Depo - Clay Hill - Sep 24 2003
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Q.

Are you aware of any employee at -- at Daystar

who is higher than Ms. Cuellar?

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A.

I don't know.

7

Q.

The way the command structure works currently,

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you're at the top, correct, ultimately responsible,

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right?

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A.

Yes.

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Q.

Mr. Salls works underneath and reports to

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you --

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A.

Yes.

14

Q.

-- correct?

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Underneath Mr. Salls is -- are

the supervisors -- the shift supervisors, correct?

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A.

Under Mr. Salls would be maybe Ms. Cuellar.

17

Q.

And what is her title?

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A.

I don't know.

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MR. DAW:
Q.

I do.

(BY MR. COLLMER)

Why don't you know

Mrs. Cuellar's title at the company?

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A.

That's just --

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Q.

Okay.

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A.

-- because that's just not how I do it.

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Q.

Well, how do you do it?

O'NEAL * PROBST * WELLS - 713.521.1314

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MR. DAW:
Q.

Oh, come on.

(BY MR. COLLMER)

Don't --

You don't know what the --

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you don't -- you don't know what Ms. Cuellar's title is

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at the company?

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MR. DAW:

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that's harassing.

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you --

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He's already asked --

Now

He just said he didn't know, and now

MR. COLLMER:

I'm just perplexed that he
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