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1 cell phone number that they were calling.

2 Q Okay. So based on your knowledge, that

3 phone number, (313)633-7036, is Ms. Phillips' cell

4 phone number?

5 A I believe so.

6 Q Okay. And they talked for eight minutes

7 and 48 seconds?

8 A Somebody did.

9 Q And the next page which is May 1, 2007 at

10 12:05 p.m, you're stating that Pat Smith talked to

11 Ms. Bennett -- or I'm sorry, scratch that. That Pat

12 Smith talked to Ms. Phillips for nine minutes and 36

13 seconds?

14 A What is the day?

15 Q 5-01-07.

16 A My copy looks like 3.36. Is that --

17 Q Okay. I am going to represent to you that

18 that is actually a nine.

19 A Okay.

20 Q But I see -- the copy is bad.

21 A I will believe you.

22 Q They talked for some amount of time. And

23 then if we go to the last page, you are indicating

24 that on 5-1-07 at 6:11 p.m. Ms. Bennett called Ms.

25 Phillips and they talked for four minutes and six

147

1 documents in support of interrogatory 9D and 9E; is

2 that correct?

3 A I believe it states that, yes.

4 Q And those are documents that support --

5 identifying all employees in the medical review

6 department with whom charging party spoke with

7 between April 30, 2007 and May 2, 2007? D, and all

8 dispatchers with whom charging party communicated

9 between April 30, 2007 and May 2, 2007, correct?

10 A Yes.

11 Q If we look at document request number 18.

12 A What was that again, please?

13 Q 18, on page 14 of Exhibit 1.

14 A Page 18?

15 Q Uh-huh.

16 MR. HOWLETT: No, page 14 you said.

17 Q (BY MS. GIBBS) Page 14, number 18, I'm

18 sorry. Number 18 asked for you to produce any and

19 all documents showing communication between

20 defendant and employee Ray Snapp between April 30,

21 2007 through May 30, 2007, including but not limited

22 to all communications between Snapp and dispatch.

23 And what was provided was these phone records and

24 what was marked as DTC245. How do these documents

25 show communications between defendant and Ray Snapp?

146

1 seconds?

2 A Yes.

3 Q And then again at 7:47 p.m. they talked

4 for two minutes?

5 A That appears correct.

6 Q Okay. If we look at -- if we go back to

7 those request to produce documents.

8 A Which exhibit would that be?

9 Q Exhibit 1. And these are marked

10 DTC0000232 through 234, correct?

11 A Yes.

12 Q And so these were responsive to your

13 request to produce documents seven? Page 11,

14 request for documents.

15 A Number seven?

16 Q These were part of the -- responsive to

17 that request to produce documents?

18 A It appears so, yes.

19 Q Okay. Number 17?

20 A Okay.

21 Q Number 18?

22 A Okay.

23 Q And number 19, correct?

24 A Okay.

25 Q And then number seven is actually

148

1 Or where in these documents does it show

2 communications between defendant and Ray Snapp?

3 A It doesn't.

4 Q It doesn't?

5 A I don't see that it makes a direct

6 reference between Anita Phillips and Ray Snapp.

7 Q Okay. I wasn't asking for Anita Phillips

8 and Ray Snapp. I was asking between defendant and

9 Ray Snapp?

10 A Oh, excuse me.

11 Q So how do these documents show

12 communication between -- where do these documents

13 show communication between defendant and Ray Snapp?

14 A I can't answer that.

15 Q Why?

16 A I don't see a reference to Ray Snapp in

17 the documents.

18 Q Okay. And why were these documents

19 produced in response to that request to produce

20 documents?

21 A Those could have been produced by our

22 operations department or Decker.

23 Q Okay.

24 A I don't know.

25 Q It says the only person that assisted in

TONY LONGINOTTI September 28, 2010

Toll Free: 800.866.5560

Facsimile: 248.205.7040

Suite 925

2301 West Big Beaver Road

Troy, MI 48084

www.esquiresolutions.com

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