EXHIBIT 4 

TO 

PLAINTIFF’S CONTROVERTING STATEMENT OF FACTS 

IN RESPONSE TO 

DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

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Miller Certified Reporting, LLC

UNITED STATES DISTRICT COURT 

DISTRICT OF ARIZONA 

Cleopatria Martinez, )

 )

 Plaintiff, )

 )

vs. ) NO. CV 15-01759 NVW 

 )

Maricopa County Community )

College District, a political )

subdivision of the State, and )

Rufus Glasper and Debra )

Glasper, husband and wife, )

 )

 Defendants. )

________________________________) 

RULE 30(B)(6) DEPOSITION OF JUDY CASTELLANOS

Phoenix, Arizona 

December 15, 2016 

10:23 a.m. 

Miller Certified Reporting, LLC 

Post Office Box 513 

Litchfield Park, Arizona 85340 

(P)623-975-7472 (F)623-975-7462 

www.MillerCertifiedReporting.com

Nicole Tatlow, RPR 

Certified Reporter (AZ 50671) 

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I N D E X

 WITNESS PAGE

 JUDY CASTELLANOS 

 EXAMINATION BY MR. ROBAINA 5 

 EXAMINATION BY MS. BALCH 80 

 FURTHER EXAMINATION BY MR. ROBAINA 84 

* * * 

E X H I B I T S

 NO. DESCRIPTION PAGE

 No. 1 Letters dated August 9, 2013 10 

 No. 2 Residential Faculty Policies 2012-2013 12 

 No. 3 Residential Faculty Policies 2013-2014 13 

 No. 4 Hearing Committee Findings of Fact, 20 

 Conclusions of Law, and Recommendation 

 No. 5 Administrative Regulation: Fiscal 25 

 Management, Section 1 

 No. 6 Letters dated February 10, 2014; 26 

 Hearing Committee Findings of Fact, 

 Conclusions of Law, and Recommendation 

 No. 7 List of Faculty Suspended; Copies of 52 

 Suspensions 

 No. 8 List of Faculty Suspended 53 

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 No. 9 Suspension Documents for Jason Martinez 60 

 No. 10 Suspension Documents for Walter Kehowski 61 

 No. 11 Suspension Information for Harry Kaino 62 

 No. 12 Suspension Documents for Scott Geddis 63 

 No. 13 Suspension Documents for David Sanchez 63 

 No. 14 E-mails dated August 11, 12, and 13, 64 

 2014 

 No. 15 E-mail dated August 13, 2014 65 

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A. These were in regards to Dr. Martinez's

dismissal, binding, that the committee presented to the

Chancellor for his or her review.

Q. So --

MS. BALCH: Edmundo, if you want to continue this

line of questioning here -- 

MR. ROBAINA: Well, she's here on a 30(b)(6) --

MS. BALCH: -- you certainly can. 

Yeah, yeah, yeah. But --

MR. ROBAINA: -- to answer regarding MCCCD

policies related to discipline.

MS. BALCH: No, I understand. I think that the

witness is getting a little bit confused, though, as to kind

of legal terminology. If -- I'm happy to offer -- if you

want to take a quick break, I think I can speed this along.

If you want to continue, you're welcome to.

MR. ROBAINA: No, I -- I want to continue.

THE WITNESS: Can I take a break?

MR. ROBAINA: Sure.

(Recess taken from 10:55 a.m. to 11:07 a.m.)

MR. ROBAINA: So before we -- before I forget it,

are we going to stipulate that -- let me start it this way.

BY MR. ROBAINA:

Q. You understand that you're here on a 30(b)(6)

deposition representing MCCCD with respect to Residential

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Faculty Policies -- I'm sorry -- with respect to MCCCD

policies related to discipline, Cleopatria Martinez's

suspension, including any process given to her with respect

to suspensions -- I'm sorry -- any process given with

respect to -- let me start that again.

You're also here for -- in relation to

Cleopatria Martinez's suspension, including any process

given with respect to suspensions. Do you understand that?

A. Yes.

Q. And you're also here regarding any pronouncements

regarding decisions made by the Governing Board related to

Dr. Martinez. Do you understand that?

MS. BALCH: I don't necessarily know that she's

the person most knowledgeable to stipulate all that,

Counsel.

MR. ROBAINA: Okay. So we'll stipulate on that

one?

MS. BALCH: We'll stipulate at No. 4. Correct.

MR. ROBAINA: Let's talk about that one real

quickly. So we're stipulating that the Governing Board made

no pronouncements with regard to Dr. Martinez, the intent to

dismiss her, or her suspension, correct?

MS. BALCH: Yes. The intent to dismiss or

suspension order issued in this case.

MR. ROBAINA: Okay. They have not made any

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Miller Certified Reporting, LLC

actions with regard to her at all? With regard to

suspension or intent to dismiss, right?

MS. BALCH: That is my understanding. We are

willing to stipulate to that.

MR. ROBAINA: Okay.

BY MR. ROBAINA:

Q. Who do you report to?

A. Barb Basel.

Q. I'm sorry. I should -- I should ask, during the

time frame relevant to this case, which is 20- -- 2013 and

2014, who did you report to?

A. 2013, I want to say James Bowers.

Q. Okay. Is he still with the District?

A. No.

Q. Was he succeeded by LaCoya Shelton-Johnson?

A. No. He was the director of the HR Solutions

Center.

Q. Oh.

A. Then he was interim as the Vice Chancellor, and

then LaCoya Shelton-Johnson received that position.

Q. Okay. Let me show you what I'd like to have

marked as Exhibit 5.

(Exhibit No. 5 marked.)

BY MR. ROBAINA:

Q. Will you take a look at that? You don't have to

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