 A. No. Q. So when you say that you believe genres Gee knew that it was unlawful, did you have any reason to believe that Scott Reedy or Helen Robles knew that assigning people by gender was illegal? A. Absolutely I know they knew it was illegal. Q. How did you know that? A. Because of conversations that were made that they knew that that's why they changed the employee request form. Q. What comments did you hear? A. That we were told not to put male or female because they could get in trouble. Q. Who said that? A. Both Helen Robles and Scott Reedy. My purpose here is to Q. I?m sorry. exhamst you: memoxy. When did Mr. Reedy say that? A. Between the first and second staff meeting. To the best of your recollection, what ?0 did Reedy say A. That we were to not put anything down as far as them requesting ?w ?them? being the Thomgson Court Reporters, ins (312} 421w3377 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 10 of 33 PageID #:1006 Page 31 1 client requesting male or female, that we were IX) just to take mental note of what client wanted 3 what. Q. So Mr. Reedy told you to take a mental note of the sex~specifio requests of clients? 6 A. If that particular client called, yes. 7 Q. What did you take that to mean? 8 MR. WICZER: I object to the form of the 9 question. 10 BY MR. 11 Q. You can answer. 12 A. I thought it was wrong. I knew from 13 prior staffing job that we were to send able-bodied 14 whether it be male or female as long as they 15 could w? if there were any lifting restrictions, as 16 long as they weren't pregnant, if they could work 17 in that particular establishment then we were to 18 send, if they were willing to go, to that 19 particular client. 28 Q. how many times did hr. Reedy tell yes to 21 take a rental note of the sex-specific requests or ?2 clients or scnethirg along those lines? 23 A once 2% Q. The: was between the first and seoond $hompson Court Reporters, {312} $21?33?7 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 11 of 33 PageID #:1007 W.) No} (.Page 32:: staff meetings? A. Yes. Q. $0 thet was sometime in the summer oi 2316? A. Yes. Q. end you said Ms. Reblee also made those oemmemts to you? Yes. How many times? How often? A. Q. A. Many occasions. Q. A. Probably two or three times. Q. To the best of your recollection, what did Ms. Robles tell you? A. It was along the same lines, that we were mentally to remember kind of sort of which clients. There were two specifically that I could remember off the top 0f my head that really only wanted sex?speeific people. Q. ehet Clieete were those? A. I can't remember the names. Gne was a packaging mm seep packaging company, and another was a yrinting. Q. Se ?ed Reblee make these Thempeon Court Reporters, Inc (3123 422-3377 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 12 of 33 PageID #:1008 is.) he": 5:333- Page 33 comments to you? A. Around the same times as the meetings. Also; there was one occasion after the meetings that, apparently, the supervisor of that 5039 packaging company had made a complaint to her that I had sent male people because I couldn't find any female peeple to fill that position, and I was later told by that supervisor to call him directly and tell him that if I cannot find females that he requested that I wasn't to send any males unless he asked. Q. Did you have a conversation with Ms. Robles about this? A. She asked me if that supervisor contacted me, and I said yes. Q. What else did Ms. Robles say? A. It was left at that. Q. Yea don't remember the name of the aempany? A. The campany I den?t. I remember the superviser. His name was Juaa. But it was a soap packaging company in west Chicago. I believe the address was Industrial ?riva. 63?. 39:3} :3 Ceurt Repertere, {312} 421w3377 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 13 of 33 PageID #:1009 .3) Page 34 A Yes. Q. After yam had that canvaraatiah with did yea repart_it t0 Saurce ?ne? A. I wag under the impressien that he had called me per hie convaraatian with Halan he tala me that he talked to Helan abcut it. And then onca she cama into the offica she askad ma if Juan haa cantacted me. Q. And did yuu have any further conversation with Helen about this mm A. No. Q. And after that conversation with Juan, did you ever have an occasion that yQu could not supply female amplayees t0 68?? A Yes. Q. Did yOu call him? A I did. And what happehad? A. Try t9 find me mora. I had exhausted many phone calls. It get almost to a point with that specific company that they ?idn?t want to return because they felt Thempsah Chart Rapertara, Inc {312? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 14 of 33 PageID #:1010 kg? {\fi M1 N3 Page 35 Q. And d3 yen know why they felt uncamfartable? A. They said and I can't prove it. I can?t prave it at all. But they gaid that they were just mm they felt like they ware being leaked at like pieces of meat. Q. Did this Juan persen make any othe: Specific requeets abeut the wemem that were assigned to 68?? A. That they be pretty. feundation, MR. WICZER: Objection, hearsay, farm. BY MR. Did Juan say this to you directly? Yes. Was this over the phone? Yes. ?3 t) K) Thie was during the ceurse 0f youz emgleimemt at ?gurca One? A. Yes. Q. 39 remember whee that $53? A. Dates, n3. They called an a daily baeis. Were y?j ??af traine? bf Searge as Thempeen Sour: Repertere. Ema (312) 421~3377 Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 15 of 33 PageID #:1011 Page 123 indieeted in yeut teetimeey earlier you eeuld Search by ability, right? Ad Correct. Q. That ability wee en whet the temperety employee marked en their epplicetiem; is the: eerreet? A. Correct. Q. Were there times that you weuid cell temperary empleyees fer an open pesitien and they weuld not accept the position? A. Every day. Q. Were there times that you would call a temporary employee and you couldn't get aheld of them? A. Every day. Q. Were there times durieg your employment with Scarce One where it wee actually difficult to find empleyees te fill peeitiene? A. Every day. Q. Weeid yea say that was mete the mere? Ye eteer wetee; it wee ?ifficuit te fine W: 5m: M.) ?if? if} c" t? 4 (I) :13 Ceett Repertets, inc 5312) 421-337? Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 16 of 33 PageID #:1012 the {$13; 'Soott Reedy on at least one occasion said that if a Page 124 put words in your mouth, so correct me if I'm wrong. gut there could be days whete there's one job for Seotoe Qne eustomez available end you neeid make ten phone galls eno everyene turns you ?ewn and en the 11th call sueoess? A. Absolutely, as is with any staffing job. That was my prior experience at the other staffing company. MR. I have nothing else. FURTHER EXAMENATION BY MR. Q. Ms. Buzo, I just have a couple follow~up questions for you. -In response to some questions at the beginning of the deposition, you mentioned that Source One client asks for a gender~specific employee you're supposed to take a mental note of it? At Correct. Qt $9 yon remember that? 3, Yes? Q, ?ne neien Robies eiso said enet te is that eetteot? Thompsen Cent: Reporters, ?ne {312) ?21~33?7 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 17 of 33 PageID #:1013 Jim (ks?) t? 3 fd-J ER) m. Page 125 A. Carrect. Q. Yam undetgtasd that ta mean that yea were met tg datument the request but hater it, setteet? A. Carrect. Q. Se then when yam had that meeting with Elliet and Scott and Scett said you are ta tell peeple that Scarce One's practice is to net assign people by gender, that is centrary to what he previeusly teld yam; isn't that Gettect? A. Corract. Q. So he was telling you to lie? A. Corract. Q. And that was Mr. Reedy; is that correct? A. Yes. Q. Did the fact that you were terminated from Source One affect yam: ability to be hanest in this depositien? A. Absolutely net. MR. BQCAMP: That*s it. FERTEER at 1) if?? 3 1:32 w?ia? meeting? Soutt Regettere, Inc (312) 421~33?? Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 18 of 33 PageID #:1014 if? {'33 10 ll l2 l3 Page 126 i A. The one that the three of us had. Q. specificelly A Yen, myself, and Mr. Reedy. Q. what did he say to yam that was a lie? A That we wer? to tell the EEOC that we were not ueing these praatices. Q. As a ge ferward we woaldm't nee these practicee any lemger? Is that what he Said specifically? foumdation. MR. Objection, THE WITNESS: That we would no lenger use those practicee. BY MR. WICZER: Q. That's what he teld you? A. As far as I can remember, yes. Q. And he told yeu not to use these practices, right? A. Correct. Q. And yam went gut and yen use? these practicee? A. According ta the client as they asked for, again, because I was in fear gf pessibly lasing my jab. Q. Eat it weea?t that Eee?y Eied t? Thempse? Ceurt Repotters, inc {312) 421m33? Case: 104-4 Filed: 07/11/13 Page 19 of 33 PageID #:1015 {.{\Ja in h} fa} be) Page 127 you. He gave yon a directieh net t0 do semethihg that yen did? A. Other than to take a mental note. Q. So when he said he take a mental mete, that?s what you understeed ts be the lie? MR. Ohjeetien, misehareeterizes the testimony. THE WITNESS: NO. The lie was to say that nothing was going eh. BY MR. WICZER: Q. Wellsay that nothing was going on when, in fact, that it was going on. Q. Did he use those words? Let's be specific about what he said to you. A. To be 100 percent specific as to exact verbatim as you have said to say, I cannot remember 100 percent every single word that was said almost three years age. I can remember it being said that we were to net use these practices anymere under the fast that there was same sert ef an investigation by the EEOC. Q. Se year useerstandihg was that yes Reedy was gee net he nee Thempsen Cenrt Regerters, Zhe {312} ?21m33?? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 20 of 33 PageID #:1016 Page 128 certain in the future; is that eerrect? A. When I was employed there, yes. Q. Thet?e whet he teld t0 yeu during that meetihg; ie thet right? A. He said d0 net use even though yeu are directed by the alient this is what they want, that you are to not write down anything else athex than If the client asks, put it what ie an that sheet. on there. Q. I'm confused by your testimony. If I understeod your previous testimony, it was that Mr. Reedy told you that as a ge forwazd that you are hot A. we were not to talk about the old form at all, period. Q. That's all that wee talked about during that meeting? A. As far as I can remember, yes. It was an EEOC specific meeting. Yen were there. Mr. Reedy was there. I was in that meeting. It wag the three cf as only. I was tale by yea that the at some paint coul? be aentacting us as individuals and that we were ta say that the aid fexm was me longer in use and ta net talk about it. Thempeeh Ceurt Reporters, Ihe {312} ?21m337? Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 21 of 33 PageID #:1017 Page 129 1 Q. And the eld form at that peint was not 2 1e use; is that right? 3 A. Correct. Even theugh the same praaticee were being need. 5 Q. Been theegh but Mr. Reedy told yea not 6 to use these practices; is that right? and the 7 eely reason yeu used them is because they used the 8 wards "make a mental note about it"; is that right? A. Correct. 10 Q. 80 other than using the words "make a 11 mental note about it," that gave you what you 12 thought the right to go out and when the customers 13 called to place based on gender, right? 14 MR. Objection, argumentative. 15 BY MR. WECZER: 16 Q. These two words "mental note," yes or 17 no? 13 MR. Objection, argumentative, miseeataeterizes her testimony. 1.0 SE Tee Meetel mete was used, yes. 21 BE ea QESZER 22 These eere tee tee eerds use? that 23 led get te teat gee sneeid glaee emp1eyees ef Seezee See based ee gender? 53:1.? $21) at I @hempsee Seert Reperters, Inc {312) 421*3377 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 22 of 33 PageID #:1018 FM.) FR) M) Page 130 MR. Objectien, mischarecterizes testimeny, argumentative. BY MR. Q. Is that right, yes er me? A. These are the exact wards verbatim that I remember. Q. These were the enly twe words ?m A. No. Q. What ether wards were used? A. I don't remember correctly verbatim what was said other than the fact it was not to be talked about and if asked about it, that it was no longer to be used. Q. The form? A. The practice. Q. The same practice that Mr. Reedy told you met te use? MR. Objection te ferm. THE WITNESS: It was ta1king seecificaliy abeet the form. BY MR. Q. whet I?m hearing here is the: gee ieplied certain teiegs bese? ee 3e Thempsee Ceurt Repertere, Inc (312) 421w33?? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 23 of 33 PageID #:1019 kgFR.) Mg {at} Page 131 testifying. Objectien te the question. BY MR. e1ezee: Q. Yea MR. dee?t knew if that?e queetiee. You can if yeu understand it. THE I den't understand it. BY MR. Q. Were there any ether words that you remember other than mental note that led you to believe A. I'm sure there were. Q. What were they? A. But I don't remember. Q. So how d0 you know that Mr. Reedy lied te you? A. Because I can remember specifically being tald by ycurself that there were to be no comments at all made ta the EEQC if this ever came about any day in that present moment er in the future. Q. eny whet? A. The fexm or practice. Q. eze gee eeyieg that tee iexm ehee wee ee Cemrt Regertere, Ewe {312} 421~33?? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 24 of 33 PageID #:1020 Page 132 1onger being used, I told you not to tell them that there was a form in existence and you were to lie about it? A. It was before me, so I could honestly say that I had no idea about it until I actually found an old yellow copy that we were told not to ever use. And I never ever ever used it in the course of my employment. I used the form that you have entered into exhibit whatever to say that this is the form that I used. This is the form that I used. Q. But let?s be clear. You're accusing Scott Reedy of lying, right? A. I am not accusing I am stating that you and yourself both said that if at any point the EEOC is to be contacting you or will contact you that you are to say that that practice was no longer being used and that form we no longer used, which the form was no longer being used. I can honestly say that the form I used when I started working there is the form that was presented to me here today. Before me I have no idea. Thompson Sour: Reporters, Inc (312) 421w33?7 Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 25 of 33 PageID #:1021 Page 133 A. What part of what is untrue? Q. Yea said that yea were t0 tell the EEOC that the ferm wee ne lehger being weed? a. There is no untruth in anything that I said. I wag held that we were ta net talk abeut anything regarding that form. Q. You weren?t ?eld :0 lie, though? A. we were teld that if anything was asked to say that that form is no longer being used. Q. Which is true, right? MR. Let her answer the question, Elliot. BY MR. WICZER: Q. Is that true? MR. Let her answer the question in full. She has a right to answer the question without an interruption. BY MR. WICZER: Q. Is that tfue statement? eeh te the queeziee. he. net have the Eight 2e interreet gee. EH ?e were teid that they were Wm e3 2211 (if) ee were eele :hee the ferm ?e ?e leeger 1e end hempeen Ceurt Repertere, (312) ?2iw33?? wa- Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 26 of 33 PageID #:1022 m- if? 10 11 i2 13 Page 134 thet if eeythieg ever came abeut with the EEGC, if we were ever eemtected, that we were met to talk ebeet it end we were te that the practices that were beieg used were that we seed eut eny eblewbediee peteon. BY MR. WECZER: Q. And you were told to Send eat any ablewbedied petson by Scott Reedy; is that correct? A. Correct. And by Helen Robles? A. Correct. And you were told and yea knew the form was no longer in use; is that right? A. Correct. Q. And when you said so other than the practices being ased and the form no longer being used, was there anything else that you deemed to be I mean, oeunsel asked you it was a lie, and I went te knee wee: part of that ie lie. A. The simple fact that I'm being asked t0 honor a campany about sending them pretty girls er etrang big man er if they were purple with pelka~?etted, that?s who we were eeppesed ta send them, Seutt Repeetere, lee (312) Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 27 of 33 PageID #:1023 LA) {.57 Ci(A) Page 135 Q. Who told you that? A. We were told by Helen and Scott. Q. When? A. In one of those meetings. Q. So now you were told in ene of these meetings to honor gender requests? A. If it came about that the company asked for specifically male or female, we were to send that company specifically male or female. There were certain companies, two that I can name off the top of my head, they only wanted pretty girls. If at any point we didn?t send them pretty girls, those temps immediately got sent back to the office and were never allowed to go back to that company. Q. We talked about two meetings. We talked about a meeting with you, Jose, and Scott Reedy and Helen and then we talked about a meeting with me and Scott Reedy and you. From my recollection of your testimony, the meeting with Scott Reedy, ?elen, and Jose and you there was nething discussed So which meeting eow are you A. The meeting with you. Q. go the meeting with me mow teoeuse w? Thompson Sourt Reporters. lne (312) 421~33?7 Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 28 of 33 PageID #:1024 Page 136 just want to get your testimony on reCOtd as to what was ssi?. You said before prior that the form was no losgex being used sad that's what yoo?te to tell people; is that true? A. Yes. Q. You were to say that the practices being used ere basically nondisctimimatory practices, correct? A. Correct. Q. And you were directed by Scott Reedy and me at that meeting to not use discriminatory practices, right? A. Even though they still happened, yes. Q. But Elliot Wiczer and Scott Reedy at that meeting directed you not to use those ptactices; is that tight? A. Correct, even though they were still being used and both of you, Scott Ready and Elliot Wiczer, had full knowledge of it still happening. kay. shat is year basis of Scott Reedy hesiss foil thosiedoe of it w? .a A. Regs the owner ef the company. He knew exactly what was going on every day because Helen would be back in his office every day for at least Thompson Court Repottets, Inc {312} 421~33?? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 29 of 33 PageID #:1025 Page 137 1 half an haux ta an hoax expiaining ta him 2 everything that baa hagpene? that ?ay that aha was 3 there in the offiaa ax eke wanld be an the phana 4 with him far haif an hamr at iea?t evaxy $the mffiaa abaut everything that wee gaing an in the mth?r affiaes, Q. SQ year kaewledga-af what Nr1 Reedy knew 8 a: knew areubaaed an meeti?gs that Belem and "he ?ad?in?an?sff?ce that?yau were net-in @n'thasa 10 Imeeti?gg at, cerreat? I i? 11 Gver?earing things as I?m walking baak 1 12 to paY?a11 lady, Tammy, giving ha: pay eheats a: leaking ta find Why an hadn?t been yaid 2' '14 the3g?xxeat;am?untf evaxhaaxi?g1 And I undexstan? :3 ghae taat but?: k?ew e?at that Wa? 16 happa?ing'bacau?a i-??uld hear them discu$3iag -17 thingg-??-t?at gay." -:38 IIQ ?ew ?g gag km?? that knew? an $33 ?caasian. I aca?31?%?. 1:1:34 I a??ft wk? yoa t?ara itgs net e23 basinasg, any af my ??gihassg; Eau?re hi$1att?r?ay an?jzae*aam?aa33? attarnayy-and ?hempsem Ceurt Repezters, Eng (3123 ?21m3377 Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 30 of 33 PageID #:1026 Page 138 privaoy laws. I understand about there being client-attornay privilege, whatever that?s called. But I knew if I was told to not go in that back room there were two doors that had to be closed in order to go back into Scott's office, third door being Scott?s office, that if those doors were And I closed we were not allowed to go baok there. know there were a couple of occasions that there were absolutely all doors closed occasions that no one was allowed in that back office. Q. So based on those closedmdoor meetings, you have assumed therefore mm A. I assume nothing. Q. Let's find out a basis for your statement that Elliot Wiczer knew that placements were being made based on gender and told you to tell the EEOC that they were not. What is your basis for that statement in fact? A. How could you not know? You were his attorney. So it?s sagposition, right? argumentative. Loser roar gorse, Thompson Court Reporters, lno (312) 421~33?? Case: 1:11-Cv-06754 Document 104-4 Filed: 07/11/13 Page 31 of 33 PageID #:1027 fit{if} FR) i. {\me 422? Page 139 BY MR. WICZER: You?re A4 Please don?t yell at me. Q. ?re you guessing? A. I am not gueasing. You had to have known. You?re his attorney. And with full knowledge of this EEOC investigation going on, how could you not know? Q. So you don't know specifically what was discussed at that meeting? A. Because I was not invited to that meeting. Q. Or any meetings? A. Other than the ones I was invited to, no, and overbearing that, only words overhearing that that's what happened. Q. And you were not in any of those meetings, right, other them the ones you is that correct? A. Yes. Q. and go you have no way of kaowieg ehat wag a: meetings, do gee? A. Unless it was said to me, not nathing was ever said to me. Thompson Court Reporterg, Inc (312} 423-337? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 32 of 33 PageID #:1028 Pa.) rib Page 140 Q. eud in terme of Seutt Ready'e knowledge I of whet yeu were doing in plaoimg gender-specific requeete by cuetemere, did you ever tell him I think yeu :eetified yeu never told him you weze ueiug that; 15 that tight? A. No, because he wasn?t my direct supervisor. Q. And you never told Helen that, though? A. Correct, but she could see on the paper that it was happening. Q. And, again, when you say "the paper,? you?re talking about the client request form? A. The employer request form. Q. The employer request form you don't know whether she looked at er not? A. I'm sure she looked at them. But you don't know for certain, do you? A. I don?t know for certain. MR. WICZER: I heve nothing else. FURTEER 3? ER. Beie??: Knew yee?ee tureugh a LQE, e5. Buze, and this be my last queetie?. epe?euize. $hempeou Ceurt Repertere, In: (312} 421?337? Case: 1:11-cv-06754 Document 104-4 Filed: 07/11/13 Page 33 of 33 PageID #:1029 ?age 141 When Seott Reedy told you take a mental note or the olient'e requeet, what did yeu underatan? him to mean there? A. Just to keep it in mind that this was the way that it was supposed to be. MR. Thar?e all I have. VMR. WICZER: Nothing elee. MR. Ma. Euro, you have a right to review the tranecript if you ao choose. And you're not reviewing it for you can?t change your answers, but you can review it for accuracy to make sure that the court reporter took down everything correct. You can either review it after it's printed, or you can waive the review and not have to review the transcript. It?s up to you. Would you like to review the transcript? Would you prefer to waive your signature? TEE Yeah. Okay. gar the recerd, the haa eleetee to waive eignatu e. raerira aarra at eoaciuue 3 -hempaen ?ourt Reporters, inc (312} 421?33?7