EXHIBIT A

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 1 of 505
 UNITED STATES DISTRICT COURT

 DISTRICT OF ARIZONA

 Brandy Williams, )

 )

 Plaintiff, )

 )

 vs. ) Case No. 15-cv-01744-PHX-DDD

 )

 G&K Services, Inc., a )

 Minnesota corporation, )

 Jane and John Does )

 1-100; Black )

 Corporation 1-100; )

 White Partnership )

 1-100, )

 )

 Defendants. )

 )

 VIDEOTAPED DEPOSITION OF BRANDY LANE WILLIAMS

 Phoenix, Arizona

 June 14, 2016

 9:09 a.m.

CERTIFIED COPY

Reported by: CARRIE REPORTING, LLC

CARRIE A. CARIATI Certified Reporters

Registered Professional Reporter 4032 North Miller Road

Certified Realtime Reporter Suite A-100

Certified LiveNote Reporter Scottsdale, AZ 85251

Arizona CR No. 50355 (480)429-7573

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 2 of 505
2

1 I N D E X

2 WITNESS: EXAMINATION PAGE

3 BRANDY LANE WILLIAMS

4 BY MS. FRANCIS 5

 By MR. MILLS 272

5 By MS. FRANCIS 283

6

7

8 E X H I B I T S

9 DEPOSITION

EXHIBITS DESCRIPTION PAGE

10

 12 Complaint and Demand for Jury Trial 26

11

 13 Medical record from Joseph Brooks, M.D., 57

12 dated January 16, 2013

13 14 Performance Document - GK perform, Manager 198

 Evaluation, 7/1/12 through 6/30/13

14

 15 Employee Acknowledgement Form 229

15

 16 Company Policy, G&K Individual Treatment 230

16 Policy, Bates Nos. WILLIAMS-000048 through

 51

17

 17 Charge of Discrimination 234

18

 18 E-mail 237

19

 19 E-mail 238

20

 20 Series of e-mail 240

21

 21 E-mail 242

22

 22 E-mail 245

23

 23 Series of e-mail with attachments, 256

24 Bates Nos. EEOC 0026, 137, and 145

25

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3

1 VIDEOTAPED DEPOSITION OF BRANDY LANE WILLIAMS

2 was taken on June 14, 2016, commencing at 9:09 a.m. at the

3 law offices of Stinson Leonard Street, LLP, 1850 North

4 Central Avenue, Suite 2100, Phoenix, Arizona, before

5 CARRIE A. CARIATI, RPR, CRR, CLR, a Certified Reporter in

6 the State of Arizona.

7

8 COUNSEL APPEARING:

9 For the Plaintiff:

10 Mills + Woods Law, PLLC

 By: Robert T. Mills

11 5055 North 12th Street

 Suite 101

12 Phoenix, Arizona 85014

13 For the Defendants:

14 Stinson Leonard Street, LLP

 By: Carrie M. Francis

15 1850 North Central Avenue

 Suite 2100

16 Phoenix, Arizona 85004

17

18

19 Also present: Holly Rye, videographer

 Donna Fox

20

21

22

23

24

25

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4

1 VIDEO TECHNICIAN: We are going on the

2 record at 9:09 a.m. Today's date is June 14, 2016. This

3 is the video recorded deposition of Brandy Lane Williams

4 taken by defendant in the matter of Brandy Williams versus

5 G&K Services, Incorporated, Case No. 15-cv-01744-PHX-DDD

6 in the United States District Court for the District of

7 Arizona.

8 This deposition is being conducted at

9 Stinson Leonard Street, LLP, located at 1850 North Central

10 Avenue, Phoenix, Arizona. The court reporter is Carrie

11 Cariati from the firm of Carrie Reporting, LLC, located at

12 4032 North Miller Road, Scottsdale, Arizona. The

13 certified legal video specialist is Holly Rye with

14 Litigation Video Specialists, LLC, located at 3219 East

15 Camelback Road, Phoenix, Arizona.

16 Will the attorneys introduce themselves,

17 defendants first, please.

18 MS. FRANCIS: Carrie Francis from Stinson

19 Leonard Street on behalf of defendant G&K Services, Inc.

20 MR. MILLS: Bob Mills of Mills + Woods on

21 behalf of the plaintiff Brandy Williams.

22 VIDEO TECHNICIAN: Any other introductions

23 for people present in the room?

24 MR. MILLS: Also present with me is Donna

25 Fox, a paralegal in our firm.

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5

1 VIDEO TECHNICIAN: Thank you, Counsel.

2 Will the court reporter please swear in the

3 witness.

4

5 BRANDY LANE WILLIAMS,

6 a witness herein, having been first duly sworn by the

7 Certified Court Reporter to speak the truth and nothing

8 but the truth, was examined and testified as follows:

9

10 EXAMINATION

11 BY MS. FRANCIS:

12 Q. Can you state your full name for the record?

13 A. Brandy Lane Williams.

14 Q. Is it okay if I call you Brandy throughout the

15 questioning today?

16 A. Yes.

17 Q. Have you ever had your deposition taken before?

18 A. No.

19 Q. So there is a couple of ground rules since we

20 have the court reporter and the videographer taking down

21 everything. Typically it would be more of a conversation

22 where you could anticipate what I am asking and answer my

23 question maybe before I finish my question. But in this

24 situation, we have to be really careful not to talk over

25 each other and to let me finish my question completely

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6

1 before you start your answer. Is that okay?

2 A. Yes.

3 Q. If you don't understand a question I ask you --

4 and I am sure there will be many questions that I could

5 ask better -- feel free to tell me, "I don't understand

6 what you are asking," and I will rephrase the question for

7 you. Is that okay?

8 A. Yes.

9 Q. You also have to give verbal answers so that the

10 court reporter has something to write down. Were you to

11 nod your head or say "uh-huh," that is not something that

12 she can clearly take down in the record, so I may indicate

13 to you, "Is that a yes or is that a no," just so the court

14 reporter has something to take down. I am not trying to

15 suggest an answer to you in any way. I am just trying to

16 get something for the record. Is that okay?

17 A. Yes.

18 Q. Feel free to take a break at any time. We are

19 going to be here for quite a while because we have a lot

20 of information to go over. I would just ask that you

21 answer any question that is pending before you take a

22 break. Is that okay?

23 A. Yes.

24 Q. You understand that you are under oath?

25 A. Yes.

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1 Q. And you understand what that means, that you are

2 under the penalty of perjury if you were to not tell the

3 truth during this deposition today?

4 A. Yes.

5 Q. Are you on any medications currently -- are you

6 under the influence of any medications that would affect

7 your ability to recall events?

8 A. No.

9 Q. Have you had any prior involvement in court

10 proceedings other than this matter?

11 A. No.

12 Q. Have you ever filed for bankruptcy?

13 A. No.

14 Q. Have you ever filed a family court matter?

15 A. No.

16 Q. Have you ever had a family court case opened

17 against you?

18 A. No.

19 Q. Have you ever had an injunction against

20 harassment filed against you or on your behalf?

21 A. No.

22 Q. Have you ever been a witness in another case?

23 A. No.

24 Q. Have you ever provided testimony like what we

25 are doing here today?

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1 A. No.

2 Q. What did you do to prepare for your deposition

3 today?

4 A. Just reviewed my medical documentation as well

5 as my history with G&K.

6 Q. When you say your history with G&K, what did

7 that entail?

8 A. My employment date, my termination date, and

9 dates that I was promoted into different positions.

10 Q. Where did you find that information?

11 A. I have the copy of my hire letter and then also

12 copies of my agreement of promotion and my letter of my

13 raise.

14 Q. And are those documentations that have all been

15 provided to your counsel to produce to us in this case?

16 A. Yes.

17 Q. Do you have any notes that you took during your

18 employment about events that relate to this lawsuit?

19 A. Yes.

20 Q. When did you take those notes?

21 A. During my employment with G&K as they occurred.

22 Q. And did you look at those notes for the purposes

23 of refreshing your memory about testimony that you were

24 going to give today?

25 A. Yes.

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1 Q. How many pages do those notes consist of?

2 A. Approximately 30 to 40 pages each.

3 Q. And where are those notes kept?

4 A. They are kept on my computer. They were in my

5 e-mail.

6 Q. So what type of word processing program are they

7 on?

8 A. It was just a pdf format. They were just

9 scanned from my printer to my computer.

10 Q. So you had handwritten notes that were kept in

11 what form originally? Was it a binder or how did you

12 compile this?

13 A. Yes, they were just in a -- in a folder.

14 Q. And you scanned those into a file that you

15 maintain on your computer?

16 A. Yes.

17 Q. When did you scan those documents into your

18 computer?

19 A. At the beginning of my contact with Bob --

20 Q. And can you approximate a date?

21 A. -- about approximately March of 2015.

22 Q. And what is that file on your computer named?

23 A. G&K.

24 Q. And to clarify, you looked at those notes

25 yesterday?

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1 A. Yes.

2 Q. And did you review the notes in their entirety?

3 A. I scanned through them, but I read quite a few

4 of them.

5 Q. Have those notes been provided to your counsel

6 for production to the defendant in this case?

7 A. Yes.

8 MS. FRANCIS: Have those notes been

9 produced?

10 MR. MILLS: I believe we produced

11 everything, right? I am not aware -- I am not aware of

12 anything that we have that you don't have. I mean,

13 that's --

14 MS. FRANCIS: Okay. I don't think we have

15 handwritten notes about the events leading into the

16 complaint. I think we have handwritten notes about the

17 job issues --

18 MS. FOX: I think that is what she thinks

19 you are talking about.

20 MS. FRANCIS: Okay.

21 MS. FOX: We don't have any handwritten

22 notes in this case.

23 MR. MILLS: Can I -- let me ask -- this may

24 help clarify.

25 MS. FRANCIS: Sure.

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1 MR. MILLS: Are you talking about the

2 notebook that you gave us with the handwriting in it?

3 THE WITNESS: Yes, just about issues with

4 work.

5 MR. MILLS: Okay. Yeah, you have that.

6 BY MS. FRANCIS,

7 Q. Okay. Those notes consist of actual work

8 issues, HR issues that you dealt with when you worked

9 there, correct?

10 A. Yes.

11 Q. Do you have any notes about the events

12 concerning your disability or the claims that you are

13 asserting in the lawsuit?

14 A. No.

15 Q. Did you make any sort of timeline for purposes

16 of the litigation?

17 A. No.

18 Q. What other documents did you review besides the

19 notes that we just talked about and the letters that you

20 described previously for preparation?

21 A. My complaint to the EEOC and then my rebuttal

22 statement to the EEOC and then as well as my e-mails that

23 I had saved from my employment at G&K.

24 Q. Did you forward e-mails from your work computer

25 to your personal computer?

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1 A. Yes.

2 Q. Why -- when did you start doing that?

3 A. As soon as I started to feel that there was

4 retaliation and there was a wantingness for them to not

5 want me in the business anymore.

6 Q. Can you approximate a date when that first --

7 you first felt that way?

8 A. Approximately April of 2013.

9 Q. What happened in April of 2013 to start you to

10 feel that you were being retaliated against?

11 A. There was an uneasiness with the conversations

12 around me requesting to be off to go to doctors'

13 appointments, and just I was told an overall impression of

14 I am not active in the business.

15 Q. And who told you that you were not active in the

16 business?

17 A. Rachael Siggerud.

18 Q. And who was uneasy with your request for

19 doctors' appointments?

20 A. Rachael Siggerud.

21 Q. Is there anyone else that you feel retaliated

22 against you because of your medical issues other than

23 Rachael Siggerud?

24 A. Jacob Briscoe.

25 Q. Anyone else?

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1 A. Mitch Rubinoff.

2 Q. We will talk about that in more detail, but I

3 want to go back to my original question.

4 So around this time frame, April 2013, we

5 will see you starting to send e-mails to your home

6 computer?

7 A. I -- I don't recall.

8 Q. But it was because you started to feel that some

9 retaliation was ongoing or starting that you decided to

10 send e-mails to your home computer; is that correct?

11 A. Yes.

12 Q. What kind of e-mails would you send to your home

13 computer?

14 A. Just questions that I was being asked about my

15 engagement in the business or questions around my

16 participation or the time that I was taking off due to my

17 doctors' visits.

18 Q. So you would only send information to your home

19 computer that related to your medical issues?

20 A. If I felt it was closely related, yes.

21 Q. Did you send any competitive or business

22 information of G&K to your home computer?

23 A. Not -- not unless I was working on a document

24 purposely for G&K. I did work from home, but I didn't do

25 anything on my personal computer. I had a G&K-issued

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1 laptop, so if I did any work for G&K, I used the

2 G&K-issued laptop and I used their e-mail.

3 Q. So I want to be specifically clear. Did you

4 forward any business information of G&K, not information

5 related to your medical issue or leave, to your personal

6 computer?

7 A. I don't recall.

8 Q. Have you done an examination of your computer to

9 provide everything to your counsel that relates to G&K so

10 it be can produced in this case?

11 A. Yes.

12 Q. Have you preserved all the information that you

13 sent to your home computer from G&K on your home computer?

14 A. Yes.

15 Q. Have you deleted anything that relates to G&K

16 from your home computer?

17 A. I don't recall if anything has been deleted.

18 Q. Is it possible that you deleted information?

19 A. My husband has access to the computer, so I -- I

20 wouldn't be able to answer that.

21 Q. Have you deleted information?

22 A. I have not.

23 Q. Where do you keep the e-mails that you forwarded

24 to your home computer on your personal computer?

25 A. I have a Gmail account.

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1 Q. And in that Gmail account is there any subfiles

2 that relate specifically to e-mails you forwarded from

3 work?

4 A. No.

5 Q. So in your Gmail account, generally in your

6 inbox, you have information that relates to your

7 employment at G&K?

8 A. Yes.

9 Q. And you can search your inbox for those e-mails?

10 A. Yes.

11 Q. Have you done that?

12 A. Yes.

13 Q. When did you do that?

14 A. In the past two to three days.

15 Q. And what -- did you provide information at that

16 time to your counsel for production?

17 A. Yes.

18 Q. Has that information been produced to us?

19 A. Yes.

20 Q. And that had to do with the job search efforts

21 that you undertook?

22 A. Yes.

23 Q. Okay. That relates to your job search efforts

24 after G&K -- after leaving G&K, correct?

25 A. Yes.

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1 Q. Have you done a search of those e-mails in your

2 inbox that relate to the time frame when you were employed

3 at G&K and you were forwarding things to your home

4 computer?

5 A. No.

6 Q. I am trying to make sure that we have all the

7 information that you forwarded. Have you done some type

8 of search to produce everything that you forwarded from

9 your work account?

10 A. Yes. Initially when I retained Bob, I printed

11 everything out and gave him everything in person when we

12 had our first meeting.

13 Q. And that would have been when?

14 A. That would have been around May of 2013.

15 Q. And when you reference "Bob," you are talking

16 about your attorney?

17 A. Yes, my attorney, Bob.

18 MR. MILLS: You mean 2015.

19 THE WITNESS: 2015, yes, correct, 2015.

20 MR. MILLS: You said 2013.

21 BY MS. FRANCIS:

22 Q. Okay. Did you talk to anyone about preparing

23 for your deposition today --

24 A. Yes, yes.

25 Q. -- other than your counsel?

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1 A. No.

2 Q. I don't want to get into the content of your

3 conversations with your attorneys, but when did you meet

4 to prepare for the deposition?

5 A. We met over the telephone yesterday, and we met

6 Thursday last week in person.

7 Q. How long was the in-person meeting?

8 A. Four hours.

9 Q. Did you review any documents during that meeting

10 for the purposes of refreshing your testimony -- or your

11 memory so that you can provide testimony today?

12 A. Yes.

13 Q. What did you review during that meeting?

14 A. My medical documentation from my medical

15 providers as well as recorded phone documentation of

16 myself and Rachael Siggerud.

17 Q. And how many recorded conversations did you

18 review?

19 A. Two.

20 Q. Did you record any more than those two phone

21 conversations?

22 A. No.

23 Q. Did you review anything else with -- at your

24 in-person meeting with your attorneys?

25 A. Just the filing of the charge itself.

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1 Q. Anything else you can think of?

2 A. I don't recall anything else.

3 Q. And then you said you also had a phone

4 conversation yesterday with your counsel. How long did

5 that last?

6 A. Approximately 45 minutes.

7 Q. And did you review any documents during that

8 call?

9 A. My medical documentation.

10 Q. The same documents you had reviewed on Thursday?

11 A. Yes.

12 Q. Did reviewing the medical documents refresh your

13 memory about any particular events?

14 A. Nothing unusual other than the sequence of how

15 everything occurred.

16 Q. Did you talk to any of your family or friends

17 about your deposition today?

18 A. I talked to my sister. I didn't go in depth

19 about what -- about the case itself but just an awareness

20 that I was attending one today.

21 Q. Have you ever filed a charge of discrimination

22 other than in this case?

23 A. In what aspect?

24 Q. You understand what a charge of discrimination

25 is that you file with the EEOC, correct?

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1 A. Oh, okay.

2 No.

3 Q. You understand what it is though?

4 A. Yes, I understand.

5 Q. Have you filed another charge other than in this

6 case?

7 A. No.

8 Q. When you worked for G&K, did you keep any type

9 of calendar?

10 A. I did.

11 Q. And in what form?

12 A. It was in Lotus Notes, so it was through my

13 e-mail through G&K.

14 Q. Do you have a copy of your calendar from when

15 you worked at G&K?

16 A. No.

17 Q. Did you forward information from your calendar

18 to your home e-mail account?

19 A. No.

20 Q. Did you keep any type of paper calendar during

21 the time that you worked at G&K?

22 A. No.

23 Q. If we wanted to know when you had medical

24 appointments or work appointments during the time frame

25 that you worked at G&K, how could we figure that out?

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1 A. From my medical documentation.

2 Q. What about appointments that you had when you

3 were at G&K, any other way other than the Lotus calendar?

4 A. No.

5 Q. Did you print out any parts of your calendar so

6 that we could find a paper copy?

7 A. No.

8 Q. During the time that you worked at G&K, did --

9 was the calendar that you used always under the Lotus

10 program, or did that ever change?

11 A. No, it was always under the same program.

12 Q. Did you keep a diary during the time that you

13 worked at G&K?

14 A. No.

15 Q. Any text messages related to your work?

16 A. No.

17 Q. I know you produced one text message with Kaela,

18 correct?

19 A. Yes.

20 Q. Do you have additional text messages with Kaela

21 since the one that you produced in this case?

22 A. No.

23 Q. When was the last time you talked to Kaela?

24 A. It was March of 2016.

25 Q. Did you contact her or did she contact you?

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1 A. She contacted me.

2 Q. And how did she contact you?

3 A. She called me on my cell phone.

4 Q. And what did she say?

5 A. She was calling to let me know that she was

6 taking a visit to her aunt that lives in Tucson and wanted

7 to know if I would like to meet her for lunch.

8 Q. And did you?

9 A. No, I did not.

10 Q. Why not?

11 A. I was sick at the time and so I stayed home.

12 Q. Did you talk with Kaela at all about this

13 lawsuit?

14 A. No.

15 Q. To your knowledge, does Kaela know that you have

16 a lawsuit pending against G&K?

17 A. I am not aware.

18 Q. You never had a discussion with her about it?

19 A. No.

20 Q. She has never asked you about the lawsuit?

21 A. I -- I don't recall that she has.

22 Q. And so that conversation you said happened in

23 March of 2016?

24 A. Yes.

25 Q. Have you talked to her at all since then in any

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1 means, e-mail or anything like that?

2 A. Not that I recall.

3 Q. And before you talked to her in March of 2016,

4 when was the last time you had contact with her?

5 A. The last I can recall is March of 2015. She

6 takes a trip every year to her aunt's, so ...

7 Q. And it was the same situation where she called

8 and asked if you would meet?

9 A. Yes.

10 Q. And did you in 2015?

11 A. No.

12 Q. So when was the last time you physically saw

13 Kaela?

14 A. I don't recall a date, but it was at the HR

15 summit meeting for G&K in Minnesota.

16 Q. So when you were both still working there?

17 A. Yes.

18 Q. When was the last time you talked to Janelle?

19 A. I spoke to her last -- the end of last week she

20 called me.

21 Q. On your cell phone?

22 A. Yes.

23 Q. And what did she say?

24 A. She told me that you had contacted her in

25 regards to giving a deposition.

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1 Q. Anything else?

2 A. That was it.

3 Q. And what was your response?

4 A. I told her that, yes, my attorney was interested

5 in performing a deposition for her.

6 Q. And what was her response?

7 A. She stated that she didn't understand why and

8 that she didn't feel comfortable doing that.

9 Q. Did she say why she didn't feel comfortable?

10 A. Due to her termination from G&K.

11 Q. Do you -- did she say specifically what about

12 her termination made her feel uncomfortable?

13 A. She felt that it was a wrongful termination.

14 Q. Did she explain to you why?

15 A. She explained that she felt that it was very

16 last minute and that she was very unaware that it was

17 going to occur.

18 Q. Anything else?

19 A. That was it.

20 Q. Did she mention anything about any medical

21 condition she had?

22 A. No.

23 Q. Did she mention anything about maternity leave

24 or medical leave?

25 A. Yes.

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1 Q. What did she tell you about that?

2 A. She stated that she was on medical leave in 2013

3 when she had her daughter.

4 Q. And did she describe whether or not she felt

5 that played a role in her termination?

6 A. She did.

7 Q. What did she tell you?

8 A. She felt that -- that that was the reason behind

9 them terminating her.

10 Q. Did she explain to you that she would not travel

11 after her return from leave?

12 A. She did.

13 Q. And did she explain to you that that had an

14 impact on her ability to service Southern California?

15 A. No.

16 Q. What impact did she express that had on the

17 business that she would not travel?

18 A. I -- I don't recall.

19 Q. So what did she say to you specifically about

20 not being willing to travel when she returned from

21 maternity leave?

22 A. She stated that she was having difficulty

23 traveling due to nursing her newborn.

24 Q. Did she tell you that she would not travel

25 outside of her home site?

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1 A. No.

2 Q. When she said that she had difficulty traveling,

3 did she give you any details or specifics about what that

4 entailed?

5 A. No.

6 Q. And you also said that -- I'm sorry, Janelle

7 told you that she didn't think that she had any

8 information that was relevant to your case. Did she

9 explain what she meant by that?

10 A. She didn't say she didn't feel there was no

11 information that was relevant. She said that -- she

12 stated she didn't feel comfortable giving a deposition due

13 to the fact of her termination.

14 Q. Did she say anything about not overseeing you or

15 supervising you so that she wouldn't have any information

16 about your performance?

17 A. No.

18 Q. Did she oversee your performance in any way?

19 A. No. We were peers.

20 Q. And do you know when her termination occurred?

21 A. I do not know the exact date.

22 Q. It was after you left?

23 A. Correct.

24 Q. Do you know when she was on maternity leave?

25 A. She was on maternity leave when I was laid off

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1 from G&K, which was September of 2013.

2 Q. Do you know when her leave started?

3 A. I don't recall.

4 Q. And it is your understanding she was terminated

5 after her return from leave?

6 A. Yes.

7 Q. Other than Kaela and Janelle, are there any

8 other people that you think did comparable work at G&K as

9 to what you did?

10 A. There were others, but they were not in the

11 region that -- that we were in together.

12 Q. So they had different managers?

13 A. Yes.

14 Q. So the people that you would compare yourself to

15 would be Kaela and Janelle, correct?

16 A. Yes.

17 Q. Did you ever record any conversations with

18 anyone other than Ms. Siggerud?

19 A. No.

20 MS. FRANCIS: I think we are at Exhibit

21 No. 12.

22 (Deposition Exhibit No. 12 was marked for

23 identification by the reporter.)

24 BY MS. FRANCIS:

25 Q. The court reporter is showing you what we marked

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27

1 as Exhibit No. 11 to your deposition -- I'm sorry, 12.

2 Have you seen this document before today?

3 A. Yes.

4 Q. When was the last time you saw this document?

5 A. Thursday, last week.

6 Q. And did you ever provide revisions to this

7 document?

8 A. No.

9 Q. I want to talk about a few specific paragraphs.

10 If you could go to page 2 at paragraph 7 in Exhibit

11 No. 12 -- and tell me when you are there.

12 A. Okay.

13 Q. And this -- this paragraph relates to your FMLA

14 leaves, and I know there were a few of them, but I don't

15 think they are in dispute, so I want to just see if we can

16 summarily cover them. You first requested FMLA leave in

17 July of 2012, correct?

18 A. Yes.

19 Q. And that was for the birth of your child,

20 correct?

21 A. Yes.

22 Q. And you were granted leave?

23 A. Yes.

24 Q. And you were on leave for the birth of your son

25 until October 3rd of 2012, correct?

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28

1 A. Yes.

2 Q. And then you returned to your position as an HR

3 representative, correct?

4 A. Yes.

5 Q. And then you took another medical leave in

6 December of 2013, correct?

7 A. No, December of 2012.

8 Q. Thank you. That is correct.

9 And that -- at that point in time, you did

10 not have any more FMLA leave time available, correct?

11 A. Correct.

12 Q. So you were given a non-FMLA leave of absence,

13 correct?

14 A. Yes.

15 Q. And that leave of absence lasted until

16 January 11th of 2013, correct?

17 A. I don't recall the exact date.

18 Q. Do you recall how long the medical leave was --

19 the second medical leave that you took lasted?

20 A. Three to four weeks.

21 Q. About a month?

22 A. Yes.

23 Q. And when you returned from that leave, you again

24 were placed in your position of human resources

25 representative, correct?

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29

1 A. Yes.

2 Q. Do you have any concerns about how those medical

3 leaves were handled as it relates to this lawsuit?

4 MR. MILLS: Object to the form.

5 Go ahead and answer if you understand the

6 question.

7 BY MS. FRANCIS:

8 Q. I can break it down -- I can break it down

9 because it is multiple, so ...

10 MR. MILLS: Okay.

11 BY MS. FRANCIS:

12 Q. As it relates to the first leave that you took

13 for -- the leave of absence related to your son, did you

14 complain to anyone that that leave was handled

15 inappropriately?

16 A. No.

17 Q. Did you feel that anything about your initial

18 leave of absence for the birth of your child, that G&K did

19 anything wrong related to that leave?

20 A. No.

21 Q. So the second time you went on leave, which is

22 non-FMLA because we established that you used your FMLA

23 time for that year, correct?

24 A. Yes.

25 Q. And we established that lasted about 30 days.

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30

1 You requested leave, correct?

2 A. Yes.

3 Q. You were granted leave?

4 A. Yes.

5 Q. Did you ever complain to anyone at G&K about how

6 that leave was handled?

7 A. No.

8 Q. Do you have any concerns about how that three to

9 four weeks of leave was perceived or handled by G&K?

10 A. No.

11 Q. So what we are really focused on for purposes of

12 this lawsuit is the -- the third time you went on medical

13 leave, correct?

14 A. Yes.

15 Q. Good. That narrows it a lot.

16 Now, the -- the third time that you

17 requested medical leave, that would have happened on

18 July 8th of 2013, correct?

19 A. No.

20 Q. When did you request leave the third time?

21 A. It was suggested by Rachael Siggerud after I

22 requested an ADA accommodation that I should request FMLA

23 leave.

24 Q. The request that you made for an ADA

25 accommodation, that happened on July 8th of 2013, correct?

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1 A. That was the -- the first time I had put it in

2 writing, but not the first time that I had requested an

3 accommodation.

4 Q. When was the first time that you requested an

5 accommodation?

6 A. On my return from the general leave in December

7 of 2012.

8 Q. Who did you request an accommodation with?

9 A. Rachael Siggerud.

10 Q. And was this in writing or how did you make this

11 request?

12 A. It was verbally.

13 Q. Where were you?

14 A. I was in the plant location in Phoenix.

15 Q. And where was Ms. Siggerud?

16 A. I am unsure. She travels. I don't recall.

17 Q. So this was a phone conversation?

18 A. Yes.

19 Q. And was there anyone else present on the call?

20 A. No.

21 Q. And what accommodation did you request of

22 Ms. Siggerud on your return from leave in December of

23 2012?

24 A. To continue to work with my medical providers to

25 attend doctors' appointments or testing as necessary.

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1 Q. And what was Ms. Siggerud's response?

2 A. That that was fine.

3 Q. Did you do anything to formalize this request

4 through the HR department at G&K?

5 A. No.

6 Q. You understand that there is a formal process to

7 request an ADA accommodation, correct?

8 A. Yes.

9 Q. And there are other people involved in that

10 process other than Ms. Siggerud, correct?

11 A. She reassured me that she would take care of the

12 situation after our conversation.

13 Q. My question was a little bit more specific. Do

14 you want the court reporter to read it back?

15 A. Yes.

16 (The following requested portion of the

17 record was read back by the reporter.)

18 "QUESTION: And there are other people

19 involved in that process other than Ms. Siggerud,

20 correct?"

21 THE WITNESS: Yes.

22 BY MS. FRANCIS:

23 Q. Did you know their names at the time when you

24 were working at G&K?

25 A. I don't recall.

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1 Q. But there were specific people within the HR

2 department that dealt specifically with accommodation

3 requests, correct?

4 A. Yes.

5 Q. And you know that because you were in an HR role

6 for several years?

7 A. Yes.

8 Q. When you were working as an HR representative,

9 if an employee requested an accommodation, what would you

10 have done?

11 A. I would walk through the process with them, and

12 I would give them the documents to request a leave.

13 Q. And so you were familiar with what those

14 documents were?

15 A. Yes.

16 Q. What were those documents?

17 A. It was a request for FMLA leave.

18 Q. Was there an actual form that was titled

19 "Request For FMLA Leave"?

20 A. Yes.

21 Q. Was there a form that dealt specifically with

22 requests for ADA accommodations?

23 A. No.

24 Q. So when an employee requested an ADA

25 accommodation, you would give them the FMLA form?

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1 A. No.

2 Q. What would you give them when they requested an

3 ADA accommodation?

4 A. I didn't have anyone request an ADA

5 accommodation.

6 Q. What would you have done as an HR representative

7 for G&K during this time frame if someone had requested an

8 ADA accommodation?

9 MR. MILLS: Object to the form. Calls for

10 speculation.

11 Go ahead.

12 THE WITNESS: I would have suggested that

13 they put something in writing.

14 BY MS. FRANCIS:

15 Q. And submit it to who?

16 A. To myself.

17 Q. And then what would you have done with it?

18 A. Would have sent that to our corporate office to

19 benefits.

20 Q. Who?

21 A. Our benefits department.

22 Q. Was there a particular person?

23 A. I don't recall her name.

24 Q. But there was a person that you would have sent

25 it to?

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1 A. Yes.

2 Q. And did that person to your knowledge deal

3 specifically with ADA requests?

4 A. I don't recall.

5 Q. Given your experience as an HR representative,

6 is there a reason that you didn't put your request for an

7 accommodation in December of 2012 in writing?

8 A. Due to the fact that Rachael was supporting me

9 at the time, that was the reason why I didn't put anything

10 in writing initially. She was -- she was being supportive

11 of my need for a leave.

12 Q. Did you actually tell Ms. Siggerud that you

13 needed an ADA accommodation or did you use other terms?

14 A. I don't specifically remember saying I needed a

15 request for ADA.

16 Q. In December of 2012?

17 A. Yes.

18 Q. Is it possible that you just said, "I am going

19 to have some medical appointments that I may need to

20 attend, so I may have to adjust my schedule"? Is it

21 possible that the conversation went more like that?

22 A. No.

23 Q. But you are not sure you used the terms "ADA

24 accommodation"?

25 A. Correct.

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1 Q. You recall telling her that you needed time to

2 attend appointments?

3 A. Yes.

4 Q. And she was okay with that?

5 A. Yes.

6 Q. Did you have a set schedule when you worked at

7 G&K --

8 A. No.

9 Q. -- in the representative role?

10 A. No.

11 Q. In the generalist role, did you have a set

12 schedule?

13 A. No.

14 Q. When did you typically come to work -- or I

15 should say start work?

16 A. Start work, it could vary depending on meetings

17 that we had. Anywhere from 5:00 a.m. to 6:00 or 7:00 p.m.

18 Q. That was your start time or that was your

19 typical schedule?

20 A. That was my typical schedule. It would vary

21 based on meetings in the business.

22 Q. Did you have to -- when you worked remotely, did

23 you have to log on to a company remote access site?

24 A. Yes.

25 Q. And describe that process for me. What would

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1 you do when you logged on from home?

2 A. There was a -- it was called a VPN, which is the

3 company website that we had to log into for access.

4 Q. And when you would work in the office in

5 Phoenix, would you also log in the same way?

6 A. I would if I needed access to a system, if I was

7 working on something specifically.

8 Q. But you didn't always log in right when you

9 first started work?

10 A. No.

11 Q. Is there any way that we can tell -- because you

12 were an exempt employee, you didn't keep track of your

13 time, correct?

14 A. Yes.

15 Q. Is there any way we could tell when you were

16 working and when you were not working?

17 A. No.

18 Q. You didn't keep track of your hours

19 separately --

20 A. No.

21 Q. -- at any point in time?

22 A. No.

23 Q. We talked about the accommodation that you

24 discussed with Ms. Siggerud in December of 2012. Was the

25 next time that you requested an accommodation the one you

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1 submitted in writing on July 8th of 2013?

2 A. Can you be more specific?

3 Q. Sure. When we first started talking, we were

4 trying to set time lines for about when you requested an

5 accommodation, and I suggested that it was with the

6 written request that we know was dated July 8th of 2013.

7 And you told me, "No, I actually requested it earlier in

8 December of 2012" when you came back from leave, correct?

9 A. Correct.

10 Q. I am trying to understand. Was there another

11 time that you requested an accommodation between December

12 of 2012 and July 8th of 2013?

13 A. No. It had been ongoing from the first initial

14 request in December of 2012.

15 Q. Okay. Did you ever raise the issue of an

16 accommodation with anyone other than Ms. Siggerud?

17 A. I don't recall.

18 Q. You don't have a specific memory of telling

19 anyone else outside of the two conversations or the two

20 instances we talked about where you requested an ADA

21 accommodation from anyone at G&K?

22 A. No.

23 Q. Did you discuss your medical issues with anyone

24 at G&K other than Ms. Siggerud?

25 A. No.

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1 Q. So to your knowledge, the only people that --

2 within G&K that are aware of the medical issues that you

3 were going through is Ms. Siggerud?

4 A. Yes.

5 Q. Did anyone else at G&K suggest to you that they

6 knew about your medical condition other than Ms. Siggerud?

7 A. Yes.

8 Q. Who?

9 A. Jacob Briscoe.

10 Q. What did Mr. Briscoe say to you about your

11 medical condition?

12 A. He didn't say anything specific about my medical

13 condition but just the -- just the awareness of my request

14 for a leave.

15 Q. And when did this happen?

16 A. In December of twenty -- 2012.

17 Q. So on your return from your second leave, that

18 would -- your return from your second leave would have

19 been in January of 2013, correct?

20 A. Yes.

21 Q. So you are saying Mr. Briscoe informed you that

22 he was aware of your request for leave when?

23 A. In December of 2012.

24 Q. When you first requested your second leave?

25 A. Yes.

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1 Q. So where were you when this conversation

2 happened?

3 A. I was in the Phoenix location with him.

4 Q. And so you were physically present with each

5 other?

6 A. Yes.

7 Q. And what did he say to you?

8 A. That Rachael had told him that I had requested a

9 leave and that she told him that I would be out of the

10 business.

11 Q. For how long?

12 A. I don't recall.

13 Q. And what was your response to him?

14 A. That, yes, that I would be on leave.

15 Q. And did he indicate to you that he had any

16 knowledge of what your underlying medical condition was?

17 A. No. The only thing he stated was that he

18 understood that it was stemming from the birth of my son

19 from my first leave.

20 Q. And you had never discussed with Mr. Briscoe

21 that you had medical issues that resulted from the birth

22 of your son, correct?

23 A. Can you restate that?

24 Q. Okay. Did you ever discuss with Mr. Briscoe

25 that you had medical issues that stemmed from the birth of

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1 your son?

2 A. Yes.

3 Q. And when did those conversations happen?

4 A. When he told me that Rachael made him aware that

5 I had requested a leave and that I would be gone out of

6 the business for about three to four weeks.

7 Q. And what did you tell him about your medical

8 issues during that time?

9 A. I didn't tell him any specifics. I just told

10 him that I had ongoing issues from the birth of my son.

11 Q. Did you give him any specifics?

12 A. No, no.

13 Q. To the best of your recollection, is that

14 exactly what you said to him?

15 A. I -- I don't recall if that is exactly what I

16 said.

17 Q. Okay. To the best of your memory, what did you

18 specifically tell Mr. Briscoe about your medical

19 condition?

20 A. That it was just a continuance from what had

21 happened with the birth of my son.

22 Q. And what was his response?

23 A. He just said, "Okay."

24 Q. Did that interaction with Mr. Briscoe cause you

25 to feel like you were being retaliated against or treated

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1 differently?

2 A. Not at that time.

3 Q. So there was nothing about that conversation

4 that concerned you?

5 A. No.

6 Q. On any other occasion, did Mr. Briscoe discuss

7 with you your medical condition?

8 A. No.

9 Q. To your knowledge, did he have any additional

10 information other than what you provided to him about your

11 medical condition?

12 A. I am not aware.

13 Q. You -- you never heard from anyone that he had

14 additional information or he never suggested to you that

15 he knew more?

16 A. Rachael told me that she had conversations with

17 him about my leave, but I am not sure of any specifics.

18 Q. Do you have any reason to believe that any of

19 the confidential medical information that you shared with

20 Ms. Siggerud was not kept confidential?

21 A. Could you restate that?

22 Q. Sure. You provided more detail to Ms. Siggerud

23 about your medical condition, correct?

24 A. Yes.

25 Q. And you expected that to be kept confidential?

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1 A. Yes.

2 Q. Do you have any reason to believe that she

3 didn't keep that information that you provided

4 confidential?

5 A. I am unsure.

6 Q. You don't have any knowledge of anything that

7 happened that would lead you to believe she was talking

8 about your medical issues?

9 A. No. I am unaware of when they had

10 conversations.

11 Q. Okay. But you have not heard anything that

12 would suggest to you that she was disclosing your

13 confidential medical information?

14 A. Can you restate that? In -- in what aspect?

15 Q. Sure. I am wondering, she set up -- you know,

16 we are having these confidential conversations about your

17 medical issues. Did you ever learn that she had breached

18 those confidences or somebody came back to you and they

19 knew information that you don't feel they should have

20 known?

21 A. I am unaware, no.

22 Q. If you look at paragraph 13 in Exhibit No. 12 --

23 and tell me when you are there.

24 A. On page 3?

25 Q. Yes.

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1 A. Okay.

2 Q. This paragraph describes that you have a

3 disability. Do you see that?

4 A. Yes.

5 Q. When did you become disabled?

6 A. Can you explain the question a little more?

7 Q. Paragraph 13 says: Plaintiff is a qualified

8 individual with a disability.

9 Did I read that correctly?

10 A. Yes.

11 Q. When did you become disabled? I am looking for

12 a date.

13 A. I applied for Social Security and it was started

14 May of 2015.

15 Q. And what is your disability?

16 A. It was a few different things. It was due to

17 fibromyalgia, lichen planus, seborrheic dermatitis and

18 anxiety and OCD.

19 Q. And you are 100 percent disabled as of May 2015?

20 A. I am not sure. They -- they didn't give me a

21 statement of if it was a total disability but -- other

22 than "you are qualified."

23 Q. For benefits?

24 A. Yes.

25 Q. When were you first diagnosed with fibromylagia?

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1 A. Fibromyalgia?

2 Q. Myalgia.

3 A. I don't recall the specific date. I just know

4 which doctor that it was.

5 Q. Can you estimate for me when you were diagnosed?

6 A. 2015.

7 Q. And who was the physician?

8 A. John Tesser, Dr. John Tesser.

9 Q. And the second medical diagnosis you said was

10 for lichen --

11 A. Lichen planus.

12 Q. And what is that?

13 A. It is an autoimmune skin disorder.

14 Q. And when were you diagnosed with that?

15 A. I don't recall the exact date.

16 Q. Can you estimate for me a year?

17 A. 2014.

18 Q. And what was the physician that diagnosed you?

19 A. Dr. Joseph Brooks.

20 Q. And I don't know what the next thing you said

21 was. It started with an S.

22 A. Oh, seborrheic dermatitis.

23 Q. What is that?

24 A. It is a skin disorder that is also -- they

25 believe it to be autoimmune-related.

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1 Q. And when were you diagnosed with that?

2 A. In July of 2012.

3 Q. And what was the physician's name that diagnosed

4 you?

5 A. Victor Kissil.

6 Q. Can you spell the last name?

7 A. K-i-s-s-i-l.

8 Q. And you said you also were diagnosed with

9 anxiety?

10 A. Yes.

11 Q. And when were you diagnosed with that?

12 A. I don't recall the exact date.

13 Q. And can you give me a year though?

14 A. The psychiatrist I see -- she was not specific

15 on the diagnosis other than us just having conversations

16 around what I needed support with.

17 Q. And when did you start seeing that psychiatrist?

18 A. Two -- 2015.

19 Q. And what is her name?

20 A. Marianne Hutchison.

21 Q. Had you been diagnosed by any physician with

22 anxiety prior to Dr. Hutchison?

23 A. I don't recall.

24 Q. And you also said you have OCD. You have been

25 diagnosed with OCD, correct?

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1 A. Yes.

2 Q. And when were you diagnosed with that?

3 A. I would say 1999.

4 Q. And who diagnosed you with OCD?

5 A. The previous counselor that I was seeing.

6 Q. What was that person's name?

7 A. I don't recall.

8 Q. Was it in Arizona?

9 A. No.

10 Q. What state?

11 A. Arkansas.

12 Q. Do you recall the name of the medical practice?

13 A. I do not.

14 Q. Do you recall an address or a street?

15 A. Oh, no, I do not.

16 Q. Do you have any medical records related to your

17 original OCD diagnosis?

18 A. No.

19 Q. And if you look back at Exhibit No. 12 -- and we

20 are still on paragraph 13 --

21 A. Um-hum.

22 Q. -- it says that your disability substantially

23 limits one or more of your major life activities. Can you

24 tell me what major life activities your disability

25 impacts?

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1 A. I am really unaware of what that means.

2 Q. Are you unable to do anything that regular

3 people that don't have your medical conditions do?

4 A. No.

5 Q. Did your OCD prevent you from doing any of your

6 job functions at G&K?

7 A. No.

8 Q. Did your -- and I apologize for not being able

9 to say these medical terms -- the skin --

10 A. I can't even say them.

11 Q. You are -- you are doing fine.

12 Your -- the skin disorder that you told me

13 about that you were diagnosed with in July of 2012, did

14 that prevent you from doing any of your essential job

15 functions at G&K?

16 A. No.

17 Q. Did any -- did any of the medical issues that

18 you had when you were working at G&K prevent you from

19 doing any of your job functions?

20 A. No.

21 Q. So I understand the accommodation that you

22 needed was time to attend medical appointments, correct?

23 A. Yes.

24 Q. You didn't need an alteration of your job duties

25 in any way?

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1 A. No.

2 Q. You didn't need an alteration of your goals or

3 any of your performance objectives in any way?

4 A. No.

5 Q. Did you ever tell Mr. Briscoe that you had

6 mental health problems?

7 A. No.

8 Q. If you look at page 4 at paragraph 26 -- and

9 tell me when you are there --

10 A. Okay.

11 Q. -- you received a pay increase in May of 2013,

12 correct?

13 A. Yes.

14 Q. And it was around -- a little over the -- strike

15 that.

16 It was an increase of 11.2 percent?

17 A. Approximately.

18 Q. Do you have an understanding of why you received

19 that pay increase?

20 A. Yes.

21 Q. Tell me why.

22 A. I was put into a new role of HR generalist.

23 Q. Didn't your job as a generalist actually start

24 in February of 2013?

25 A. Yes.

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1 Q. Were you given a pay increase at that time?

2 A. No.

3 Q. So after your change to the new role, you only

4 got a pay increase in May?

5 A. Yes.

6 Q. Other than being in that new role, do you have

7 an understanding for why you received a pay increase?

8 A. This pay increase in May?

9 Q. Yes.

10 A. I -- I am -- can you restate that question?

11 Q. Is there any other reason that you think that

12 you got a raise in May of 2013 other than because you were

13 put in a new job?

14 A. No.

15 Q. Did your new job have more responsibilities?

16 A. Yes.

17 Q. How did your job as a generalist differ from

18 that of a representative?

19 A. It would require me to travel due to the new

20 locations that I was covering.

21 Q. Anything else?

22 A. No.

23 Q. So if we were to look at a job description for

24 what you did as an HR representative, those would be your

25 same duties as an HR generalist; just you were covering

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1 more locations, correct?

2 MR. MILLS: Object to the form.

3 THE WITNESS: No.

4 BY MS. FRANCIS:

5 Q. Why is -- why is my statement wrong?

6 A. The -- the job -- the job requirements were

7 different.

8 Q. In what way?

9 A. I -- I -- I am unsure. It was -- we were --

10 they were in the process of developing the role.

11 Q. And was it still under development at the time

12 that you left?

13 A. Yes.

14 Q. What was your understanding of how the jobs

15 differed?

16 A. That we would no longer be doing the day-to-day

17 tasks that we were doing as payroll and benefits and just

18 general things that we handled at the -- on a plant level

19 every day, that they were centralizing those things to the

20 corporate office.

21 Q. And with those functions removed, what were

22 those new functions as a generalist that you were to be

23 working on?

24 A. To be a strategic partner in the business and to

25 support the managers with any needs or concerns that they

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1 had.

2 Q. And what did that mean to you?

3 A. Just to continue as I had before with the

4 relationships that I had or to build new relationships

5 with the new locations that I was covering.

6 Q. When you were a representative, what location

7 were you assigned to?

8 A. I covered Arizona, so there were four locations.

9 There was Phoenix, Tucson, Prescott Valley and Yuma.

10 Q. And how did that change after you became a

11 generalist?

12 A. I was made aware that I would take on new

13 locations and travel to the plant in Santa Fe Springs,

14 which was in Los Angeles; and Ontario, California; Sun

15 Valley, California; and San Diego, California.

16 Q. And who had previously covered those -- those

17 locations?

18 A. Leticia Rovero.

19 Q. And what happened to her job, if you know?

20 A. She was changed to the position of talent

21 acquisition specialist for recruiting.

22 Q. Is that a lateral change or a promotion, if you

23 know?

24 A. Lateral.

25 Q. So she probably -- well, to your knowledge, she

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1 didn't get the pay increase that you got?

2 A. I am -- I am not aware.

3 Q. Would you consider your change from a -- a

4 representative to a generalist to be a promotion?

5 A. No.

6 Q. But you got a pay increase?

7 A. Yes.

8 Q. A significant one?

9 A. Yes.

10 Q. But you still see that as a lateral move?

11 A. Yes.

12 Q. Did all the representatives get promoted to

13 general -- or changed into the position of generalist?

14 A. Yes.

15 Q. How many representatives were there before the

16 HR restructuring?

17 A. In the company or just in the region I was in?

18 Q. In your region.

19 A. Three, including myself.

20 Q. I thought you just said that there was a woman

21 that also covered Southern California?

22 A. Oh, prior to the realignment?

23 Q. Right.

24 A. Oh, okay. There were -- there would have been

25 five.

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1 Q. And how many became generalists to your

2 knowledge?

3 A. Three.

4 Q. And you don't perceive that to have been a

5 promotion for those three?

6 A. No. We were all still in HR.

7 Q. And the other two, one became a talent

8 acquisition person?

9 A. Yes.

10 Q. And what --

11 A. The others became talent acquisition

12 specialists.

13 Q. And that is a recruiting position?

14 A. Yes.

15 Q. But you don't know if they received a pay

16 increase?

17 A. I am not aware, no.

18 Q. Do you talk to any of those two individuals that

19 worked before in the region?

20 A. No.

21 Q. At the time that you were transferred into the

22 role of generalist, can you approximate for me how many

23 employees there were in Phoenix that you were responsible

24 for?

25 A. I would be guessing, but I would say maybe 120.

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1 Q. And how many were there in Prescott to the best

2 of your knowledge?

3 A. Prescott Valley, there were approximately four

4 to five.

5 Q. And in Tucson?

6 A. Oh, I would be guessing on that as well.

7 Q. I know it is a long time ago, so give me your

8 best estimate.

9 A. I would say 20 to 25.

10 Q. And in Yuma?

11 A. Two.

12 Q. And how many employees would you estimate there

13 were in Santa Fe Springs?

14 A. Approximately 200.

15 Q. And in Ontario?

16 A. 20 to 30.

17 Q. And in San Diego?

18 A. Approximately the same. 20 -- 20 to 25 maybe.

19 Q. And in Sun Valley?

20 A. I would say about the same.

21 Q. 20 to 30?

22 A. 20 -- yeah, 20 to 30.

23 Q. And the other generalists were Kaela and

24 Janelle, correct?

25 A. Yes.

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1 Q. And Kaela covered the Minneapolis area, the

2 Midwest --

3 A. Yes, Minnesota.

4 Q. -- mainly?

5 A. Um-hum. Yes.

6 Q. Do you know how many employees she was

7 responsible for dealing with in her assigned locations?

8 A. I am not aware.

9 Q. And do you have any knowledge of the number of

10 employees that Janelle was overseeing at her assigned

11 locations?

12 A. No.

13 Q. Did you always have Southern California assigned

14 to you after you were a generalist or did that change?

15 A. Can you restate the question?

16 MR. MILLS: Object to the form.

17 BY MS. FRANCIS:

18 Q. Sure. Did you always have Southern California

19 assigned to you when you were working as a generalist, or

20 when you started, did you not have that and it later

21 became assigned to you?

22 A. No, I had it immediately.

23 Q. When Janelle went out on maternity leave, did

24 that affect the number of locations that you oversaw at

25 all to your knowledge?

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1 A. No.

2 Q. So you were never told that you were covering

3 Southern California for a period of time because Janelle

4 was out on leave?

5 A. No.

6 Q. If you look at paragraph 23 in Exhibit No. 12,

7 on January 11th of 2013 after you had requested or

8 indicated that you needed an accommodation in

9 December 2012, you presented Ms. Siggerud with a doctor's

10 note that cleared you to return to work?

11 A. Yes.

12 Q. Did that doctor's note indicate that you needed

13 to continue to attend medical appointments?

14 A. I don't recall.

15 (Deposition Exhibit No. 13 was marked for

16 identification by the reporter.)

17 MR. MILLS: I am so glad you are doing

18 these sequentially, too. It drives me nuts when people

19 want to start over at deposition. It drives me crazy.

20 MS. FRANCIS: I agree.

21 BY MS. FRANCIS:

22 Q. The court reporter has handed you what has been

23 marked as Exhibit No. 13. Have you seen this document

24 before?

25 A. Yes.

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1 Q. Is this the document that you provided to

2 Ms. Siggerud that is referenced in Exhibit 12 at paragraph

3 23?

4 A. I don't recall.

5 Q. Exhibit -- what is Exhibit No. 13?

6 A. It is a return to work notice.

7 Q. Did you obtain any other return to work notice

8 that you can recall other than Exhibit No. 13?

9 A. No.

10 Q. And did you give Exhibit No. 13 to Ms. Siggerud?

11 A. Yes.

12 Q. And this Exhibit 13 indicates that you have no

13 limitations at this time. Patient is cleared to return to

14 work.

15 Correct?

16 A. Yes.

17 Q. And it is dated January 16th of 2013, correct?

18 A. Yes.

19 Q. Does it indicate in Exhibit No. 13 that you need

20 an ongoing accommodation of any sort?

21 A. No.

22 Q. In Exhibit No. 12 at paragraph 27, it indicates

23 that on July 8th that you requested in writing a medical

24 accommodation; is that correct?

25 A. Yes.

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1 Q. Why did you feel the need to put this request in

2 writing when in the past you had just spoken with

3 Ms. Siggerud about time that you needed for medical

4 appointments?

5 A. In the past she had been very supportive, but as

6 the time had gone on and I attended more and more medical

7 appointments, when we would have conversations, I would

8 feel that she would be very short with me or that she

9 would be very agitated just in our conversations of what

10 was going on with my health and the number of appointments

11 that I was attending.

12 Q. Would you tell Ms. Siggerud when you had medical

13 appointments every time that you were going to an

14 appointment?

15 A. I don't recall.

16 Q. But you perceive that Ms. Siggerud was upset

17 about the number of appointments that you had, correct?

18 A. Yes.

19 Q. Can you explain to me how -- if Ms. Siggerud

20 didn't know when you were taking medical appointments, how

21 she could be upset about you taking so many appointments?

22 MR. MILLS: Object to the form.

23 Go ahead.

24 THE WITNESS: I -- I had an HR calendar or

25 I would e-mail her to let her know.

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1 BY MS. FRANCIS:

2 Q. And when you would e-mail her to let her know,

3 would you do that on every occasion that you took a

4 medical appointment?

5 A. I don't recall.

6 Q. It is possible you didn't?

7 A. I don't recall.

8 Q. So on occasion you would let her know?

9 MR. MILLS: Object to the form.

10 THE WITNESS: I -- I don't -- I am -- I am

11 not sure.

12 BY MS. FRANCIS:

13 Q. Do you have any specific memory of e-mailing

14 Ms. Siggerud and telling her you were taking a medical

15 appointment?

16 A. Yes.

17 Q. On how many occasions do you have that specific

18 memory?

19 A. I don't recall.

20 Q. Okay. Well, let's talk about the first one.

21 You said you had a specific memory of telling her you were

22 going on a medical appointment. What is the first one you

23 recall?

24 A. It would have been after I returned from leave

25 in January.

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1 Q. Why did you feel the need to discuss this

2 specific appointment with Ms. Siggerud?

3 A. Because I had just returned from the -- the

4 general leave.

5 Q. And so this would have been in what time frame?

6 A. I am -- I am not sure.

7 Q. In January of 2013 or prior to that?

8 A. In January of 2013.

9 Q. And was this done verbally or by e-mail?

10 A. Verbally.

11 Q. Let me go back to something else you said. You

12 said something about having a calendar that you put

13 appointments on, correct?

14 A. Yes.

15 Q. When you put appointments for medical -- strike

16 that.

17 Would you put your medical appointments on

18 your work calendar?

19 A. No. I wouldn't put them as medical

20 appointments. I would put them as a meeting, as Rachael

21 instructed me to do.

22 Q. So there would be no way for anyone to tell by

23 looking at your calendar that you were going on a medical

24 appointment versus an appointment with a manager, correct?

25 A. I -- I am -- I am unaware. I am -- I am not

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1 sure.

2 Q. You wouldn't identify that it was a medical

3 appointment on your calendar?

4 A. I -- I am not sure.

5 Q. Well, I am getting confused now. Would you put

6 your medical appointments on your work calendar?

7 A. No.

8 Q. So if another employee of G&K was looking at

9 your work calendar -- because other people had access to

10 your calendar, correct?

11 A. Yes.

12 Q. The Phoenix plant had access to your calendar?

13 A. Yes.

14 Q. They would not be able to tell when you were

15 taking a medical appointment versus when you had some

16 other work-related appointment, correct?

17 A. I -- I am not unsure if they would know what

18 kind of appointment it was. It would just say "meeting."

19 Q. So how would they know it was a medical

20 appointment?

21 A. I -- I am not sure.

22 Q. If you don't say it is a medical appointment,

23 how would anyone know at work that it is a medical

24 appointment?

25 A. Well, in my conversations with Jacob Briscoe, I

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1 would let him know that I was leaving the plant.

2 Verbally, I would go to his office and say: Hey, I'm

3 leaving, going to a doctor's appointment. I will be back.

4 Q. So if you told somebody, they would know?

5 A. Yes.

6 Q. But by looking at your calendar, no one would --

7 within G&K could tell that you were going to a medical

8 appointment, correct?

9 A. No.

10 Q. I am not correct?

11 A. No, you are correct. They would not know, not

12 from reading the calendar.

13 Q. Okay. So let's go back to your conversation

14 with Ms. Siggerud. You said you had a specific memory of

15 telling her about certain appointments. So the first one

16 we said was sometime in January of 2013, correct?

17 A. Yes.

18 Q. And this was a verbal conversation --

19 A. Yes.

20 Q. -- and over the phone?

21 A. Yes.

22 Q. And what did you tell her?

23 A. I don't recall specifically what I said to her.

24 Q. To the best of your memory, what did you say?

25 A. That I had the need to attend a follow-up

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1 appointment.

2 Q. And what was her response?

3 A. I don't recall.

4 Q. Was she upset?

5 A. Not that I recall.

6 Q. When is the next time you have a specific memory

7 of talking to Ms. Siggerud about taking time off for a

8 medical appointment?

9 A. I -- I don't recall. There was -- there was a

10 lot of appointments.

11 Q. I understand there were a lot of appointments.

12 What I am wanting to talk about is when you told

13 Ms. Siggerud that you had to take time off for an

14 appointment specifically. You previously testified that

15 you did have a specific memory of that happening. We

16 talked about one. Are there more that you have a specific

17 memory of?

18 A. June of 2013.

19 Q. And tell me about your memory. What do you

20 recall?

21 A. I was going to have surgery, and so I called her

22 to have a conversation with her to let her know that I

23 would need to have that day off to have the surgery

24 performed and then I would return the following day.

25 Q. And what was her response?

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1 A. I don't recall.

2 Q. Was the surgery related to the medical issues

3 that you had requested medical leave for?

4 A. Yes.

5 Q. So it was one of the ongoing issues from the

6 birth of your son, correct?

7 A. Yes.

8 Q. Was Ms. Siggerud upset about your need to take

9 time off for this surgery?

10 A. She seemed agitated by me requesting to -- to

11 take off to attend the surgery. She asked me quite a few

12 questions about why and how long, you know, I would be out

13 or how long it would be ongoing.

14 Q. Why did she -- in what way did you perceive her

15 to be agitated? What did she say besides asking you those

16 questions that led you to believe she was agitated?

17 A. She would be very short with me or she would

18 overtalk me when I was trying to explain things to her.

19 Q. Can you be more specific?

20 A. If I was trying to explain something -- if she

21 would ask me a question and I would try to explain it to

22 her, she would cut me off and be just short in her words

23 with me, very abrupt with what she was saying, or she

24 would just -- she wouldn't let me finish my sentence or

25 kind of overtalk me.

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1 Q. Did she say anything specific about your medical

2 appointment other than asking you questions about the when

3 and how long, the details of how long you would be out?

4 A. She stated that she felt that they were becoming

5 more and more common, that I was attending more

6 appointments, and I felt a frustration from her that I was

7 having to attend more doctors' appointments or -- or be

8 out of the business due to the health issues that I was

9 having.

10 Q. Did you feel that you could complete your job

11 duties irrespective of having to attend these appointments

12 or have this surgery done?

13 A. Yes. I was -- I was there every day outside of,

14 you know, the day of having the surgery. I performed my

15 job every day. I even worked from home, you know, if

16 there was a -- a task that needed to be completed as well,

17 so ...

18 Q. Did she permit you to take time off for the

19 surgery?

20 A. Yes.

21 Q. And after you returned from work, did she -- or

22 after you returned to work from the surgery, did she make

23 any comments relative to you taking that time off?

24 A. She -- she -- she did.

25 Q. What did she say?

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1 A. She called me. It was in the conversation that

2 was recorded from June.

3 Q. And during that conversation, she made a comment

4 about your surgery?

5 A. No, not about the surgery.

6 Q. Okay. The -- I was asking specifically, did she

7 ever make any comment about the time you took for the

8 surgery?

9 A. Yes, she stated that there was an issue with a

10 perception from other managers that I was away from work

11 too much.

12 Q. Okay. Did she make a comment specific to the

13 surgery?

14 A. No.

15 Q. But you believe when she talked to you about

16 this perception that it was in reference to the time you

17 took off for the surgery?

18 A. That was one of the times, yes.

19 Q. She didn't say that specifically; that was your

20 interpretation of what she said, correct?

21 A. Yes.

22 Q. Do you have a specific memory of any other

23 conversations with Ms. Siggerud about you needing time off

24 for medical appointments?

25 A. In July after I requested the ADA accommodation.

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1 Q. You told her that you were going to attend a

2 specific appointment?

3 A. Yes.

4 Q. And what was that for?

5 A. I don't recall.

6 Q. And how much time were you asking off for?

7 A. Just an hour. I normally went on my lunch, so

8 it would normally just be away from the business for about

9 an hour or so.

10 Q. And this was after you submitted a written

11 request for an ADA accommodation?

12 A. Yes.

13 Q. And what did Ms. Siggerud respond?

14 A. I -- I don't recall.

15 Q. Was she upset that you asked for this time off?

16 A. I felt that -- that she was agitated, yes.

17 Q. Why?

18 A. I -- I just -- I always get the comment from her

19 that it was becoming an issue and that other managers were

20 having an issue with the amount of time that I was taking

21 away from work, and due to the fact of the time that I was

22 taking away, that they felt that I was not engaged because

23 I was not there when I went to my doctors' appointments.

24 Q. Did Ms. Siggerud say to you specifically that

25 the number of medical appointments that you were taking

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1 was becoming an issue?

2 A. No. She said, "The time that you are missing is

3 becoming an issue."

4 Q. Did she tell you that there was a perception

5 about your availability that was an issue?

6 A. Yes.

7 Q. Did she specifically reference the time you were

8 taking for doctors' appointments or that there was a

9 perception that you were unavailable?

10 A. That there was a perception I was -- I was

11 unavailable.

12 Q. And you believed that perception to be because

13 of a change in your office space, correct?

14 MR. MILLS: Object to the form.

15 THE WITNESS: Not completely.

16 BY MS. FRANCIS:

17 Q. But you believe the perception started when

18 Mr. Briscoe moved your office location, correct?

19 A. No.

20 Q. You don't believe that is when this all started?

21 A. No.

22 Q. When did the perception start in your view?

23 A. Specifically?

24 Q. Yeah, the perception about you being

25 unavailable.

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1 A. I would say about March of 2013.

2 Q. And who do you believe had the perception that

3 you were unavailable?

4 A. Jacob Briscoe and Mitch Rubinoff.

5 Q. And why do you believe that they had this

6 perception of you in March of 2013?

7 A. Due to the fact that my role had changed and

8 that I was not completely dedicated to them and that I was

9 supporting other areas as well, and I would be in meetings

10 with Los Angeles or other locations, so I would be in my

11 office a lot and it could be possibly on the phone or

12 working on a project for a different location.

13 Q. So you believe that they had this perception of

14 you because of your travel --

15 A. Yes.

16 Q. -- and because you were supporting people other

17 than them?

18 A. That and due to the fact of me being out to

19 attend doctors' appointments.

20 Q. Did Mr. Briscoe or --

21 I think you said his name was Mitch,

22 correct?

23 A. Um-hum, yes.

24 Q. -- know when you were attending medical

25 appointments?

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1 A. Did they know?

2 Q. Yes.

3 A. Jacob Briscoe knew.

4 Q. On the occasions that you would have told him,

5 correct?

6 A. Correct.

7 Q. How many occasions did you tell Mr. Briscoe you

8 were missing work due to a medical appointment?

9 A. I don't recall.

10 Q. Do you have any specific memory of ever doing

11 that?

12 A. Not specifically, no.

13 THE WITNESS: Do you mind if we take a

14 restroom break?

15 MS. FRANCIS: That's fine, yeah.

16 VIDEO TECHNICIAN: This is the end of media

17 No. 1 in the continuing deposition of Brandy Lane

18 Williams. Today's date is June 14, 2016. The time is

19 10:31 a.m.

20 (Recess ensued from 10:31 a.m. until

21 10:43 a.m.)

22 VIDEO TECHNICIAN: We are back on the

23 record. This is the beginning of media No. 2 in the

24 continuing deposition of Brandy Lane Williams. Today's

25 date is June 14, 2016. The time is 10:43 a.m.

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1 MR. MILLS: Carrie, before we go on, Brandy

2 would like to clarify an answer that she made to a

3 question very early on in the deposition.

4 MS. FRANCIS: Why don't we do that in

5 redirect?

6 MR. MILLS: Okay. That's fine. Either

7 way.

8 MS. FRANCIS: Okay.

9 BY MS. FRANCIS:

10 Q. I want to finish the questioning related to

11 Mr. -- Mrs. Siggerud because we kind of got off on a

12 tangent on Jake, but we were talking before about your

13 specific recollection of having conversations with

14 Ms. Siggerud about taking time off for medical

15 appointments. Are there any other occasions that you

16 specifically recall talking to her about missing work

17 because of medical appointments that we have not already

18 discussed on the record?

19 A. Yes.

20 Q. Okay.

21 A. I would have conversations with Rachael weekly.

22 We would have our -- what -- what she scheduled as our

23 one-on-one meetings, and I would give her an update about

24 my medical issues and just the appointments the next week

25 that I would be attending.

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1 Q. Did you do that every week?

2 A. Every time that we would talk, I would give her

3 an update.

4 Q. And what was her response to that information?

5 A. "Okay. Thank you for letting me know."

6 Q. Did she seem agitated?

7 A. She seemed frustrated that, you know, I was

8 letting her know that I was having more appointments.

9 Q. In what way?

10 A. She would ask me maybe, "How long is this going

11 to last?" or "Do you know how much longer you will have to

12 go to appointments?" or "Have they figured out

13 specifically what is wrong with you," things like that.

14 Q. Anything that you considered to be derogatory?

15 A. Just -- just -- just from her saying, you know,

16 "This is happening a lot." That's how she would say it to

17 me, "This is happening a lot."

18 Q. She used those specific words to your memory?

19 A. Yes.

20 Q. Was this before or after you requested an ADA

21 accommodation in writing?

22 A. It was before.

23 Q. After you requested the ADA accommodation in

24 writing, did Ms. Siggerud ever make a comment about you

25 taking a lot of time for medical appointments?

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1 A. Yes.

2 Q. What did she say specifically?

3 A. That it was becoming an issue within the Phoenix

4 business with the perception that I was -- was not there

5 because I was attending a lot of appointments or I was

6 missing a lot of work.

7 Q. And I think we already covered this, but you are

8 saying it again so I want to be clear. Did Ms. Siggerud

9 specifically say that there was a perception that you were

10 unavailable due to your medical appointments, or did she

11 specifically just talk about there was a perception of

12 your unavailability?

13 A. When she would tell me about managers and them

14 making complaints that I was not there, it was about their

15 perception. When she would talk to me specifically about

16 me and her, she would tell me that she felt that I was

17 missing a lot of work due to my -- due to my medical

18 appointments.

19 Q. So you have a specific memory of her telling you

20 that you were missing too much time from work due to your

21 medical appointments after you requested an ADA

22 accommodation in writing?

23 A. Yes. And I told her that I felt concerned and I

24 felt pressured due to my health issues and I felt that I

25 was being forced out of the business due to them always

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1 having an issue around me taking time away from work to

2 attend the doctors' appointments.

3 Q. When you say "they" having an issue, who

4 specifically did you believe had an issue about you taking

5 time off for medical appointments?

6 A. I believed it to be Jacob Briscoe and Mitch

7 Rubinoff, but in conversations with Rachael, she would not

8 tell me specifically who it was. She told me that was not

9 important but that it was management in Phoenix.

10 Q. So Ms. Siggerud told you that she believed that

11 management in Phoenix was having an issue with the time

12 off that you were taking for medical appointments?

13 A. No, that they had an issue with my time away

14 from work.

15 Q. Did she say "time away from work," or did she

16 say "the perception of your unavailability"?

17 A. She would say both.

18 Q. Did this conversation with Ms. Siggerud that you

19 just described happen in one of your recorded

20 conversations?

21 A. That was one of the times that we had the

22 discussion, yes.

23 Q. I want to be specific. The time that

24 Ms. Siggerud told you that she had a concern herself with

25 the time that you were taking for medical appointments,

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1 was that in one of the recorded conversations?

2 A. That is not how she stated it, no.

3 Q. Well, that's what you told me she said.

4 A. Not in the recorded conversation.

5 Q. Okay. Well, I want to talk about the

6 conversation that you just described to me --

7 A. Um-hum.

8 Q. -- where Ms. Siggerud said to you that she

9 herself had problems with the amount of time that you were

10 taking away from work for medical appointments. Do you

11 recall telling me that?

12 A. Yes.

13 Q. When did that conversation happen?

14 A. I -- I don't recall a specific date.

15 Q. And was that one of the conversations that you

16 recorded?

17 A. No, not that time.

18 Q. Did that conversation happen after you requested

19 an ADA accommodation in writing?

20 A. No.

21 Q. When Ms. Siggerud made the comment to you that

22 she was concerned about the time that you were missing for

23 medical appointments, did she also suggest to you that you

24 request intermittent FMLA leave to deal with that concern?

25 A. Yes.

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1 Q. And was it after that conversation that you made

2 the formal request for an ADA accommodation in writing?

3 A. Which conversation specifically?

4 Q. After this conversation where Ms. Siggerud

5 suggested that in order to deal with the amount of time

6 that you were having to take for medical appointments that

7 you should take intermittent FMLA, did you make the formal

8 ADA request for an accommodation, the one you submitted in

9 writing?

10 A. I don't understand the question.

11 Q. Sure. Let me rephrase it.

12 A. Okay.

13 Q. You told me that in the conversation where

14 Ms. Siggerud suggested to you that she was concerned about

15 the time that you were taking for medical appointments,

16 that she also suggested that you apply for intermittent

17 FMLA leave, correct?

18 A. No, not at that time.

19 Q. How long after that conversation did she suggest

20 you take FMLA leave?

21 A. She suggested it when I requested the ADA

22 request in writing, not during that conversation.

23 Q. How soon after your conversation with

24 Ms. Siggerud about missing time from work for medical

25 appointments did you request the ADA accommodation in

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1 writing?

2 A. I don't recall an exact date.

3 Q. Can you approximate for me?

4 A. A week maybe.

5 Q. Not long after?

6 A. Not long.

7 Q. Is it fair to say that is what prompted you to

8 submit the request in writing?

9 A. What -- what prompted -- I'm sorry?

10 Q. The conversation with Ms. Siggerud.

11 A. It was multiple of previous conversations that

12 we had leading up to that point, not specifically that

13 one, but it was our weekly meetings that escalated it to

14 me having a concern of feeling that there was an issue

15 with me missing work due to my appointments.

16 Q. And so you believe that within a week you

17 submitted that request in writing?

18 A. If I had to guess.

19 Q. So it was before your ADA request that

20 Ms. Siggerud took an issue with your attendance, correct?

21 A. Yes.

22 Q. And the company granted your request for

23 intermittent FMLA leave, correct?

24 A. Once they received the documentation from my

25 doctor, yes, they did.

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1 Q. Even though you didn't -- strike that.

2 Even though you were not eligible for FMLA

3 leave at that point in time, correct?

4 A. I was eligible for FMLA.

5 Q. Hadn't you used all your FMLA time for the birth

6 of your son?

7 A. From the year prior.

8 Q. And when did it start again?

9 A. It is on a rolling calendar, so every -- every

10 -- every year.

11 Q. And when does the year start for the company?

12 A. It would -- it would be from the time that you

13 took the leave. It wouldn't be from the -- the time with

14 the company.

15 Q. Hadn't you taken more than three months' time

16 off in the preceding year under FMLA already at the time

17 that you requested your intermittent FMLA leave?

18 A. Yes.

19 Q. So you didn't have any more FMLA time, correct?

20 A. I had just become eligible again. We were at

21 that year mark for me to become eligible to obtain FMLA

22 again.

23 Q. Didn't you return from your FMLA leave in

24 October of 2012?

25 A. Yes.

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1 Q. And you were requesting FMLA leave again on

2 July 8th of 2013, correct, or in that time frame, July of

3 2013?

4 A. July of 2013. Rachael told me that she had

5 checked with the benefits department and that they had

6 made her aware that I was eligible for FMLA and she

7 suggested that I request leave.

8 Q. Was there any concern with how that request for

9 intermittent FMLA leave was handled?

10 A. Yes.

11 Q. What were your concerns about how the request

12 for leave was handled?

13 A. There were questions -- it took them a while to

14 get me the paperwork, and Rachael had made a -- a response

15 to the benefit department that she wanted to follow my

16 leave closely and be very involved in it.

17 Q. Were you aware that she had made that request at

18 the time that you were submitting your FMLA leave?

19 A. Yes.

20 Q. How were you made aware that she had made that

21 comment?

22 A. She told me that she would work closely with me

23 through the leave and that she would monitor my leave with

24 Marie Smith and Nikki Kietzer.

25 Q. Did she indicate to you why she wanted to work

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1 closely with you through the leave?

2 A. She wanted to make sure of the length of time

3 that I was taking off and, because it was intermittent, of

4 the number of hours that I was taking to go towards the

5 leave.

6 Q. Did she indicate any other reason that she

7 wanted to work closely with you to manage the leave?

8 A. She wanted to make sure that it didn't continue

9 to affect my relationship with the Phoenix management team

10 due to the perception that I was not available in the

11 business due to me going to appointments.

12 Q. Did she suggest anything -- any other reason

13 that she wanted to closely monitor your leave?

14 A. No, not that I am aware of.

15 Q. And did her comment concern you?

16 A. It did.

17 Q. Why?

18 A. I -- I felt that she was looking for a reason to

19 try to get me to quit my job or that she was making it the

20 main point of our conversations when we would have our

21 meetings every week.

22 Q. Did she say anything else to you that you

23 haven't already told me on the record about your leave

24 that made you uncomfortable?

25 A. I don't recall.

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1 Q. So she told you that she needed to be aware of

2 when you were taking leave because it was intermittent and

3 she needed to know how to track that for purposes of

4 eligibility, correct?

5 A. That and to make sure that the Phoenix business

6 knew where I was at all times and that she didn't want

7 them to think that I was not engaged.

8 Q. Did you believe that her need to track your

9 leave to keep account of the hours that you were using for

10 the intermittent FMLA time was something that she needed

11 to do?

12 A. I -- I don't feel that it was something that she

13 needed to do specifically. I felt that I should have had

14 more of that relationship with the benefits department,

15 with the employee relations manager and then the benefits

16 manager. They kept track of -- of the leave.

17 Q. How?

18 A. They would -- they would process the paperwork,

19 and then they would request time of when I would take off.

20 Q. Would you -- how would you tell the benefits

21 people when you were using your FMLA intermittent leave

22 time?

23 A. Well, Rachael requested that I tell her and then

24 she would tell them.

25 Q. Did you object to that at all?

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1 A. No.

2 Q. Do you think it was important for Rachael to

3 know when you were taking time off for medical

4 appointments?

5 A. I do think that it was important for her to know

6 where I was. She was my boss.

7 Q. Is there a business reason that you can think of

8 that she would need to track that?

9 A. No.

10 Q. You don't think that she needs to know when you

11 are working and when you are not working?

12 A. No, I do believe that she should have known when

13 I was working, when I wasn't.

14 Q. Do you believe that the business also needed to

15 track when you were using FMLA time?

16 A. Yes, the benefits department, yes.

17 Q. Did you ever tell Ms. Siggerud that you would

18 prefer to deal with the benefits department directly?

19 A. I don't recall.

20 Q. You don't recall ever doing that?

21 A. No. I just did what she instructed me to do as

22 far as requesting the leave and then who she would -- who

23 she wanted me to keep in contact with.

24 Q. Did you have conversations with Ms. Siggerud

25 about the perception of your unavailability having nothing

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1 to do with the time that you were taking off for medical

2 appointments?

3 MR. MILLS: Object to the form.

4 BY MS. FRANCIS:

5 Q. Let me rephrase that.

6 You said you would usually take these

7 medical appointments during lunch, correct?

8 A. Yes.

9 Q. And you would typically only do that once or

10 twice a week, correct?

11 A. Approximately.

12 Q. So explain to me how you believe the medical

13 appointments created a perception of your unavailability.

14 A. They could -- my medical appointments, they

15 would be random. They -- they could possibly be first

16 thing in the morning or they could be last thing at the

17 very end of the day or most of the time I would take them

18 during my lunch if I could. It just would depend on the

19 availability of the appointment with the doctor.

20 Q. Okay. And if you are doing these medical

21 appointments early in the morning, late in the day and

22 during lunch, can you explain to me why you believe that

23 the medical appointments were creating a perception of

24 your unavailability?

25 A. Because I would be away from the business for

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1 the first part of the day or either the end of the day or

2 if I was gone during the middle of the day.

3 Q. What time would you typically come in if you had

4 a medical appointment in the morning?

5 A. I -- I don't recall.

6 Q. What time would you leave in the afternoon if

7 you had an appointment at the end of the day?

8 A. Around -- I would have to guess and say 3:30,

9 3:45.

10 Q. And if you took your appointment during lunch

11 when would you typically leave and return back to the

12 office?

13 A. It could have been anywhere between 11:00 a.m.

14 and noon.

15 Q. Did you understand that the perception of your

16 unavailability also had to do with issues apart from you

17 taking time to attend medical appointments?

18 A. No.

19 Q. Did Ms. Siggerud discuss with you that people

20 thought you were unavailable because you would accept

21 attendance at meetings and then you wouldn't show up to

22 those meetings?

23 A. I would show up to the meetings.

24 Q. Okay. My question was a little bit more

25 specific.

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1 Do you want the court reporter to read it

2 back?

3 A. Yes.

4 (The following requested portion of the

5 record was read back by the reporter.)

6 "QUESTION: Did Ms. Siggerud discuss with

7 you that people thought you were unavailable because you

8 would accept attendance at meetings and then you wouldn't

9 show up to those meetings?"

10 THE WITNESS: I -- I don't really

11 understand the way the question is stated.

12 BY MS. FRANCIS:

13 Q. Okay. Let me rephrase it.

14 Did Ms. Siggerud discuss with you that

15 people thought you were unavailable because on your

16 calendar you would say that you were going to attend a

17 meeting and then you wouldn't actually come to the

18 meeting? Did she discuss that with you?

19 A. Yes.

20 Q. And did she tell you that that led to the

21 perception of unavailability?

22 A. Not that entirely.

23 Q. But in part?

24 A. In part, yes.

25 Q. Did she also discuss with you that when you

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1 would be late to meetings that that would lead to the

2 perception of your unavailability?

3 A. She only discussed with me the perception of

4 being late twice. There was just two meetings. That was

5 it. There was nothing outside of that that I was late

6 for, but she did have a conversation with me around two

7 times, that they felt I was not engaged due to me being

8 about five to ten minutes late for two specific meetings.

9 Q. And did she discuss with you that she was

10 frustrated because you had failed to attend one-on-one

11 meetings with her and you wouldn't call beforehand and let

12 her know that you were going to be unavailable?

13 A. Yes.

14 Q. And you also felt that the perception of your

15 unavailability had to do with the fact that your office

16 was moved, correct?

17 A. That was part of it, yes.

18 Q. It was a big part of it?

19 A. It was a very small part.

20 Q. Isn't that what you think started this whole

21 perception of your unavailability?

22 MR. MILLS: Object to the form.

23 THE WITNESS: No.

24 BY MS. FRANCIS:

25 Q. Why did -- strike that.

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1 What did you tell Ms. Siggerud about your

2 office move and how you think it was perceived in

3 relationship to your availability?

4 A. I told her that I felt that due to my previous

5 health issues and then me also going into the new role

6 that I felt that Jake was removing me from the business by

7 moving my office to the front of the plant.

8 Q. Do you think the office move to the front of the

9 plant made people think that you were not at work?

10 A. Yes.

11 Q. Why?

12 A. It was very hidden. It was an office behind a

13 -- like a partition of other, like, cubicles, and you

14 couldn't see my door unless you walked, like, directly

15 behind the partitions.

16 Q. When you worked throughout the day, did you get

17 up and talk to people?

18 A. Yes.

19 Q. Did Jake explain to you why he had moved your

20 office location?

21 A. Yes.

22 Q. Why?

23 A. He stated because my HR function was changing,

24 that he felt that the route manager could more utilize the

25 office that I was in for different -- different support

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1 for the service department, because I was in the back by

2 the -- by the service department. My previous job mainly

3 supported the employees and the drivers, so I would be

4 there when they checked in in the afternoon.

5 Q. And in your new role, you supported management?

6 A. Yes, in that location and other locations as

7 well.

8 Q. So you didn't need to have the direct contact

9 with the employees on a daily basis, correct?

10 A. No, I still supported the employees if they had

11 an issue with the corporate call center or if they had

12 questions. My role was still to be engaged with all of

13 the employees in all of the locations.

14 Q. But would you agree with me that it was more

15 specific, that you were to be strategically partnering

16 with management at the locations, correct?

17 A. Yes.

18 Q. You were not processing payroll or keeping track

19 of timecards or those daily functions anymore, correct?

20 A. I did. I helped assist with that. I helped the

21 managers because that became part of their job description

22 and part of their roles, so in part of the transition,

23 that was part of my job to help support them through that

24 time, so if they had an issue with payroll or if an

25 employee had an issue with missing hours, they would still

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1 come to me and tell me that they were missing an hour, and

2 I would work with the manager. So I was still partaking

3 in some of my previous job responsibilities to help

4 everyone.

5 Q. As you were transitioning those duties to the

6 managers on-site, correct?

7 A. Yes.

8 Q. But those were not your direct responsibilities

9 anymore, correct?

10 A. Correct.

11 Q. So the person that took your office space was

12 somebody that was directly managing the service

13 department?

14 A. He was not a manager. He was just a support

15 admin, and they put him in that office, yes.

16 Q. And he dealt with the departments that were

17 right outside that office?

18 A. Yes.

19 Q. Did you object to the office move to Mr. Briscoe

20 -- or Jake?

21 A. Yes.

22 Q. What did you say?

23 A. I told him that I didn't really want to move,

24 that, you know, I -- I was still going to be helping, you

25 know, everyone and all the employees, and I kind of felt

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1 like it was taking me away from everyone.

2 Q. And what did he say?

3 A. He told me that he needed more space, and I was

4 not on his payroll anymore. I was a corporate employee,

5 so he should honestly charge me to rent the office he was

6 putting me in up front.

7 Q. Anything else?

8 A. Not that I recall.

9 Q. Did you think that Mr. Briscoe was moving your

10 office because of your medical appointments or your

11 medical condition?

12 A. No.

13 Q. So I want to go back to your discussions with

14 Ms. Siggerud about your medical appointments. We first

15 started talking about your specific memories and we

16 identified a few, and then after we took a break, you

17 explained that you talked to her about your medical

18 appointments on your one-on-one meetings weekly, correct?

19 A. Yes.

20 Q. When did you remember that you had those

21 discussions every week with her? What refreshed your

22 memory?

23 A. Just remembering back to when we would meet

24 every week when we would have, you know, conversations

25 just updating each other on what was going on.

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1 Q. Okay. But it was a change in your testimony

2 between the breaks, and so I just wanted to know, did you

3 look at something specifically that refreshed your memory?

4 MR. MILLS: Object to the form.

5 THE WITNESS: No, no, I didn't look at

6 anything. I was just thinking back to your question of,

7 you know, when did I remember talking to her or verbally

8 telling her that -- that I was having these appointments,

9 and then I remembered, oh, yeah, we met every week on the

10 phone as a phone conversation to have a one-on-one and she

11 called it to update each other about what was going on

12 with the business of G&K.

13 BY MS. FRANCIS:

14 Q. And you would tell her every week about the

15 medical appointments that you had upcoming?

16 A. If I had one at the time, I would make her aware

17 that I had one.

18 Q. When were these one-on-one meetings?

19 A. They were every week.

20 Q. What day?

21 A. I don't -- I don't recall.

22 Q. Were they on the same day every week?

23 A. I don't believe so, but I don't recall

24 specifically which day.

25 Q. Okay. Is it possible that they were on the same

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1 day at the same time every week?

2 A. It could be a possibility but they -- they did

3 change if she was traveling or if she canceled them or if

4 she rescheduled with me.

5 Q. Or if you rescheduled with her?

6 A. Right, correct.

7 Q. But was it typically set for the same day and

8 time every week?

9 A. I -- I believe so.

10 Q. You just don't remember what day and time,

11 correct?

12 A. Right.

13 Q. When you requested the intermittent FMLA

14 leave -- we talked about the concerns that you believe

15 Ms. Siggerud had about managing closely that leave time.

16 Was there any other reason that you are -- strike that.

17 Other than what we have already talked

18 about with Ms. Siggerud, is there -- were there any other

19 concerns you had with how G&K handled your request for

20 intermittent FMLA leave?

21 A. I didn't have any concerns, but I felt -- I felt

22 pushed to make that decision by Rachael when she suggested

23 that I -- that I take the leave.

24 Q. And did that concern you?

25 A. It did.

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1 Q. Why?

2 A. Because I felt that I was performing my job as I

3 normally would every day, that I was at work every day and

4 performing my -- my normal job functions and just with the

5 support of, you know, going, you know, to doctors'

6 appointments, you know, on my lunch or, you know, in the

7 morning or in the afternoon, that I could have continued

8 to perform my job as normal just with the support from

9 her.

10 Q. So you didn't think you needed to have FMLA

11 intermittent leave?

12 A. I didn't think about it.

13 Q. But you were concerned that she suggested that

14 you apply for intermittent FMLA leave?

15 A. I was.

16 Q. And that's because you didn't think you needed

17 to be on intermittent FMLA leave?

18 A. No. I -- I felt that it came from -- because of

19 the fact that I requested an ADA accommodation in writing.

20 Q. I guess I am having a hard time understanding

21 why that concerned you.

22 A. Because I could have functioned in my job with

23 an accommodation without taking the leave.

24 Q. So you didn't think you needed the FMLA

25 intermittent leave?

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1 A. No.

2 Q. No, I am correct, you didn't think that you

3 needed it?

4 A. Correct.

5 Q. Okay. Did G&K also grant your request for an

6 ADA accommodation after you submitted that request in

7 writing in July?

8 A. They never really addressed the ADA

9 accommodation. It pretty much went from "We got your

10 letter for a request" to "You should request FMLA."

11 Q. I am going to show you what has been previously

12 marked as Exhibit No. 4.

13 MR. MILLS: No. 4 you said?

14 MS. FRANCIS: Yes.

15 BY MS. FRANCIS:

16 Q. Is this -- is Exhibit No. 4 the request for an

17 ADA accommodation that you submitted in writing?

18 A. Yes.

19 Q. And you copied somebody named Nikki Kietzer on

20 this request. Who is Nikki Kietzer?

21 A. She was in the benefits department at the

22 corporate office.

23 Q. Do you know what her position was, her job

24 title?

25 A. I think just benefits specialist.

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1 Q. And what made you submit this request in

2 writing?

3 A. Just from all of the ongoing conversations with

4 -- with Rachael and just always with -- with the talk of

5 there being an issue around me taking time away from work

6 to go to doctors' appointments.

7 Q. So that was happening -- those discussions were

8 happening prior to your ADA request?

9 A. In writing --

10 Q. No, the discussion --

11 A. -- but verbally I had requested for her to

12 support me, but we did we have conversations.

13 Q. So there was conversations about your time off

14 for medical appointments prior to your request for ADA,

15 correct?

16 A. Yes.

17 Q. And the accommodation that you requested was

18 time away from work to attend medical appointments,

19 correct?

20 A. Medical appointments and counseling.

21 Q. So the accommodation you were requesting was

22 time off from work, correct?

23 A. Yes.

24 Q. Or time during the day to take or go to your

25 medical appointments?

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1 A. Yes.

2 Q. You felt like you could still complete your

3 daily job requirements even when you were taking time to

4 go to the medical appointments, correct?

5 A. Yes. I had been since my previous leave.

6 Q. So you didn't actually want a reduction in your

7 schedule; you just wanted permission to come and go to

8 attend these appointments?

9 A. Yes.

10 Q. After you submitted Exhibit No. 4, were you

11 permitted to attend all the medical appointments that you

12 needed to go to?

13 A. Yes.

14 Q. Was there ever an occasion where someone at G&K

15 told you you could not have time off to attend a medical

16 appointment?

17 A. No. They -- because they were not aware that I

18 was going to medical appointments. They were just on the

19 calendar as a meeting, so I would say no.

20 Q. Well, Ms. Siggerud knew because you told her in

21 the one-on-one meetings, correct?

22 A. Yes.

23 Q. Did she ever tell you that you couldn't take

24 time to attend a medical appointment?

25 A. No.

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1 Q. At the time you wrote Exhibit No. 4, did -- had

2 you retained counsel?

3 A. No.

4 Q. Did anyone assist you in writing Exhibit No. 4?

5 A. No.

6 Q. Did you research or do any online investigation

7 as to what you should put in a request for an

8 accommodation?

9 A. Yes.

10 Q. What -- what sites did you go to?

11 A. I don't remember specific sites, but I just

12 Googled, you know, ADA request in writing or writing an

13 ADA request.

14 Q. Did you do any other kind of research?

15 A. Not that I recall.

16 Q. Did you talk with anyone?

17 A. No.

18 Q. And in your role as an HR representative, up to

19 this point in time where you wrote Exhibit No. 4, had you

20 ever received an ADA request from an employee --

21 A. No.

22 Q. -- in any of your jobs that you held?

23 A. No.

24 Q. To your knowledge, was Mr. Briscoe aware that

25 you had made a formal request for an ADA accommodation?

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1 A. Yes.

2 Q. How do you know he was aware?

3 A. Rachael told me that she had a conversation with

4 him.

5 Q. Did she tell you what specifically she told him?

6 A. No.

7 Q. Did he ever discuss with you your ADA

8 accommodation request?

9 A. Not that I recall.

10 Q. Did Mr. Briscoe ever talk to you about any of

11 the time you took to attend to medical appointments?

12 A. Not that I recall.

13 Q. Did Mr. Briscoe ever make any comment to you

14 about your medical condition that you perceived to be

15 discriminatory or derogatory?

16 A. Can you restate the question?

17 Q. Sure. We talked about when you thought

18 Ms. Siggerud made comments that you believe were

19 derogatory or discriminatory about the time that you were

20 taking for medical appointments. Did Mr. Briscoe ever say

21 anything like that to you?

22 A. Yes. He made a comment previously when I had

23 returned from leave from the birth of my son that -- we

24 were at lunch one day and he stated that he didn't

25 understand how women could juggle a career and having

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1 children in the workplace, and he thought that they should

2 make a choice between one or the other because it took too

3 much time away from them at work and that's why he had his

4 wife stay at home.

5 Q. Did he make any comments about your medical

6 condition?

7 A. No, not directly.

8 Q. Any comment about the time you were taking to go

9 to medical appointments that you believed was

10 discriminatory or derogatory?

11 A. Not directly, no.

12 Q. When you say "not directly," did he do that

13 indirectly?

14 A. I -- I am unaware of the conversations he had

15 with Rachael.

16 Q. But do you believe that somebody told you that

17 he made comments that were discriminatory about your

18 medical condition?

19 A. Rachael was saying that someone was making --

20 had concerns about the time I was taking away to go to

21 doctors' appointments, but she would not share with me

22 specifically who it was.

23 Q. So when you said "indirectly," you believe he

24 may have made comments, but not directly. Is that what

25 you are referring to?

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1 A. Yes.

2 Q. And did Mitch -- what is Mitch's last name?

3 A. Rubinoff.

4 Q. -- Rubinoff make any comments about the time you

5 were taking for medical appointments that you believed was

6 discriminatory or derogatory?

7 A. Not directly medical appointments, but that, you

8 know, I was -- was not there because I was gone away from

9 the business.

10 Q. And he made those comments to you?

11 A. Yes.

12 Q. What would he say?

13 A. "Wow, you are sure gone a lot," or "We hardly

14 see you anymore since you had your son," or he would ask

15 me, you know, "Are you doing okay? You seem to still be

16 having issues, you know, since returning from leave."

17 Just -- just kind of like, you know, casual conversation

18 here and there.

19 Q. And what would you respond?

20 A. That I was -- that I was okay, that everything

21 was fine.

22 Q. Do you believe that his comments were

23 inappropriate?

24 A. Not that I recall. I don't recall.

25 Q. Did you ever tell him that you disliked what he

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1 was saying or that he should stop making those kinds of

2 comments?

3 A. I don't recall.

4 Q. When he would say to you, "We never see you

5 anymore," could that comment have been about your

6 overseeing other locations and not your medical condition?

7 A. I am not sure. I would be reading into what he

8 said.

9 Q. Well, I asked you specifically about comments

10 relating to your medical condition and then you told me

11 that comment, so you obviously perceived that comment to

12 be about your medical condition, correct?

13 A. I felt it could have been related to it.

14 Q. Could it also have been because you were

15 traveling now?

16 A. It could have been.

17 Q. Or his comment that we never see you, you are

18 not around or you are gone a lot, those could also be

19 related to your handling of new locations, correct?

20 A. Possibly.

21 Q. Did anyone else at G&K make any comments about

22 your medical condition or the time you were taking off

23 work that we have not discussed that you believed was

24 discriminatory or derogatory in any way?

25 A. Not that I recall, no.

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1 Q. And did you make any notes about when there was

2 a comment made that you felt was inappropriate?

3 A. No, but I would tell Rachael about them during

4 our one-on-one weekly meetings.

5 Q. And what was her typical response?

6 A. "Well, just try to stay positive, you know, have

7 a good relationship with everyone, just reassure them that

8 you are there to support them."

9 Q. Did you indicate to her that you wanted her to

10 take any action to make sure that those types of comments

11 stopped?

12 A. I don't recall.

13 Q. Were you talking about this perception of

14 availability or were you actually complaining of

15 discrimination when you would have these conversations

16 with her?

17 A. I -- I don't recall.

18 Q. Did you use the word "discrimination"?

19 A. I -- I don't recall specific words that I said

20 to her.

21 Q. Did you ever tell Ms. Siggerud that you thought

22 you were being treated differently because of your medical

23 condition?

24 A. Yes.

25 Q. Differently than who?

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1 A. Differently than other generalists in the same

2 position as myself.

3 Q. How do you know how generalists in different

4 positions were being treated?

5 A. We would have weekly meetings or the other

6 generalists and I would have conference calls together or

7 we would call each other for support to ask them about

8 ideas of what they are doing in their business and in the

9 new role.

10 Q. Tell me specifically who you think was being

11 treated different than you because of your medical

12 condition.

13 A. Janelle and Kaela.

14 Q. Okay. How was Janelle treated differently than

15 you?

16 A. I don't feel that they were as discussed as much

17 as being away from the business when Janelle would take

18 appointments to go to maternity appointments or doctors'

19 appointments -- as much with her as it was with me and me

20 taking time away. Janelle would state to me, "Well,

21 Rachael doesn't really say anything to me when I go to my

22 appointments. She is fine with them."

23 Q. And do you know how much time off Janelle was

24 taking?

25 A. I -- I do not.

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1 Q. Did you talk with Rachael about that?

2 A. No.

3 Q. So did you ever say to Rachael, "I think you are

4 treating me differently than Janelle because Janelle tells

5 me you don't care about the time that she takes off for

6 pregnancy-related appointments"?

7 A. No, not specifically, but I did tell her that I

8 felt that she was retaliating against me for requesting

9 time away from work.

10 Q. Okay. Well, we will get there.

11 A. Okay.

12 Q. Because what I am wanting to focus in on now is

13 how you believe that you were being treated differently

14 because of your medical issues, and you just told me you

15 compared yourself to Janelle, and Janelle was taking

16 medical appointments and Rachael apparently didn't have a

17 problem with what Janelle was doing, correct?

18 A. Correct.

19 Q. Did you ever tell Rachael that?

20 A. No.

21 Q. Did you ever tell anyone at G&K that you thought

22 that was going on?

23 A. Just Janelle.

24 Q. And what did Janelle tell you to do?

25 A. Just to make sure to, you know, make Rachael

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1 aware of the appointments I was attending.

2 Q. Did she suggest that you file a complaint?

3 A. No.

4 Q. Did you feel the need to file a complaint?

5 A. Not right away, no.

6 Q. In what other way did you feel that you were

7 treated differently because of your medical condition?

8 A. The requests that I was getting when it came to

9 my performance review, and then also the request to come

10 up with a specific game plan of what I was going to be

11 doing day to day in my job for the general manager, which

12 was Jacob Briscoe in Phoenix.

13 Q. Let's talk about the performance review first --

14 well, is that the complete list of the reasons that you

15 feel like you were treated differently because of your

16 medical condition?

17 A. That is the ones that I can recall, yes.

18 Q. Okay. If you think of another one while we are

19 going through this deposition, let me know.

20 A. Okay.

21 Q. So we already talked about your comparison to

22 Janelle, and you didn't tell Rachael about how you felt

23 with that, correct?

24 A. Right.

25 Q. The performance review, why do you think you

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1 were treated differently because of your medical condition

2 when it comes to your performance review?

3 A. I felt that mine was requested to be much more

4 descriptive than theirs -- than theirs were that I felt

5 that mine was a lot more detailed than theirs was.

6 Q. Did someone tell you that you had to

7 specifically detail items in your performance review?

8 A. Yes.

9 Q. Who?

10 A. Rachael Siggerud.

11 Q. How did you know that she didn't have that same

12 requirement of the other generalists?

13 A. I had a meeting and a conversation with Kaela

14 and Janelle, and I was asking them for ideas around --

15 since we were in the same position of -- kind of what they

16 were putting in their performance review, and they just

17 told me that theirs was really vague, and I said, "Well,

18 you are not being specific?" And they said, "Well, we are

19 just putting just general goals," and I kind of left it at

20 that.

21 Q. But do you know anything about the conversations

22 that Rachael had with Janelle or Kaela about what should

23 be in their performance review?

24 A. No. They just stated to me that she just told

25 them to just put their -- their general goals in of what

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1 we were performing as a -- as a generalist.

2 Q. And you believe she told you something

3 different?

4 A. Yes.

5 Q. And she told you that you had to be specific?

6 A. Sorry, can you restate that?

7 Q. Sure. When it comes to your performance review

8 -- this is occurring in 2013, correct?

9 A. Yes.

10 Q. And Rachael told you that you had to be specific

11 about your goals?

12 A. Yes.

13 Q. Did she --

14 A. She said, "You need to be as detailed as

15 possible."

16 Q. But you don't know if she told that same thing

17 to the other generalists and they didn't follow her

18 instruction, correct?

19 A. I am not aware of the conversation she had with

20 them, no.

21 Q. Okay. You get to write your own goals in your

22 performance review, correct?

23 A. Yes, with the assistance from Rachael.

24 Q. But they are goals that you established and set

25 for yourself for the upcoming year, correct?

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1 A. With guidance from her.

2 Q. Right.

3 A. Sorry.

4 Q. Did she ask you to revise any draft of your

5 performance review to be more specific?

6 A. Yes.

7 Q. Do you have copies of the drafts?

8 A. I do not. I saved it as a draft in G&K

9 software, and then she would review it, and then I would

10 update it and then save it.

11 Q. Did she ever change the language for your goals

12 herself?

13 A. No.

14 Q. So all the revisions were done by you?

15 A. Yes.

16 Q. Do you recall how many revisions or drafts there

17 were of your 2013 goals?

18 A. I don't recall.

19 Q. More than one?

20 A. More than one possibly.

21 Q. More than four?

22 A. No.

23 Q. Any other reason you think that you were treated

24 differently other than this performance -- strike that.

25 Any other aspects of the performance review

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1 for 2013 where you think you were treated differently

2 because of your medical condition?

3 A. Yes.

4 Q. What?

5 A. I was taken out of my role and put into a

6 temporary role and told that I would be able to return to

7 my regular job after my leave was up, and no one else was

8 taken out of their job or their role when they requested a

9 leave.

10 Q. Okay. So you believe that your transfer to a

11 recruiting position was because of your medical request?

12 A. Yes. Rachael stated that she felt that it would

13 better help accommodate me to attend appointments, and

14 that she felt that it would be a better fit until I was

15 done with my leave.

16 Q. And when did this conversation happen?

17 A. Not long after I requested the ADA request in

18 writing.

19 Q. Was this one of the conversations that you

20 recorded?

21 A. I am not sure if it specifically includes that.

22 Q. And you have a specific memory of Rachael

23 telling you that you were being transferred to a

24 recruiting position because it would better allow for you

25 to attend medical appointments?

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1 A. Yes.

2 Q. And those were her specific words?

3 A. Yes, because she had initially stated that she

4 felt that I didn't want to be at G&K and that she was

5 going to give me three days to think about whether I

6 wanted to be in that position, or she would assist me in

7 finding a role outside of the business as well if I chose

8 to take that route.

9 Q. And was that stated in one of the recorded

10 conversations?

11 A. Yes.

12 Q. And that is the conversation that you recorded

13 in July?

14 A. I am not sure which exact one it was.

15 Q. Well, it was after your ADA request, correct?

16 A. I don't recall. I am not sure if it was before

17 or after.

18 Q. But you believe it was recorded?

19 A. It was, yes.

20 Q. And she told you specifically that you had three

21 days to think about it --

22 A. Yes.

23 Q. -- otherwise she was going to transfer you?

24 A. Not that she was going to transfer me, but she

25 felt that I was unhappy, and I reassured her that I was

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1 not, that I loved being at G&K and that I wanted to

2 continue my job there, and she stated that she felt that I

3 didn't, and she told me that she was going to give me

4 three days to make that decision of whether I wanted to

5 stay with the business or find a different job.

6 Q. And so did you respond within the three days and

7 tell her what your decision was?

8 A. I assured her that I didn't need to have the

9 three days to think about it because I knew that I loved

10 working for G&K and that I loved working with everyone

11 that I worked with because I had great relationships with

12 them.

13 Q. Did you ever suggest to Ms. Siggerud that you

14 thought you would be interested in working in a

15 recruitment role like some of the other HR representatives

16 had been transferred into?

17 A. No. No.

18 Q. So you never suggested in any way to her that

19 you wanted to transfer?

20 A. Not that I recall, no.

21 Q. Were you interested in the recruitment role at

22 all?

23 A. I didn't feel that I had a -- had an option.

24 Rachael kind of told me this is a temporary position, we

25 are going to put you into it and we will allow you to

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1 return to your job afterwards, so I was open to it, just

2 because I didn't want to be combative, you know, with her.

3 I kind of just, you know, wanted to just show her that I

4 was, you know, engaged and I was being supportive of the

5 business, so I told her I was excited about the -- the

6 role to help, you know, with recruiting.

7 Q. Did you object at all to the transfer?

8 A. No.

9 Q. Did you indicate to her that you liked doing

10 recruiting when you were an HR representative?

11 A. I don't recall.

12 Q. Did you do recruiting when you were in the

13 representative position?

14 A. I did.

15 Q. Did you enjoy that work?

16 A. I enjoyed the whole position itself. I did a

17 lot of different tasks, and it -- it was one of the things

18 I did enjoy doing, yes.

19 Q. Did you ever express that to her?

20 A. I don't recall.

21 Q. Did you express to her that you were frustrated

22 with your generalist role because it was undefined?

23 A. Yes.

24 Q. Do you think that those types of comments could

25 make Ms. Siggerud think that it would be a better fit for

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1 you to be in a recruiting role?

2 A. No.

3 Q. If you expressed to her that you don't like your

4 current job -- I know you like working for G&K, but this

5 new job as a generalist isn't really well-defined, people

6 don't know what you do, but you liked what you did before

7 and part of that was recruiting. That's where the other

8 representatives went. They didn't go to a generalist

9 position; they went to a recruiting position. Can you see

10 how Ms. Siggerud would interpret that -- maybe she thinks

11 that you would be a better fit for a recruiting position

12 rather than a generalist position?

13 A. No, because during our meetings and our

14 conversations and one-on-ones, I told her I was excited

15 about the new role and I was excited to see where it was

16 going to go and I was excited to build new relationships

17 with the new locations that I was being assigned as well,

18 so I was -- I was always positive with her about my new

19 role and -- and what we were doing. Outside of, you know,

20 stating the frustration of the role. I always tried to

21 stay positive with it.

22 Q. I understand. But you did express to her that

23 you were frustrated with the new role?

24 A. With the job description of the role, yes.

25 Q. And how your role was perceived by the managers

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1 you were supposed to be working with, correct?

2 A. Yes.

3 Q. Because the managers indicated to you they

4 didn't really know what your job function was, correct?

5 A. Correct.

6 Q. And that frustrated you?

7 A. Yes.

8 Q. And you told that to Ms. Siggerud?

9 A. Yes.

10 Q. And you also expressed that some of the

11 functions that you had previously, like recruiting, you

12 enjoyed?

13 A. Yes, as well as myself and Janelle and Kaela.

14 All of our group, we would have a group meeting, a group

15 conference call with Rachael, and we would all explain to

16 her that we all felt frustrated with the new role, and we

17 were all having issues with the new -- with -- with the

18 managers, that they were confused by what all of us were

19 doing. So it was -- it was all of us together.

20 Q. But you had in your one-on-one conversations and

21 in the conversations that you recorded -- which we will go

22 over -- expressed individual frustration with your

23 relationship with the Phoenix plant specifically, correct?

24 A. All of the locations, not just Phoenix, but Los

25 Angeles as well as Phoenix.

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1 Q. So you were having problems with the managers in

2 forming a new strategic relationship with them in your new

3 role in L.A. and Phoenix, correct?

4 A. Yes.

5 Q. And those were your two biggest locations?

6 A. Yes.

7 Q. Is there any way that you can think that hearing

8 this information from you led Ms. Siggerud to believe that

9 it might be a better fit for you to work in recruiting?

10 MR. MILLS: Object to the form.

11 THE WITNESS: No, no.

12 BY MS. FRANCIS:

13 Q. No?

14 A. No.

15 Q. You don't understand that maybe she thought that

16 was a better position for you?

17 A. No, no. I felt like she was taking me away from

18 the role due to me attending my medical appointments and

19 the managers stating that I was not available. I don't

20 think it had to do with me and my frustration with the

21 position itself.

22 Q. Okay. You also said that you felt that you were

23 treated differently because of the game plan that you were

24 asked to develop about your day-to-day job functions with

25 the plant manager in Phoenix; is that correct?

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1 A. I'm sorry. I hate to ask. Can we take a break

2 for a moment?

3 Q. Sure. Well, we have a question pending. Can

4 you answer the question and then we will take a break?

5 A. Okay.

6 Can you restate the question?

7 Q. I -- I will restate it.

8 So that we know where to pick up when we

9 come back, we were talking about how you felt you were

10 treated differently because of your medical issue, and the

11 one remaining thing we have to cover is the game plan that

12 you were asked to develop with the Phoenix plant manager,

13 correct?

14 A. Yes.

15 Q. Is there anything else we need to cover as far

16 as how you feel you were treated differently because of

17 your medical condition?

18 A. Not that I can think of at this moment.

19 MS. FRANCIS: Okay. We can take a break.

20 VIDEO TECHNICIAN: This is the end of media

21 No. 2 in the continuing deposition of Brandy Lane

22 Williams. Today's date is June 14, 2016. The time is

23 11:40 a.m.

24 (Recess ensued from 11:40 a.m. until

25 12:38 p.m.)

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1 VIDEO TECHNICIAN: We are back on the

2 record. This is the beginning of media No. 3 in the

3 continuing deposition of Brandy Lane Williams. Today's

4 date is June 14, 2016. The time is 12:38 p.m.

5 BY MS. FRANCIS:

6 Q. I want to go back and talk about your transfer

7 to the recruiting position. So if you could turn to what

8 has been previously marked as Exhibit No. 3, and I am

9 going to talk mainly about the last three pages.

10 If you want to, let your counsel look at

11 those before we begin the questioning.

12 MR. MILLS: Yes. Yes.

13 BY MS. FRANCIS:

14 Q. And I will ask you to read those three pages of

15 notes which we previously identified as Ms. Siggerud's

16 notes, and these that I am pointing you to are titled

17 "Brandy" and then an arrow to the right, "Recruiting

18 Transition." And let me know when you are done reading

19 those.

20 A. Okay.

21 Q. Did you have a conversation with Ms. Siggerud

22 that followed the outline of your recruiting transition

23 that I just had you read?

24 A. Yes.

25 Q. Are the items in her notes things that she told

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1 you verbally?

2 A. Some of them.

3 Q. Okay. Let's start with point No. 1. Did she

4 tell you verbally point No. 1?

5 A. Yes.

6 Q. Did she tell you verbally point No. 2?

7 A. Yes.

8 Q. Point No. 3 captures a comment that she claims

9 you made to her. Did you make that comment to

10 Ms. Siggerud?

11 A. No.

12 Q. Did you ever tell Ms. Siggerud that recruiting

13 holds a strong appeal to you?

14 A. She asked if I enjoyed recruiting and I said

15 yes.

16 Q. Did you tell Ms. Siggerud that you would have

17 liked to apply for a job in recruiting if you knew one was

18 open?

19 A. No, not that I recall.

20 Q. Did you say something like that to her?

21 A. She asked me if a position came open in

22 recruiting, would I be interested in helping Michael

23 Hammond.

24 Q. And what was your response?

25 A. "Yes, possibly."

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1 Q. Did Ms. Siggerud tell you verbally point No. 4?

2 A. Yes.

3 Q. Did she tell you verbally point No. 5?

4 A. Yes.

5 Q. Did she tell you verbally point No. 6?

6 A. Can we go back to No. 5?

7 Q. Not yet.

8 A. Okay. No. 6?

9 Q. Just -- are you going to change your position

10 that she told you that verbally?

11 A. Well, I was just going to give you information

12 about it. Okay.

13 Q. We will go over each of them. I just -- I just

14 want to know --

15 A. Okay.

16 Q. -- what you agree she did convey to you over the

17 phone.

18 A. Okay.

19 Q. So we are on point No. 6.

20 A. Partially -- part of that, not the complete

21 statement.

22 Q. Which part did you discuss with her?

23 A. Stepping away from the team will allow the air

24 to clear and work on the relationship.

25 Q. She didn't tell that you she was not confident

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1 that you would be successful if things remained the same

2 in Phoenix because of the distrust and damage in the

3 relationships?

4 A. I don't recall.

5 Q. Is it possible she said that and you just don't

6 recall?

7 A. It could be possible.

8 Q. Did she convey point No. 7 to you verbally?

9 A. She did state that, but I did not request to go

10 into the position. She offered it.

11 Q. And you agreed?

12 A. I didn't feel that I had a choice, because she

13 told me, "Starting Monday, you will be working for Michael

14 Hammond in this temporary role in recruiting."

15 Q. She offered you the position and you accepted

16 it, correct?

17 A. Yes.

18 Q. Did she convey point No. 8?

19 A. Yes.

20 Q. And did she convey to you the final point No. 9

21 from her notes?

22 A. Yes.

23 Q. Do you recall any other specifics about this

24 conversation that are not captured by Ms. Siggerud's

25 notes?

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1 A. Yes. I asked her if I would be returning back

2 to my regular role as a generalist after the position, and

3 she stated it would be based on my performance and that we

4 would discuss it once the temporary position had expired.

5 Q. Anything else that is not captured by her notes?

6 A. Nothing that I recall.

7 Q. During this conversation, did Ms. Siggerud make

8 any mention of your medical condition?

9 A. Yes.

10 Q. When?

11 A. When we were having this conversation and she

12 was telling me about me starting this new position the

13 following week, that she felt that it was best due to my

14 health conditions and me having to take time away from

15 work and that this would better fit me than the current

16 position I was in.

17 Q. Did you also tell her that the stress that was

18 resulting from the complications with the Phoenix branch

19 was detrimental to your health?

20 A. No. I told her that the -- the stress from the

21 accusations of me not being at work because I was

22 attending appointments was causing me stress and making my

23 condition worse.

24 Q. Didn't you tell her that it was the stress --

25 because of your inability to form a relationship with the

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1 leadership at Phoenix was causing you stress, not the

2 medical appointment issue?

3 A. No, no.

4 Q. Anything else that happened during this phone

5 call that was not captured by the notes?

6 A. I -- I don't know. I am not sure.

7 Q. Nothing that you can recall right now?

8 A. Nothing that I can recall, no.

9 Q. Okay. Let's go back to talk about them. If you

10 can, flip back to point No. 1. It says that in

11 Ms. Siggerud's notes: Still struggling with the HRG role,

12 structure and what activity you can be doing to

13 effectively support your team but especially Phoenix.

14 What does that mean to you?

15 A. I was voicing concern as well as Janelle and

16 Kaela. We were all voicing concern that we were confused

17 around what the job description was, because at this point

18 no -- no -- no written job description had been

19 established or provided to us, and she was telling us that

20 we are responsible for developing the role and what it

21 was.

22 Q. You understood what your job was as a generalist

23 well enough to describe it to managers, correct?

24 A. From the direction of the HR team when we had

25 our HR realignment meeting, yes, I portrayed to them what

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1 I was -- what information I was given during the -- the

2 meeting about the realignment.

3 Q. So if Jake asked you, "What are your job

4 duties," you were able to tell him what your job duties

5 were, correct?

6 A. I was, but they were very vague and very gray,

7 and he stated he was still confused by them because he

8 didn't feel like it was anything concrete of what we were

9 doing.

10 Q. Okay. I understand what you believe his

11 perception was, but based on the conversations, even

12 though there was not a written job description, you still

13 had a basic understanding of what you were supposed to be

14 doing as a generalist, correct?

15 A. I had an idea.

16 Q. Well, you were able to convey that to the

17 managers when they asked you what your job entailed,

18 correct?

19 A. I conveyed what -- what they reiterated to us

20 during the meeting, but from my understanding from

21 Rachael, it was a developing role.

22 Q. I understand it was developing, but you also

23 understood what your duties were because you were told

24 what they were when the role was initiated, correct?

25 MR. MILLS: Object to the form.

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1 BY MS. FRANCIS:

2 Q. You are saying what they conveyed to you during

3 a meeting. Somebody told you what your job duties were,

4 correct?

5 A. Not necessarily job duties. They told us how we

6 should help with the transition but that they were still

7 developing the role and we would continue to have meetings

8 over the next several months to learn more about the

9 position and more about what our job really was.

10 Q. When Jake Briscoe asked you what your job duties

11 were as a generalist, you provided him an answer, correct?

12 A. I did, and I told him that they were still

13 developing and they would -- more would be added to it and

14 I would be able to give him more information as time

15 passed.

16 Q. But you were able to describe specific job

17 duties that you were to do as a generalist when Jake asked

18 you what your job entailed?

19 A. Not specific. Not specific. It was -- I would

20 give him very broad answers about what we were working on

21 to support them with.

22 Q. But you gave him an answer --

23 A. Yes.

24 Q. -- which contained a description of your job

25 duties?

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1 A. Yes.

2 Q. Point No. 2 states: As of today, there is

3 clearly a breakdown in your relationship with Phoenix, and

4 you demonstrate a lot of animosity towards some people in

5 particular.

6 Did I read that correctly?

7 A. Yes.

8 Q. What does this mean to you?

9 A. I felt it just went back to the managers telling

10 her -- I mean, because she never would tell me

11 specifically. She would just say "the management group in

12 Phoenix." But I felt it just went back to me missing time

13 from work but then also combined with them being really

14 confused about what the position itself was.

15 Q. Is there a specific event that led to the

16 breakdown in your relationship with Phoenix?

17 A. Can you restate that?

18 Q. Sure. Was there a specific event that led to a

19 breakdown in your relationship with the Phoenix management

20 team?

21 A. It all kind of corresponded at the same time, so

22 me coming back from the leave also occurred at the same

23 time as the realignment of me going into a new position.

24 So I would say that I felt it was both of those things.

25 Q. Well, you moved into the recruiting role in late

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1 July of 2013, correct?

2 A. Correct.

3 Q. And you took on the generalist role in February

4 of 2013, correct?

5 A. Correct.

6 Q. Was there something that happened in or around

7 July? Because she says: As of today, there is clearly a

8 breakdown.

9 Was there something that happened --

10 A. I think it was all the events leading up to that

11 day, not specifically that day.

12 Q. So you are not aware of anything that happened

13 in July that led to a breakdown?

14 A. Other than me requesting an accommodation -- an

15 ADA accommodation, that is what sparked the events of me

16 going into a new role. There was no talk of going into a

17 different position prior to me requesting an ADA

18 accommodation.

19 Q. Who did you demonstrate a lot of animosity

20 towards?

21 MR. MILLS: Object to the form.

22 THE WITNESS: I am unsure who she was

23 speaking of.

24 BY MS. FRANCIS:

25 Q. Did you express to her that you disliked anyone

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1 in Phoenix?

2 A. No.

3 Q. Did you express to her that you didn't want to

4 work with any particular manager in Phoenix?

5 A. No.

6 Q. Did you express to her that you felt that Jake

7 was unresponsive to your attempts to develop alliance or

8 strategy within his leadership team?

9 A. Yes.

10 Q. And tell me specifically what you told her as to

11 that point.

12 A. I expressed to her that I -- when I came back

13 from the realignment meeting that I sat down with Jake and

14 tried to give him feedback from the meeting of what we

15 discussed and that he was very confused by why HR had made

16 that turn to go that direction. And he was frustrated

17 with the fact of we were asking questions about his

18 financials and the business, and he stated that it was his

19 business and he was going to run it the way he saw fit and

20 he didn't understand why HR was questioning him or wanting

21 to get involved with the financial aspect of the location

22 that I was at with him.

23 Q. And how many times did you have conversations

24 with him about his lack of understanding as to why you

25 were involving yourself in the financial aspects of the

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1 plant's business?

2 A. I don't know the exact times or number of times

3 but it was several times.

4 Q. You also mentioned earlier that a lot of the

5 functions that you had performed as an HR representative

6 were now being performed by the management team at the

7 location, correct?

8 A. Yes.

9 Q. So Mr. Briscoe's management team was having to

10 do a lot of the HR functions that you had previously

11 performed, correct?

12 A. They were handling payroll. Anything else would

13 be -- the managers were instructed to have the -- hand the

14 employee a brochure, and there was an employee hotline

15 they could call for assistance instead of contacting me

16 directly at the location.

17 Q. And you had previously done payroll, correct?

18 A. Yes.

19 Q. How time consuming is payroll?

20 A. It -- it wasn't very time consuming for me

21 because I had experience in it.

22 Q. When you transitioned that role to the managers

23 in Phoenix, how did that go?

24 A. They were frustrated by it, that they had to

25 take on more job -- you know, job duties, and they

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1 stressed the fact that they felt that an HR person was at

2 the location so they felt that it should still be part of

3 my responsibilities and not theirs.

4 Q. Did Mr. Briscoe tell you that specifically?

5 A. He did not but Mitch Rubinoff did.

6 Q. Were there any other duties that they assumed

7 after the realignment locally that they expressed to you

8 they were frustrated with other than payroll?

9 A. I want to say it was their duties. They were --

10 they were frustrated with the change -- the chain

11 management of things. Instead of being able to talk to me

12 because I was there, they expressed frustration with

13 having to have to call someone and then wait for them to

14 call them back from a centralized location.

15 Q. What about hiring? Who did hiring after the

16 realignment at the plant?

17 A. The talent acquisition specialist of the

18 representatives that were moved into those roles, they

19 would do the screening and the phone interviews, but the

20 managers still continued to do the same role of

21 interviewing the candidates and choosing and then offering

22 the offer of employment.

23 Q. Did they have any additional work in the hiring

24 process before and after the realignment?

25 A. Yes. They were required to do the onboarding

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1 portion of new employees as they were hired on their first

2 day.

3 Q. Did they --

4 A. So they were required to do their paperwork and

5 fill -- have the new employees fill the documents out and

6 walk them through their training videos and submit all

7 their new-hire paperwork to the corporate office.

8 Q. And did they express to you that they were

9 frustrated that that was now a job duty that was being

10 placed on them?

11 A. Yes. They stated that they were already

12 struggling -- keeping up with their own positions much

13 less having to do HR functions on top of their -- their

14 already original jobs.

15 Q. Who told you that?

16 A. The route managers that were at the location and

17 then the service managers, the sales managers. Everyone

18 pretty much in management in Phoenix and in Los Angeles

19 had concerns about take -- having to do these extra steps

20 or taking extra time out of their day to complete the task

21 whenever -- I was still involved in the location with

22 them.

23 Q. Did Mr. Briscoe express those concerns

24 specifically?

25 A. Yes.

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1 Q. And Mitch?

2 A. Yes.

3 Q. Were there any other functions or tasks that the

4 local managers had to perform that had traditionally been

5 done by an HR representative after the realignment?

6 A. I am trying to think. I believe another thing

7 would have been if -- if an employee had questions about

8 benefits but they -- the manager would just have to

9 recommend for them to call the -- the employee hotline

10 that G&K developed.

11 Q. But they were the first point of contact where

12 they hadn't previously been on benefits issues?

13 A. Correct.

14 Q. Anything else that you think of that they had to

15 do after the realignment?

16 A. I can't -- I can't recall anything else.

17 Q. We already talked about No. 3 and 4 and 5.

18 Point No. 6, you said that Ms. Siggerud did

19 convey to you that time away from Phoenix will allow the

20 air to clear and then you can work on the relationships

21 from both sides, correct?

22 A. Can you -- I'm sorry, can you restate that?

23 Q. Did Ms. Siggerud convey to you that part of

24 point No. 6?

25 A. Yes.

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1 Q. And you don't believe she conveyed the top part,

2 the first part of point No. 6 --

3 A. No.

4 Q. -- that she was not confident that you would be

5 successful?

6 A. No, she didn't portray distrust and damage. She

7 just stated that she felt that it would better the

8 relationship.

9 Q. Did Ms. Siggerud convey to you that it may be

10 possible for you to stay in the recruiting position if an

11 opening becomes available?

12 A. She did. She stated it would be based on my

13 performance and then if something became available. If

14 not, I would return to my generalist role.

15 Q. Okay. One of the other reasons -- going back to

16 where we were before the lunch break -- you said that you

17 felt you were treated differently had to do with you were

18 required to develop a game plan for Phoenix. Tell me

19 specifically what you were asked to do.

20 A. Rachael stated that she wanted me to come up

21 with a -- a game plan document, being very specific, along

22 the lines of how I was going to develop these

23 relationships with the -- with the managers, and then how

24 I would show them that I -- I do have engagement, and how

25 I would show them that I was going to continue to support

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1 them in a positive way.

2 Q. And you don't believe anybody else was asked to

3 do that?

4 A. No one else was.

5 Q. Do you know if the other generalists were having

6 the same issues with the management team to the level that

7 you were in Phoenix?

8 A. Yes.

9 Q. Who was Kaela having the same -- these same

10 issues with?

11 A. Her plant manager.

12 Q. Which one?

13 A. Her -- the one that she was located at in Saint

14 Paul.

15 Q. Do you know the person's name?

16 A. I do not recall his name. Chuck, I think maybe.

17 Q. And what is this information -- information

18 based on?

19 A. Conversations in our meetings, our group

20 meetings between Kaela, Janelle and I.

21 Q. When would you have these group meetings?

22 A. Just randomly when we were trying to come up

23 with new ideas or new strategies of what to do in this new

24 role.

25 Q. Was Rachael involved in these conversations?

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1 A. Sometimes she was and sometimes she was not.

2 Q. Do you have a specific memory of her

3 participating in a call where Kaela expressed that she was

4 having serious issues in forming a relationship with the

5 Saint Paul plant manager?

6 A. Yes.

7 Q. When did that occur?

8 A. I don't recall the exact date.

9 Q. What did Kaela say?

10 A. She stated that Chuck was very resistant to the

11 change and that he was being very aggressive with her and

12 very short and very rude and condescending when he was

13 talking to her and that she had to go and get her plant --

14 her general manager involved, Andy.

15 Q. Did Kaela have a good relationship with Andy?

16 A. Yes, from what I understand.

17 Q. And Andy would have been in the same position as

18 Jake Briscoe?

19 A. Yes.

20 Q. Do you know if Kaela had any issues in her

21 relationship with any general managers of the locations

22 she supervised?

23 A. I think she just had Andy, but, no, nothing that

24 I recall.

25 Q. Okay. Did Janelle express that she had any

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1 relationship issues with any of the general managers at

2 any of the locations she supervised?

3 A. No.

4 Q. Do you know what Chuck's position was?

5 A. He was the plant manager.

6 Q. And that is a subordinate to the general

7 manager?

8 A. Yes.

9 Q. And do you know whether or not Kaela was asked

10 to develop a game plan to deal with Chuck, the plant

11 manager?

12 A. No, but she did just express that in her

13 conversations with Andy, her GM, that he was also confused

14 about her role and what she was to be doing.

15 Q. Okay. I want to talk specifically about the

16 game plan that you were asked to develop by Ms. Siggerud.

17 Did that deal specifically with just Phoenix and Jake

18 Briscoe?

19 A. She told me that it was for Jake and the Phoenix

20 management team.

21 Q. And you said "no" to my question before, but it

22 is not a clear answer because of the way the question was

23 posed. Do you know if Kaela was asked to develop a game

24 plan to deal with Chuck, the plant manager, in Saint Paul?

25 A. No.

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1 Q. You don't know or, "no," she was not asked to do

2 that?

3 A. She was not asked. Sorry.

4 Q. How do you know she was not asked to do that?

5 A. I asked her.

6 Q. And she said?

7 A. "No."

8 Q. Did she have a requirement to do anything to

9 develop or correct that relationship?

10 A. No.

11 Q. Not that you are aware of?

12 A. When I asked her, she said, "no."

13 Q. What was done in response to Chuck's behavior,

14 if you know?

15 A. She told me that he was written up and given a

16 disciplinary.

17 Q. And did it resolve after that, if you know?

18 A. I -- I don't recall.

19 Q. Do you recall when, about, this was happening?

20 A. I don't know a specific date, no.

21 Q. Was the discipline issued by Andy, the GM?

22 A. I am not sure. I am not sure if she involved

23 Rachael or if it was between her and Andy.

24 Q. Do you know outside of that one incident that

25 Chuck was written up for whether he had ongoing issues

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1 with Kaela?

2 A. I am not sure she -- she expressed to me -- she

3 -- she -- he was always difficult to work with.

4 Q. Did she give you any more specifics other than

5 that?

6 A. She didn't give me specific dates or anything,

7 no.

8 Q. Any specifics about issues she had in the

9 relationship other than this one instance that Chuck was

10 written up for?

11 A. Not anything I can remember exactly, no.

12 Q. Can you look at what has been previously marked

13 as Exhibit No. 10? Do you recognize Exhibit No. 10?

14 A. Yes.

15 Q. What is it?

16 A. My response to the EEOC to the rebuttal

17 statement of G&K.

18 Q. So you wrote the -- the letter portion, correct?

19 A. Yes, I wrote the response.

20 Q. And then you attached exhibits?

21 A. Yes.

22 Q. Are all the exhibits that you submitted to the

23 EEOC in your rebuttal present in Exhibit No. 10? Is it

24 complete?

25 MR. MILLS: Take your time and look at it.

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1 THE WITNESS: Yes.

2 BY MS. FRANCIS:

3 Q. "Yes," it is complete?

4 A. Yes, it is complete.

5 Q. The exhibits that you attached then were all

6 e-mails that you had sent to your home e-mail account?

7 A. My personal e-mail account.

8 Q. If you look at page 2 in the letter portion of

9 the rebuttal that is labeled Williams, dash, 00089, in the

10 second full paragraph, it -- you talk about your salary

11 increase in May of 2013. Do you see that?

12 A. Yes.

13 Q. You say: Although G&K is stating that there

14 were performance issues, I was given an increase to come

15 to standard salary of an 11.2 increase from $45,305 to

16 $50,365, May 4, 2013.

17 Did I read that correctly?

18 A. Yes.

19 Q. You were given an increase to come to the

20 standard is what you said.

21 A. Yes.

22 Q. What does that mean?

23 A. When they offered me the new role and I started

24 in this position in May, I -- after reviewing documents of

25 our compensation, I noticed that the general position --

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1 the generalist position had been posted and that I was not

2 at the minimum starting point at this position, so I was

3 being paid less than the other two generalists.

4 Q. So actually you got a pay increase when you

5 first moved into the position of generalist, correct?

6 A. No.

7 Q. Well, what were you being paid at -- what rate

8 were you being paid at?

9 A. The same salary that I was as a representative.

10 Q. So then a generalist position was posted for

11 where?

12 A. I'm sorry, can you --

13 Q. You said that you saw a generalist position

14 posted and you realized that you were below what the

15 posting had for a pay level, correct?

16 A. Yes, the compensation plan.

17 Q. Okay. What specifically did you see that led

18 you to believe your compensation was lower than it should

19 be?

20 A. The -- the minimum starting point in the

21 compensation plan was significantly higher than what I was

22 being paid currently.

23 Q. Where did you see the minimum compensation?

24 What kind of document was this?

25 A. It was a shared document on the HR portal, and

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1 it was under the compensation plans.

2 Q. And what was the starting salary minimum for

3 this position?

4 A. It was the 50,365.

5 Q. And who did you notify about this discrepancy?

6 A. Rachael.

7 Q. And what did she tell you?

8 A. She told me that she had noticed that and that

9 she had mentioned it to Pelham Chastang and she was glad

10 that I brought it up and that she wanted to discuss it

11 with me. And she stated that she would review it with

12 Eric -- Eric McNaul and Pelham Chastang, and it also would

13 be based on my current performance, and she would talk to

14 him, and she would get back to me and let me know what

15 their decision would be.

16 Q. And what did she tell you?

17 A. A week or two passed by -- we were on a trip

18 together. We were traveling. We were in Los Angeles

19 together. She was introducing me to all the new managers

20 that I would be working with, and she -- we returned home.

21 And it was approximately a week to two weeks later, she

22 called me and told me that she discussed it with Pelham

23 Chastang and that they reviewed my job performance and

24 also they reviewed the compensation plan, and they agreed

25 that I would be raised to the minimum level for the

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1 generalist position.

2 Q. And were any of these conversations documented,

3 or can we find this in e-mails?

4 A. I don't recall.

5 Q. If you look at Exhibit M to Exhibit 10, it is a

6 compilation of e-mails that I want to talk about. So tell

7 me when you are there. The first page is labeled

8 WILLIAMS 000119.

9 A. Okay.

10 MS. FRANCIS: Do you need to look at it,

11 Bob?

12 MR. MILLS: No.

13 BY MS. FRANCIS:

14 Q. Do you recognize this document that is within

15 Exhibit No. 10 labeled as WILLIAMS 119?

16 A. Yes.

17 Q. What is this document?

18 A. This was after I had surgery due to the health

19 conditions that I was having, and this was when I had

20 returned to work, and this was the restrictions that I was

21 given from my doctor.

22 Q. And what is the date of this e-mail?

23 A. June 14, 2013.

24 Q. Did you have the surgery on June 13th?

25 A. I don't recall if it was the 12th or the 13th.

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1 Q. But you returned to work on the 14th, correct?

2 A. Yes, I returned to work on the 14th.

3 Q. And you e-mailed Ms. Siggerud at 4:00 p.m. --

4 A. Yes.

5 Q. -- to let her know that you were in the office,

6 correct?

7 A. Yes.

8 Q. And you told her that you had restrictions of no

9 lifting, pulling, pushing over ten pounds, prolonged

10 standing, no climbing stairs for two weeks, correct?

11 A. Yes.

12 Q. And what was her response?

13 A. I don't recall.

14 Q. Did you say anything in this document about

15 having to attend follow-up appointments?

16 A. Yes.

17 Q. For the next two weeks, correct?

18 A. Yes.

19 Q. Did you require any additional appointments

20 related to the surgery outside of the two-week period?

21 A. No, not related to this specific appointment.

22 Q. This specific medical procedure?

23 A. Yes.

24 Q. So related to the surgery, you only needed

25 follow-up appointments for two weeks, correct?

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1 A. With this doctor.

2 Q. What other doctor did you need to follow up with

3 other than the surgeon?

4 A. Dr. Joseph Brooks, he was my primary

5 gynecologist. He referred me to this surgeon that I had

6 surgery with, and I continued my medical care with him

7 after the surgery.

8 Q. And was that care ongoing from your condition

9 prior to the surgery, or was that ongoing related to the

10 surgery specifically?

11 A. It was ongoing from my previous condition.

12 Q. Okay. So as it relates just to the surgery, you

13 had two weeks of follow up with your surgeon and then a

14 follow up with your primary care physician and then you

15 would continue your previous treatment, correct?

16 A. Yes.

17 Q. If you look at the next page in this exhibit,

18 which is labeled WILLIAMS 120, do you recognize this

19 document?

20 A. Yes.

21 Q. What is it?

22 A. Response from Rachael.

23 Q. And what does she say?

24 A. "Thank you for your update."

25 Q. And does she go on?

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1 A. Yes.

2 Q. What does she say?

3 A. "I am glad you are back up and around, and

4 hopefully everything went well."

5 Q. Did she describe that she was not able to reach

6 you on the phone number you provided?

7 A. She -- she did state that.

8 Q. Was that a work phone number or a different

9 phone number?

10 A. I am not sure what number she tried to reach me

11 at.

12 Q. It says the voicemail doesn't appear to be

13 active.

14 Does that indicate to you whether that was

15 your personal cell phone or work line?

16 A. I don't -- I don't know which one she tried to

17 call. It states: Is this your G&K phone?

18 So I -- I am not sure she knew which number

19 it was either.

20 Q. Had you given her a number to contact you?

21 A. Normally she contacted me on my G&K cell phone

22 that was given to me by the company.

23 Q. It sounds like you may have provided her a

24 different phone number though, correct?

25 A. She knew my personal cell phone number also.

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1 Q. Do you recall having any issues with voicemail

2 on either of those accounts in June of 2013?

3 A. I don't recall.

4 Q. Do you know if this was the same phone number

5 that other people from G&K would have tried to reach you

6 on?

7 A. I am not sure what number she was calling, but

8 mostly everyone contacted me on my G&K cell phone.

9 Q. Did you do anything after receiving this to

10 ensure that people at G&K could reach you?

11 A. Yes.

12 Q. What did you do?

13 A. I checked my e-mail on the company-issued phone

14 to make sure that it was working and to make sure that my

15 voicemail was there. I called the phone and I listened to

16 my voicemail when it came on to make sure that everyone

17 knew who they were contacting and they could actually

18 leave me a message.

19 Q. And there were no problems that you encountered?

20 A. No.

21 Q. Were there any problems with your cell phone

22 around this time frame that you had to correct?

23 A. My personal cell phone?

24 Q. Yes.

25 A. No.

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1 Q. Did you provide your personal cell phone number

2 to anyone other than Ms. Siggerud at G&K to contact you

3 on?

4 A. I don't recall. They might have contacted me

5 from me contacting them from that number.

6 Q. But there are some people that use their

7 personal cell phone for business regularly. Was that your

8 practice?

9 A. No.

10 Q. Did you have a G&K cell phone?

11 A. Yes.

12 Q. So you carried two cell phones?

13 A. Yes.

14 Q. Did Ms. Siggerud say anything in her -- in her

15 response about being concerned about your follow-up

16 appointments?

17 A. She was concerned about how long it would take

18 before I would be back to normal and if it was part of my

19 previous health condition and if that was still ongoing.

20 Q. Does she say that in WILLIAMS 120?

21 A. No. She stated it verbally in a conversation.

22 Q. After this e-mail exchange?

23 A. Yes, during our one-on-one I believe.

24 Q. What did you respond when she expressed concern

25 about how long it would take for you to be back to normal?

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1 A. I reassured her that I, you know, was in the

2 office every day and performing my job and that outside of

3 just going to my doctors' appointments that I was capable

4 of still performing my job as normal.

5 Q. And did that seem to alleviate her concerns, or

6 was there more discussion about this?

7 A. I don't recall.

8 Q. You don't recall talking about the surgery

9 specifically again --

10 A. No, I don't recall.

11 Q. -- or the follow-up appointments until you would

12 be back to normal?

13 A. I -- I don't recall.

14 Q. If you look at the next page in the groupings of

15 e-mails, it is labeled WILLIAMS 121, and tell me if you

16 recognize this e-mail exchange.

17 A. Yes.

18 Q. We only have one page of this e-mail in what you

19 provided to the EEOC in your rebuttal. Do you recall what

20 Ms. Siggerud's original e-mail was that you were

21 responding to that was about the subject, "flights today"?

22 A. I don't -- I don't recall.

23 Q. Was there an occasion where you missed a flight

24 related to work?

25 A. Yes.

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1 Q. And when was that?

2 A. It was approximately a week or two before they

3 laid me off.

4 Q. And tell me what happened.

5 A. I was very sick, and I had just found out that I

6 was pregnant as well, and I notified Rachael that I was

7 too ill to travel, and I requested to cancel my flight.

8 Q. And did they cancel the flight?

9 A. I canceled the flight with the travel agency.

10 Q. Okay. So this e-mail about flights today is

11 unrelated to what happened in September, correct?

12 A. Yes.

13 Q. Okay. So you have no idea what the prior e-mail

14 about flights today concerned?

15 A. At this time, I don't remember, no.

16 Q. Do you have a memory of missing any other flight

17 other than the one you have already told us about?

18 A. Work-related, no.

19 Q. Did you have to change a flight because of a

20 delay or any work issues?

21 A. I don't recall.

22 Q. And her response to you -- your e-mail about

23 flights today says: I put in your vacation time request

24 for last week because I have not seen it come through yet

25 and added today as well.

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1 Did I read that correctly?

2 A. Yes.

3 Q. What is she referencing, if you know?

4 A. Oh, can you restate that?

5 Q. What, if you know, is Ms. Siggerud referencing

6 when she says that sentence about your vacation time and

7 "added today as well"?

8 A. Oh, my baby-sitter that I had for my son, her

9 father had passed away -- well, he was passing away in

10 Iowa and she notified me, like, spur of the moment that

11 she could -- could not keep my son for the next two weeks

12 because she was leaving immediately that day to fly to

13 Iowa to be with her father when he passed away.

14 Q. And so did you take vacation time off of work to

15 cover when your baby-sitter was going to be out of town?

16 A. Yes.

17 Q. And how long did that last?

18 A. I don't recall exactly. I think it was

19 approximately a week.

20 Q. It says: I have put in vacation time request

21 for last week and added today as well.

22 So it looks like it went longer than a

23 week, correct?

24 MR. MILLS: Object to the form.

25 THE WITNESS: I don't recall. It -- it

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1 could have possibly been in the middle of one week and

2 carried into the next.

3 BY MS. FRANCIS:

4 Q. Okay. But your sitter was away for two weeks,

5 correct?

6 A. Correct.

7 Q. And what did you do for coverage when you were

8 not able to take vacation time and stay home?

9 A. My husband and I tried to share the

10 responsibility. I took off for part of the time and he

11 took off for the remaining part of the time. He took

12 vacation as well.

13 Q. So what is your best estimate of how much time

14 you took off related to this issue?

15 A. I would say a week.

16 Q. In her next sentence, Ms. Siggerud says: I

17 certainly understand that you have some frustrating things

18 happening right now in your personal life with daycare,

19 your health and family illness.

20 The daycare issue is what we just

21 discussed, correct?

22 A. Yes.

23 Q. And we talked about your health issues, correct?

24 A. Correct.

25 Q. What were the family illness issues that you

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1 were encountering?

2 A. The only thing that comes to mind is my son.

3 Because he did go to daycare, he stayed ill quite a bit

4 from catching viruses or colds and stuff from the other

5 children in the daycare.

6 Q. And would you stay home on those occasions when

7 he couldn't go to daycare?

8 A. Yes.

9 Q. So he actually went to a daycare facility?

10 A. When she is speaking of this, those times, he

11 was going to a daycare facility. Outside of that, I --

12 because he was staying so sick, I tried to alleviate that

13 because of the concerns from Rachael. That is when I

14 entailed my neighbor down the street to keep him.

15 Q. So there was a period of time when he was going

16 to a daycare?

17 A. Yes.

18 Q. And there was of a period of time where you were

19 having the neighbor that had the ill relative that she had

20 to go to Iowa for, correct?

21 A. Yes.

22 Q. When your son was ill and couldn't go to the

23 daycare center, would you take off work to stay with him?

24 A. Yes.

25 Q. How often did that happen?

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1 A. I don't recall how often. But even when I did

2 take off to take care of him, I could still work remotely.

3 I had a G&K issued laptop, so I would still work from

4 home, and I would still perform, you know, functions, or

5 anyone from the office could call me on my G&K phone and I

6 would still help them over the phone or assist in, like,

7 any requests that they had, because I could do it all from

8 my laptop.

9 Q. Can you estimate for me how many times you had

10 to take off work to stay home with your son when he

11 couldn't go to daycare?

12 A. I don't recall the exact number.

13 Q. Can you give me a range of any sort?

14 A. I -- I really don't remember.

15 Q. More than ten?

16 A. No, I wouldn't say it was that many.

17 Q. More than five?

18 A. Possibly.

19 Q. And she says: However, it is concerning that it

20 always seems to be last minute, and I would like to have

21 some conversation when you return about the impact to our

22 business and team when your plans suddenly change and you

23 are unavailable.

24 Did I read that correctly?

25 A. Correct.

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1 Q. And is this what you were talking about

2 previously when you said that Ms. Siggerud expressed that

3 she was concerned about the time that you took away from

4 the business for medical appointments?

5 A. Yes, because she states: Due to your health.

6 Q. And did you have a follow-up conversation when

7 you returned from vacation?

8 A. Yes.

9 Q. And is that what you have already described to

10 me or is there another conversation?

11 A. No.

12 Q. No, that's what you have already described?

13 A. Correct.

14 Q. Okay. I don't want to cover ground we have

15 already covered.

16 Within the same exhibit -- and I think it

17 is under Exhibit N to Exhibit 10 at WILLIAMS 124 -- there

18 is another e-mail. So let me know when you are there.

19 A. Okay.

20 Q. There is kind of a note that is covering part of

21 the text, but do you recognize Exhibit -- I should say do

22 you recognize WILLIAMS 124, which is an exhibit to your

23 rebuttal, Exhibit No. 10?

24 A. Yes.

25 Q. And what is that?

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1 A. It was an e-mail requesting help from Rachael of

2 what to write for the -- the performance review.

3 Q. And Rachael's response to you answers that

4 question about what you should put in your G&K performance

5 document, correct?

6 A. Correct.

7 Q. And this is dated June 27th of 2013, correct?

8 A. Correct.

9 Q. And she states: I recommend that you go ahead

10 and update the midyear section with updates based on your

11 original goals for fiscal year '13, then update your

12 year-end with the new goals.

13 Did I read that correctly?

14 A. Correct.

15 Q. Does she say in here any way -- does she say in

16 here how specific you should be about your goals?

17 A. Not in the e-mail. We had a verbal conversation

18 about it.

19 Q. And at this time when you are updating your

20 performance document, the midyear section is based upon

21 your original goals, which would have been written when

22 you were still a representative, correct?

23 A. Correct. And I was on maternity leave and the

24 goals were never completed.

25 Q. Okay. So you would have completed your annual

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1 goals in or around July of the prior year, correct?

2 A. Can you restate that?

3 Q. In July of 2012 you would put your goals in for

4 2013, correct?

5 A. Correct, and I was on maternity leave.

6 Q. So you did not do your original goals, correct?

7 A. Correct.

8 Q. And when you returned from maternity leave, did

9 you put in your original goals?

10 A. No, because we were in the realignment

11 transition.

12 Q. When you returned to your position -- that would

13 have been in October, correct --

14 A. Correct.

15 Q. -- of 2012?

16 A. Correct.

17 Q. And you were in that position until February of

18 2013, correct?

19 A. Correct, outside of the leave in December.

20 Q. And during that time frame, you didn't establish

21 goals for what you would be doing in 2013 in the

22 representative position?

23 A. No. I had mentioned it to Jacob Briscoe, and he

24 stated that we would wait until the realignment and he

25 knew what I would be doing.

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1 Q. After you sent this e-mail to Ms. Siggerud in

2 June of 2013, did you insert goals for the first part of

3 the year where you were a receptionist -- not a

4 receptionist, a representative, sorry.

5 A. I would have to see the document. I am not -- I

6 am not sure of when I updated it or -- or placed new goals

7 in there.

8 Q. Did Mr. Briscoe have input on what your goals

9 were when you were a representative?

10 A. Yes, we did those together. He was my direct

11 supervisor.

12 Q. So you would work on your performance objectives

13 together?

14 A. Yes.

15 Q. And then when you were a generalist, you would

16 work on those performance goals with Ms. Siggerud?

17 A. Correct.

18 Q. After receiving this e-mail, WILLIAMS 124, did

19 you update your performance objectives?

20 A. I don't -- I don't recall.

21 Q. If you could look at WILLIAMS 127 -- still in

22 Exhibit No. 10 -- and tell me, do you recall this e-mail?

23 A. Yes.

24 Q. When is it dated?

25 A. July 16th.

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1 Q. And you are writing to Ms. Siggerud?

2 A. Yes.

3 Q. And what do you say?

4 A. I asked -- I made her aware that I was in

5 Tucson, and I asked her a question about the merit and

6 asked her if I was on a performance improvement plan.

7 Q. Why did you believe that you were on a

8 performance improvement plan or you might be?

9 A. From -- because from the time I requested the

10 ADA accommodation, it seemed like every time her and I had

11 a conversation, it was always something around, "You are

12 not engaged," "The management team feels like you are not

13 available, you are not in the business." It just felt

14 like we couldn't have a normal conversation. It was -- it

15 was always something around me not being available,

16 although I was there every day.

17 Q. Didn't those conversations actually start before

18 you requested an ADA accommodation?

19 A. They -- they began before.

20 Q. And did Ms. Siggerud tell you whether or not you

21 were on an action improvement plan?

22 A. Yes.

23 Q. What did she say?

24 A. No, not at this time.

25 Q. When she said, "Not at this time," what did you

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1 -- did you indicate -- strike that.

2 When she said, "Not at this time," did that

3 indicate to you that your performance was at a level that

4 it may soon become part of an improvement plan?

5 A. No. I just felt that she was leaving it open to

6 potentially have an issue. I just felt that she kept

7 building upon things after every conversation we would

8 have, and I kind of felt like it was an open-ended answer

9 of "Not right now, but if I continue to have issues with

10 the conversations with you, then maybe potentially."

11 Q. When you took over Southern California in your

12 new role as generalist, did you undertake or participate

13 in any training specific to California law?

14 A. No.

15 Q. You understand that California has complex

16 employment laws?

17 A. Yes.

18 Q. And you were starting to provide HR services in

19 California, correct?

20 A. Yes.

21 Q. But you didn't feel it necessary to learn any of

22 the specific HR legal requirements?

23 MR. MILLS: Object to the form.

24 THE WITNESS: I had done -- okay.

25 MR. MILLS: Go ahead.

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1 THE WITNESS: I had done my own self-study.

2 I had applied to take my PHR, and the information was

3 included in my previous studies in my HR.

4 BY MS. FRANCIS:

5 Q. What previous studies?

6 A. I was studying for the professional human

7 resources test. I was studying to -- to be seated for

8 that test, to get my certification in HR.

9 Q. And how -- when were you doing this?

10 A. I don't recall the exact date.

11 Q. Was it before you took the original leave for

12 your son's birth?

13 A. Yes.

14 Q. And did you ever complete that certification?

15 A. I tested for it twice I believe.

16 Q. And did you complete and get that certification?

17 A. No.

18 Q. So you tested twice and you didn't pass either

19 time?

20 A. No. I didn't pass by, like, two points.

21 Q. On both occasions?

22 A. Yes, I believe so.

23 Q. Other than that certification course, did you do

24 anything to educate yourself about California-specific

25 employment laws?

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1 A. No, because I was not handling anything legally

2 or specifically when it came to California laws as in

3 regards to the California leave rules and obligations.

4 The corporate office and the employee hotline was handling

5 all specific issues when it came to anything legally

6 related to a leave of absence or an FMLA or anything --

7 anything of that sort.

8 I was more dealing with the business aspect

9 in regards to financials and sales and being more of a

10 strategic partner and not dealing with any compensation or

11 any benefit plans. That was all given to the localized

12 office in -- in Minnesota.

13 Q. How about schedules and meal break periods?

14 A. The corporate office dealt with that, or Rachael

15 dealt directly with that with the GM.

16 Q. What about overtime issues?

17 A. Rachael dealt with that.

18 Q. Do you know if Janelle had any specialized

19 training in California employment laws?

20 A. I believe she had a certification in HR.

21 Q. Do you know if she had any specific training

22 relative to California?

23 A. I am -- I am unsure.

24 Q. So you don't know what her California-specific

25 knowledge was?

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1 A. No.

2 Q. How many years, do you know, had Janelle been

3 working in California in an HR capacity?

4 A. I believe a year prior to coming to G&K.

5 Q. Do you know when she started with G&K?

6 A. She started, I am guessing, a year after I had

7 been there. I had trained with the previous person in her

8 position when I started prior to her coming on board.

9 Q. Okay. So you started before she did?

10 A. Yes.

11 Q. But you believe that she came from a California

12 HR-based position prior to working at G&K?

13 A. I am unsure what position she held. I was just

14 aware that she worked for a bank.

15 Q. In California?

16 A. Yes.

17 Q. In an HR capacity?

18 A. I am unsure if it was an HR position.

19 Q. Do you think that you were more qualified than

20 Janelle to handle HR issues in California?

21 A. I don't know if I would say "more qualified,"

22 but I -- I performed the position, and I was more -- I had

23 more of a relationship with those individuals in those

24 locations because I had had previous experience with them

25 in my visits.

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1 Q. You mean with the manager -- plant manager in

2 L.A.?

3 A. Yes.

4 Q. How would you describe your relationship with

5 her?

6 A. I didn't have much interaction with -- with her.

7 I more had interaction with their HR representative,

8 Leticia Rovero, because she trained me when I was first

9 initially hired with G&K, and I went and stayed a few days

10 in Los Angeles and met all of their managers, and I worked

11 closely with her when I first started.

12 Q. And after the realignment, she was in a

13 recruiting position, correct?

14 A. Correct.

15 Q. Did she still work in L.A.?

16 A. Yes.

17 Q. But once you became a generalist, you were to

18 work more with the management level people in L.A.,

19 correct?

20 A. Correct.

21 Q. And so your relationship with the plant

22 manager -- what was her name?

23 A. His name -- I -- Patrick Lemos was his name.

24 Q. And how would you describe your relationship

25 with him?

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1 A. Great. We had a really good relationship.

2 Q. How often did you go to California once you

3 assumed the generalist role?

4 A. I had initially went with Rachael. She asked me

5 to wait till when she could go with me, and she wanted to

6 schedule the business visits around her travel, because

7 she wanted to go with me to introduce me to everyone and

8 just explain the whole realignment of HR to all the

9 managers.

10 Q. So you went once?

11 A. I went once with Rachael, and then I went back

12 an additional time to San Diego by myself.

13 Q. And how long did you stay in San Diego?

14 A. Approximately three days.

15 Q. And why were you going to San Diego?

16 A. To introduce myself to the managers there at the

17 location and to just build on the relationships with them

18 and to start the -- the strategic partnership with them

19 and to discuss talent management and succession planning.

20 Q. Who was the general manager in San Diego?

21 A. Tom Dunn I believe.

22 Q. And so you met with him once for three days,

23 correct?

24 A. Yes.

25 Q. And you met with the plant manager in L.A. on

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1 one occasion for one day with Rachael, correct?

2 A. Yes.

3 Q. Did you make any other trips to California

4 during the time that you were a generalist?

5 A. Not after that, no.

6 Q. Did you ever go to Ontario?

7 A. Yes.

8 Q. And that is in California, correct?

9 A. Yes.

10 Q. When did you do that?

11 A. When I was with Rachael. The same trip we went

12 to Santa Fe Springs in L.A., and then we drove to Ontario

13 one day, and then the following day we drove to Sun

14 Valley, California.

15 Q. So you visited all of the locations once?

16 A. Correct.

17 Q. Who was the manager in Ontario?

18 A. I don't -- I don't recall his name.

19 Q. And who was the manager in Sun Valley?

20 A. I don't recall a specific name.

21 Q. Was there a woman manager in L.A. that you had

22 issues with?

23 A. The general manager there was Angie Gracyck and

24 I thought we had a great relationship. I only met her

25 once.

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1 Q. Did you get any feedback from her about what she

2 felt your role should entail or whether or not you were

3 accomplishing your goals?

4 A. No.

5 Q. Do you know if she provided any feedback back to

6 Ms. Siggerud about your role?

7 A. I was not aware of any.

8 Q. And you said she was the general manager,

9 correct?

10 A. Yes.

11 Q. But you told me previously there was a different

12 general manager or was that a plant manager in L.A.? You

13 said his name was Patrick.

14 A. Patrick Lemos is the plant manager in Los

15 Angeles.

16 Q. And Angie was the general manager?

17 A. Correct.

18 Q. So Angie would have worked under Patrick,

19 correct?

20 A. No. Patrick would have worked under Angie.

21 MS. FRANCIS: Okay. Can we take a quick

22 break?

23 MR. MILLS: Sure.

24 VIDEO TECHNICIAN: This is the end of media

25 No. 3 in the continuing deposition of Brandy Lane

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1 Williams. Today's date is June 14, 2016. The time is

2 1:46 p.m.

3 (Recess ensued from 1:46 p.m. until

4 1:57 p.m.)

5 VIDEO TECHNICIAN: We are back on the

6 record. This is the beginning of media No. 4 in the

7 continuing deposition of Brandy Lane Williams. Today's

8 date is June 14, 2016. The time is 1:57 p.m.

9 BY MS. FRANCIS:

10 Q. Can you look at what has previously been marked

11 as Exhibit No. 8?

12 A. Okay. Yes.

13 Q. Have you seen Exhibit No. 8 before?

14 A. Yes.

15 Q. What is it?

16 A. The phone conversation between Rachael Siggerud

17 and myself.

18 Q. Have you read the transcript?

19 A. Not in its entirety.

20 Q. Have you verified that what is contained within

21 the transcript is an accurate depiction of what was said

22 during your phone call that you recorded with Rachael?

23 A. A portion of it.

24 Q. Okay. Which portion have you confirmed is

25 correct?

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1 A. I think I read the first two or three pages.

2 Q. And did it appear correct to you?

3 A. Yes.

4 Q. Okay. I would ask -- I need verification that

5 what was said in this transcription is what you said on

6 that call. So I don't know if we want to take a break and

7 do that off the record, but I am going to ask you that

8 question about both of the transcripts that you provided.

9 So I apologize. Maybe we can go off the record so that

10 you can do that; otherwise, I am going to have to go

11 through the statements that are within the transcript. Do

12 you understand?

13 A. Yes. I -- I'll take time to read them.

14 MS. FRANCIS: Okay.

15 VIDEO TECHNICIAN: We are off the record at

16 1:59 p.m.

17 (Recess ensued from 1:59 p.m. until

18 2:33 p.m.)

19 VIDEO TECHNICIAN: We are back on the

20 record at 2:33 p.m.

21 BY MS. FRANCIS:

22 Q. During the break, I asked you to review Exhibits

23 Nos. 8 and 9 that were previously marked in depositions.

24 Have you had a chance to review Exhibit No. 8?

25 A. Yes.

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1 Q. And is Exhibit No. 8 an accurate transcription

2 of a conversation that you recorded on June 26th of 2013

3 between yourself and Ms. Siggerud?

4 A. Yes.

5 Q. I will ask you the same question about Exhibit

6 No. 9. Is Exhibit No. -- well, have you had an

7 opportunity to review in full Exhibit No. 9?

8 A. Yes.

9 Q. Is Exhibit No. 9 an accurate transcription of a

10 conversation that you recorded with Ms. Siggerud and

11 yourself on July 17th of 2013?

12 A. Yes.

13 Q. Okay. Go back to Exhibit No. 8. On June 26th,

14 why did you decide to record your conversation with

15 Ms. Siggerud?

16 A. I felt that I was beginning to be retaliated

17 against just for the mere fact that every time we had a

18 conversation, it was around the perception that I wasn't

19 in the business or that I was away from the business.

20 Q. Did you plan the recording in advance of the

21 call?

22 A. No.

23 Q. Did you have a recording device available to you

24 when the call was ongoing?

25 A. My phone.

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1 Q. You can record on your phone?

2 A. Yes, my cell phone.

3 Q. Do you have a special application to do that?

4 A. It is on every iPhone I think.

5 Q. What is the program called?

6 A. Microphone I think or Recorder. I am not sure.

7 Q. Did you put Ms. Siggerud on speakerphone?

8 A. Yes.

9 Q. And then you recorded what was being said

10 through your iPhone?

11 A. Yes.

12 Q. And was this on the G&K phone?

13 A. Yes.

14 Q. And do you have an understanding of whether or

15 not -- well, strike that.

16 Did you tell Ms. Siggerud that you were

17 recording the phone call?

18 A. No.

19 Q. Why did you choose not to tell her that?

20 A. In the state of Arizona, I was not aware that

21 you were required to tell the other person.

22 Q. Where was Ms. Siggerud when you were recording

23 her?

24 A. I am unaware of where she was. She traveled a

25 lot so I am unsure where she was.

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1 Q. Do you have a understanding of whether or not it

2 is legal to record interstate phone calls, where one party

3 is outside of Arizona?

4 A. I am not aware, no.

5 Q. Have you done any research to determine that as

6 of today?

7 A. No.

8 Q. Do you know where Ms. Siggerud was when you

9 recorded the phone call with her on July 16 -- I'm sorry,

10 July 17 of 2013?

11 A. No.

12 Q. She was not in the state of Arizona?

13 A. Not that I am aware of.

14 Q. And as to the call on June 26 of 2013 that you

15 recorded, Ms. Siggerud wasn't in Arizona when you recorded

16 that phone call either, was she?

17 A. Not that I am aware of.

18 Q. You don't know where she was?

19 A. No.

20 Q. The recording in Exhibit No. 8 starts at minute

21 number -- strike that.

22 The -- the transcript in Exhibit No. 8

23 starts at minute 33; is that correct?

24 A. I am unaware what that means.

25 Q. Where it says "commencement of audio file" on

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1 the beginning of the transcription --

2 A. Um-hum.

3 Q. -- and it says 33:10:01 -- do you see that?

4 A. Yes.

5 Q. -- what does that indicate to you?

6 A. I don't know.

7 Q. Are you aware if the transcription starts in the

8 middle of the phone call that you recorded?

9 A. No.

10 Q. You believe that the transcription includes the

11 complete portion of the call that you recorded?

12 A. I don't recall.

13 Q. Did you record the call from the very beginning

14 of your conversation with Ms. Siggerud?

15 A. I don't recall.

16 Q. And you provided the complete audio files for

17 Exhibit No. 8 and 9 to your counsel?

18 A. Yes.

19 Q. Do you know if there is a portion of the call

20 that is not included in the transcriptions that we have in

21 Exhibits 8 and 9?

22 A. No. I provided everything that was on my phone.

23 I don't have anything else outside of this.

24 Q. But after reviewing these exhibits, can you tell

25 whether or not there was part of the call that is not

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1 included in the transcription?

2 A. No.

3 Q. You can't tell?

4 A. I can't tell. Not that I am aware of.

5 Q. If you look at page 19 of Exhibit No. 8 -- and

6 tell me when you are there.

7 A. Page 17 through 20.

8 Q. Right. And then there is a square at the top

9 right that is page 19.

10 A. Okay.

11 Q. Are you there?

12 A. Yes.

13 Q. At line 13 through 16, Ms. Siggerud is speaking,

14 and she discusses that there was an argument between you

15 and Mitch. Do you see that?

16 A. Yes.

17 Q. What was the argument between you and Mitch?

18 A. I don't believe that we had an argument. I

19 believe that maybe he had a perception that we had an

20 argument, but we were just in a discussion about a

21 business matter that he got upset about just from the

22 answer that I was giving him from what he asked me. But I

23 don't remember getting into an argument with him, no.

24 Q. Tell me specifically what happened.

25 A. I don't remember specifically what we were

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1 discussing.

2 Q. What was he upset about?

3 A. I don't recall. We were -- we were having a

4 meeting about the Phoenix business, but I don't recall

5 specifically what it was about.

6 Q. What answer did you give him that was upsetting?

7 A. That we should be more positive, and that we

8 would -- we would be able to work through these situations

9 together, and he got very upset and said that he was

10 already doing everything that he could do and he couldn't

11 take on any more work and, you know, I think he just

12 became frustrated by me continuing to say that we should

13 be positive.

14 Q. What work was he going to have to take on that

15 he felt that he couldn't take on any more?

16 A. I believe the issue was around them responding

17 and following up with their customers through service and

18 the fact that his managers weren't able to perform their

19 jobs due to that they were running routes and delivering

20 goods all the time because they didn't have enough drivers

21 because he had a lot of turnover in his department.

22 Q. And when you were telling him to stay positive,

23 what did you mean by that?

24 A. I just felt a lot of pushback just from trying

25 to work with him and help be supportive to him in his

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1 role, just to let him know, you know, not to focus on all

2 the negative things and that we would get through those

3 together and I was there to help him and help support him.

4 Q. And you said he was very upset. What did he do

5 that indicated to you he was very upset?

6 A. He just got very loud with me and raised his

7 voice and was yelling at me in front of everyone in the

8 meeting.

9 Q. How many people were there?

10 A. Possibly eight.

11 Q. Do you recall specifically who?

12 A. It was service, so it was his managers, himself,

13 and then Jake and then our plant manager and myself. I

14 can't recall everyone that was there though.

15 Q. There is a suggestion in some of the documents

16 that have been produced that you would critique and point

17 out things that the Phoenix managers were doing wrong and

18 either report on them or tell somebody that they were

19 doing things that were wrong. Do you agree that that was

20 something that has been said about your relationship with

21 the Phoenix managers?

22 A. No.

23 Q. Have you ever heard that before --

24 A. No.

25 Q. -- that you pointed out things they were doing

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1 wrong instead of partnering them to try and come up to

2 resolutions? Have you heard that before or anything like

3 that?

4 A. No.

5 Q. So you don't have an understanding of what that

6 would have been about?

7 A. I -- I haven't been told that before previously,

8 no.

9 Q. Has Mitch ever suggested to you that instead of

10 pointing out things that they are doing wrong that you

11 should work with them to come to solutions?

12 A. No. I was always supportive with him.

13 Q. Did you ever go on routes with the drivers?

14 A. Possibly once or twice.

15 Q. And during those trips, did you point out things

16 that the drivers were doing wrong?

17 A. No. I was there only on -- to observe.

18 Q. Did you ever point out any safety issues that

19 the plant was doing wrong?

20 A. In what aspect?

21 Q. In any aspect. Did you ever say that there are

22 these safety things that they were not following at the

23 plant?

24 A. That was part of my job, yes.

25 Q. How often did you do that?

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1 A. When I went through a walk-through with the

2 managers of the plant, they asked for everyone to

3 participate in the meeting and that if we saw anything

4 unsafe to bring it to their attention so we could include

5 it in our group notes for our group meetings, so it was

6 everyone's responsibility.

7 Q. Who are you referring to?

8 A. Our safety team, our management team at the

9 plant.

10 Q. So this was something that was specific to

11 Phoenix?

12 A. Each location had -- had -- had a safety team

13 that involved their location managers.

14 Q. We already established that you only went to the

15 other locations in California on one occasion each.

16 During those visits did you point out safety issues?

17 A. No, I was not -- I didn't participate in their

18 safety walk-through.

19 Q. Okay. So you only did that in Phoenix?

20 A. I did it Pittsburg once when I went up for a

21 visit.

22 Q. And that is California as well?

23 A. Yes.

24 Q. And who was the general manager there?

25 A. Scott.

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1 Q. And how would you describe your relationship

2 with him?

3 A. We only met maybe on two occasions.

4 Q. And when you were physically present there?

5 A. Yes, when I was physically present, yes.

6 Q. So you went to Pittsburg twice?

7 A. I believe so, yes.

8 Q. What was the purpose of your visits?

9 A. Training, or just shadowing the HR person that

10 was there and just getting ideas from their plant manager

11 to take back to Phoenix.

12 Q. Was this before you became a generalist?

13 A. Yes.

14 Q. After you became a generalist, did you go to

15 Pittsburg, California?

16 A. I -- I don't recall.

17 Q. Was that one of your locations?

18 A. No.

19 Q. What safety issues do you recall reporting on at

20 the Phoenix plant?

21 A. Prior to me moving into the generalist role?

22 Q. After.

23 A. None. I -- I didn't point out anything in the

24 generalist role. I don't recall anything.

25 Q. Did you point out any issues that the Phoenix

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1 management team was doing wrong with the HR functions that

2 were transitioned to them? Like, we talked about payroll

3 and processing. Did you point out any errors in what they

4 were doing with the functions that were transferred to

5 them after the realignment?

6 A. I did, after I was presented the information

7 from Rachael and then also from the corporate office from

8 the department that was having the issue.

9 Q. What errors did you point out?

10 A. Payroll errors or getting time sheets in on

11 time.

12 Q. And who would you report to -- who would you

13 report those errors to?

14 A. Whichever manager it was that had the -- that

15 had the issue with the payroll.

16 Q. So was it a local manager or was it somebody in

17 corporate that you reported to?

18 A. I don't understand the question, sorry.

19 Q. When you found errors in payroll --

20 A. Um-hum.

21 Q. -- who did you report those errors to?

22 A. I didn't find the errors. The corporate office

23 would let me know that they found the errors when they

24 processed payroll, and they would ask me to help them with

25 the manager and for me to please have a conversation with

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1 them letting them know that we needed some improvement

2 around the time in processing the payroll.

3 Q. What were the issues specifically with Phoenix

4 in payroll?

5 A. Turning in the payroll late after payroll had

6 been closed out or turning in a time sheet late or adding

7 on commissions after payroll had been processed or

8 requesting a check request for a separate check outside of

9 payroll.

10 Q. And how did the management team in Phoenix

11 respond when you brought these issues to their attention?

12 A. Just as before, that they were frustrated that

13 they, you know, didn't have time to be doing it, and it

14 was just an additional function that HR should be doing,

15 and that's why they felt that they were inadequate in some

16 things because they were not used to doing it and that,

17 you know, it is not something that, you know, they felt

18 should be part of their job function.

19 Q. Were there any other errors that you pointed out

20 in some of the functions that were transferred to the

21 businesspeople after the realignment other than the

22 payroll that we talked about?

23 A. Not that I recall, no.

24 Q. If you look at Exhibit No. 9 on page 14 -- tell

25 me when you are there.

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1 A. Okay.

2 Q. At lines 20 and 21, you indicate that you had a

3 conversation with Ms. Siggerud on July 9th about the lack

4 of engagement and support. Do you see that?

5 A. Yes.

6 Q. What were you referencing?

7 A. I am unsure. I am not really sure of the

8 specific --

9 Q. Did Ms. Siggerud relay to you on or about

10 July 9th that there was a perception that you were not

11 engaged?

12 A. Yes.

13 Q. And what did you understand that to mean?

14 A. That that was other's opinions or just how they

15 felt around how much I was in the business.

16 Q. And who are the people that you were discussing

17 that had that perception?

18 A. From my understanding, she was discussing with

19 me that the Phoenix management group had a perception that

20 I was not engaged or in the business.

21 Q. And the lack of support, is that a problem that

22 you were bringing to Ms. Siggerud's attention?

23 A. I am unsure.

24 Q. Were there complaints that you were not getting

25 support from the Phoenix leaders?

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1 A. Yes.

2 Q. And you expressed those to Ms. Siggerud?

3 A. Yes.

4 Q. And what did you mean when you would tell her

5 you were not getting support from the Phoenix leaders?

6 A. Just as far as the -- the job duties itself,

7 when -- when her and I would have our one-on-one meetings

8 and she would suggest that I get more involved and ask

9 managers about the financials of the business or ask them

10 to teach me about their role, they would get very

11 defensive about it and very agitated -- of why did HR want

12 to know anything about, you know, financials with the

13 business. And they -- I think they -- they felt that I

14 was being very intrusive into, you know, their -- their

15 part of the business or their job or like I was

16 questioning them about what they were doing, although this

17 is what Rachael had instructed me to do. And she told us

18 that was -- part of our job is to -- to learn and -- to

19 learn the business and to just observe and to meet with

20 the managers and follow them or shadow them as much as we

21 could. But when I asked about it, I felt that they would

22 push back and that they -- they wouldn't involve me in

23 these things.

24 Q. When you are saying "they," who are you

25 referring to?

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1 A. It would be service, Mitch Rubinoff, and

2 sales -- the sales manager.

3 Q. Do you recall that person's name?

4 A. He was very new at the time. Gary -- I don't

5 remember his last name, but he was -- he was a pretty new

6 sales manager.

7 Q. And you felt he was giving you pushback about

8 learning his role and function?

9 A. He was still learning himself, so I think it was

10 kind of hard to follow him or get information from him.

11 Because, you know, I would ask him and he would say,

12 "Well, we could learn together," or, you know, "I would be

13 happy to show you what I would do," but I think, you know,

14 he was still learning too, so I couldn't obtain a lot of

15 information from him.

16 Q. So who was the pushback coming from other than

17 Mitch?

18 A. From Jake and from Mitch and from -- from the

19 branch manager in Tucson.

20 Q. What was that person's name?

21 A. Andy -- Andy -- Andy Brown, I think.

22 Q. And when had you gone to Tucson to try and

23 engage with him?

24 A. That was I think in the other recorded

25 conversation, so it was -- I don't recall the exact date.

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1 Q. But that is discussed in Exhibit No. 8 you are

2 saying?

3 A. Possibly. I am not exactly sure.

4 Q. So you don't know when you went to Tucson but

5 how many times did you engage or attempt to engage with

6 the Tucson manager?

7 A. He came up for our quarterly business reviews or

8 I would -- I would randomly go down and meet with him and

9 his employees, or prior to the generalist role, I would go

10 down for the benefit meetings or the benefit rollouts, or

11 I would go down and help with the performance reviews at

12 the year-end. So I had been down for several visits to

13 Tucson and Prescott Valley.

14 Q. Let's talk about Tucson specifically. On how

15 many occasions do you think you attempted to engage with

16 the Tucson management team where you received pushback?

17 A. I would be guessing. I -- I don't -- I don't

18 know the exact number of times.

19 Q. Can you estimate for me?

20 A. More than five.

21 Q. And what about Prescott Valley? Did you

22 encounter a similar reaction there where the management

23 team didn't really want you to engage with them?

24 A. Yes. They were very frustrated about adding HR,

25 you know, job duties to their -- to their positions also.

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1 Q. So they gave you the same pushback you were

2 feeling in Tucson?

3 A. Yes.

4 Q. And how many times did you attempt to engage

5 with them and get that pushback, if you can estimate for

6 me?

7 A. More than five.

8 Q. If you look at page 15 in Exhibit No. 9, I think

9 we already talked about the one-on-one meeting that you

10 missed with Ms. Siggerud, correct?

11 A. Yes.

12 Q. Did that happen on more than one occasion?

13 A. No.

14 Q. At lines 14 through 16, it talks about a

15 worker's comp sharpshooters' meeting and that you were

16 late for that.

17 A. Yes.

18 Q. Do you recall what that was about?

19 A. Yes.

20 Q. What happened?

21 A. We were -- I was on an HR support team. Once

22 the HR realignment had occurred, we were all placed on a

23 support team with other HR individuals outside of the

24 region we were in because they just wanted us to be more

25 diverse and not just have people who were in our region.

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1 And I was on this -- this team with the

2 previous HR person that was in my role prior to her

3 getting promoted, and she helped to train me, but she had

4 set up this meeting and -- in Lotus Notes on our calendar,

5 and I had accepted it. And the code that she sent us, the

6 code was wrong, and so I had called her and she stated,

7 "Oh, yes, I'm sorry. I know the code was wrong," and she

8 re-sent it to everyone, and then we all dialed in and we

9 got on the conference call.

10 Q. So you were not the only one that was late to

11 that call?

12 A. No.

13 Q. Did you receive criticism for being late to any

14 other meetings?

15 A. Two other meetings I believe.

16 Q. What other meetings?

17 A. I don't remember specifically what they were

18 about.

19 Q. Do you remember who they were with?

20 A. The Phoenix management group.

21 Q. And they were meetings that you had accepted

22 attendance to?

23 A. Yes.

24 Q. And do you recall why you were late to those two

25 meetings?

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1 A. I had gone in and they were all kind of just

2 sitting around -- sitting around chatting and they had not

3 began yet, and so I left out -- I was having a lot of

4 female problems at the time and I was bleeding very

5 heavily, and so I would randomly have to go and change my

6 clothes in the restroom or go to the bathroom or I would

7 go to my office to, you know, get something out of my

8 personal belongings, and they had already started after I

9 had left out the first time, and then when I went back in

10 to join after I got done changing my clothes, they had

11 already began.

12 Q. And that happened on two occasions?

13 A. Yes.

14 Q. And did you let Ms. Siggerud know that was the

15 reason you were late?

16 A. Yes.

17 Q. And what was her response?

18 A. "I understand, but you need to understand that

19 it is everyone's perception that you don't care because --

20 because you are late."

21 Q. Were there any other meetings that you were

22 criticized for coming late to or not showing up to that we

23 have not talked about?

24 A. Not that I am aware of, no.

25 Q. If you could look at page 23 in Exhibit No. 9,

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1 at -- starting at line 10, Ms. Siggerud suggests that she

2 is hearing -- what she is hearing you say is that you

3 don't want to work in that generalist role. She

4 understands the job has changed, and it is not what

5 everybody wants. And she says: I would like you to kind

6 of think about it for the next couple of days.

7 Do you see that part?

8 A. Yes.

9 Q. Is this where you contend Ms. Siggerud told you

10 that you had three days to think about whether or not you

11 wanted to stay in your position?

12 A. Yes.

13 Q. Where does she give you three days?

14 A. It was after the -- after the recording had

15 stopped, and we had another conversation about my FMLA

16 leave.

17 Q. And that happened during this same phone call

18 that you recorded?

19 A. Not during this recording, no.

20 Q. Okay. It was on a different occasion that she

21 gave you the three days?

22 A. No. She told me at this time that she wanted me

23 to take time to think about it.

24 Q. Right. And I am trying to figure out -- because

25 you said in your complaint and charge that she gave you

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1 three days to think about it, so when did that occur?

2 A. After this conversation.

3 Q. On this same date?

4 A. No.

5 Q. On what date?

6 A. I don't know the exact date.

7 Q. It was after this call she said: I am going to

8 give you three days to think about it.

9 Correct?

10 A. Yes.

11 Q. And you were transferred into the recruiting

12 position on July 29th, correct?

13 A. Yes.

14 Q. So this conversation is on July -- excuse me --

15 July 17th, correct?

16 A. Correct.

17 Q. So the conversation where she gave you three

18 days happened somewhere in between those two dates?

19 A. Yes.

20 Q. But you don't recall specifically?

21 A. No.

22 Q. In Exhibit No. 9, you tell her you don't need

23 time to think about it, correct?

24 A. Correct.

25 Q. And that is consistent with what you testified

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1 previously you told her when she offered to give you three

2 days to think about it too?

3 A. Correct.

4 Q. If you look at page 25 at line 5, you are

5 speaking in the phone call, and you say that you never

6 planned on leaving the company but I feel like, you know,

7 I should -- I shouldn't continue to stress myself

8 considering the health situation that I am in if it is not

9 going to be beneficial to me. If I feel that my morale

10 has dropped due to the situation and I feel that I am not

11 wanted, then I don't feel like I should continue to make

12 an effort.

13 Did I read that correctly?

14 A. Yes.

15 Q. Did you make those statements to Ms. Siggerud?

16 A. Yes.

17 Q. Look at page 27, please. If you look at lines 3

18 through 5, Ms. Siggerud is talking during the call, and

19 she says: Ultimately, it sounds to me that what you are

20 saying, like, you are not quite sure that this is what you

21 want.

22 Did I read that correctly?

23 A. Yes.

24 Q. And she goes on at lines 12 and 13, and she

25 says: And so if what you are asking for is for transition

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1 support --

2 And you interrupt her at line 14, and say:

3 Yes.

4 Correct?

5 A. Yes.

6 Q. So when she is talking about transition support,

7 she is talking about transitioning you to a different

8 position, correct?

9 A. I am unaware of what she meant by "transition."

10 Q. Well, during this phone call -- because you have

11 already read Exhibit No. 9 -- she talks about

12 transitioning you to a different position if you are

13 unhappy in the general -- in the generalist position,

14 correct?

15 A. Are you asking me if she had previously stated

16 that she was going to move me into a position?

17 Q. No. During this -- this phone call that you

18 recorded, that is Exhibit No. 9 --

19 A. Um-hum.

20 Q. -- Ms. Siggerud is talking with you about the

21 possibility of a transition to another position if you

22 don't want to work in the generalist job, correct?

23 A. She had not stated that yet, no.

24 Q. On page 25 and 26, if you start at line 20 and

25 go to page 26, line 5, isn't Ms. Siggerud talking about if

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1 this is not the kind of job that you want if you would

2 rather have a different kind of schedule she understands

3 that and to let her know?

4 A. Yes.

5 Q. And didn't you take that to mean if you wanted

6 to do a different job, she would support you in

7 transitioning?

8 A. No, I don't recall her saying transition. I

9 just merely remember her saying "support." So I took it

10 as she would be willing to provide me with more support in

11 my current role, not to move into a different one.

12 Q. When she asks you to think about what you wanted

13 to do, wasn't part of what she was asking you to think

14 about doing was whether or not you wanted to transition to

15 another position?

16 A. I am unsure. She was always very -- very vague

17 in our conversations. I always had a hard time really

18 understanding what she was -- what she was trying to

19 convey as in, you know, being supportive of me or -- she

20 always made me -- felt like -- like she kind of was

21 pushing me to say I wanted to quit. I always felt the --

22 the -- like the push from her, just like trying to feed me

23 words or trying to tell me this is -- this is -- this is

24 what you want to do. "You are not happy, right?" And I

25 would tell her, "No, I am happy. I love my job. I love

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1 being here," but she would, you know, keep pushing back

2 and saying, "Well, no, that is not what I am hearing you

3 say," and I would say, "I am not saying that," and she

4 would say, "But, no, that is what you just said, right?"

5 Q. Look at page 34.

6 A. Okay.

7 Q. If you start where Ms. Siggerud is talking at

8 line 19, she says: I want you to think over this for the

9 next few days if this is what you want. And if it is not

10 what you want, I am not going to hold it against ya, we

11 will come up with a transition plan. I will support ya.

12 We can either look for something else within G&K. I can

13 help you with the transition plan to find something else

14 outside of G&K, but I will work with you -- or ya -- to

15 figure it out.

16 Did I read that correctly?

17 A. Yes.

18 Q. So part of the transition plan that she was

19 talking about or the transition support during this call

20 was a transition to another position within G&K, correct?

21 A. Right. She stated that after I said "yes" to

22 her question.

23 Q. And you answered yes, that you would be

24 interested in transition support, correct?

25 A. That was prior to her making that statement, so

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1 no.

2 Q. But she was referring to transition support and

3 you said yes?

4 A. That was prior to her explanation though of what

5 she meant within the company or outside of the company.

6 Q. Well, you understand what transition means,

7 right?

8 A. I just heard her say "support," so I thought she

9 meant supporting me in my current role.

10 Q. My question is different. You understand what

11 "transition" means?

12 A. Yes.

13 Q. What does "transition" mean to you?

14 A. To -- a change.

15 Q. A change in position in this situation, correct?

16 A. Yes.

17 Q. Previously, you told me that you believe the

18 perception of your unavailabilities was related entirely

19 to your medical issues, correct?

20 A. Yes.

21 Q. On page 30 starting at line 24 of Exhibit No. 9,

22 you are talking to Ms. Siggerud, and you tell her that you

23 feel like this perception about your unavailability, this

24 "dilemma" you call it, started when Jake decided to move

25 your office, correct?

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1 A. What line is that on?

2 Q. Page 30, line 24 through 31 of Exhibit 9.

3 A. I say that I felt that that is where it began,

4 yes.

5 Q. And you say: I felt like that's where this

6 dilemma has occurred.

7 Correct?

8 A. No. I said I felt like where this went

9 downhill.

10 Q. Look at page 31, line 8 and 9. You state: I

11 felt like that's where this dilemma has occurred.

12 Correct?

13 A. Yes.

14 Q. And you are referring to the perception in

15 Phoenix about your unavailability, correct?

16 A. Correct.

17 Q. And your office move has nothing to do with your

18 medical condition, does it?

19 MR. MILLS: Object to the form.

20 THE WITNESS: Can you restate that?

21 BY MS. FRANCIS:

22 Q. Sure. You are describing here that you believe

23 the perception originated from the office move, correct?

24 A. That was part of it, yes.

25 Q. You say that's where this -- you feel like this

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1 dilemma has occurred, correct?

2 A. Yes.

3 Q. And the office move has nothing to do with your

4 medical condition, does it?

5 A. No.

6 MR. MILLS: Same objection.

7 MS. FRANCIS: Did you get an answer?

8 MS. REPORTER: The answer was, "No."

9 THE WITNESS: Can we take a break?

10 MS. FRANCIS: Yes.

11 VIDEO TECHNICIAN: We are off the record at

12 3:10 p.m.

13 (Recess ensued from 3:10 p.m. until

14 3:20 p.m.)

15 VIDEO TECHNICIAN: We are back on the

16 record at 3:20 p.m.

17 BY MS. FRANCIS:

18 Q. You previously mentioned that you missed a

19 flight because you were really sick and you couldn't go on

20 that trip. Do you recall telling me that?

21 A. Yes.

22 Q. Did you ever tell anyone after the July 8th

23 accommodation request at G&K that you needed a different

24 accommodation?

25 A. No.

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1 Q. Because it sounds like what you are describing

2 is that your medical condition got worse; is that correct?

3 A. No.

4 Q. It just had -- you had an issue that it worsened

5 for a short period of time that you could not take that

6 trip?

7 A. I got sick from my son --

8 Q. Okay.

9 A. -- yeah, from him going to daycare.

10 Q. So that was unrelated to your underlying medical

11 condition that you needed the accommodation for?

12 A. Correct.

13 Q. Okay. Do you recall generally when that

14 happened? Is it consistent with the time frame in that

15 e-mail? You said I think two weeks before your

16 termination?

17 A. Yeah, two weeks before my termination. It was,

18 like, the first of September, first part of September of

19 2013.

20 Q. And -- and the only complication that you had

21 was an illness from your son. It was not that your

22 medical condition worsened, the one --

23 MR. MILLS: Let me object to the form.

24 BY MS. FRANCIS:

25 Q. Yeah, let me restate that. That was horrible.

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1 Sorry.

2 I just want to be clear that your medical

3 treatment that you received the ADA accommodation for to

4 go to ongoing medical appointments -- your medical

5 condition was stable; it didn't get worse during your

6 employment?

7 A. No.

8 Q. No, it didn't get worse?

9 A. No, it didn't, no.

10 Q. Okay. So it was stable during the time that you

11 were working?

12 A. It was the same as it had been from the start.

13 Q. Okay.

14 MS. FRANCIS: Let's mark another exhibit.

15 (Deposition Exhibit No. 14 was marked for

16 identification by the reporter.)

17 BY MS. FRANCIS:

18 Q. Do you recognize Exhibit 14?

19 A. Yes.

20 Q. What is it?

21 A. My annual performance document.

22 Q. For what year?

23 A. 2012 and 2013.

24 Q. Can you identify for me what parts of the

25 comments you wrote and what part of the comments

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1 Ms. Siggerud wrote?

2 A. I wrote the midyear comment summary.

3 Q. Section 1?

4 A. Section 1, yes.

5 And I wrote individual objective 1,

6 individual objective 2, and I wrote the year-end overall

7 review, and I wrote section 4, development goal and

8 relocation preferences.

9 Q. Which part of the document did Ms. Siggerud

10 write, if you know?

11 A. She wrote the manager comments after section 3.

12 Q. Within section 3?

13 A. In section 3, yes.

14 Q. Did you also write the individual objective

15 No. 3?

16 A. Yes.

17 Q. Did Ms. Siggerud revise any of the parts that

18 you wrote to include a specific performance objective?

19 A. No.

20 Q. So I am clear that each of the performance

21 objectives that are set in here and that you have

22 identified as portions that were written by you, those are

23 objections -- objectives that you created for yourself?

24 A. Her and I created them together.

25 Q. Is there any specific objective that

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1 Ms. Siggerud told you you must have in here?

2 A. Each one of them were specifics that her and I

3 discussed that she stated I should include in my review.

4 Q. Were there any that she developed on her own

5 that she told you that you had to do?

6 A. All of -- the whole document was from --

7 direction from her.

8 Q. In collaboration with you?

9 A. Correct.

10 Q. And I want to know if there was anything --

11 well, let me rephrase the question.

12 Was there any objective that Ms. Siggerud

13 and you discussed and put into the plan that you were

14 uncomfortable with or you felt you couldn't meet?

15 A. No.

16 Q. Did you meet the goals that you set for yourself

17 in 2013?

18 A. Yes.

19 Q. Did you meet all of them?

20 A. Yes.

21 Q. If you look at the manager comments that are

22 within section 3, which is the year-end overall summary,

23 where you indicated those were written by Ms. Siggerud --

24 A. Yes.

25 Q. -- she states: Brandy, I am very disappointed

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1 to see that you have not completed anything in your G&K

2 perform document, although we have spoken about it on

3 several occasions over the past month.

4 Did I read that correctly?

5 A. Yes.

6 Q. What did you think she meant?

7 A. I'm sorry, can you restate that?

8 Q. When she wrote this and this was given to you as

9 your performance evaluation, what did you believe that

10 Ms. Siggerud was telling you?

11 A. I was not given this immediately. Ms. Siggerud

12 didn't complete this approximately until August 28th, two

13 months after I had completed my portion of it, and I was

14 in the -- already the temporary recruiting role. So we

15 didn't have much conversation around the end -- the

16 overall end of this performance review.

17 Q. Okay. Well, I don't think that answers my

18 question, but let's go to the last page where it talks

19 about the audit history so we are clear about when you

20 created this document.

21 A. Okay.

22 Q. You created this document on July 26th, correct?

23 A. That's when I finalized it.

24 Q. Well, it says: Created by.

25 A. But that was the day that I finalized it for her

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1 to review it. I had been working on it since June 27th.

2 Q. Okay. So you submitted this document to

3 Ms. Siggerud on July 26th of 2013, correct?

4 A. No, I finalized it on that date. We save drafts

5 while we work on it, and we just save it and your manager

6 can review it and make suggestions for you to make

7 changes, and then you have to finalize it to put it into

8 the mode to where the manager can make their comments on

9 it, and I didn't finalize it for her to make her comment

10 until the 26th --

11 Q. Of July?

12 A. -- of July.

13 Q. And then it was last updated and completed on

14 August 28th, correct?

15 A. By Rachael.

16 Q. Right. So it took about a month for her to

17 provide her feedback and input, correct?

18 A. Correct.

19 Q. Not two months?

20 A. From the time that it had been -- that it had

21 been started it was two months.

22 Q. But you agree you submitted it to her in final

23 form for her comments on July 26th, correct?

24 A. She had reviewed it prior to that.

25 Q. I know. We are not communicating.

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1 A. Okay.

2 Q. You submitted it in final form on July 26th for

3 Ms. Siggerud to then provide her input and response, yes?

4 A. Yes, after her suggested changes.

5 Q. And she provided her response a month later?

6 A. Correct.

7 Q. And part of the response that she provided was

8 what we were looking at previously, the manager comments,

9 correct?

10 A. Correct.

11 Q. And when Ms. Siggerud said to you, "I am very

12 disappointed to see that you have not completed anything

13 in your G&K perform document," what did you believe that

14 meant?

15 A. I felt that she went in and changed that when

16 she finalized this document. She did not really portray

17 that to me, because we had been working on it since June,

18 so I felt like this was put in after the fact when she

19 made the change in August.

20 Q. Okay. But when she is telling you that she is

21 disappointed because you have not done something, what is

22 it that she believes you have not done?

23 A. I am unsure, because I had been working on this

24 document.

25 Q. What is the G&K perform document?

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1 A. This document here.

2 Q. Okay. Did you take that to mean that she didn't

3 believe that she had completed any of the objectives that

4 you had set for yourself?

5 A. I believe that is what she was telling me.

6 Q. So the objectives -- the portions that you wrote

7 where you say you are going to do certain things or meet

8 certain goals, Ms. Siggerud believed that you had not met

9 any of that -- those goals, correct?

10 MR. MILLS: Object to the form.

11 THE WITNESS: I am unaware of what thoughts

12 she had.

13 BY MS. FRANCIS:

14 Q. But you believe that is what she was telling you

15 in that manager comment section?

16 A. I didn't really make an assumption about what

17 she was saying.

18 Q. She is saying that you have not completed

19 anything that you put in your performance document,

20 correct?

21 A. That is what she stated, yes.

22 Q. Did you implement any new safety measures to

23 decrease injuries in 2013 when you were a generalist?

24 A. Where is that located in the document?

25 Q. In section 1.

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1 A. I'm sorry, I don't see where it states that.

2 Q. The second to last sentence.

3 A. In section 1 at the top here?

4 Q. In the part that you wrote, it says: We will

5 continue as a team to plan and implement new safety

6 measures to decrease injuries.

7 Do you see that? It is the second to last

8 line in the paragraph you wrote.

9 A. Oh, objective 2? I'm sorry, I am lost on where

10 we are looking at on the document.

11 Q. (Indicating).

12 A. Oh, on the first page, okay, in the midyear

13 comments.

14 I stated that we would continue as a team

15 to make those changes together, not that I would

16 individually do those things alone, no.

17 Q. My question to you was: Did you implement any

18 new safety measures in 2013 to decrease injuries?

19 A. As a team we did, yes.

20 Q. What?

21 A. We had a safety management team that we met with

22 monthly to all collaborate and come up with new ideas.

23 Together we all did a safety walk through the plant

24 together as the management team or the members of the --

25 the safety team that we had at the Phoenix location, and

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1 we would do those things together.

2 Q. What specific new safety measures were

3 implemented in 2013?

4 A. There was an issue, I believe, with their swamp

5 coolers, their evaporative coolers in the plant and they

6 had broke down a few times throughout the summer.

7 So as a team, we decided that we would get

8 with the engineering team and make sure that there was

9 regular maintenance being done on those things and it was

10 being documented and that they were being proactive about

11 making sure that they fixed the problem before they broke

12 down so we could keep the employees in the plant location

13 cool in the summertime.

14 Q. Anything else?

15 A. I don't recall anything else. That -- that was

16 our -- I think our biggest challenge.

17 Q. What was the newly implemented wheel of safety?

18 A. Oh, that was a game that we played every month

19 as incentive with our employees at the location to get

20 them to join in to have a safe workplace as well as we

21 would give away prizes. They would -- in our safety

22 meeting with all the employees with the -- with the safety

23 management group, we would let them spin the wheel if

24 their name was drawn. So we would help to try to get the

25 employees engaged from the plant with the safety as well,

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1 and we would have them put in ideas for safety improvement

2 also along with the management team, and whoever put in

3 the most ideas for a safety improvement, then we would

4 draw names, and if we draw -- if we drew their name, they

5 got to spin the wheel of safety, and then they got a prize

6 that was on the wheel. It was like Wheel of Fortune.

7 Q. Did you implement any ideas that came from that

8 program?

9 A. We did it all together as a team.

10 Q. I am looking for specifics.

11 A. I don't recall.

12 Q. What is the Coach to Win model?

13 A. It was an initiative that came from corporate,

14 and it was just to keep morale up within the business, to

15 coach the employees around their performance or around the

16 business itself or it could be possibly around their job

17 description and to help build their morale and to help

18 them be positive.

19 Q. Did you use the Coach to Win model in your

20 interactions with the management at the locations you

21 serviced?

22 A. Yes, and I also did training with the service

23 department with their route managers on the Coach to Win

24 model to help with their employees as well.

25 Q. Did you develop any programs for classroom

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1 training?

2 A. We were in the midst of working on those things,

3 but we -- I don't believe we had completed and established

4 anything yet, no.

5 Q. Did you develop any programs for hands-on

6 training with a mentor coach?

7 A. No. By the time this was finalized, I was moved

8 into the temporary recruiting role, so I was told by

9 Rachael to not worry about continuing with the -- these

10 generalist goals.

11 Q. Well, you moved in the end of July of 2013 --

12 A. Correct.

13 Q. -- which is the end of the fiscal year for the

14 company, correct?

15 A. Correct.

16 Q. So the performance objectives are complete for

17 the year prior. It would have been July of 2012 to July

18 of 2013, correct?

19 A. Correct.

20 Q. So at the time you moved, there is a full year

21 of work to review, correct?

22 MR. MILLS: I will object to the form.

23 THE WITNESS: No. We -- we had not

24 implemented these new things until after I transitioned

25 into the generalist position.

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1 BY MS. FRANCIS:

2 Q. So that would have been in February of 2013?

3 A. Correct.

4 Q. So the performance that you are being evaluated

5 for is between February of 2013 and July of 2013, correct?

6 A. Yes.

7 Q. During that time period, did you develop any

8 programs for hands-on training with a mentor or coach?

9 A. Yes.

10 Q. What?

11 A. I did training with the managers around how to

12 process their payroll. I did training with managers of

13 how to onboard their new employees into the business. I

14 think that is kind of what this means, that it was

15 hands-on training with a mentor.

16 Q. You thought that related to the transition of HR

17 functions?

18 A. Yes.

19 Q. Did you develop any training programs that were

20 exposure-based?

21 MR. MILLS: Object to the form.

22 THE WITNESS: I think this is stating that

23 I would participate in or experience exposure-based

24 training myself with the managers.

25 So Rachael had given us instructions that

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1 it was our new role to learn from the other managers and

2 for not -- for them not to feel that we are being invasive

3 or questioning them about their job, and more so that we

4 were trying to learn from them.

5 And so that is what all these objectives

6 were was to learn from the managers, to go with them on

7 route rides, or go with them when they go to visit a

8 customer and just how they deal with handling a contract

9 or deal with handling a contract renewal and just to

10 observe, not to tell the customer that we were HR, but

11 just to say that we were part of the management team and

12 just to sit in on a meeting, just to learn from them what

13 their job goal was.

14 That way we could come back together as an

15 HR team and share those ideas with each other as the

16 generalist in the region that we were in so we could come

17 up with ideas for each other as how to better improve the

18 functions that we were experiencing when we were with the

19 managers.

20 BY MS. FRANCIS:

21 Q. Okay. You changed my question and then you

22 answered the question that you wanted to answer, so I am

23 going to ask you to try to listen to the question

24 specifically.

25 A. Okay.

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1 Q. The performance evaluation says another goal is

2 to focus and drive leadership development through

3 developing programs. That means you developing programs,

4 correct?

5 A. As a team, not me individually, as the

6 generalist team that I was on.

7 Q. Does it say anything here about working as a

8 team in this paragraph that we are talking about?

9 A. No, but it doesn't state that it was me

10 individually.

11 Q. Okay. And you told me that you perceived this

12 section to be about learning what management does, and we

13 already talked about the fact that management wasn't

14 receptive to that and you got a lot of pushback, correct?

15 A. Correct.

16 Q. So you were not able to do what you are

17 describing you believe this performance goal is, to learn

18 what management does, to attend ride-alongs, to

19 participate in what they are doing for their job duties,

20 correct?

21 MR. MILLS: Object to the form.

22 THE WITNESS: Correct. But Rachael told me

23 to keep trying and to not give up and to keep trying to

24 build a positive relationship with them.

25 BY MS. FRANCIS:

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1 Q. Rachael gave you a 1, and you rated yourself

2 lower for this section. You rated yourself a 3.

3 A. That -- that would be higher.

4 Q. No, I mean lower than you had in other sections.

5 You had given yourself a 5 and 4 previously, correct?

6 A. Mostly they were all 3s, except for the

7 year-end, which was 4.

8 Q. Under section 2, you didn't give yourself a 5?

9 A. That was a group rating.

10 Q. It says: Employee rating.

11 A. In the description, it says: This is a group

12 rating and will be given to you either by your location

13 manager or through an e-mail for corporate employees.

14 Q. Okay. So that was something that was given to

15 you. That was not set by you?

16 A. Right, correct.

17 Q. And then in core values, did you give yourself a

18 4 --

19 A. Yes.

20 Q. -- and Rachael gave you a 2?

21 A. Yes.

22 Q. Did she explain why she gave you a 2?

23 A. No.

24 Q. Did you get to talk to her about this

25 performance evaluation after she put in her comments?

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1 A. No. I didn't know when she had completed it.

2 Q. And she never gave it back to you so you could

3 see it?

4 A. No. I was well into the temporary role by then.

5 Q. In individual objective No. 1, she gave you a 1

6 for "not meeting." Do you see that?

7 A. Yes.

8 Q. Do you have an understanding of why she rated

9 you a 1 under this objective?

10 A. No. Because I felt that I was performing all of

11 these functions.

12 Q. Under individual objective 2, did you meet with

13 leaders monthly to review and update 9 Block?

14 A. Yes.

15 Q. What is 9 Block?

16 A. This is a succession planning tool, and it's

17 blocks that you place employees in on how you feel how

18 successful they are. And so I would meet with the

19 managers monthly, just reviewing and updating on the

20 progress of their employees and if they wanted to move

21 them strategically, if they were going to move them up

22 within the business or if they felt they were going down

23 and out.

24 Q. And would you have that meeting with each of the

25 leaders at the different locations you serviced monthly?

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1 A. Yes, in Phoenix and the Los Angeles group as

2 well.

3 Q. What about the other locations?

4 A. All of Arizona and all of Southern California.

5 Q. Because we talked about some more remote

6 locations like Yuma and Tucson, did you also have these

7 leader meetings monthly with them?

8 A. Yes, that was part of our Arizona Phoenix group.

9 Q. Did you update IDPs for all green box talent

10 with leaders?

11 A. Yes.

12 Q. Did you schedule biweekly meetings with leaders

13 to develop assignments for HPEs?

14 A. Yes, high potential employees.

15 Q. What did that entail?

16 A. It would be -- for instance, San Diego, we had

17 an employee that was a route driver, and he was interested

18 in eventually being promoted to a route manager. So we

19 would periodically take him out of his role and allow him

20 a day to go with the route manager to kind of shadow him

21 to kind of just see what the job was about and somewhat

22 train them ahead of time, just for a role of interest for

23 themselves.

24 Q. Did you coach your leadership teams on effective

25 performance management?

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1 A. Yes.

2 Q. Did you identify low performers?

3 A. Yes.

4 Q. Did you suggest termination for anyone?

5 A. We would discuss it. I wouldn't necessarily

6 make a recommendation. It would be up to the manager. I

7 would question them about how they felt the employee was

8 performing, and then I would ask them how they felt what

9 -- what path they felt the employee was on, if they felt

10 that they were going to be sufficient for promotion, or if

11 they felt that they were not going to be, and if they saw

12 them going through a path downward.

13 Q. What did you do to help assist the low

14 performers?

15 A. That was not part of my job responsibility

16 directly. That was the manager's job, and I would give

17 the manager suggestions around ideas of what to do with

18 low performers to help build their morale, or we would

19 have, like, group meetings with the managers to try to

20 support the employees and ask them for their ideas of

21 changes that they thought we could implement to make their

22 environment more positive.

23 Q. Did you actively participate in weekly growth

24 meetings with your leadership teams?

25 A. I'm sorry, can you say that again?

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1 Q. Did you actively participate in weekly growth

2 meetings to help your leadership teams at the locations

3 improve their business opportunities and revenue?

4 A. Yes, that was every Monday morning at 5:00 a.m.

5 Q. With which leaders?

6 A. Service and sales.

7 Q. From which location?

8 A. The Phoenix location.

9 Q. And when did you do that with the other

10 locations?

11 A. I -- I don't -- I am not sure of the -- the Los

12 Angeles location was different than the Phoenix location.

13 I just participated in the Phoenix one because I was

14 physically at the location. I think the Los Angeles ones

15 were a different day. They didn't request that I did them

16 weekly. They requested I attend I believe like once a

17 month, and if I did, it was over the phone.

18 Q. Did you spend one-on-one time in the field with

19 territory sellers, route manager, route sales reps,

20 service managers, sales managers --

21 A. Yes.

22 Q. -- from all those locations?

23 A. Not all the locations.

24 Q. And I think previously you described that you

25 only went on two routes, correct?

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1 A. I went out with sales, and I also went out with

2 a service employee.

3 Q. One occasion each, correct?

4 A. Yes.

5 Q. Is that the only time that you spent in the

6 field with these types of employees?

7 A. I don't recall. I don't believe so. I think

8 there was more, but I am not sure of how many times.

9 Q. But you only recall specifically those two?

10 A. Correct.

11 Q. And those were both in Phoenix?

12 A. Correct.

13 Q. You never spent time in the field with employees

14 at any of the other locations, correct?

15 A. Correct.

16 Q. Do you believe that you had learned the key

17 financials of the business?

18 A. No.

19 Q. Do you believe that you had a functional grasp

20 and understanding to support the financial goals of the

21 business?

22 A. No.

23 Q. Under objective No. 3, did you expand your

24 knowledge of OFCCP rules?

25 A. Yes.

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1 Q. How?

2 A. I had numerous materials at home that I had

3 purchased on my own. I had -- I have numerous HR

4 publications, or I was a member of the SHRM society so

5 there was publications and I could log in. I had access

6 to HR tools through their website, which was the national

7 HR society.

8 Q. Did you educate your leadership teams on OFCCP

9 rules?

10 A. On -- I'm sorry, can you say that again?

11 Q. Did you educate your leadership teams on OFCCP

12 rules?

13 A. We had conversations around it, yes.

14 Q. Did you develop any training?

15 A. No, our corporate office did that. We had a

16 training department.

17 Q. When you say you had conversations with

18 leadership about OFCCP rules, how many occasions?

19 A. I don't recall specifically.

20 Q. And which locations?

21 A. Both -- all of them.

22 Q. So you talked with each of the management

23 members from every location about OFCCP rules?

24 A. No. It would only come up if they had an issue

25 around it and they had questions about it.

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1 Q. So when you were asked questions, you would

2 answer them about OFCCP issues?

3 A. I would, and if I didn't know the answer, I

4 would get Rachael involved and I would ask her expertise

5 and her feedback.

6 Q. Other than being asked questions by the

7 management team, did you do anything to educate the

8 management team about OFCCP rules?

9 A. I don't -- I don't recall.

10 Q. Did you educate the leadership teams at the

11 locations about EEOC rules?

12 A. Yes.

13 Q. Did you develop anything for educating them

14 about EEOC rules other than answering their questions?

15 A. There was a management training that I did do

16 with all of the managers in regards to the EEOC and the

17 rights of the employees, yes.

18 Q. When did you do that?

19 A. I don't recall the exact date.

20 Q. Was it when you were a generalist?

21 A. Yes.

22 Q. And which locations did you provide that

23 training to?

24 A. The Phoenix location.

25 Q. Any others?

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1 A. Not that I recall.

2 Q. And why did you only provide that training in

3 Phoenix?

4 A. I don't believe that I had scheduled yet with

5 the Los Angeles group, and I had to wait for travel

6 approval from Rachael.

7 Q. Did you do any training of the leadership team

8 on union avoidance issues?

9 A. No.

10 Q. Did you provide the leadership team with any --

11 teams with any information about the NLRA?

12 A. Not specifically training, but we would have

13 conversations around all of these issues.

14 Q. When they would ask you questions?

15 A. When they would ask me questions. Or if we were

16 in a group meeting together, I would give them feedback or

17 give them information around all of the -- the HR facets.

18 Q. When they raised an issue, or did you do

19 affirmative training on these issues?

20 A. I did not schedule a date and do a specific

21 training no, no.

22 Q. Okay. My question was a little more specific.

23 Did you only answer questions and issues that were raised

24 by the management team, or did you go out and proactively

25 educate these leaders about these legal issues?

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1 A. Yes, I did both.

2 Q. Okay. What training program other than the EEOC

3 did you develop on the issues we have been talking about?

4 Did you develop something on the NLRA?

5 A. No, this -- this was -- this would have been

6 information that was provided from our training department

7 at corporate of what they instructed us to help train the

8 managers on.

9 Q. So did you provide training to your management

10 teams on the NLRA?

11 A. Not a particular group -- not a particular

12 meeting that was scheduled, no, no.

13 Q. Did you provide any particular training to your

14 leadership teams on OSHA?

15 A. No.

16 Q. We already talk about the safety information.

17 Did you provide any training to your

18 management teams at the locations on the Civil Rights Act?

19 A. I am unsure what you mean by "training," because

20 it states I will provide knowledge. It did not state I

21 would provide training.

22 Q. Okay. Did you provide any type of knowledge or

23 information to the management teams about the Civil Rights

24 Act?

25 A. Yes.

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1 Q. And outside of the training that you already

2 described on the EOC -- EEOC issues, did you do any

3 training?

4 A. Yes.

5 Q. What training or information did you provide the

6 leadership team on Civil Rights Act issues?

7 A. I would provide them with information in regards

8 to retaliation and discrimination and anything when it

9 came to an employee's rights within the business and in

10 regards to any of these issues that are listed.

11 Q. So would you provide that information

12 proactively? You would print out materials and give it to

13 them, or would you just provide information when they

14 asked you for information?

15 A. We would have verbal conversations in meetings

16 or at our one-on-ones together.

17 Q. When were you asked to provide that information,

18 or did you proactively do that?

19 A. No, I would proactively provide that information

20 during our meetings.

21 Q. And did you do that at any location other than

22 Phoenix?

23 A. Yes.

24 Q. When did you do that in L.A.?

25 A. When we were on the phone -- when I had phone

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1 conversations, if we were discussing a performance or a

2 succession plan for someone, I would give updates if

3 anything had changed, or I would just share knowledge with

4 the managers around any HR issues that I felt were

5 pertinent to any situation that they were currently

6 experiencing.

7 Q. So if you were discussing an employee's specific

8 situation, you would provide information about any

9 applicable laws?

10 A. Correct.

11 Q. Outside of a specific employee situation, did

12 you provide general information outside of the EEOC

13 training we have already talked about to the management

14 teams?

15 A. What type of general information?

16 Q. Would you prepare materials for them, updates

17 for them on these laws?

18 A. On all of these that are listed here?

19 Q. Any of them.

20 A. I -- I -- no. I would only have verbal

21 conversations with them.

22 Q. I understand that you had verbal conversations

23 with them. Would you only provide those in response to a

24 specific employee situation, or would you give verbal

25 updates at meetings on these laws?

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1 A. I would do both.

2 Q. Going back to the manager comments section where

3 Ms. Siggerud is talking, she says: As you are well aware

4 based on our previous conversations, your performance is

5 below expectations for the role of HR generalist.

6 Were you aware that your performance was

7 below expectations?

8 A. No. The only conversations we had was around

9 the perception of them believing I was not engaged or

10 available.

11 Q. Well, we also know you had conversations about

12 your inability to get a strategic alliance going with the

13 Phoenix management team, correct?

14 A. Can you restate that?

15 Q. Sure. You testified that you got a lot of

16 pushback from the Phoenix management team about working

17 with them strategically, correct?

18 A. No.

19 Q. Would Jake let you have information about the

20 financial parts of the business?

21 A. No.

22 Q. All right. Weren't you supposed to partner with

23 him and shadow him and understand what his job entailed?

24 A. Yes.

25 Q. And did he let you do that?

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1 A. Not at every occasion, no.

2 Q. In general, did he let you do that?

3 A. Not at every occasion.

4 Q. So you got pushback, we talked about, from the

5 Phoenix management team. And it was similar with Mitch,

6 correct?

7 A. Yes.

8 Q. And it says: A great part of that deficit is

9 resulting from the ineffective relationship you have with

10 the Phoenix leadership team.

11 Did I read that correctly?

12 A. Correct. It was nothing based on my

13 performance. It was all based on their perception and the

14 relationships.

15 Q. Do you believe you had an ineffective

16 relationship with the Phoenix leadership?

17 A. No.

18 Q. You believe you were effective in working with

19 Jake and his leadership team?

20 A. I believe my effort was effective, yes.

21 Q. I understand you believe that you made yourself

22 available to him to do these things, but do you think that

23 you actually accomplished establishing a team relationship

24 with him?

25 A. No.

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1 Q. She says that you did not complete the game plan

2 document to set expectations for your support of Phoenix

3 and L.A. as we had discussed.

4 I know we talked about the game plan

5 previously. Is she correct that you did not complete

6 that?

7 A. She had only requested that I do one for

8 Phoenix, not Los Angeles.

9 Q. And did you do it?

10 A. Yes.

11 Q. Where is that document?

12 A. I don't have a copy of that. I e-mailed it to

13 Rachael.

14 Q. What was it called?

15 A. Phoenix Game Plan.

16 Q. How many pages was it?

17 A. One, I believe.

18 Q. So when she says here that you didn't complete

19 the game plan document, she is just incorrect?

20 A. That is incorrect.

21 THE WITNESS: Do you mind if I go to the

22 restroom?

23 MR. MILLS: That's fine.

24 MS. FRANCIS: That's fine.

25 VIDEO TECHNICIAN: This is the end of --

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1 this is the end of media No. 4 in the continuing

2 deposition of Brandy Lane Williams. Today's date is June

3 14, 2016. The time is 4:00 p.m.

4 (Recess ensued from 4:00 p.m. until

5 4:09 p.m.)

6 VIDEO TECHNICIAN: We are back on the

7 record. This is the beginning of media No. 5 in the

8 continuing deposition of Brandy Lane Williams. Today's

9 date is June 14, 2016. The time is 4:09 p.m.

10 BY MS. FRANCIS:

11 Q. When we took a break, we were talking about

12 Exhibit 14. Do you still have that in front of you?

13 A. Yes.

14 Q. Okay. If you look to the page that has

15 section 4, development goal and relocation preferences --

16 A. Yes.

17 Q. -- under the employee comments section, the

18 paragraph that starts "overall," you state: I look

19 forward to taking on new tasks and temporarily helping to

20 support recruiting currently.

21 Did I read that correctly?

22 A. Yes.

23 Q. And you were referring there to your transition

24 to the recruiting position?

25 A. Yes.

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1 Q. Because you signed this on July 26th of 2013,

2 correct?

3 A. Correct.

4 Q. And you moved to the recruiting position in the

5 end of July?

6 A. Correct.

7 Q. I think the 29th, correct?

8 A. Correct.

9 Q. And you state: I currently would be interested,

10 if the opportunity came open, to supporting areas in the

11 Southern areas or certain portion of the mid-Central area.

12 My main interest would be the Gulf Plains or Southeast

13 mainly.

14 And then you list specific states. Did I

15 read that correctly?

16 A. Yes.

17 Q. When was the first time that you saw the

18 completed performance document for 2013 that included

19 Ms. Siggerud's comments?

20 A. I don't recall the exact date.

21 Q. Was it when you were still working at G&K?

22 A. Yes.

23 Q. And did you have an opportunity to discuss her

24 comments with her?

25 A. I don't -- I don't recall. I was -- I was busy

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1 working, doing the recruiting, so I -- I don't remember a

2 conversation.

3 Q. Did she set up a meeting where you were to

4 discuss your performance evaluation?

5 A. I -- I don't recall.

6 Q. Did you give her any feedback about her comments

7 in the performance evaluation document?

8 A. I don't recall that I did.

9 Q. You never told her that you disagreed with any

10 of her comments?

11 A. No, not that I am aware of, no.

12 Q. Do you believe that her comments were

13 retaliatory for your ADA leave?

14 A. I do.

15 Q. Did you report that to anyone at G&K?

16 A. No. Other than Rachael, no.

17 Q. You told Rachael that you believed her comments

18 in the performance evaluation were discriminatory?

19 A. Oh, sorry, no, no.

20 Q. Did you tell that to anyone at G&K?

21 A. No.

22 Q. I am going to mark another exhibit. I believe

23 we are on 15.

24 (Deposition Exhibit No. 15 was marked for

25 identification by the reporter.)

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1 BY MS. FRANCIS:

2 Q. The court reporter has marked Exhibit No. 15.

3 Have you seen this document before?

4 A. Yes.

5 Q. Is that your signature?

6 A. Yes.

7 Q. What is Exhibit No. 15?

8 A. Employee acknowledgment form.

9 Q. For what?

10 A. For receiving an employee handbook.

11 Q. Did you receive an employee handbook?

12 A. Yes.

13 Q. When?

14 A. On 5/16 on my start -- on my hire date.

15 Q. 5/16 of what year?

16 A. 2011.

17 (Deposition Exhibit No. 16 was marked for

18 identification by the reporter.)

19 BY MS. FRANCIS:

20 Q. The court reporter has marked and provided you

21 with Exhibit No. 16 to your deposition. Do you recognize

22 that document?

23 A. Yes.

24 Q. What is it?

25 A. The -- G&K's Individual Treatment Policy.

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1 Q. Did you receive this at or around the same time

2 that you received the company employee handbook?

3 A. No, this is not included in the employee

4 handbook.

5 Q. Did you receive a copy of Exhibit 16 when you

6 started your employment?

7 A. I don't recall receiving this that day, no.

8 Q. How soon after you started do you recall seeing

9 this document?

10 A. During my HR training.

11 Q. When would that have been?

12 A. The first month of my employment at G&K.

13 Q. Did you have access to this document on an

14 intranet?

15 A. I -- I did, after I was trained on where all --

16 where all the HR documents were.

17 Q. And you understood that this policy applied to

18 you as an employee of G&K?

19 A. Yes.

20 Q. If you look at the second page, it describes

21 reporting incidents. Do you see that?

22 A. Yes.

23 Q. And it states: Any employee who feels she has

24 been subject to discrimination, harassment or violence

25 should object to the behavior and report the incident to

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1 his or her manager or supervisor immediately.

2 Did I read that correctly?

3 A. Yes.

4 Q. Did you ever report any of the retaliatory or

5 discriminatory conduct that we have talked about in your

6 deposition today to Ms. Siggerud's manager?

7 A. Not that I recall, no.

8 Q. Did you report it to any manager at G&K?

9 A. Rachael Siggerud.

10 Q. Okay. Outside of your own manager -- which you

11 believe she was the one discriminating and retaliating

12 against you, correct?

13 A. Correct.

14 Q. Did you report her behavior to anyone else at

15 G&K?

16 A. Not that I recall.

17 Q. Did you understand that there was a corporate

18 employee relations department within G&K that you could

19 report to?

20 A. I am trying to remember. I would say yes.

21 Q. Did you report any information about any of the

22 treatment that we have talked about which is part of your

23 complaint to the corporate employee relations department?

24 A. No.

25 Q. Did you complain to the regional director of

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1 human resources?

2 A. Yes. That was Rachael.

3 Q. Above her?

4 A. No.

5 Q. Do you understand what the open line program

6 was?

7 A. Yes.

8 Q. What was the open line program?

9 A. It was an anonymous line where you can call and

10 report employee issues or safety concerns anonymously to

11 this number I believe.

12 Q. Could you also identify yourself if you wanted

13 to?

14 A. I suppose.

15 Q. Did you ever call or report any of the incidents

16 that you are complaining about now to this reporting line?

17 A. No.

18 Q. Did you understand that it was G&K company

19 policy to comply with the Americans with Disabilities Act?

20 MR. MILLS: Object to the form.

21 THE WITNESS: I'm sorry?

22 BY MS. FRANCIS:

23 Q. Did you understand that it was G&K's company

24 policy to comply with the Americans with Disabilities Act?

25 MR. MILLS: Same objection.

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1 Go ahead.

2 THE WITNESS: Yes.

3 (Deposition Exhibit No. 17 was marked for

4 identification by the reporter.)

5 BY MS. FRANCIS:

6 Q. The court reporter has marked Exhibit No. 17 to

7 your deposition. Do you recall seeing this document?

8 A. Yes.

9 Q. Is that your signature on this document?

10 A. Yes.

11 Q. Did you read what was written under The

12 Particulars Are section before signing this document?

13 A. I reviewed it, yes.

14 Q. Did you declare under penalty of perjury that

15 the above was true and correct?

16 A. Yes.

17 Q. Is all the information in the descriptive

18 section titled The Particulars Are correct?

19 A. Yes.

20 Q. Did Ms. Siggerud tell you on July 17, 2013, that

21 you had three days to think about resigning?

22 A. She stated she would give me time to think about

23 it -- or a few days to think about it.

24 Q. But she didn't tell you you had three days?

25 A. I misconstrued that with the verbal conversation

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1 after the --

2 Q. Okay. You --

3 A. -- recording.

4 Q. You still contend that at some point she told

5 you you specifically had three days to think about

6 resigning?

7 A. Yes.

8 Q. But it didn't happened on July 17th?

9 A. I -- I don't recall.

10 Q. Well, we have the tape recording of your

11 conversation with Ms. Siggerud on July 17th that has been

12 marked as Exhibit No. 9, correct?

13 A. Correct.

14 Q. And that is not -- that statement is not made by

15 Ms. Siggerud in Exhibit No. 9, is it?

16 A. No.

17 Q. So it is your position that you had another

18 conversation with her about this same topic on a later

19 date where she gave you three days to resign?

20 A. Yes.

21 Q. It is not possible that she gave you time to

22 think about it or said take a few days to think about it

23 instead of telling you specifically that you have three

24 days to think about resigning?

25 A. Can you restate that?

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1 Q. Sure. Is it possible that you misconstrued

2 Ms. Siggerud's statement in Exhibit No. 9 where she said

3 take some time to think about this with the statement that

4 you have in Exhibit No. 17 that Ms. Siggerud specifically

5 gave you three days to think about resigning?

6 A. I must have gotten the two -- the two

7 conversations confused.

8 Q. Okay. And I am not asking you about whether or

9 not there were two conversations now. I understand that

10 that is your position. I am just asking you if it is

11 possible that you are mistaken about her giving you

12 specifically three days to resign, and what she really

13 said to you was "Take some time to think about it"?

14 MR. MILLS: Object to the form.

15 THE WITNESS: No. She did state that to

16 me, just maybe not at this particular recorded

17 conversation.

18 BY MS. FRANCIS:

19 Q. And what was going to happen after the three

20 days? What was your understanding?

21 A. That she would help me find a position within

22 the business or she would help me to obtain a position

23 outside of G&K.

24 Q. And at what -- at what date did she return to

25 you after this three days was up to get your decision?

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1 A. I don't recall. It was over a weekend I

2 believe.

3 Q. And did she call you and say: I have given you

4 your three days. What is your decision?

5 A. No, because I reassured her that I didn't need

6 time to think about it, because I enjoyed being there and

7 I didn't want to quit.

8 Q. So there was no response after you were given

9 the opportunity to think about this for three days?

10 A. No.

11 (Deposition Exhibit No. 18 was marked for

12 identification by the reporter.)

13 BY MS. FRANCIS:

14 Q. The court reporter marked Exhibit No. 18 to your

15 deposition. Do you recognize this document?

16 A. Yes.

17 Q. What is it?

18 A. It appears to be an e-mail to Jacob Briscoe from

19 myself.

20 Q. Why are you sending this e-mail?

21 A. Because my son was sick.

22 Q. Did you take time off to deal with the issue

23 that is reflected in Exhibit 18?

24 A. I don't recall.

25 Q. Did Mr. Briscoe object to you taking this time

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1 to care for your son?

2 A. I don't recall.

3 (Deposition Exhibit No. 19 was marked for

4 identification by the reporter.)

5 BY MS. FRANCIS:

6 Q. The court reporter has marked Exhibit No. 19 to

7 your deposition. Do you recognize this document?

8 A. I -- I don't recall this e-mail, no.

9 Q. Does this e-mail look like it came from your

10 e-mail account?

11 A. I am not sure. It just has my name. It doesn't

12 have an e-mail address.

13 Q. Well, it is in the same format as Exhibit No. 18

14 that we just looked at, correct?

15 A. Correct.

16 Q. And it says from Brandy Williams to J. Briscoe,

17 correct?

18 A. Correct.

19 Q. And it is dated 11/29/2012, correct?

20 A. Correct.

21 Q. Have you had an opportunity to read the

22 statement within Exhibit No. 19, the e-mail portion?

23 A. Yes.

24 Q. Did you write that?

25 A. I vaguely remember writing it.

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1 Q. So you do have a memory of writing this?

2 A. Somewhat.

3 Q. Is there any part of it that you believe you

4 didn't write?

5 A. No.

6 Q. Does it sound like something that you would have

7 written?

8 A. Yes.

9 Q. And in this e-mail, you tell Mr. Briscoe that

10 you had a doctor's appointment yourself.

11 A. Correct.

12 Q. And you say to Mr. Briscoe: I am dealing with a

13 serious health issue currently that I am trying to get

14 under control.

15 Correct?

16 A. Correct.

17 Q. You are saying: I am currently seeing a

18 specialist that I was referred to.

19 Correct?

20 A. Correct.

21 Q. So this is you providing information about your

22 medical condition to Mr. Briscoe, correct?

23 A. No specifics about my condition but, yes, that I

24 had a medical condition.

25 Q. And you tell him that you need to take some

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1 vacation time, correct?

2 A. Yes, correct.

3 Q. Do you recall Mr. Briscoe's response to this

4 e-mail, Exhibit No. 19?

5 A. No, I do not.

6 Q. Do you recall him objecting to you taking time

7 off to deal with your health issues that you identified in

8 Exhibit No. 19?

9 A. No, I do not.

10 (Deposition Exhibit No. 20 was marked for

11 identification by the reporter.)

12 BY MS. FRANCIS:

13 Q. The court reporter has marked Exhibit No. 20 to

14 your deposition. Tell me after you have had an

15 opportunity to review it.

16 A. Can you state that again?

17 Q. Tell me after you have had a chance to review

18 it.

19 A. I reviewed it.

20 Q. Do you recognize the e-mail chain that is in

21 Exhibit No. 20?

22 A. Yes.

23 Q. Starting with the first e-mail, which is from

24 you to Ms. Siggerud on August 9, 2013, at 12:11 p.m., you

25 e-mail Ms. Siggerud and tell her that you have a doctor's

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1 appointment that you have to go to, correct?

2 A. Correct.

3 Q. And you say: Should I also let Michael know?

4 Michael is the person that you were

5 reporting to in the recruiting position?

6 A. Correct.

7 Q. And you said: I am unsure, but I know you said

8 I am still reporting to you.

9 So even in the recruiting position, you

10 were still reporting to Ms. Siggerud?

11 A. Yes.

12 Q. And Ms. Siggerud responds and says that she will

13 let Michael know and asks how long you expect to be out

14 and can you make sure to reschedule any interviews this

15 afternoon, correct?

16 A. Correct.

17 Q. And she asks: So I can let Marie know, is this

18 related to your FMLA leave or is this something different?

19 Correct?

20 A. Correct.

21 Q. And what is your response?

22 A. Something different, I suppose.

23 Q. And did Ms. Siggerud let you take time off to

24 attend a medical appointment?

25 A. Yes. I used my lunch hour to attend.

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1 Q. And did she object at all to you taking that

2 time?

3 A. No, she didn't object to me using my lunch to go

4 to my appointment, no.

5 Q. Well, she didn't object to you rescheduling any

6 interviews this afternoon?

7 A. No.

8 Q. Did you come back after lunch, or did you take

9 the afternoon off because you were not feeling well?

10 A. No, I came back, and I worked well into the

11 evening.

12 Q. So did you have to reschedule any interviews?

13 A. I don't recall.

14 (Deposition Exhibit No. 21 was marked for

15 identification by the reporter.)

16 BY MS. FRANCIS:

17 Q. The court reporter has marked Exhibit No. 21 to

18 your deposition. Do you recognize this document?

19 A. Yes.

20 Q. What is Exhibit No. 21?

21 A. An e-mail to Michael Hammond.

22 Q. From who?

23 A. From myself.

24 Q. What date?

25 A. February 12th.

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1 Q. I'm sorry?

2 A. Wait, no, no. Oh, September 12, 2013.

3 Q. And why are you writing Mr. Hammond?

4 A. Because my daughter was sick.

5 Q. And are you asking for time off work to deal

6 with that issue?

7 A. Yes.

8 Q. And did he object to you taking time off work?

9 A. No, no.

10 Q. Do you recall how much time you took off this

11 day?

12 A. I don't recall. I -- I don't even think I left

13 this day. I think I asked my neighbor that I had on her

14 emergency list to actually pick her up, so I don't believe

15 that I left this day.

16 Q. When you were doing recruiting, were you working

17 from home?

18 A. Yes.

19 Q. Okay. So when you are telling Michael that you

20 have to pick up your daughter, you have to stop working to

21 go do that, correct?

22 A. Correct.

23 Q. So you are taking time that you would normally

24 be recruiting to go do that?

25 A. Correct. But I could do recruiting any hour of

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1 the day.

2 Q. Then why did you feel the need to tell him that

3 you were going to do this?

4 A. Just to be respectful. I was working for him.

5 I just wanted to make him aware of what I was doing.

6 Q. You said you apologize for the inconvenience.

7 Did you have to reschedule anything because of this?

8 A. I don't recall.

9 Q. Is it possible that you had to reschedule

10 something?

11 MR. MILLS: Object to the form.

12 Go ahead.

13 THE WITNESS: I don't recall.

14 BY MS. FRANCIS:

15 Q. Okay. What did you mean when you said that you

16 apologize for the inconvenience? What was the

17 inconvenience?

18 A. I just felt from previous conversations with

19 Rachael that any time I took away from the business was

20 inconveniencing managers or giving them a perception that

21 I was not engaged. So I just felt that with Michael that

22 I wanted to keep a good relationship with him, so I just

23 was letting him know that, you know, I felt bad for having

24 to ask to go get my daughter.

25 Q. Did Michael object in any way?

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1 A. No.

2 (Deposition Exhibit No. 22 was marked for

3 identification by the reporter.)

4 BY MS. FRANCIS:

5 Q. The court reporter has marked Exhibit No. 22 to

6 your deposition. Do you recognize this e-mail?

7 A. I don't recall this e-mail, no.

8 Q. It looks like Michael Hammond sent you an e-mail

9 on September 18, 2013, at 4:06 p.m., subject line: Are

10 you working today, question mark.

11 Do you see that?

12 A. Yes.

13 Q. And he says: Brandy, I am following up to my

14 voicemail. I am hearing from several managers that they

15 cannot get ahold of you. If you are not working, I really

16 need to know. Marissa is out sick today and I sent you a

17 note earlier asking to be her backup. Please confirm

18 either way if you are working at your earlier [sic]

19 opportunity.

20 Did I read that correctly?

21 A. Correct.

22 Q. Did you respond to this e-mail?

23 A. I don't recall.

24 Q. You don't recall receiving this e-mail?

25 A. I -- I don't recall receiving this, no.

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1 Q. Do you recall Mr. Hammond discussing with you

2 that managers couldn't get ahold of you?

3 A. No, I don't recall. I do recall him telling me

4 that Marissa was out sick, and he left me a voicemail

5 asking me if I was working. And I believe that I called

6 him back and we had a conversation, and I did let him know

7 that I was and who I was working with.

8 Q. Do you know what managers were trying to get

9 ahold of you that couldn't?

10 A. I do not. I don't recall.

11 Q. So you believe after you received this e-mail

12 you had a phone conversation with Mr. Hammond?

13 A. I believe so.

14 Q. When you were working in the recruiting

15 position, did you receive any performance feedback?

16 A. Yes.

17 Q. Who did you receive performance feedback from?

18 A. From Rachael.

19 Q. Was Rachael tracking your recruiting statistics?

20 A. I am unaware that she was.

21 Q. Did you receive any information about how many

22 positions you were able to fill compared to other

23 recruiters?

24 A. No.

25 Q. Do you know on average how many positions other

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1 recruiters were filling?

2 A. No.

3 Q. So you didn't receive any feedback specifically

4 about how successful you were at filling positions?

5 A. Just that I was doing a great job and that they

6 had seen improvement since they put me into the temporary

7 role and that other managers had specifically made

8 comments that I reacted and responded to them in realtime

9 and that they were pleased with my performance.

10 Q. And that was one e-mail that you recall that

11 feedback in, correct?

12 A. Correct.

13 Q. You attached that to your rebuttal statement to

14 the EEOC?

15 A. Correct.

16 Q. Other than that one e-mail, did you receive any

17 other feedback about your performance as a recruiter?

18 A. No.

19 Q. How many positions did you fill once you started

20 working in the recruiting role?

21 A. I don't recall. There was a lot.

22 Q. Did you tell anyone that you were overwhelmed by

23 the request volume?

24 A. No.

25 Q. Did you get any feedback on how many days it

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1 took you to fill a particular position compared to other

2 recruiters?

3 A. No.

4 Q. Are you aware that one position was open close

5 to 92 days before it was filled?

6 A. No, I am unaware of that -- any position that

7 was open for that long.

8 Q. Do you have an understanding of why you didn't

9 stay in the recruiter role?

10 A. I was told that they decided not to offer me a

11 permanent position based on performance as a recruiter.

12 Q. Did they give you any specific detail about what

13 performance issues led them not to offer you a permanent

14 position?

15 A. No. They just stated they felt I was not a good

16 fit.

17 Q. Who said that?

18 A. Rachael told me that that was the conversation

19 she had with Michael.

20 Q. And when did she tell you that?

21 A. When they met with me in the Phoenix location on

22 the 24th.

23 Q. Was that the date of your termination?

24 A. Yes -- no, my termination was on the 27th but

25 they told me on the 24th of September of 2013 that my last

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1 day would be September 27th of 2013.

2 Q. Okay. So this was during the termination

3 meeting that they told you you were not going to be

4 offered a permanent recruiting position, correct?

5 A. Correct.

6 Q. And they said that was based on performance

7 issues as a recruiter?

8 A. And that they had reevaluated the region that I

9 was in from the HR realignment, and that they felt it was

10 overstaffed so that they were laying me off.

11 Q. Did you ever hear from any of the other

12 recruiters that they were -- I'm sorry, not recruiters --

13 the other generalists that they were bored in their

14 position?

15 A. Yes.

16 Q. Did you hear that from Kaela?

17 A. Yes.

18 Q. What specifically do you recall her saying about

19 being bored?

20 A. That she didn't understand her role or her new

21 job and she was frustrated and confused by what the job

22 description was or what she was supposed to be doing on a

23 day-to-day basis.

24 Q. Did she use the term "bored" specifically?

25 A. Yes.

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1 Q. And did Janelle make that same comment to you?

2 A. Yes. They both stated that they basically sat

3 around all day and did nothing.

4 Q. Now, I know you were part of a termination due

5 to the realignment. Are you aware if anybody else was

6 terminated as part of this realignment around the same

7 time that you were?

8 MR. MILLS: Object to the form.

9 THE WITNESS: No, no one.

10 BY MS. FRANCIS:

11 Q. Do you know what happened to other regions,

12 whether or not after the realignment there was

13 consideration about, okay, should we have less generalists

14 or more generalists?

15 A. No.

16 Q. Do you know in the other regions how many

17 generalists were employed?

18 A. No.

19 Q. Did you know that the Northwest region had three

20 generalists and the other regions only had two?

21 A. No. I didn't recall how many were in each other

22 territory, no.

23 Q. But you don't have any reason to dispute that if

24 that is what the managers have said?

25 MR. MILLS: Object to the form.

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1 BY MS. FRANCIS:

2 Q. You have no knowledge about how many generalists

3 were in the other regions?

4 A. No.

5 Q. And then other than yourself, are you aware of

6 any other individuals that were terminated as part of the

7 reorganization?

8 A. During which time?

9 Q. Around the time that you were terminated.

10 A. No.

11 Q. Or within a year of the realignment, did you

12 hear about anyone else being terminated other than

13 yourself?

14 A. No.

15 Q. Do you believe that you were the only one that

16 were terminated as part of that reorganization?

17 A. Yes.

18 Q. And why do you believe that?

19 A. Due to the perception of me not being in the

20 business because I was attending medical appointments.

21 Q. But why do you believe you were the only one

22 that was terminated at this time?

23 A. Because I was taking time away from work.

24 Q. I understand that that is why you believe you

25 were terminated. My question is a little more specific.

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1 Why do you think you were the only one that was

2 terminated?

3 A. I -- I am -- I don't know.

4 Q. Okay. Because in documents like the complaint,

5 which we can pull back up if we need to, you say that --

6 and I think it is even in the charge -- you make the

7 statement that you were the only one selected for

8 termination, and I am just wondering what your factual

9 basis is for that statement.

10 A. I was not made aware that there was anyone else

11 that was laid off or terminated but myself. I was told

12 that I -- that the region was reviewed and that I was the

13 one that was chosen.

14 Q. Out of the region?

15 A. Correct.

16 Q. Do you have an understanding as to whether or

17 not other regions were assessed and different people were

18 let go as part of the same process?

19 A. I am not aware, no.

20 Q. So when you say you were the only one let go, it

21 is because you are aware only that you were terminated

22 from the Northwest region at this time?

23 A. Yes.

24 Q. Now, at some time after your termination, you

25 became aware that there were positions posted by G&K in

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1 the HR department, correct?

2 A. Correct.

3 Q. When did you first become aware that there was a

4 position for an HR position -- strike that.

5 When did you first become aware that G&K

6 posted an HR position after your termination?

7 A. I don't recall the exact date. It was a few

8 months after I was let go.

9 Q. And what position was that?

10 A. HR generalist.

11 Q. And what location was that position in?

12 A. It was in the Northwest region.

13 Q. Did it have a specific site location?

14 A. No.

15 Q. It didn't list that it was a position in

16 Minnesota?

17 A. Not that I recall. I just recall it stated

18 Northwest region.

19 Q. Do you know if it was a change in the business

20 operations that required the hiring of another generalist

21 at that point in time?

22 A. I was no longer employed, so I -- I don't know

23 what changes were made, no.

24 Q. Do you know whether or not Janelle and Kaela

25 continued to work in their position as generalist after

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1 you left?

2 A. Yes.

3 Q. For how long?

4 A. I -- I don't recall.

5 Q. Do you know if Janelle went out on another

6 medical leave after you were terminated?

7 A. No.

8 Q. Do you know if Kaela went out on a leave after

9 you were terminated?

10 A. No.

11 Q. Do you have any understanding of why that job

12 was posted for an HR generalist after your termination?

13 A. No. As far as I was aware, they were both still

14 working for G&K.

15 Q. And you believe the position was located where?

16 A. In the Northwest region, because it was a remote

17 position. You could do the function from anywhere in that

18 region to support a location.

19 Q. So to your knowledge, it didn't identify a

20 physical location for where the generalist had to work?

21 A. No.

22 Q. And did you apply for that position?

23 A. Yes.

24 Q. The first posting that you saw?

25 A. I believe so.

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1 Q. And what was the response that you received?

2 A. That the position was closed or canceled I

3 believe.

4 Q. Isn't it true that you didn't apply for -- the

5 first time you saw a posting, but then there was a posting

6 in December of -- I think years later, there were two

7 positions posted that you applied for, one that was

8 canceled. Did you only see one -- strike that.

9 Did you only see one posting or more than

10 one posting?

11 A. More than one posting.

12 Q. Okay. And did you apply every time you saw a

13 posting for an HR generalist position?

14 A. No, not all of them.

15 Q. Did you apply to the first one you saw?

16 A. I don't recall if it was the first one.

17 Q. How many postings do you believe you saw for an

18 HR generalist at G&K?

19 A. Two to three I believe.

20 Q. And you only applied for one?

21 A. Correct.

22 Q. And you were told that that position or posting

23 had been canceled, correct?

24 A. I believe so.

25 Q. Well, you provided documentation to the EEOC

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1 that shows the response you received, correct?

2 A. Correct.

3 Q. That was part of your rebuttal that you

4 submitted?

5 A. Yes, correct.

6 (Deposition Exhibit No. 23 was marked for

7 identification by the reporter.)

8 BY MS. FRANCIS:

9 Q. Do you recall -- well, the court reporter has

10 marked Exhibit No. 23. Have you seen this document

11 before?

12 A. Yes.

13 Q. Is this information that you sent to the EEOC

14 investigator?

15 A. Correct.

16 Q. And you state in your e-mail to the investigator

17 that you saw a G&K position posted on February 12th of

18 2014, correct?

19 A. Correct.

20 Q. And you also -- well, strike that.

21 And you attached a copy of the posting?

22 A. Correct.

23 Q. And it states that this is a human resources

24 generalist position, correct?

25 A. Correct.

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1 Q. And it states that the location of the position

2 is in Minnetonka, correct?

3 A. Correct, but they all stated that because they

4 were corporate employees. I was a corporate employee as

5 well, and it stated my location was Minnetonka, Minnesota,

6 even as a generalist.

7 Q. Even though you were assigned in the Phoenix

8 location?

9 A. Correct.

10 Q. So the location didn't specifically provide you

11 any details about where the job would be performed

12 physically?

13 A. No. Because it just said supporting a region

14 over -- covering multiple locations in multiple states.

15 Q. When it says "HR generalist business partner,"

16 do the terms "business partner" have any significant

17 meaning to you?

18 A. I would compare it to strategic partner.

19 Q. But do you think that this HR generalist

20 position is the same position you performed, or is it a

21 different position because it says HR generalist business

22 partner?

23 A. I believe it to be the same just reading the job

24 functions.

25 Q. Did you apply for the position in Exhibit

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1 No. 23?

2 A. I don't recall if this is the one I applied to.

3 Q. Were the recruiting -- were postings for

4 recruiting positions also referred to as "HR generalist,"

5 or was the posting different for a recruiting position, if

6 you know?

7 A. I'm sorry, can you repeat that?

8 Q. Sure. If the position was a recruiting position

9 like you had temporarily worked in, would it say "HR

10 generalist," or would it say something different, if you

11 know?

12 A. It would say something different.

13 Q. What would you believe a recruiting posting

14 would say?

15 A. Talent acquisition specialist.

16 Q. What did you do to find work after you were

17 terminated from G&K?

18 A. I was initially on unemployment, so I worked

19 with the unemployment department. I checked their website

20 for job listings that they had posted relating to the

21 field that I was in and also applied through online

22 methods, CareerBuilder, jobing.com or monster.com, other

23 various sites as well.

24 Q. I'm sorry, I didn't mean to interrupt.

25 Are you finished?

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1 A. Yes.

2 Q. How many positions do you think you applied for

3 per week?

4 A. Per week?

5 Q. On average.

6 A. 15 to 20 probably.

7 Q. Did you get any job offers?

8 A. No.

9 Q. You didn't work for anyone between the time that

10 you were unemployed and you went on permanent or full

11 disability?

12 A. No -- oh, I did not work for anyone? I did

13 work, yes.

14 Q. What job offers did you get?

15 A. Oh, I worked for -- I am sorry. I misstated

16 myself.

17 I -- I did get a job offer, I'm sorry, and

18 I -- I worked at the Home Depot.

19 Q. Did you only get one job offer?

20 A. I got also an additional job offer at Wells

21 Fargo as a teller.

22 Q. And did you accept that position?

23 A. I did initially, yes.

24 Q. And what was the pay?

25 A. I don't recall. Around 9 to $10 an hour.

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1 Q. And you said you accepted it initially. Did you

2 resign?

3 A. I did not start training.

4 Q. Why?

5 A. I just didn't feel comfortable with the position

6 just coming from my previous job I was in as a generalist.

7 I just was unsure if I would be happy in a different field

8 than what I had been in.

9 Q. So you were given an offer of employment and you

10 rejected it?

11 A. I did.

12 Q. Do you recall when that happened?

13 A. January of 2015.

14 Q. And you said you also received a job offer from

15 Home Depot, correct?

16 A. Correct.

17 Q. And when did you receive that job offer?

18 A. January of 2015.

19 Q. Was it around the same time that you got the

20 Wells Fargo offer?

21 A. Yes.

22 Q. And what position was the Home Depot?

23 A. Cashier.

24 Q. And what was the pay for Home Depot?

25 A. $9 an hour, I believe.

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1 Q. And why did you accept the position with Home

2 Depot instead of Wells Fargo?

3 A. I regretted not accepting the position with

4 Wells Fargo, and then because I continued in my job search

5 and I was not getting any HR calls at the time, so I

6 decided, you know, to take the Home Depot offer.

7 Q. How much time passed between the Wells Fargo

8 offer and the Home Depot offer?

9 A. I don't recall. Approximately maybe a week or

10 so. I don't really remember.

11 Q. Did you ever go back to Wells Fargo and say that

12 you would like to reapply?

13 A. No.

14 Q. Why not?

15 A. Because I accepted the position with Home Depot.

16 Q. And how long did you work at Home Depot?

17 A. Approximately a month and a half.

18 Q. And why did you stop working at Home Depot?

19 A. I was continuing my search for a job in HR, and

20 I just felt that I was not, you know, happy in that

21 position, and just -- it was not equivalent to what I had

22 before.

23 Q. So you quit?

24 A. Yes.

25 Q. Did you get any other job offers after G&K?

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1 A. Not that I recall.

2 Q. So you had unemployment income during this time

3 frame?

4 A. Correct.

5 Q. And did you have unemployment income after Home

6 Depot?

7 A. No. I only had unemployment income for I

8 believe three months after I left G&K.

9 Q. Why did your benefits stop?

10 A. Because it is based on what you accrue and what

11 you pay in, so the benefit amount that was available to me

12 had ran out.

13 Q. Okay. So you received the full benefit amount?

14 A. Yes.

15 Q. Did you have any other income?

16 A. No.

17 Q. When did you apply for Social Security

18 disability benefits?

19 A. January of 2015.

20 Q. So it took five months for you to get those

21 benefits?

22 A. It took ten months.

23 Q. I thought you became -- what date did you become

24 disabled under -- strike that.

25 On what date did you start receiving Social

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1 Security benefits?

2 A. November of 2015.

3 Q. Did you get the determination that you were

4 qualified for benefits on May 1 of 2015?

5 A. No. I didn't get it until October I believe.

6 Q. Of 2015?

7 A. Correct.

8 Q. I believe in your expert report on your wage

9 loss it states that you became eligible for Social

10 Security benefits on May of 2015. Would that be

11 incorrect?

12 A. That is what -- the Social Security department

13 stated that was the first date they considered me disabled

14 was May of 2015.

15 Q. Okay. But you didn't receive benefits until

16 October?

17 A. Correct, because they wouldn't retro back to

18 May, that they would begin at the time that they gave me

19 the determination.

20 Q. So it took ten months before you started

21 receiving benefits from the time of your application?

22 A. Correct.

23 Q. Do you have documentation concerning that

24 application process?

25 A. It was done online, so I submitted it online. I

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1 don't think I have any documentation, no.

2 Q. Do you have an account with Social Security that

3 you could go and get that information?

4 A. I do have an account. I am not sure if the

5 application is listed on there.

6 Q. Okay. Can you provide information to your

7 counsel so we can subpoena information from Social

8 Security about that application process?

9 THE WITNESS: I thought we already did

10 that.

11 MR. MILLS: I don't think so.

12 BY MS. FRANCIS:

13 Q. I don't think so.

14 A. We already provided the letter from Social

15 Security from the account.

16 Q. Right. I am talking about the application.

17 MR. MILLS: They want to -- they want to

18 request information directly from Social Security.

19 THE WITNESS: Oh, okay.

20 BY MS. FRANCIS:

21 Q. About the application process.

22 A. Oh, okay.

23 Q. So if you could give your counsel whatever

24 information you have, that would be helpful.

25 A. Okay.

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1 MS. FRANCIS: Can we take a break? I think

2 I am close.

3 MR. MILLS: Sure.

4 MS. FRANCIS: How long do you think you are

5 going to have?

6 MR. MILLS: Not very long. I will just

7 have a few questions.

8 VIDEO TECHNICIAN: We are off the record at

9 4:58 p.m.

10 (Recess ensued from 4:58 p.m. until

11 5:04 p.m.)

12 VIDEO TECHNICIAN: We are back on the

13 record at 5:04 p.m.

14 BY MS. FRANCIS:

15 Q. When you were in the recruiting position, who

16 covered the locations that you had previously covered when

17 you were a generalist?

18 A. I believe it was Kaela, Kaela Ellison.

19 Q. Were you aware that Janelle was out on maternity

20 leave during the time frame you were in the recruiting

21 position?

22 A. Yes. And Rachael told me that she would also

23 help cover HR issues as well with Kaela.

24 Q. Okay. So Kaela was basically servicing all of

25 the Northwest region by herself when you were in the

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1 recruiting role for a period of time?

2 A. No. Rachael was also helping with my location

3 also.

4 Q. But she was the only generalist?

5 A. She was the only generalist, yes.

6 Q. Okay. Do you know how long Kaela was the only

7 generalist working in the Northwest region?

8 A. I don't recall.

9 Q. Do you believe that there were any legitimate

10 business reasons that went into the decision to eliminate

11 your position?

12 A. No.

13 Q. None at all?

14 A. No.

15 Q. After your termination, do you believe that you

16 suffered any medical issues because of the termination?

17 A. I believe that it aggravated them due to the

18 stress.

19 Q. Was your stress relieved after the termination

20 because you were no longer struggling with the generalist

21 role?

22 A. No.

23 Q. What additional stress did you undergo after the

24 termination?

25 A. Just not having a job. I mean, that was a huge

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1 thing was to lose such an important job to myself and my

2 family.

3 Q. And how long do you think that you suffered

4 additional stress because of the termination?

5 A. I don't recall. It was quite a while.

6 Q. Did you suffer any new medical symptoms because

7 of your termination?

8 A. No.

9 Q. Did you have other things that were going on in

10 your life after your termination that caused you stress

11 besides your medical condition?

12 A. No.

13 Q. Did you have any issues with your marriage?

14 A. Yes.

15 Q. And when did those start?

16 A. When I started having health issues.

17 Q. When was that?

18 A. After the delivery of my son in July of 2012.

19 Q. And those were ongoing after your termination?

20 A. Yes.

21 Q. And when did those resolve?

22 A. They still occur sporadically. Now it just

23 depends on my, you know, flare-ups or my health state, so

24 it kind of just comes and goes.

25 Q. I am talking about your -- the stress that is

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1 caused by your marital issues.

2 A. When did that resolve?

3 Q. Um-hum.

4 A. I am unsure.

5 Q. Is it ongoing?

6 A. It is.

7 Q. Are you still married?

8 A. Yes.

9 Q. Have you applied for or made an application for

10 divorce?

11 A. No.

12 Q. Has your husband?

13 A. Yes.

14 Q. When did he do that?

15 A. I don't remember the exact date. It was a few

16 years ago. It was before my employment with G&K.

17 Q. Okay. But since your employment with G&K, has

18 he filed for divorce?

19 A. No.

20 Q. When I asked you at the beginning of the

21 deposition that you had -- strike that. Start again.

22 Sorry.

23 When I asked you at the beginning of the

24 deposition if you had been involved in any court

25 proceedings, why didn't you tell me about the time that

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1 your husband had filed for divorce?

2 A. Oh, I must not have understood the question. I

3 thought it meant me filing something directly. I didn't

4 -- I was not aware if someone else had filed the request.

5 Q. Okay. My question was really broad. Have you

6 ever been involved in any other court proceedings other

7 than this?

8 A. Yes.

9 Q. Okay. Other than the time that your husband

10 filed for divorce, have you been involved in any other

11 court proceedings?

12 A. I filed a lawsuit before, yes.

13 Q. Against who?

14 A. The City of West Memphis.

15 Q. And where was that filed?

16 A. In federal court in Arkansas.

17 Q. What year did you file that case?

18 A. I don't recall the exact date. It has been well

19 over ten years.

20 Q. Who was the defendant?

21 A. A police officer, Officer Nash.

22 Q. And what were you claiming in the lawsuit?

23 A. Assault from the police officer.

24 Q. And what was the result of that litigation?

25 A. There was a settlement.

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1 Q. Is that settlement confidential?

2 A. I don't believe so.

3 Q. How much money did you receive?

4 A. The settlement amount was $7,000, but my portion

5 was less due to attorneys' costs.

6 Q. Have you been involved in any other court

7 proceedings that we have not talked about?

8 A. Outside of the divorce request from my husband

9 and the City of West Memphis, none that I recall.

10 Q. Okay. I want to be clear. You have not filed

11 for bankruptcy?

12 A. No, no.

13 Q. And you never filed an injunction for protection

14 from harassment?

15 A. Not that I recall, no.

16 Q. Has anyone ever filed a petition for protection

17 from you for harassment?

18 A. Not that I recall, no.

19 Q. Have you received a medical opinion from any of

20 your treating physicians that any medical issue was caused

21 specifically by your termination?

22 A. Have I received any medical report?

23 Q. Medical opinion.

24 A. No.

25 Q. Have you asked anyone to be a witness for you in

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1 this case?

2 A. No.

3 Q. Have you asked anyone to assist you with the

4 litigation that has refused?

5 A. No.

6 Q. After you talked with Janelle, did she agree to

7 provide a deposition?

8 A. She stated that she would call you and talk to

9 you about doing the deposition.

10 Q. Okay.

11 A. Yes.

12 Q. She has not returned my calls, just for the

13 record.

14 A. Yeah, I don't know.

15 Q. But when she spoke with you, she said she would

16 appear?

17 A. Correct.

18 Q. How long ago was that, again?

19 A. Friday.

20 Q. Have you understood all the questions that I

21 have asked you when you haven't told me to rephrase?

22 A. Yes.

23 Q. Okay. Is there any changes or modifications

24 that you need to make to any testimony that you provided?

25 A. Not that I can think of, no.

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1 MS. FRANCIS: Okay. I don't have any

2 further questions.

3 MR. MILLS: Okay. I just have a few.

4

5 EXAMINATION

6 BY MR. MILLS:

7 Q. Brandy, if you could turn back to Exhibit 14,

8 which is the performance document, performance review.

9 A. Okay.

10 Q. Got it?

11 A. Yes.

12 Q. You were asked a series of questions about

13 certain things that you wrote in this document. Do you

14 recall that?

15 A. Yes.

16 Q. And on the first page in the midyear comments

17 summary, you had written about monthly safety meetings

18 with the plant managers.

19 A. Yes.

20 Q. And do you recall testifying about that?

21 A. Yes.

22 Q. And those meetings occurred?

23 A. Yes.

24 Q. Was Rachael Siggerud present at those meetings?

25 A. No.

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 273 of 505
273

1 Q. Was she present at any of them?

2 A. No.

3 Q. Even one?

4 A. No.

5 Q. And then at the end of that paragraph, you talk

6 about -- do you remember testifying about the wheel of

7 safety meetings?

8 A. Correct.

9 Q. Was Rachael Siggerud present at any of those

10 meetings?

11 A. No.

12 Q. Even one?

13 A. None that I recall.

14 Q. If you turn to the second page, do you remember

15 testifying about the Coach to Win model?

16 A. Correct.

17 Q. Was Rachael Siggerud present at any of your

18 discussions with anyone at the company about the

19 Coach to Win model?

20 A. No.

21 Q. And in the second sentence of the individual

22 objective No. 1 where it states hands-on training with a

23 mentor or coach --

24 Do you see that?

25 A. Yes.

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 274 of 505
274

1 Q. Do you remember giving some testimony about

2 that?

3 A. Yes.

4 Q. Was Rachael Siggerud present at any of the times

5 that you gave a training?

6 A. No.

7 Q. Go down to the individual objective No. 2.

8 A. Okay.

9 Q. Item No. 1: Meet with leaders monthly to review

10 and update 9 Block.

11 Do you remember testifying about that?

12 A. Yes.

13 Q. Was Rachael Siggerud present at any of your

14 discussions about 9 Block?

15 A. No.

16 Q. Item No. 3: Schedule biweekly meetings with

17 leaders to develop assignments for HPEs.

18 Do you remember testifying about that?

19 A. Yes.

20 Q. Was Rachael Siggerud present at any of those

21 meetings?

22 A. No.

23 Q. Do you recall you testified about meetings that

24 occurred I believe you said Monday mornings at 5:00 a.m.?

25 A. Yes.

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 275 of 505
275

1 Q. And those were -- what meetings were those?

2 Remind me again.

3 A. It was -- it was the business financial

4 meetings, service -- it was for service.

5 Q. You state in individual objective No. 2 -- you

6 have a reference in here to weekly growth meetings to help

7 leaders monitor and improve business opportunities and

8 revenue. Is that what those meetings were?

9 A. Yes.

10 Q. Was Rachael present at any of those meetings?

11 A. No.

12 Q. Did those meetings occur in person or were they

13 telephonic?

14 A. In person.

15 Q. Okay. Did she attend even one of those

16 meetings, if you recall?

17 A. In person, no.

18 Q. Okay. Did she ever attend telephonically?

19 A. I don't recall.

20 Q. Was Rachael present when you ever provided

21 information to anyone at G&K regarding EEOC rules and

22 claims?

23 A. No.

24 Q. Was Rachael Siggerud present when you provided

25 information to anyone at G&K regarding retaliation and

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 276 of 505
276

1 discrimination?

2 A. No.

3 Q. Was she present when you ever had discussions

4 with anyone at G&K regarding employees' rights?

5 A. No.

6 Q. Was she ever present when you provided

7 information or training to anyone at G&K regarding the

8 Civil Rights Act, the state human rights act, the AD --

9 ADA, the ADAAA 2008, the FMLA, the California Medical

10 Leave Act, USSERA and affirmative action?

11 A. No.

12 Q. So it sounds like with respect to many, if not

13 most, of the objectives that you put down in Exhibit 14,

14 Rachael Siggerud wouldn't have personal knowledge about

15 whether you complied with that objective or not, would

16 she?

17 MS. FRANCIS: Object to the form and

18 foundation.

19 THE WITNESS: No.

20 BY MR. MILLS:

21 Q. She didn't observe you, did she?

22 MS. FRANCIS: Same objection.

23 THE WITNESS: No.

24 BY MR. MILLS:

25 Q. So she wouldn't have any personal knowledge --

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 277 of 505
277

1 strike that.

2 She wouldn't have -- strike that.

3 She wouldn't have any personal knowledge of

4 you performing most of -- most of the objectives that you

5 have listed in this Exhibit 14; is that correct?

6 MS. FRANCIS: Object to the form and

7 foundation.

8 THE WITNESS: No.

9 BY MR. MILLS:

10 Q. Do you recall being asked some questions about

11 the management at Phoenix being resistant or receiving

12 some pushback after you assumed the role of HR generalist?

13 A. Yes.

14 Q. Did Jake Briscoe ever say or do anything that

15 suggested to you that he was suspicious of your role as an

16 HR generalist?

17 A. Yes.

18 Q. What?

19 A. That he didn't understand our reasoning behind

20 me needing to be involved in the financials of his

21 business.

22 Q. Did Jake ever express to you that he didn't

23 think that the financials of the Phoenix plant were any of

24 your business?

25 A. Yes.

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 278 of 505
278

1 Q. What specifically did he say?

2 A. He didn't understand why HR needed to know

3 anything about financials.

4 Q. Now, prior to the time that -- that you became

5 an HR generalist, the financials of the Phoenix plant were

6 handled by Jake?

7 A. Yes.

8 Q. Was Mitch involved in that?

9 A. Yes.

10 Q. Okay. And did -- did Mitch express to you that

11 he was not happy that you were now involved in the

12 financials?

13 A. Yes.

14 Q. All right. What did he say?

15 A. That he didn't understand the new role that I

16 was in or understand why he needed to teach me about the

17 financials or why we needed to know what numbers he was

18 needing in the service department.

19 Q. Did -- did they say anything to you that

20 indicated that they didn't want you to know what the

21 numbers were?

22 A. Yes.

23 Q. What did they say?

24 A. They would tell me that they felt that it was

25 just HR's job now to be tattletales, to tell on the

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 279 of 505
279

1 locations.

2 Q. And did Jake or Mitch indicate to you that they

3 resented that?

4 A. Yes.

5 Q. Which one?

6 A. Both.

7 Q. Were there other things that Jake and/or Mitch

8 expressed to you that they resented about your new role as

9 an HR generalist?

10 A. I don't recall.

11 Q. Who at -- was there someone at -- at corporate

12 who told you that a part of your job as an HR generalist

13 was to be involved with the financials of the local

14 plants?

15 A. Yes.

16 Q. Who?

17 A. Rachael Siggerud and Eric McNaul.

18 Q. What specifically did Ms. Siggerud and

19 Mr. McNaul say to you about your involvement in that?

20 MS. FRANCIS: Object to the form.

21 BY MR. MILLS:

22 Q. Let's start with Ms. Siggerud. What did Rachael

23 Siggerud say to you that you were supposed to be doing

24 with respect to the financials at the local plants?

25 A. That we were part of the management team at each

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 280 of 505
280

1 location and that we were just as responsible as the

2 financials of the business because we were a part of the

3 group as everyone else, and that we should learn as much

4 as possible by shadowing managers, and we would be judged

5 on the success of the business in our performance review

6 at the end of the year as well as all the other managers.

7 Q. What did Mr. McNaul say to you about what --

8 what you were supposed to be doing with respect to the

9 financials at the local plants?

10 A. Eric McNaul told me that I should be the eyes

11 and ears for the corporate office and that it was my job

12 to make sure legally that the Phoenix business was doing

13 the right thing and that I should report any -- anything

14 that I felt was a concern with the business to the

15 corporate office.

16 Q. Did you do that in your role as an HR

17 generalist?

18 A. Yes.

19 Q. Did you act as the eyes and ears of management?

20 A. Yes.

21 Q. Was Jake Briscoe aware that that is what you

22 were doing?

23 A. Yes.

24 Q. Did you tell him that is what you were doing?

25 A. Not in so many words, no. I told him that we

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 281 of 505
281

1 were part of, you know, the management team together.

2 Q. Did Jake -- did Jake ever say or indicate

3 anything to you that -- that led you to believe that --

4 that he knew that you were there to serve as the eyes and

5 ears of corporate?

6 A. Yes.

7 Q. Okay.

8 A. And he told me that I needed to make sure not to

9 take any concerns or issues to Rachael or Eric until I

10 passed it by him first because it was his business and his

11 decision.

12 Q. Before the realignment, Jake had been your

13 immediate supervisor --

14 A. Yes.

15 Q. -- is that true?

16 A. Yes.

17 Q. And after you became an HR generalist, Jake was

18 no longer your supervisor, was he?

19 A. Correct.

20 Q. Rachael was now your supervisor?

21 A. Correct.

22 Q. But Jake still wanted you to run past him

23 anything that you were going to report back to Rachael or

24 Eric?

25 A. Yes.

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 282 of 505
282

1 Q. Did you do that?

2 A. No.

3 Q. Why not?

4 A. Rachael told me that she was my direct

5 supervisor and that I should discuss all concerns with her

6 and that if there was an issue, then she would discuss

7 them directly with Jake herself.

8 Q. Before you became an HR generalist, Jake had

9 done your performance reviews?

10 A. Yes.

11 Q. And what kind of reviews did you get from him?

12 A. They were very good.

13 Q. What kind of relationship did you have with Jake

14 before you became an HR generalist?

15 A. We had a really good relationship.

16 Q. Who hired you at G&K?

17 A. Jake Briscoe.

18 Q. He interviewed you?

19 A. Yes.

20 Q. He was the one that offered you a job as an HR

21 representative?

22 A. Yes.

23 MR. MILLS: I think that's all I have.

24 MS. FRANCIS: Okay. I just have a few

25 follow-up questions.

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 283 of 505
283

1 EXAMINATION

2

3 BY MS. FRANCIS:

4 Q. You had weekly one-on-one meetings with

5 Ms. Siggerud, correct?

6 A. Correct.

7 Q. And during the one-on-one meetings, would you

8 discuss with her what work you were doing?

9 A. Yes.

10 Q. And so you would provide her details about what

11 you were doing on a weekly basis?

12 A. Yes.

13 Q. So Ms. Siggerud knew what tasks you were

14 performing, what trainings you were doing, things of that

15 nature, correct?

16 A. I would just give her a summary of what things I

17 was working on.

18 Q. So you would tell her what you were doing?

19 A. Yes.

20 Q. So Ms. Siggerud had personal knowledge of the

21 job tasks that you were completing because you would have

22 one-on-one meetings with her --

23 MR. MILLS: Object to the form.

24 BY MS. FRANCIS:

25 Q. -- every week, correct?

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 284 of 505
284

1 A. She had an idea, but she was never there to --

2 Q. Personally observe?

3 A. -- personally observe me in performing the

4 functions.

5 Q. Correct. But you would tell her what you were

6 doing?

7 A. I wouldn't have specifics on everything, but I

8 would give her a summary on what I was working on, yes.

9 Q. And she would ask you questions about what you

10 were doing --

11 A. Yes.

12 Q. -- and what your plans were to do in the future,

13 correct?

14 A. Yes.

15 MS. FRANCIS: Okay. No further questions.

16 MR. MILLS: Okay. We are done I guess.

17 VIDEO TECHNICIAN: This concludes the video

18 recorded deposition of Brandy Lane Williams. Today's date

19 is June 14, 2016. The time is 5:25 p.m.

20 (Proceedings adjourned at 5:25 p.m.)

21

22

23

 BRANDY LANE WILLIAMS

24

25

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 285 of 505
285

1 CERTIFICATE

2 I HEREBY CERTIFY that the foregoing deposition

was taken by me pursuant to notice; that I was then and

3 there a Certified Court Reporter for the State of Arizona,

and by virtue thereof authorized to administer an oath;

4 that the witness before testifying was duly sworn by me to

testify to the whole truth and nothing but the truth;

5 pursuant to request, notification was provided that the

deposition is available for review and signature; that the

6 questions propounded by counsel and the answers of the

witness thereto were taken down by me in shorthand and

7 thereafter transcribed through computer-aided

transcription under my direction, and that the foregoing

8 typewritten pages contain a full, true, and accurate

transcript of all proceedings had upon the taking of said

9 deposition, all done to the best of my skill and ability.

 I FURTHER CERTIFY that I am in no way related to

10 nor employed by any of the parties hereto, nor am I in any

way interested in the outcome hereof.

11 I FURTHER CERTIFY that I have complied with the

ethical obligations set forth in ACJA Sections

12 (J)(1)(g)(1) and (2).

 DATED at Phoenix, Arizona, this 27th day of

13 June, 2016.

14

 CARRIE A. CARIATI

15 Registered Professional Reporter

 Certified Realtime Reporter

16 Certified LiveNote Reporter

 Certificate No. 50355

17

18 I CERTIFY that this Registered Reporting Firm

has complied with the ethical obligations set forth in

19 ACJA Sections (J)(1)(g)(1) and (2).

20

 DATED at Scottsdale, Arizona, this 27th day of

21 June, 2016.

22

 _____________________________________

23 Registered Reporting Firm R1064

 CARRIE A. CARIATI, Owner

24

25

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 286 of 505
EXHIBIT B

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 287 of 505
Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

Jacob Samuel Briscoe - June 22, 2016 1

 UNITED STATES DISTRICT COURT

 FOR THE DISTRICT OF ARIZONA

 BRANDY WILLIAMS, )

 )

 Plaintiff, )

 )

 vs. ) No.

 ) 2:15-CV-01744-

 G & K SERVICES, INC., a Minnesota ) DJH

 corporation; JANE AND JOHN DOES )

 1-100; BLACK CORPORATIONS 1-100; )

 WHITE PARTNERSHIPS 1-100, )

 )

 Defendants. )

 ____________________________________)

 VIDEOCONFERENCE DEPOSITION OF JACOB SAMUEL BRISCOE

 Phoenix, Arizona

 June 22, 2016

 9:00 a.m.

 PREPARED BY:

 Robin L. B. Osterode, RPR, CSR

 Certified Reporter No. 50695

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 288 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 2

 1

 2 VIDEOCONFERENCE DEPOSITION OF JACOB

 3 SAMUEL BRISCOE, commenced at 9:00 a.m., on June 22,

 4 2016, at Phoenix, Arizona, before Robin L. B.

 5 Osterode, RPR, CSR, Arizona Certified Reporter

 6 No. 50695.

 7

 8

 9 * * *

10

11 APPEARANCES:

12 For Plaintiff:

13 MILLS & WOODS LAW PLLC By: Robert T. Mills

14 5055 North 12th Street, Suite 101 Phoenix, Arizona 85014

15 (480) 999-4556 docket@millsandwoods.com

16

 For Defendants:

17

 STINSON LEONARD STREET, LLP

18 By: Kristin Berger Parker 1850 North Central Avenue, Suite 2100

19 Phoenix, Arizona 85004 (602) 279-1600

20 kristin.parker@stinsonleonard.com (Via Videoconference)

21

 Also Present:

22

 Donna Fox 23

 

24

 

25

Page 3

 1 I N D E X 

 2 JACOB SAMUEL BRISCOE PAGE 

 3 Examination by Mr. Mills 4, 62 

 4 Examination by Ms. Parker 60 

 5

 

 6

 

 7

 

 8

 

 9

 

10 EXHIBITS MARKED 

11 EXHIBITS DESCRIPTION PAGE 

12 Exhibit 25 Bates stamped documents 15 G&K000129 - G&K000132

13

 Exhibit 26 Bates stamped documents 13 14 G&K000136 - G&K000139 

15

 

16

 

17

 

18

 

19

 

20

 

21

 

22

 

23

 

24

 

25

Page 4

 1 JACOB SAMUEL BRISCOE

 2 called as a witness herein, having been first duly

 3 sworn, was examined and testified as follows:

 4 5 E X A M I N A T I O N

 6 BY MR. MILLS: 

 7 Q. Please state your full name for the record?

 8 A. Jacob Samuel Briscoe.

 9 Q. Good morning, Mr. Briscoe. My name is Bob

10 Mills and I represent Brandy Williams, and I'm going

11 to be asking you some questions this morning. Have

12 you ever had your deposition taken before?

13 A. No.

14 Q. Okay. Have you ever been a party to a

15 lawsuit before?

16 A. No.

17 Q. Have you ever testified in court as a

18 witness?

19 A. No.

20 Q. Have you ever testified in any

21 administrative proceeding as a witness?

22 A. Administrative as in unemployment, things

23 like that.

24 Q. Okay. You have?

25 A. Yes.

Page 5

 1 Q. Okay. That's one -- one of the ground

 2 rules for the deposition is when I ask you a question

 3 you need to answer it verbally. Sometimes witnesses

 4 have a tendency to either nod or shake their head or

 5 say "uh-huh" or "huh-uh," but the court reporter

 6 can't pick that up, so we need a clear answer. The

 7 other thing is if you don't understand a question

 8 that I'm asking you, just tell me that you don't

 9 understand it, and I'll try and rephrase it.

10 Otherwise, I'll assume that you did

11 understand it. And, lastly, you're free to -- I

12 don't think this will take all day, but you're

13 certainly free to take a break whenever you feel like

14 you need one. The only thing I would ask is if

15 there's a question pending, you answer the question

16 before the break; is that okay?

17 A. I understand.

18 Q. Okay. Where do you live, sir?

19 A. Currently, I live in Carlisle,

20 Pennsylvania.

21 Q. How long have you lived there?

22 A. About 18 months.

23 Q. Okay. Are you employed, sir?

24 A. I am.

25 Q. By whom?

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(1) Pages 2 - 5

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 289 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 6

 1 A. Equipment Depot.

 2 Q. And what do you do for Equipment Depot?

 3 A. I'm a general manager.

 4 Q. Are you stationed in Carlisle,

 5 Pennsylvania?

 6 A. My office is in Mechanicsburg,

 7 Pennsylvania.

 8 Q. And does your job require you to travel

 9 from time to time?

10 A. Very little.

11 Q. And what are your job duties as a general

12 manager with Equipment Depot?

13 A. I oversee the service department, which is

14 a group of technicians. I oversee the sales

15 department. I oversee the parts department, and

16 general operations of that business.

17 Q. Okay. How many employees do you manage?

18 A. About 75, approximately.

19 Q. And were you formerly employed by G & K

20 Services?

21 A. Yes.

22 Q. From when to when were you employed by --

23 by G & K?

24 A. For 20 years, so it would have been 1993

25 through 2015, approximately, with a break for

Page 7

 1 military service in 2003.

 2 Q. Okay. And after you left G & K in 2015,

 3 did you go directly to Equipment Depot or did you

 4 work somewhere else in between?

 5 A. I spent three months in my job search

 6 before I went to Equipment Depot.

 7 Q. Okay. But you didn't have any other

 8 employment between G & K and Equipment Depot?

 9 A. No.

10 Q. What positions did you hold at G & K during

11 your 20 years of service there?

12 A. I started out as a route sales

13 representative. I was an account manager. I was a

14 route manager. I was a service manager. A branch

15 manager. A business manager. And a general manager.

16 Q. And while -- while you were working for G &

17 K, were you working in Phoenix?

18 A. For 10 years in Phoenix.

19 Q. What other locations did you work at?

20 A. I worked in our Salt Lake, Utah location.

21 Our Ogden branch in Utah. Also in Seattle,

22 Washington, over various periods of time.

23 Q. And during what period of time were you the

24 general manager in Phoenix?

25 A. From 2011 through 2015.

Page 8

 1 Q. Is that the position you held when you --

 2 when you left G & K?

 3 A. Yes.

 4 Q. And while you were the general manager in

 5 Phoenix, who was the manager?

 6 MS. PARKER: Objection; form.

 7 THE WITNESS: The manager of --

 8 BY MR. MILLS: 

 9 Q. Of G & K in Phoenix?

10 A. I don't understand the question.

11 Q. Okay. Did you have a manager who was

12 working under you when you were the general manager?

13 MS. PARKER: Objection; form.

14 You can answer.

15 THE WITNESS: Yes, I had multiple managers

16 that worked for me in --

17 BY MR. MILLS: 

18 Q. Okay.

19 A. -- Phoenix, Arizona.

20 Q. Okay. How many?

21 A. I had a service manager, a sales manager, a

22 plant manager, an office manager, and at one point I

23 had an HR generalist that also worked for me. She

24 was not a manager. But those were my direct reports

25 as general manager.

Page 9

 1 Q. Who was the HR generalist?

 2 A. Brandy Williams.

 3 Q. How many employees did you manage at the --

 4 at the Phoenix location of G & K?

 5 A. There was approximately 90 to 100 in that

 6 location.

 7 Q. Okay. And while you were --

 8 A. And all the --

 9 Q. I'm sorry, go ahead.

10 A. -- and all the branches that rolled up

11 under that group.

12 Q. And what -- what were the other branches

13 that rolled up under that group?

14 A. The Tucson, Arizona branch, so I had a

15 branch manager there that also reported to me and

16 then I had a small location in Yuma, Arizona, and

17 Prescott, Arizona.

18 Q. So during the time that you were the

19 general manager in Phoenix, you were also general

20 manager for Tucson and Prescott and Yuma?

21 A. Yes.

22 MS. PARKER: Object to the form.

23 THE WITNESS: Sorry.

24 MS. PARKER: That's all right.

25 THE WITNESS: Yes.

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(2) Pages 6 - 9

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 290 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 10

 1 BY MR. MILLS: 

 2 Q. You knew Brandy Williams while you were

 3 working in Phoenix. Correct?

 4 A. Yes.

 5 Q. Did you interview Brandy Williams when she

 6 applied for a job at G & K?

 7 A. I did.

 8 Q. And are you the individual that hired her

 9 to work at G & K?

10 A. Yes.

11 Q. You made that decision to hire Brandy.

12 Correct?

13 A. I did, with input of other individuals that

14 also interviewed her, but I was the hiring manager.

15 Q. Okay. And Brandy was in the HR Department,

16 human resources?

17 MS. PARKER: Object to the form.

18 MR. MILLS: Strike that -- let me -- let me

19 rephrase the question.

20 Q. For what position did you hire Brandy

21 Williams?

22 A. She was an HR generalist.

23 Q. You hired her as an HR generalist?

24 A. Yes.

25 Q. Okay. And when was that?

Page 11

 1 A. I don't recall the exact date.

 2 Q. Was it -- would it have been in 2011? Does

 3 that sound right?

 4 A. That sounds right. It was about four years

 5 ago.

 6 Q. And during the -- during the time that you

 7 worked with Brandy, did -- did she work in Phoenix as

 8 well?

 9 A. Yes, her office was in Phoenix.

10 Q. And for a time, you were Brandy's direct

11 supervisor. Correct?

12 A. Yes.

13 Q. Was there a period of time when you stopped

14 being her direct supervisor?

15 A. Yes.

16 Q. And when was that?

17 A. Sometime, about -- maybe less than a year

18 after she started. They changed the HR organization,

19 and she reported to a different manager.

20 Q. Okay. And just very general terms, can you

21 tell me your understanding of how they -- how they

22 changed the HR structure?

23 MS. PARKER: Objection; foundation.

24 You can answer, to the extent you know.

25 THE WITNESS: Yeah, they -- they had each

Page 12

 1 HR individual report to a regional director and they

 2 divvied up the job responsibilities of the generalist

 3 amongst that group and made them specialized.

 4 BY MR. MILLS: 

 5 Q. Okay. And do you know who Brandy's

 6 supervisor was after that reorganization?

 7 A. Yes.

 8 Q. Who was that?

 9 A. Rachel Siggerud.

10 Q. Had you worked with Rachel Siggerud before?

11 A. Yes.

12 Q. In -- in what respect?

13 A. She was our HR director for the region that

14 I was in.

15 Q. Okay. And that was the Northwest Region.

16 Correct?

17 A. Yes.

18 Q. During the time that you were Brandy

19 Williams' direct supervisor, did you do her

20 performance reviews?

21 A. I did the first year that she worked for

22 G & K.

23 Q. And then did someone else do those reviews?

24 MS. PARKER: Objection; foundation.

25 MR. MILLS: Let me -- let me rephrase the

Page 13

 1 question, that was -- that was bad.

 2 Q. During the time that you were her direct

 3 supervisor, was there anyone else who did performance

 4 reviews of Brandy, to your knowledge?

 5 A. Not directly to my knowledge, no.

 6 (Marked for identification Exhibit 26.)

 7 BY MR. MILLS: 

 8 Q. Okay. Can you take a look at the document

 9 that we premarked as Exhibit 26.

10 MS. PARKER: When you've had a chance to

11 review it, you can just tell him you're done.

12 THE WITNESS: Okay, I've -- I've had a

13 chance to look at this document.

14 BY MR. MILLS: 

15 Q. Okay. Have -- have you -- sorry, have you

16 seen this document before, sir?

17 A. Obviously, at some point I have.

18 Q. Okay. Is this --

19 A. It's got my name on it electronically.

20 Q. Yeah, this is the -- this is entitled a

21 manager evaluation. Correct?

22 A. Uh-huh.

23 Q. Yes?

24 A. Yes.

25 Q. And is this an evaluation that you prepared

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Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 14

 1 regarding Brandy Williams?

 2 A. Not according to my recollection, it shows

 3 that the author is Rachel Siggerud.

 4 Q. Okay. If you go down through the document,

 5 let's go down to Section 1, "G & K Performance

 6 Objectives." Do you see that?

 7 A. Yup. Yes.

 8 Q. And the very -- very last line in the -- in

 9 the box says "Last modified by Jacob Briscoe, July

10 26, 2012." Do you see that?

11 A. I do.

12 Q. Do you know what that means that it was

13 last modified by you?

14 A. I don't, because she didn't report to me at

15 that time, so I don't know why it's got my name on

16 it, other than I may have transferred it or

17 something.

18 Q. Brandy was not reporting to you during this

19 time period of January 1st, 2012 through June 2012?

20 A. I don't recall exactly when she moved, but

21 at some point she did move during that year.

22 Q. Okay. You don't recall doing this

23 evaluation, though?

24 A. I'm sure I had some input on this, but I

25 don't remember the details.

Page 15

 1 Q. Is it possible that you're the one that

 2 gave the ratings to Brandy, the manager ratings?

 3 MS. PARKER: Objection; form.

 4 THE WITNESS: I would say it's possible,

 5 yes.

 6 BY MR. MILLS: 

 7 Q. Okay. And if you read through the actual

 8 ratings in the document, all of the manager's ratings

 9 appear to be meets expectations. Correct?

10 A. That would be correct.

11 (Marked for identification Exhibit 25.)

12 BY MR. MILLS: 

13 Q. Okay. I'd like for you to take a look at

14 the document that we've premarked as Exhibit 25. And

15 let me know when you've had a chance to review that.

16 A. Yup, I've had a chance.

17 Q. Okay. You recognize this document?

18 A. I do.

19 Q. Okay. And is this a -- is this a

20 performance review that -- that you prepared with

21 respect to Brandy Williams?

22 A. Yes, it is.

23 Q. Okay. Okay. And if you turn to page Bates

24 number 129 of Exhibit 25. That's where the

25 manager -- manager evaluation begins. Correct?

Page 16

 1 A. Correct.

 2 Q. And in all of the categories in that

 3 section, the manager rating is "meets expectations";

 4 is that correct?

 5 A. That is correct.

 6 Q. And if you turn to the last page of the

 7 document, Bates number G & K 132.

 8 THE REPORTER: Mr. Briscoe, you're moving

 9 your paper, I think, somewhere near the microphone

10 and it's causing a little bit of ruckus.

11 THE WITNESS: We'll move it. Thank you.

12 THE REPORTER: You bet.

13 THE WITNESS: Okay. I'm on page 132.

14 BY MR. MILLS: 

15 Q. Okay. At the very top of the page, there's

16 a section called manager comments. Do you see that?

17 A. I do.

18 Q. Okay. And I'm just going to read it.

19 it -- it says, "Brandy, you're very strong when it

20 comes to your understanding of HR issues, and the

21 legal aspects that are often overlooked by line

22 managers. You're a strong addition to our team and

23 you can help develop the managers in this business

24 become better in their roles as leaders. Your work

25 on helping drive our pipelines has been critical and

Page 17

 1 will be an important aspect in helping us drive

 2 strong business performance. Continue to drive these

 3 efforts." Did I read that correctly?

 4 A. You did.

 5 Q. And are these comments, comments that you

 6 wrote?

 7 MS. PARKER: We actually couldn't quite

 8 hear that last word.

 9 BY MR. MILLS: 

10 Q. Oh. Are these comments --

11 MS. PARKER: Could you read back the

12 question?

13 MR. MILLS: Sure.

14 Q. The manager comments on page Bates numbered

15 132, are those comments that you made, or that you

16 wrote?

17 A. These are my comments.

18 Q. Okay. Could you describe for me your

19 relationship with Brandy Williams?

20 MS. PARKER: Objection; form.

21 You can answer.

22 THE WITNESS: She was my employee.

23 BY MR. MILLS: 

24 Q. Were you friendly with her?

25 MS. PARKER: Objection; form.

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Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 18

 1 THE WITNESS: Friendly, as any other

 2 employee, no relationship or engagement outside of

 3 the office.

 4 BY MR. MILLS: 

 5 Q. Okay. Have you spoken with Brandy since

 6 she left G & K?

 7 A. No.

 8 Q. During the time that you were her direct

 9 supervisor, did you consider to -- her to be a

10 competent employee?

11 MS. PARKER: Objection; form. Not limited

12 as to time or --

13 THE WITNESS: She was brand new in her

14 role. She was learning in our organization. I felt

15 like, as noted in her midyear review, that she was

16 coming along and had things to offer to my team that

17 they needed.

18 BY MR. MILLS: 

19 Q. Okay. During the time that you were her

20 direct supervisor, did you voice any criticisms or

21 complaints to Brandy, about her job performance?

22 A. Yes. There were a few instances where we

23 had issues that I was not pleased with the way she

24 was conducting business.

25 Q. And what were those?

Page 19

 1 A. An example would be her talking to plant

 2 employees and bringing them into her office during

 3 working hours as a group, and allowing them to, in a

 4 group setting, complain about things they didn't like

 5 in the business. Which in my opinion was not

 6 productive and not the proper way for an

 7 HR professional to conduct themselves.

 8 Q. And did you -- did you tell Brandy that you

 9 didn't think that that was appropriate?

10 A. I did.

11 Q. And did she stop doing that after you

12 talked to her?

13 A. She did not stop doing that after I talked

14 to her.

15 Q. Okay. And -- and how frequently did it

16 happen after that?

17 A. A few times, not -- not -- not on a

18 frequent basis.

19 Q. Less than five?

20 A. I believe less than five, yes.

21 Q. Any other things that you -- that you

22 voiced a criticism or complaint to Brandy Williams

23 about while you were her direct supervisor?

24 A. Yes. Her -- her behavior as an HR -- after

25 a period of time that she felt comfortable, she

Page 20

 1 started taking on the role of an HR auditor or an

 2 HR cop versus an HR partner, business partner,

 3 someone there to help. So she was not engaged in

 4 what I considered productive behavior.

 5 Q. What do you mean by "HR auditor" or

 6 "HR cop"?

 7 A. She was looking for things to get my

 8 managers in trouble or to share with Rachel, who she

 9 had a dotted line reporting to at that point, that

10 she felt weren't the proper way to run the business.

11 Q. At what -- at what point in time did that

12 start?

13 MS. PARKER: Objection; form.

14 THE WITNESS: I would imagine it was

15 sometime after this midyear performance review is

16 when that behavior started to really become an issue.

17 BY MR. MILLS: 

18 Q. Was it after the restructuring of the HR

19 department?

20 MS. PARKER: Objection; form.

21 THE WITNESS: I don't believe it started

22 after that. I think after that it was more

23 pronounced.

24 BY MR. MILLS: 

25 Q. Did Brandy at some point involve herself in

Page 21

 1 or attempt to involve herself in the finances or

 2 bookkeeping of the business in Phoenix?

 3 MS. PARKER: Objection; form.

 4 THE WITNESS: She did not personally

 5 involve herself. That was an objective that was

 6 given to her by Rachel as an opportunity to

 7 understand the business at a greater level, and so I

 8 provided opportunities for her to understand the P&L

 9 and the implications of the financials, and more

10 broadly understand the business than she previously

11 did.

12 BY MR. MILLS: 

13 Q. Okay. When you testified a few minutes ago

14 that you thought Brandy was looking for things to get

15 your managers in trouble, could you be a bit more

16 specific for me and give me some examples of that?

17 MS. PARKER: Objection; form.

18 THE WITNESS: I didn't testify a few months

19 ago, so I don't understand the question.

20 BY MR. MILLS: 

21 Q. A few minutes ago, I'm sorry.

22 A. Okay. All right. Thank you for the

23 clarification. She was -- she spent time with my

24 service team, and complained about the communication

25 that my managers had with their employees. She also

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Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 22

 1 complained about the communication that my plant

 2 management had with their employees.

 3 Q. And what, specifically, were her

 4 complaints?

 5 A. That they weren't positive enough.

 6 Q. Did you ever tell Brandy that you thought

 7 that that behavior wasn't appropriate?

 8 MS. PARKER: Objection; form.

 9 THE WITNESS: We had many conversations

10 about her interactions with my direct supervise --

11 direct reports.

12 BY MR. MILLS: 

13 Q. And during those conversations or

14 communications, did you say anything to her about her

15 interaction with the managers or employees that you

16 just described?

17 A. I did. I -- I explained to her that her

18 role was to be a business partner and not to try and

19 tell them how to do their jobs. So in order for her

20 to be successful, she needed to find productive ways

21 to help them with their jobs, not -- not come in on

22 the back side and explain what they should have done

23 differently.

24 Q. When did those conversations occur?

25 MS. PARKER: Objection; form.

Page 23

 1 THE WITNESS: I had weekly one-on-ones with

 2 all of my employees and it would have occurred mostly

 3 in those meetings.

 4 BY MR. MILLS: 

 5 Q. Would those conversations have occurred

 6 after Brandy became -- or strike that.

 7 Would those conversations have occurred

 8 when Brandy was no longer under your direct

 9 supervision?

10 MS. PARKER: Objection; form.

11 THE WITNESS: No, after she didn't report

12 to me anymore and reported to Rachel, I would have

13 shared my concerns with Rachel directly and Rachel

14 would have had those conversations.

15 BY MR. MILLS: 

16 Q. Do you know what Brandy's job title was

17 during -- or strike that.

18 Do you know what Brandy's job title was

19 during the time she was under your direct

20 supervision?

21 A. I don't recall.

22 Q. Do you recall that her title was an HR

23 representative?

24 A. That does sound correct.

25 Q. And then at some point after the

Page 24

 1 reorganization, her title became an HR generalist?

 2 MS. PARKER: Objection; foundation.

 3 THE WITNESS: That sounds correct.

 4 BY MR. MILLS: 

 5 Q. There were certain things that -- that the

 6 HR representatives, including Brandy did, that the HR

 7 generalists did not do; is that correct?

 8 MS. PARKER: Objection; foundation.

 9 THE WITNESS: Yes, as I mentioned, they

10 broke up the responsibilities of the various

11 HR individuals and specialized their functions.

12 BY MR. MILLS: 

13 Q. The HR representatives handled payroll and

14 benefits. Right?

15 A. Correct.

16 Q. Okay. And after the -- after the

17 reorganization, the HR representatives no longer

18 handled that. Right?

19 A. Those responsibilities primarily moved to

20 corporate employees and the managers individually.

21 Q. Okay. Did that create more work for you

22 after the reorganization of the HR department?

23 A. It did.

24 Q. And were you unhappy with that?

25 A. I wasn't unhappy with it, other than it

Page 25

 1 took us away from focusing on more important things,

 2 so --

 3 Q. Did you -- okay. Go ahead.

 4 A. So I don't think that's a fair -- fair

 5 characterization. I didn't -- I didn't like it. I

 6 wouldn't say I was not happy with it.

 7 Q. Did you ever voice to anyone at G & K that

 8 you were not pleased that you -- you were having to

 9 take on more responsibilities after this

10 reorganization in the HR department?

11 MS. PARKER: Objection; form,

12 mischaracterizes prior testimony.

13 You can answer.

14 THE WITNESS: I did.

15 BY MR. MILLS: 

16 Q. And to whom did you voice that?

17 A. Primarily to my direct supervisor Eric

18 McNaul, and also Rachel Siggerud.

19 Q. And what, if anything, did they say to you

20 in response to that?

21 MS. PARKER: Objection; form.

22 THE WITNESS: I don't recall the specific

23 comments, other than just generally, you know, we --

24 we understood it was change and we just didn't like

25 the change.

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Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 26

 1 BY MR. MILLS: 

 2 Q. And I take it, then, that after Brandy was

 3 no longer under your direct supervision, you no

 4 longer did her performance reviews?

 5 A. I did not do her performance reviews after

 6 that.

 7 Q. To your knowledge, did you have any input

 8 in her performance review after -- after she left

 9 your direct supervision?

10 MS. PARKER: Objection; form, foundation.

11 THE WITNESS: In my role as a general

12 manager, my input on all of the regional staff was

13 generally taken by whichever manager they reported

14 to, because they were support structure or support

15 staff for each location.

16 BY MR. MILLS: 

17 Q. Do you know who was doing her performance

18 reviews after she left your direct supervision?

19 A. It should have been Rachel Siggerud. I'm

20 assuming that's who it was.

21 Q. What complaints or criticisms of Brandy

22 Williams' work performance did you voice to Rachel

23 Siggerud?

24 MS. PARKER: Objection; form.

25 THE WITNESS: Shortly after the transition

Page 27

 1 to the new role, Brandy began to disengage from the

 2 business, and was not quite as available as I would

 3 have liked to have seen on multiple occasions.

 4 BY MR. MILLS: 

 5 Q. Now, when you say that Brandy began to

 6 disengage, do you mean that she was not physically

 7 present at times?

 8 MS. PARKER: Objection; form.

 9 THE WITNESS: No, she -- she was not

10 responsive. She would not respond to messages or

11 e-mails in a timely manner. Requests from myself or

12 my staff.

13 BY MR. MILLS: 

14 Q. Did you complain -- did you ever complain

15 to Rachel that Brandy was missing work?

16 MS. PARKER: Objection; form.

17 THE WITNESS: Not that she was missing

18 work, but that she was not -- not making herself

19 available.

20 BY MR. MILLS: 

21 Q. Did you ever complain to Rachel that Brandy

22 was late to work or -- or leaving work early?

23 A. The only time I remember having an issue

24 with her being late to work is when she was late to

25 one of my meetings.

Page 28

 1 Q. And that was just one time?

 2 A. That's the only specific time that I

 3 remember.

 4 Q. At some point did you move Brandy's office

 5 at the Phoenix location?

 6 MS. PARKER: Objection; form.

 7 THE WITNESS: At one point we did move her

 8 office back to the office that the previous HR

 9 individual had used, which was in an office up in the

10 area by my office.

11 BY MR. MILLS: 

12 Q. Okay. And is that in a location that's

13 more remote from the other employees of G & K?

14 MS. PARKER: Objection; form.

15 THE WITNESS: No, actually, that office is

16 in the center of the building, so it's more central

17 to the entire operation.

18 BY MR. MILLS: 

19 Q. Were you aware of Brandy Williams taking

20 time off work to attend medical appointments?

21 MS. PARKER: Objection; form.

22 THE WITNESS: I'm sure at some point she

23 had medical appointments that she went to that I

24 would have been aware of.

25 BY MR. MILLS: 

Page 29

 1 Q. Did she tell you that she was attending

 2 medical appointments?

 3 A. I'm sure she did.

 4 Q. Were you aware that Brandy had a medical

 5 condition?

 6 MS. PARKER: Objection; form.

 7 THE WITNESS: Not a specific condition that

 8 I'm aware of, no.

 9 BY MR. MILLS: 

10 Q. What, if anything, did you know about her

11 medical condition?

12 MS. PARKER: Objection; form.

13 THE WITNESS: Just that she had doctors'

14 appointments, like pretty much everybody else does.

15 BY MR. MILLS: 

16 Q. Other than, as you described it, Brandy

17 beginning to disengage, as you put it, what other

18 criticisms or complaints about Brandy did you voice

19 to Rachel Siggerud?

20 A. Nothing different than the previous

21 conversations I'd had with Brandy, similar

22 conversations I had with Rachel, about her engagement

23 with my team, and not really being a productive

24 teammate with my direct reports.

25 Q. Were there any other -- to the best of your

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Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 30

 1 knowledge, were there any other types of complaints

 2 or criticisms of Brandy that you voiced to Rachel

 3 Siggerud?

 4 MS. PARKER: Objection; form.

 5 Go ahead.

 6 THE WITNESS: Yeah, the -- the -- the

 7 biggest one that I remember, and as I mention this

 8 has been a while, so almost a lifetime ago, we had a

 9 meeting where I brought together my sales management,

10 my service management, my plant management, my office

11 manager, and I invited Brandy to come in for that

12 meeting also, to discuss the on-boarding of our sales

13 and service teams and ways that we can improve that

14 process. We had a significant amount of new sales

15 reps that we were on-boarding. Which obviously

16 brings with it challenges as you on-board new

17 employees. And the service team was going through a

18 significant amount of turnover also.

19 As I mentioned, Brandy came late to that

20 meeting, and we were already mid-conversation, and

21 she immediately jumped into the conversation and

22 began to argue with my service manager, as I recall,

23 about what he was doing wrong in his department. And

24 that the conversation went south pretty fast. She

25 was -- she was pretty hot, and she eventually walked

Page 31

 1 out of the room. Actually, slammed the door where it

 2 reverberated through the office, and never came back

 3 to that meeting. So I did talk to Rachel about that

 4 specific incident.

 5 BY MR. MILLS: 

 6 Q. Who was the service manager?

 7 A. Mitch Rubinoff, which isn't his legal name.

 8 His first name's Herbert, but -- since it's a record,

 9 I thought I'd mention that.

10 Q. Any other types of -- of criticisms or

11 complaints of Brandy that you would have voiced to

12 Rachel Siggerud?

13 A. Not that I recall.

14 Q. Did you -- did you voice any complaints or

15 criticisms of Brandy to anybody at G & K, other than

16 Rachel or Brandy herself?

17 A. No. No.

18 Q. Did you ever prepare a -- a written

19 complaint or a written criticism of Brandy's job

20 performance?

21 MS. PARKER: Objection; form.

22 THE WITNESS: The answer to that is no.

23 When she was still working directly for me, I wasn't

24 to the point where I felt we were at that point. So

25 no, I did not.

Page 32

 1 BY MR. MILLS: 

 2 Q. Did you ever at any point after she was --

 3 after she left your direct supervision prepare any

 4 sort of written complaint or criticism regarding her

 5 job performance?

 6 MS. PARKER: Same objection.

 7 THE WITNESS: Not that I recall.

 8 BY MR. MILLS: 

 9 Q. Did you ever prepare any -- anything in

10 writing criticizing her for missing time from work?

11 MS. PARKER: Objection; form.

12 THE WITNESS: That's possible. I don't

13 recall.

14 BY MR. MILLS: 

15 Q. Okay. Did G & K have procedures for --

16 that you could have utilized -- strike that.

17 Did G & K have procedures in place that you

18 could have utilized to complain about Brandy missing

19 time from work?

20 MS. PARKER: Objection; form, foundation.

21 THE WITNESS: I don't recall a procedure.

22 BY MR. MILLS: 

23 Q. Did you ever prepare anything with respect

24 to any other employees missing time from work?

25 MS. PARKER: Objection; form.

Page 33

 1 THE WITNESS: We -- we did have a document

 2 that we used for our line employees that we would

 3 track attendance on, but we typically did not track

 4 attendance like that for salaried management.

 5 BY MR. MILLS: 

 6 Q. Okay.

 7 A. I never did.

 8 Q. Was -- did -- did G & K have any sort of

 9 form or a procedure that -- that you could utilize

10 to -- to document a complaint about an employee with

11 respect to their job performance?

12 MS. PARKER: Objection; form, foundation.

13 THE WITNESS: Yes, we had performance

14 improvement-type documentation. I don't recall the

15 exact terminology that G & K uses, but there was

16 forms.

17 BY MR. MILLS: 

18 Q. Did you ever prepare any sort of

19 performance improvement documentation with respect to

20 Brandy Williams?

21 A. No.

22 Q. Okay. Did you ever request that anybody

23 else do that?

24 A. No.

25 Q. After the restructuring of the HR

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Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 34

 1 department, were there other responsibilities that --

 2 that you had to take on that had previously been

 3 responsibilities of the HR representative?

 4 A. During the initial transition, I took on

 5 the E-Verify process, because I had a new office

 6 manager starting and we needed to get her enrolled in

 7 that program, and I'd previously had access to that.

 8 Q. Anything else?

 9 A. No, for me specifically, that was the only

10 thing that I really got bogged down in.

11 Q. Did you ever tell Brandy that you didn't

12 know what her -- her job was as an HR generalist?

13 MS. PARKER: Objection; form.

14 THE WITNESS: I don't recall using that

15 wording at all. But there was confusion about the

16 new jobs when that started, and so that was a

17 conversation of exactly what their responsibilities

18 were and what they should be focused on.

19 BY MR. MILLS: 

20 Q. And -- and --

21 A. So there was some --

22 Q. I'm sorry. Go ahead.

23 A. There was some ambig -- ambiguity in what

24 that role was.

25 Q. And you were -- you were confused as well

Page 35

 1 as to what the new role was for the HR generalist.

 2 Correct?

 3 MS. PARKER: Objection; form.

 4 THE WITNESS: Yeah, it was not a clearly

 5 defined role, at least from my visibility.

 6 BY MR. MILLS: 

 7 Q. Did anybody at G & K ever explain to you,

 8 or attempt to explain to you, what the role of an HR

 9 generalist was going to be going forward?

10 MS. PARKER: Objection; form.

11 THE WITNESS: The answer is yes, it was --

12 it was a topic of discussion multiple times.

13 BY MR. MILLS: 

14 Q. Okay.

15 A. And I think that got burned up over time,

16 but initially it was not very clear.

17 Q. And who had those conversations with you?

18 A. I had conversations with Rachel, but it was

19 also a topic of discussion in some of our general

20 manager meetings, and things like that, both at the

21 regional and corporate level.

22 Q. Do you ever remember seeing a written job

23 description for an HR generalist?

24 A. I don't recall ever seeing one, but

25 G & K has very specified job descriptions for every

Page 36

 1 role that I've ever hired for, so I'm sure it exists.

 2 Q. Were you ever asked to provide any input as

 3 to what the job responsibilities of an HR generalist

 4 should be?

 5 A. No.

 6 Q. Did you ever volunteer any input as to what

 7 you thought the job responsibilities of an HR

 8 generalist should be?

 9 A. No.

10 Q. Did you ever express to Rachel Siggerud,

11 that you were -- you were confused about what the

12 role of an HR generalist was supposed to be?

13 A. Yes.

14 Q. And what -- what did she say to you?

15 A. She then tried to explain it to me the best

16 that she could, based on her information. I don't

17 remember the specific conversation, but I know we had

18 the conversation.

19 Q. Did Rachel tell you that there were other

20 managers who were confused as well?

21 MS. PARKER: Objection; form.

22 THE WITNESS: I do not remember Rachel

23 saying that.

24 BY MR. MILLS: 

25 Q. And can you tell me just in -- in -- in

Page 37

 1 very general terms as best you can, how the role of

 2 an HR generalist differed from that of an HR

 3 representative?

 4 A. The primary difference is basically doing

 5 away with the administrative functions and not really

 6 focusing on the recruiting functions that the HR

 7 representative had previously helped us with, and so

 8 it was focused on employee development plans,

 9 performance improvement plans, that kind of thing.

10 Really looking at the broader picture versus getting

11 into some of the administrative stuff.

12 Q. Were you --

13 A. Such as payroll.

14 Q. Okay. Were you in favor of that change?

15 MS. PARKER: Objection; form.

16 THE WITNESS: I -- I don't know that I was

17 in favor or disenfavored [sic] with it. At the end

18 of the day, it didn't really matter. As long as the

19 function lived somewhere, I -- I don't really care.

20 BY MR. MILLS: 

21 Q. Did you prefer it when you had an HR

22 representative as opposed to an HR generalist?

23 MS. PARKER: Objection; form.

24 MR. MILLS: Let me -- let me rephrase --

25 THE WITNESS: As a general manager?

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 297 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 38

 1 BY MR. MILLS: 

 2 Q. Yeah. Let me rephrase the question.

 3 Did you prefer having an HR representative

 4 as opposed to an HR generalist?

 5 A. Yeah, as a general manager, of course, I

 6 want all my people to report directly to me and have

 7 complete control over that. So --

 8 Q. All right. Did it become more difficult

 9 after Brandy became an HR generalist, in that you

10 would have to communicate with her -- with a

11 different supervisor, Rachel Sig -- Siggerud?

12 A. No, because I'd always talked with Rachel,

13 too, in her previous role she was over the region

14 anyway, so that communication did not change.

15 Q. Did you ever meet Rachel Siggerud,

16 personally?

17 A. Yes, she was in our business on a regular

18 basis.

19 Q. How many times did she get to Phoenix while

20 you were there?

21 A. Oh --

22 MS. PARKER: Objection; form.

23 THE WITNESS: There was a period of time

24 where she was probably in the business almost

25 monthly, if not every other month.

Page 39

 1 BY MR. MILLS: 

 2 Q. How was your relationship with Eric McNaul?

 3 MS. PARKER: Objection; form.

 4 THE WITNESS: She was his employee and they

 5 traveled together on a regular basis.

 6 BY MR. MILLS: 

 7 Q. Was Eric McNaul your direct supervisor?

 8 A. Yes.

 9 Q. And how did you get along with him?

10 A. Fine.

11 Q. How frequently would Eric McNaul come to

12 the Phoenix location?

13 A. Typically, on a monthly basis.

14 Q. Did you tell Brandy Williams that you

15 didn't think HR brought any value to the business?

16 A. No.

17 Q. Did you ever express that to anybody at --

18 at G & K?

19 A. No, that's --

20 Q. Did you ever express to anybody at

21 G & K that you didn't -- you didn't -- you didn't

22 understand what value HR added to the -- to the

23 business?

24 MS. PARKER: Objection; form.

25 THE WITNESS: The answer to that is no.

Page 40

 1 MS. PARKER: Can we take a quick break?

 2 MR. MILLS: Sure.

 3 MS. PARKER: I -- thank you.

 4 MR. MILLS: What, like 5, 10 minutes?

 5 MS. PARKER: Yeah.

 6 (Recessed from 9:53 a.m. until 10:02 a.m.)

 7 BY MR. MILLS: 

 8 Q. Okay. Mr. Briscoe, from your perspective,

 9 what was Brandy's relationship with Mitch Rubinoff?

10 MS. PARKER: Objection; foundation.

11 You can answer.

12 THE WITNESS: I don't think they liked each

13 other.

14 BY MR. MILLS: 

15 Q. Okay. Was it a -- was it a personality

16 conflict or how would you describe it?

17 A. I would describe it as Mitch not

18 appreciating her support or her lack of support in

19 his department. Meaning that he didn't like the way

20 she engaged with him and his managers.

21 Q. Okay. And do you know whether Mitch --

22 Mitch ever told Brandy that?

23 A. I don't know that he did or didn't.

24 Q. Did you ever talk to Brandy about that,

25 specifically?

Page 41

 1 A. Bas -- basically, the exact same comments

 2 that you and I have already discussed, yes.

 3 Q. Okay. Do you know whether Mitch is still

 4 at G & K?

 5 A. He is not.

 6 Q. When did he leave, if you know?

 7 A. About a year before I left, approximately.

 8 Q. And did he leave voluntarily or was he

 9 terminated?

10 A. Voluntarily.

11 Q. Do you know where he's at now?

12 A. I believe he -- he's in California, and I

13 believe he works for Specialty Linen, or something

14 like that. He works for a different company in

15 California.

16 Q. Were you aware that Brandy Williams -- let

17 me -- let me rephrase the question. During the time

18 that you were at G & K, were you aware that Brandy

19 Williams had made a request for accommodation under

20 the Americans with Disabilities Act?

21 A. No.

22 Q. Are you aware of that now?

23 MS. PARKER: Objection to form, to the

24 extent it calls for a legal conclusion.

25 THE WITNESS: Based on the comment you just

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 298 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 42

 1 made, I'm -- I'm assuming that happened.

 2 BY MR. MILLS: 

 3 Q. I was just wondering if you know about it

 4 from any source, other than from me or from your

 5 counsel?

 6 MS. PARKER: You're breaking up a little

 7 bit, Bob. I'm not sure what we can do about it.

 8 MR. MILLS: It's fine on this end, so I'm

 9 not really --

10 MS. PARKER: And it's not a lot here, but

11 it's every so often just one word goes blank. So I

12 guess I can't really tell you anything except we may

13 just say, hey, can you read that back. So let's have

14 the court reporter read that question back.

15 (Record read.)

16 MS. PARKER: And so you -- I'll just note

17 for the record you specifically excluded

18 conversations with counsel.

19 MR. MILLS: Yes. Yes.

20 MS. PARKER: Just so you understand,

21 Mr. Briscoe, he's asking if you -- he's not asking

22 about any conversations that you and I have had or

23 you and any other attorneys have had. So did you

24 have any prior knowledge of this?

25 THE WITNESS: No, I didn't have any prior

Page 43

 1 knowledge.

 2 BY MR. MILLS: 

 3 Q. Okay. And by the way, is Ms. Parker

 4 representing you as your counsel today?

 5 A. Yes.

 6 Q. Now, you're aware that -- that Brandy

 7 Williams' employment with G & K was terminated?

 8 A. Yes.

 9 Q. And that was in September of 2013?

10 A. I believe so.

11 Q. Did you play any role in the decision to --

12 to terminate Brandy Williams' employment?

13 MS. PARKER: Objection to form.

14 THE WITNESS: I was not aware that she was

15 leaving until the announcement was made.

16 BY MR. MILLS: 

17 Q. Were you present when the announcement was

18 made or -- that was a bad question. Let me rephrase

19 that.

20 Were you there in the Phoenix location

21 when Brandy was told that she was being terminated?

22 A. I don't remember if I was in the building

23 that day or not, but I was in Phoenix as an employee

24 at that point.

25 Q. Did you say anything to Brandy Williams

Page 44

 1 after you learned that her employment was being

 2 terminated?

 3 A. I don't even recall talking to her after

 4 she was terminated.

 5 Q. Do you know when the decision was made to

 6 terminate Brandy Williams' employment with G & K?

 7 MS. PARKER: Objection; foundation, and

 8 asked and answered.

 9 THE WITNESS: I don't.

10 BY MR. MILLS: 

11 Q. Did anybody ever tell you that a decision

12 had been made in June 2013 to eliminate Brandy

13 Williams' position at G & K?

14 MS. PARKER: Objection; foundation. And

15 Mr. Briscoe has already testified that he doesn't

16 know about the termination decision.

17 But you can go ahead.

18 THE WITNESS: No.

19 BY MR. MILLS: 

20 Q. Did anybody tell you that a decision had

21 been made in June to terminate Brandy Williams'

22 employment, in particular?

23 A. No.

24 MS. PARKER: Same objections.

25 BY MR. MILLS: 

Page 45

 1 Q. Is that something that you would have

 2 expected someone at G & K to have told you if that

 3 decision had been made in June 2013?

 4 A. No.

 5 MS. PARKER: Objection; form.

 6 BY MR. MILLS: 

 7 Q. That's something you would have wanted to

 8 know as the general manager at the Phoenix location?

 9 MS. PARKER: Objection; form.

10 THE WITNESS: No, she was not my employee,

11 so that's not something I would have been involved

12 with directly.

13 BY MR. MILLS: 

14 Q. Did anybody at G & K ever ask you whether

15 you thought that Brandy should be let go?

16 MS. PARKER: Objection; form. Asked and

17 answered.

18 THE WITNESS: The answer is no.

19 BY MR. MILLS: 

20 Q. After Brandy Williams left G & K, was she

21 replaced by another HR generalist?

22 MS. PARKER: Objection; foundation, form.

23 THE WITNESS: They did not hire any new

24 employees after that point that I'm aware of.

25 BY MR. MILLS: 

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 299 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 46

 1 Q. Was there an HR generalist at G & K that

 2 you worked with after Brandy had left the company?

 3 A. Yes, her -- yes, her -- her

 4 responsibilities were transferred to another

 5 individual with the same title.

 6 Q. And who was that?

 7 A. I don't recall her name. She worked in

 8 California.

 9 Q. Does "Janelle" sound familiar?

10 A. Yes.

11 Q. Did you ever meet Janelle?

12 A. I've traveled to the Sacramento location

13 where she worked, and I'm sure I met her, but not in

14 Phoenix.

15 Q. To your knowledge, did -- did Janelle ever

16 come to the Phoenix location of G & K?

17 A. No. No.

18 Q. To your knowledge, did Janelle go to any of

19 the other Arizona locations of G & K?

20 MS. PARKER: Objection; foundation.

21 BY MR. MILLS: 

22 Q. Whether it be Tucson or Prescott or Yuma?

23 A. Not to my knowledge.

24 Q. Did you find Janelle to be accessible as an

25 HR generalist?

Page 47

 1 MS. PARKER: Objection; form

 2 THE WITNESS: I don't recall any issues

 3 with Janelle.

 4 BY MR. MILLS: 

 5 Q. Do you recall ever trying to contact

 6 Janelle?

 7 A. I'm sure I sent her e-mails and asked for

 8 information, but I don't recall any specifics.

 9 Q. How frequently would you do that?

10 A. As frequently as needed. I don't recall.

11 Q. Was it more frequently than once a month?

12 A. Probably not.

13 Q. Okay. When you were working with Brandy

14 Williams at the Phoenix location, would you

15 communicate with her every day?

16 A. I would communicate probably on a daily

17 basis, at least verbally, if nothing more than a

18 greeting and a good morning, but --

19 Q. Did anybody from the Phoenix location,

20 other than yourself, ever communicate with -- with

21 Janelle after she became the HR generalist?

22 MS. PARKER: Objection; form, foundation.

23 BY MR. MILLS: 

24 Q. To your knowledge?

25 A. That information would have been given to

Page 48

 1 all the department heads and they would have had

 2 access directly to Janelle.

 3 Q. Was there a period of time when you were at

 4 G & K when Janelle stopped serving as the HR

 5 generalist, for the Northwest Region?

 6 A. Not that I recall.

 7 Q. Did you ever express to Janelle any

 8 complaints or criticisms regarding her job

 9 performance as an HR generalist?

10 A. No.

11 Q. Did you ever voice to Rachel Siggerud any

12 complaints or criticisms about Janelle in her role as

13 an HR generalist?

14 MS. PARKER: Objection; form.

15 THE WITNESS: Not that I recall, no.

16 BY MR. MILLS: 

17 Q. And for how long was Janelle serving as an

18 HR generalist while you were the general manager in

19 Phoenix?

20 MS. PARKER: Objection; form, foundation.

21 THE WITNESS: I don't recall the specific

22 dates.

23 BY MR. MILLS: 

24 Q. Was Janelle -- was Janelle the HR

25 generalist at the time that you left G & K?

Page 49

 1 MS. PARKER: Objection; form, foundation.

 2 THE WITNESS: I believe so.

 3 BY MR. MILLS: 

 4 Q. And --

 5 MS. PARKER: Can we take just a brief --

 6 can we just take a brief break?

 7 MR. MILLS: Sure.

 8 (Recessed from 10:15 a.m. until 10:22 a.m.)

 9 THE WITNESS: Can I clarify one thing?

10 MR. MILLS: Sure. Go ahead.

11 THE WITNESS: Primarily, after Brandy left,

12 I dealt directly with Rachel --

13 BY MR. MILLS: 

14 Q. Okay.

15 A. -- for all HR matters, at least at my desk.

16 Q. Do you know whether there was an HR

17 generalist assigned to the Phoenix location?

18 MS. PARKER: Objection; relevance.

19 You can go ahead.

20 THE WITNESS: Yes, there -- I'm sure there

21 was. As I mentioned earlier, I can't recall the

22 name.

23 BY MR. MILLS: 

24 Q. And that -- and that would have been

25 Janelle?

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 300 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 50

 1 MS. PARKER: Objection; relevance,

 2 mischaracterizes prior testimony. He just said he

 3 couldn't recall.

 4 BY MR. MILLS: 

 5 Q. Well, we've been talking about Janelle for

 6 a while, so is it your recollection that Janelle was

 7 the -- the HR generalist that was assigned to

 8 Phoenix, after Brandy left?

 9 MS. PARKER: Objection; foundation.

10 You can answer to the best of your

11 recollection.

12 THE WITNESS: As I said, I didn't recall

13 the name, and you mentioned Janelle. So I remember

14 Janelle being one of the HR generalists.

15 BY MR. MILLS: 

16 Q. Do you remember --

17 A. Yeah.

18 Q. -- that the HR generalist that was assigned

19 to Phoenix was located in California?

20 MS. PARKER: Objection; relevance,

21 foundation.

22 THE WITNESS: So, so -- so over -- over

23 that period of time, of the two years that we're

24 talking about right now, I dealt with Brandy mostly

25 in my location. I dealt with -- oh, I just went

Page 51

 1 blank -- of the HR generalists out of St. Paul,

 2 Minneapolis probably just as much as Brandy, and then

 3 Janelle at some point, potentially, but -- but

 4 primarily after -- after Brandy left, I dealt

 5 directly with Rachel, until she left the company.

 6 Oh, the HR generalist in St. Paul was Kayla.

 7 BY MR. MILLS: 

 8 Q. And when you say that you dealt primarily

 9 with -- with Rachel, what do you mean by that?

10 A. I would call her and work through her, and

11 then she would direct me to whoever she wanted to

12 deal with, whatever issue we were working on.

13 Q. Would she refer you to an HR generalist?

14 A. Typically one of the generalists, Kayla was

15 often the generalist that I dealt with.

16 Q. How frequently did you speak with Kayla?

17 MS. PARKER: Objection; relevance.

18 Go ahead.

19 THE WITNESS: Over the years I've talked to

20 Kayla a lot. So I don't know if it was every other

21 month or what, but -- and I communicated with Kayla

22 quite a bit.

23 BY MR. MILLS: 

24 Q. So you're thinking maybe every other month

25 you would communicate with Kayla?

Page 52

 1 A. Potentially, yes.

 2 Q. And not more frequently than that?

 3 MS. PARKER: Object; relevance.

 4 THE WITNESS: Occasionally, it could have

 5 been more frequently than that, depending on what was

 6 going on in the business.

 7 BY MR. MILLS: 

 8 Q. How frequently did you communicate with

 9 Rachel?

10 MS. PARKER: Objection; relevance.

11 Sorry, go ahead.

12 THE WITNESS: Several times a month.

13 BY MR. MILLS: 

14 Q. Was that before or after Brandy left?

15 MS. PARKER: Objection; form, relevance.

16 You can go ahead.

17 THE WITNESS: Before and after. It was on

18 a pretty consistent basis a couple of times a month.

19 BY MR. MILLS: 

20 Q. Were you aware at some point that Janelle

21 went on maternity leave?

22 MS. PARKER: Objection; relevance.

23 Go ahead.

24 THE WITNESS: No.

25 BY MR. MILLS: 

Page 53

 1 Q. And do you recall the date when you left

 2 G & K?

 3 A. Yes, it was in September of 2014.

 4 Q. So that would have been about a year after

 5 Brandy was let go?

 6 A. That -- that sounds correct.

 7 Q. Did you leave voluntarily?

 8 A. I had a separation agreement, so yes, I

 9 left voluntarily.

10 Q. G & K didn't -- did anybody at G & K tell

11 you that you needed to leave?

12 A. We discussed it, and we agreed to part

13 ways.

14 Q. And with whom did you discuss parting ways?

15 A. Eric McNaul.

16 Q. And did he tell you that you were no longer

17 going to be employed by G & K?

18 A. He did not use that -- that phrase, no.

19 Q. But was it clear to you that that's what

20 was happening?

21 A. Yes.

22 Q. Do you know why you were being let go from

23 G & K?

24 A. I do.

25 Q. And what was that?

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 301 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 54

 1 A. Primarily, the -- the financial aspects of

 2 the business, the previous few months were not very

 3 good. And I had an employee contact, actually, the

 4 CEO of the company, and make a complaint. HR came in

 5 and did an investigation, and ultimately, the

 6 allegation that was raised was shown not to be true,

 7 but at that point, they decided to let me go, based

 8 on a comment I'd made several months before that.

 9 Q. And what was that comment?

10 MS. PARKER: Objection; relevance.

11 You can go ahead.

12 THE WITNESS: I had an employee call HR and

13 I made a comment to one of my managers about putting

14 the name of employees on a wheel that we had for

15 safety bonuses and said we'd spin the wheel to decide

16 who was going to be let go next.

17 BY MR. MILLS: 

18 Q. And that didn't sit well with HR?

19 MS. PARKER: Objection; relevance.

20 Go ahead.

21 THE WITNESS: No, it did not.

22 BY MR. MILLS: 

23 Q. Had you had -- or strike that.

24 Had Eric McNaul ever expressed to you

25 displeasure with the finances at the Phoenix location

Page 55

 1 before?

 2 MS. PARKER: Objection; form, relevance.

 3 Go ahead.

 4 THE WITNESS: Of course he had.

 5 BY MR. MILLS: 

 6 Q. And for -- for how long had that been going

 7 on?

 8 MS. PARKER: Objection; form, relevance.

 9 THE WITNESS: Several months. I don't know

10 exactly how many months. I'd have to go back and

11 look at the financials, but --

12 BY MR. MILLS: 

13 Q. Did you disagree with G & K's decision to

14 let you go?

15 MS. PARKER: Objection; relevance.

16 THE WITNESS: Of course I did.

17 BY MR. MILLS: 

18 Q. Did you ever file a -- an EEOC complaint or

19 a grievance against G & K for letting you go?

20 A. No, I did not.

21 Q. Have you ever sued G & K?

22 A. No.

23 Q. Have you spoken with Eric McNaul since you

24 left G & K?

25 A. I've spoken to him probably three or four

Page 56

 1 times in the last 18 months.

 2 Q. To your understanding, was it -- was it his

 3 decision to let you go, or was it somebody else's?

 4 A. My understanding is it was his decision. I

 5 mean, it could have been the CEO's, for all I know, I

 6 don't know.

 7 Q. What did you talk to him about, when you

 8 talked to him, since you left G & K?

 9 MS. PARKER: Objection; form.

10 Go ahead.

11 THE WITNESS: Yeah, I talked to him about

12 the new jobs that I was interviewing for and where I

13 ended up with my employment.

14 BY MR. MILLS: 

15 Q. Anything else?

16 A. No. Eric grew up in the part of --

17 actually, he was born in the part of the country that

18 I moved to, so that's what we talked about.

19 Q. Did you ever talk to him about Brandy

20 Williams or -- or her litigation against G & K?

21 A. No.

22 Q. Did you ever talk to anybody else at G & K,

23 since you left the company, regarding Brandy Williams

24 or her litigation against the company?

25 MS. PARKER: Objection; form.

Page 57

 1 THE WITNESS: No, the only contact I've had

 2 with G & K was being notified that I was going to be

 3 contact -- contacted by the lawyers about this

 4 deposition.

 5 BY MR. MILLS: 

 6 Q. Okay. What did you do to prepare for the

 7 deposition?

 8 A. I met with my attorney yesterday.

 9 Q. For how long?

10 A. Two and a half hours.

11 Q. Anything else?

12 A. No.

13 Q. Did your separation agreement with

14 G & K contain any type of a provision wherein you

15 agreed that you would not disparage G & K's business?

16 MS. PARKER: Objection; form, relevance.

17 THE WITNESS: I don't recall. I haven't

18 looked at the separation agreement since I signed it.

19 BY MR. MILLS: 

20 Q. Did -- did your separation agreement with

21 G & K contain any sort of a provision that you would

22 cooperate with G & K in any litigation arising from

23 anything in connection with your employment with the

24 company?

25 MS. PARKER: Objection; form, relevance.

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 302 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 58

 1 THE WITNESS: Not that I recall. As I

 2 said, I haven't looked at it since I signed it, so

 3 it -- it may or may not be in there, I don't know.

 4 BY MR. MILLS: 

 5 Q. Did you receive some sort of a -- of a

 6 severance when you were terminated?

 7 MS. PARKER: Objection; form, relevance.

 8 THE WITNESS: The answer is yes.

 9 BY MR. MILLS: 

10 Q. And how much was that?

11 MS. PARKER: Objection; relevance.

12 THE WITNESS: It was the basic severance

13 package for a layoff, which was like 10 weeks, plus

14 accrued vacation. It was essentially three months.

15 BY MR. MILLS: 

16 Q. And what were you making at the time you

17 left G & K?

18 MS. PARKER: Relevance.

19 THE WITNESS: Somewhere in the neighborhood

20 of $130,000, before bonuses.

21 MR. MILLS: I think I'm about done. If you

22 can just give me a minute to look through my notes,

23 and see if there's anything I need to follow up on.

24 (Recessed from 10:34 a.m. until 10:35 a.m.)

25 BY MR. MILLS: 

Page 59

 1 Q. Okay. Mr. Briscoe, are you still there?

 2 A. I am.

 3 Q. Were you ever put on a performance review

 4 program at G & K?

 5 MS. PARKER: Objection; form, relevance.

 6 THE WITNESS: A formal program, no.

 7 BY MR. MILLS: 

 8 Q. Okay. Informal program?

 9 A. Not that I recall.

10 MR. MILLS: Okay. That's all I have.

11 Thank you, sir.

12 MS. PARKER: All right. Bob, I am going to

13 have a couple questions, but just give us a few

14 minutes.

15 MR. MILLS: Okay. Do you want to take a

16 break?

17 MS. PARKER: Yes. Thank you.

18 MR. MILLS: All right.

19 MS. PARKER: 10 minutes.

20 MR. MILLS: Okay.

21 (Recessed from 10:35 a.m. until 10:44 a.m.)

22 MS. PARKER: So I did have some questions

23 for Mr. Briscoe.

24 25 

Page 60

 1 E X A M I N A T I O N

 2 BY MS. PARKER: 

 3 Q. You were asked earlier and testified about

 4 some -- some comments that you made to Rachel

 5 Siggerud regarding Brandy Williams' attendance. Did

 6 any of those comments, with respect to Brandy

 7 Williams' attendance, have to do with her medical

 8 appointments?

 9 A. No.

10 MR. MILLS: Object to the form.

11 BY MS. PARKER: 

12 Q. Did you ever talk to Rachel Siggerud about

13 Brandy Williams' medical appointments?

14 A. No.

15 Q. Did you ever complain to Rachel Siggerud

16 about Brandy Williams' medical appointments?

17 A. No.

18 Q. What was the content of your comments to

19 Rachel Siggerud about Brandy Williams' availability?

20 A. The conversations I had with Rachel were

21 about her -- us knowing when she was at work and when

22 she was not at work, not where -- what she was doing

23 while she wasn't there. I wasn't sure if she was

24 working from home or traveling, and just knowing

25 where she was, so we knew how to get ahold of her

Page 61

 1 when she wasn't responding to us.

 2 Q. Great. And then I wanted to come back to a

 3 question that you were asked earlier about

 4 conversations with others regarding Ms. Williams.

 5 Did you ever have any discussions with Eric McNaul

 6 regarding Brandy Williams' performance?

 7 A. I had conversations with Eric McNaul on a

 8 continuous basis, talking about the business, during

 9 those conversations if I had issues going on with my

10 employees, I would have discussed, generically, what

11 was going on and let him know my concerns.

12 Q. And do you recall if you discussed the same

13 topics with Mr. McNaul that you discussed with Rachel

14 Siggerud?

15 A. Yes, I would have discussed the same

16 issues.

17 Q. All right. And then I just had a couple of

18 questions with respect to job description. In your

19 job at G & K, did you have any responsibility for

20 creating job descriptions?

21 A. No.

22 Q. Do you have any knowledge of G & K's

23 process for creating job descriptions for new

24 positions?

25 A. Not the process, just that it was an

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(15) Pages 58 - 61

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 303 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

Page 62

 1 HR function.

 2 Q. And during your time at G & K, had you

 3 previously hired an employee into a brand-new

 4 position?

 5 A. No.

 6 MS. PARKER: That's all of my questions.

 7 MR. MILLS: Just one question.

 8 9 F U R T H E R E X A M I N A T I O N

10 BY MR. MILLS: 

11 Q. After Brandy became an HR generalist, she

12 was no longer your employee. Right?

13 A. Correct. She was no longer my employee.

14 MR. MILLS: Okay. That's all I have.

15 THE REPORTER: Ms. Parker, could I get your

16 copy order, please.

17 MS. PARKER: Yeah, so -- well, I'll

18 instruct Mr. Briscoe to read and sign. And I know

19 we've been doing that.

20 So you'll -- you'll have the opportunity to

21 review the transcript before it's final.

22 THE WITNESS: Okay.

23 MS. PARKER: And we would just like the

24 same format that we've had for other depositions

25 where we've gotten, I think it's the mini and there's

Page 63

 1 some sort of bundle.

 2 THE REPORTER: Okay.

 3 MS. PARKER: Does that sound right?

 4 THE REPORTER: I -- I can figure that one

 5 out.

 6 MS. PARKER: All right. Same format.

 7 THE REPORTER: Thank you so much.

 8 MR. MILLS: All right. Thank you everyone.

 9 MS. PARKER: Thank you.

10 THE WITNESS: Thank you.

11 (Proceedings concluded at 10:48 a.m.)

12 13 14 15 ___________________________ 16 JACOB SAMUEL BRISCOE

17 18 19 20 21 22 23 24 25 

Page 64

 1 STATE OF ARIZONA ) 

 2 COUNTY OF MARICOPA ) 

 3 BE IT KNOWN the foregoing deposition was 

 4 taken by me pursuant to stipulation of counsel; that I was 

 5 then and there a Certified Reporter of the State of 

 6 Arizona, and by virtue thereof authorized to administer an 

 7 oath; that the witness before testifying was duly sworn by 

 8 me to testify to the whole truth; notice was provided that 

 9 the transcript was available for signature by the 

10 deponent; that the questions propounded by counsel and the 

11 answers of the witness thereto were taken down by me in 

12 shorthand and thereafter transcribed into typewriting 

13 under my direction; that the foregoing pages are a full, 

14 true, and accurate transcript of all proceedings and 

15 testimony had and adduced upon the taking of said 

16 deposition, all to the best of my skill and ability. 

17 I FURTHER CERTIFY that I am in no way related to 

18 nor employed by any parties hereto nor am I in any way 

19 interested in the outcome hereof. 

20 DATED at Phoenix, Arizona, this 29th day of 

21 June, 2016. 

22

 

23 ______________________________ Robin L. B. Osterode, RPR, CSR

24 Certified Reporter No. 50695 

25

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(16) Pages 62 - 64

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 304 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

$

$130,000 (1) 58:20

[

[sic] (1) 37:17

A

access (2) 34:7;48:2

accessible (1) 46:24

accommodation (1)

 41:19

according (1) 14:2

account (1) 7:13

accrued (1) 58:14

Act (1) 41:20

actual (1) 15:7

actually (5) 17:7;28:15;

 31:1;54:3;56:17

added (1) 39:22

addition (1) 16:22

administrative (4) 4:21,

 22;37:5,11

against (3) 55:19;

 56:20,24

ago (5) 11:5;21:13,19,

 21;30:8

agreed (2) 53:12;57:15

agreement (4) 53:8;

 57:13,18,20

ahead (15) 9:9;25:3;

 30:5;34:22;44:17;

 49:10,19;51:18;52:11,

 16,23;54:11,20;55:3;

 56:10

ahold (1) 60:25

allegation (1) 54:6

allowing (1) 19:3

almost (2) 30:8;38:24

along (2) 18:16;39:9

always (1) 38:12

ambig (1) 34:23

ambiguity (1) 34:23

Americans (1) 41:20

amongst (1) 12:3

amount (2) 30:14,18

announcement (2)

 43:15,17

answered (2) 44:8;

 45:17

anymore (1) 23:12

appear (1) 15:9

applied (1) 10:6

appointments (7) 28:20,

 23;29:2,14;60:8,13,16

appreciating (1) 40:18

appropriate (2) 19:9;

 22:7

approximately (4) 6:18,

 25;9:5;41:7

area (1) 28:10

argue (1) 30:22

arising (1) 57:22

Arizona (5) 8:19;9:14,

 16,17;46:19

aspect (1) 17:1

aspects (2) 16:21;54:1

assigned (3) 49:17;

 50:7,18

assume (1) 5:10

assuming (2) 26:20;

 42:1

attempt (2) 21:1;35:8

attend (1) 28:20

attendance (4) 33:3,4;

 60:5,7

attending (1) 29:1

attorney (1) 57:8

attorneys (1) 42:23

auditor (2) 20:1,5

author (1) 14:3

availability (1) 60:19

available (2) 27:2,19

aware (11) 28:19,24;

 29:4,8;41:16,18,22;

 43:6,14;45:24;52:20

away (2) 25:1;37:5

B

back (8) 17:11;22:22;

 28:8;31:2;42:13,14;

 55:10;61:2

bad (2) 13:1;43:18

Bas (1) 41:1

based (3) 36:16;41:25;

 54:7

basic (1) 58:12

basically (2) 37:4;41:1

basis (7) 19:18;38:18;

 39:5,13;47:17;52:18;

 61:8

Bates (3) 15:23;16:7;

 17:14

became (5) 23:6;24:1;

 38:9;47:21;62:11

become (3) 16:24;

 20:16;38:8

began (3) 27:1,5;30:22

beginning (1) 29:17

begins (1) 15:25

behavior (4) 19:24;

 20:4,16;22:7

benefits (1) 24:14

best (4) 29:25;36:15;

 37:1;50:10

bet (1) 16:12

better (1) 16:24

biggest (1) 30:7

bit (4) 16:10;21:15;

 42:7;51:22

blank (2) 42:11;51:1

Bob (3) 4:9;42:7;59:12

bogged (1) 34:10

bonuses (2) 54:15;

 58:20

bookkeeping (1) 21:2

born (1) 56:17

both (1) 35:20

box (1) 14:9

branch (4) 7:14,21;

 9:14,15

branches (2) 9:10,12

brand (1) 18:13

brand-new (1) 62:3

Brandy (79) 4:10;9:2;

 10:2,5,11,15,20;11:7;

 12:18;13:4;14:1,18;

 15:2,21;16:19;17:19;

 18:5,21;19:8,22;20:25;

 21:14;22:6;23:6,8;

 24:6;26:2,21;27:1,5,15,

 21;28:19;29:4,16,18,

 21;30:2,11,19;31:11,

 15,16;32:18;33:20;

 34:11;38:9;39:14;

 40:22,24;41:16,18;

 43:6,12,21,25;44:6,12,

 21;45:15,20;46:2;

 47:13;49:11;50:8,24;

 51:2,4;52:14;53:5;

 56:19,23;60:5,6,13,16,

 19;61:6;62:11

Brandy's (7) 11:10;

 12:5;23:16,18;28:4;

 31:19;40:9

break (6) 5:13,16;6:25;

 40:1;49:6;59:16

breaking (1) 42:6

brief (2) 49:5,6

bringing (1) 19:2

brings (1) 30:16

BRISCOE (12) 4:1,8,9;

 14:9;16:8;40:8;42:21;

 44:15;59:1,23;62:18;

 63:16

broader (1) 37:10

broadly (1) 21:10

broke (1) 24:10

brought (2) 30:9;39:15

building (2) 28:16;

 43:22

bundle (1) 63:1

burned (1) 35:15

business (21) 6:16;

 7:15;16:23;17:2;18:24;

 19:5;20:2,10;21:2,7,

 10;22:18;27:2;38:17,

 24;39:15,23;52:6;54:2;

 57:15;61:8

C

California (4) 41:12,15;

 46:8;50:19

call (2) 51:10;54:12

called (2) 4:2;16:16

calls (1) 41:24

came (3) 30:19;31:2;

 54:4

can (25) 8:14;11:20,24;

 13:8,11;16:23;17:21;

 25:13;30:13;36:25;

 37:1;40:1,11;42:7,13;

 44:17;49:5,6,9,19;

 50:10;52:16;54:11;

 58:22;63:4

care (1) 37:19

Carlisle (2) 5:19;6:4

categories (1) 16:2

causing (1) 16:10

center (1) 28:16

central (1) 28:16

CEO (1) 54:4

CEO's (1) 56:5

certain (1) 24:5

certainly (1) 5:13

challenges (1) 30:16

chance (4) 13:10,13;

 15:15,16

change (4) 25:24,25;

 37:14;38:14

changed (2) 11:18,22

characterization (1)

 25:5

clarification (1) 21:23

clarify (1) 49:9

clear (3) 5:6;35:16;

 53:19

clearly (1) 35:4

comfortable (1) 19:25

coming (1) 18:16

comment (4) 41:25;

 54:8,9,13

comments (12) 16:16;

 17:5,5,10,14,15,17;

 25:23;41:1;60:4,6,18

communicate (6) 38:10;

 47:15,16,20;51:25;

 52:8

communicated (1)

 51:21

communication (3)

 21:24;22:1;38:14

communications (1)

 22:14

company (7) 41:14;

 46:2;51:5;54:4;56:23,

 24;57:24

competent (1) 18:10

complain (6) 19:4;

 27:14,14,21;32:18;

 60:15

complained (2) 21:24;

 22:1

complaint (6) 19:22;

 31:19;32:4;33:10;54:4;

 55:18

complaints (9) 18:21;

 22:4;26:21;29:18;30:1;

 31:11,14;48:8,12

complete (1) 38:7

concerns (2) 23:13;

 61:11

concluded (1) 63:11

conclusion (1) 41:24

condition (3) 29:5,7,11

conduct (1) 19:7

conducting (1) 18:24

conflict (1) 40:16

confused (3) 34:25;

 36:11,20

confusion (1) 34:15

connection (1) 57:23

consider (1) 18:9

considered (1) 20:4

consistent (1) 52:18

contact (4) 47:5;54:3;

 57:1,3

contacted (1) 57:3

contain (2) 57:14,21

content (1) 60:18

Continue (1) 17:2

continuous (1) 61:8

control (1) 38:7

conversation (5) 30:21,

 24;34:17;36:17,18

conversations (16)

 22:9,13,24;23:5,7,14;

 29:21,22;35:17,18;

 42:18,22;60:20;61:4,7,

 9

cooperate (1) 57:22

cop (2) 20:2,6

copy (1) 62:16

corporate (2) 24:20;

 35:21

correctly (1) 17:3

counsel (3) 42:5,18;

 43:4

country (1) 56:17

couple (3) 52:18;59:13;

 61:17

course (3) 38:5;55:4,16

court (3) 4:17;5:5;

 42:14

create (1) 24:21

creating (2) 61:20,23

critical (1) 16:25

criticism (3) 19:22;

 31:19;32:4

criticisms (8) 18:20;

 26:21;29:18;30:2;

 31:10,15;48:8,12

criticizing (1) 32:10

Currently (1) 5:19

D

daily (1) 47:16

date (2) 11:1;53:1

dates (1) 48:22

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(1) $130,000 - dates

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 305 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

day (4) 5:12;37:18;

 43:23;47:15

deal (1) 51:12

dealt (6) 49:12;50:24,

 25;51:4,8,15

decide (1) 54:15

decided (1) 54:7

decision (10) 10:11;

 43:11;44:5,11,16,20;

 45:3;55:13;56:3,4

defined (1) 35:5

department (11) 6:13,

 15,15;10:15;20:19;

 24:22;25:10;30:23;

 34:1;40:19;48:1

depending (1) 52:5

deposition (4) 4:12;5:2;

 57:4,7

depositions (1) 62:24

Depot (6) 6:1,2,12;7:3,

 6,8

describe (3) 17:18;

 40:16,17

described (2) 22:16;

 29:16

description (2) 35:23;

 61:18

descriptions (3) 35:25;

 61:20,23

desk (1) 49:15

details (1) 14:25

develop (1) 16:23

development (1) 37:8

differed (1) 37:2

difference (1) 37:4

different (4) 11:19;

 29:20;38:11;41:14

differently (1) 22:23

difficult (1) 38:8

direct (20) 8:24;11:10,

 14;12:19;13:2;18:8,20;

 19:23;22:10,11;23:8,

 19;25:17;26:3,9,18;

 29:24;32:3;39:7;51:11

directly (9) 7:3;13:5;

 23:13;31:23;38:6;

 45:12;48:2;49:12;51:5

director (2) 12:1,13

Disabilities (1) 41:20

disagree (1) 55:13

discuss (2) 30:12;53:14

discussed (6) 41:2;

 53:12;61:10,12,13,15

discussion (2) 35:12,19

discussions (1) 61:5

disenfavored (1) 37:17

disengage (3) 27:1,6;

 29:17

disparage (1) 57:15

displeasure (1) 54:25

divvied (1) 12:2

doctors' (1) 29:13

document (10) 13:8,13,

 16;14:4;15:8,14,17;

 16:7;33:1,10

documentation (2)

 33:14,19

done (3) 13:11;22:22;

 58:21

door (1) 31:1

dotted (1) 20:9

down (3) 14:4,5;34:10

drive (3) 16:25;17:1,2

duly (1) 4:2

during (19) 7:10,23;

 9:18;11:6,6;12:18;

 13:2;14:18,21;18:8,19;

 19:2;22:13;23:17,19;

 34:4;41:17;61:8;62:2

duties (1) 6:11

E

earlier (3) 49:21;60:3;

 61:3

early (1) 27:22

EEOC (1) 55:18

efforts (1) 17:3

either (1) 5:4

electronically (1) 13:19

eliminate (1) 44:12

else (9) 7:4;12:23;

 13:3;29:14;33:23;34:8;

 56:15,22;57:11

else's (1) 56:3

e-mails (2) 27:11;47:7

employed (4) 5:23;

 6:19,22;53:17

employee (13) 17:22;

 18:2,10;33:10;37:8;

 39:4;43:23;45:10;54:3,

 12;62:3,12,13

employees (15) 6:17;

 9:3;19:2;21:25;22:2,

 15;23:2;24:20;28:13;

 30:17;32:24;33:2;

 45:24;54:14;61:10

employment (8) 7:8;

 43:7,12;44:1,6,22;

 56:13;57:23

end (2) 37:17;42:8

ended (1) 56:13

engaged (2) 20:3;

 40:20

engagement (2) 18:2;

 29:22

enough (1) 22:5

enrolled (1) 34:6

entire (1) 28:17

entitled (1) 13:20

Equipment (6) 6:1,2,12;

 7:3,6,8

Eric (10) 25:17;39:2,7,

 11;53:15;54:24;55:23;

 56:16;61:5,7

essentially (1) 58:14

evaluation (4) 13:21,

 25;14:23;15:25

even (1) 44:3

eventually (1) 30:25

E-Verify (1) 34:5

everybody (1) 29:14

everyone (1) 63:8

exact (3) 11:1;33:15;

 41:1

exactly (3) 14:20;

 34:17;55:10

examined (1) 4:3

example (1) 19:1

examples (1) 21:16

except (1) 42:12

excluded (1) 42:17

Exhibit (5) 13:6,9;

 15:11,14,24

exists (1) 36:1

expectations (2) 15:9;

 16:3

expected (1) 45:2

explain (4) 22:22;35:7,

 8;36:15

explained (1) 22:17

express (4) 36:10;

 39:17,20;48:7

expressed (1) 54:24

extent (2) 11:24;41:24

F

fair (2) 25:4,4

familiar (1) 46:9

fast (1) 30:24

favor (2) 37:14,17

feel (1) 5:13

felt (4) 18:14;19:25;

 20:10;31:24

few (7) 18:22;19:17;

 21:13,18,21;54:2;

 59:13

figure (1) 63:4

file (1) 55:18

final (1) 62:21

finances (2) 21:1;54:25

financial (1) 54:1

financials (2) 21:9;

 55:11

find (2) 22:20;46:24

Fine (2) 39:10;42:8

first (3) 4:2;12:21;31:8

five (2) 19:19,20

focused (2) 34:18;37:8

focusing (2) 25:1;37:6

follow (1) 58:23

follows (1) 4:3

form (63) 8:6,13;9:22;

 10:17;15:3;17:20,25;

 18:11;20:13,20;21:3,

 17;22:8,25;23:10;

 25:11,21;26:10,24;

 27:8,16;28:6,14,21;

 29:6,12;30:4;31:21;

 32:11,20,25;33:9,12;

 34:13;35:3,10;36:21;

 37:15,23;38:22;39:3,

 24;41:23;43:13;45:5,9,

 16,22;47:1,22;48:14,

 20;49:1;52:15;55:2,8;

 56:9,25;57:16,25;58:7;

 59:5;60:10

formal (1) 59:6

format (2) 62:24;63:6

formerly (1) 6:19

forms (1) 33:16

forward (1) 35:9

foundation (17) 11:23;

 12:24;24:2,8;26:10;

 32:20;33:12;40:10;

 44:7,14;45:22;46:20;

 47:22;48:20;49:1;50:9,

 21

four (2) 11:4;55:25

free (2) 5:11,13

frequent (1) 19:18

frequently (9) 19:15;

 39:11;47:9,10,11;

 51:16;52:2,5,8

friendly (2) 17:24;18:1

full (1) 4:7

function (2) 37:19;62:1

functions (3) 24:11;

 37:5,6

G

gave (1) 15:2

general (18) 6:3,11,16;

 7:15,24;8:4,12,25;9:19,

 19;11:20;26:11;35:19;

 37:1,25;38:5;45:8;

 48:18

generalist (33) 8:23;

 9:1;10:22,23;12:2;

 24:1;34:12;35:1,9,23;

 36:3,8,12;37:2,22;38:4,

 9;45:21;46:1,25;47:21;

 48:5,9,13,18,25;49:17;

 50:7,18;51:6,13,15;

 62:11

generalists (4) 24:7;

 50:14;51:1,14

generally (2) 25:23;

 26:13

generically (1) 61:10

given (2) 21:6;47:25

goes (1) 42:11

Good (3) 4:9;47:18;

 54:3

Great (1) 61:2

greater (1) 21:7

greeting (1) 47:18

grew (1) 56:16

grievance (1) 55:19

ground (1) 5:1

group (6) 6:14;9:11,13;

 12:3;19:3,4

guess (1) 42:12

H

half (1) 57:10

handled (2) 24:13,18

happen (1) 19:16

happened (1) 42:1

happening (1) 53:20

happy (1) 25:6

head (1) 5:4

heads (1) 48:1

hear (1) 17:8

held (1) 8:1

help (3) 16:23;20:3;

 22:21

helped (1) 37:7

helping (2) 16:25;17:1

Herbert (1) 31:8

herein (1) 4:2

herself (5) 20:25;21:1,

 5;27:18;31:16

hey (1) 42:13

hire (3) 10:11,20;45:23

hired (4) 10:8,23;36:1;

 62:3

hiring (1) 10:14

hold (1) 7:10

home (1) 60:24

hot (1) 30:25

hours (2) 19:3;57:10

HR (69) 8:23;9:1;

 10:15,22,23;11:18,22;

 12:1,13;16:20;19:7,24;

 20:1,2,2,5,6,18;23:22;

 24:1,6,6,11,13,17,22;

 25:10;28:8;33:25;34:3,

 12;35:1,8,23;36:3,7,12;

 37:2,2,6,21,22;38:3,4,

 9;39:15,22;45:21;46:1,

 25;47:21;48:4,9,13,18,

 24;49:15,16;50:7,14,

 18;51:1,6,13;54:4,12,

 18;62:1,11

huh-uh (1) 5:5

human (1) 10:16

I

identification (2) 13:6;

 15:11

imagine (1) 20:14

immediately (1) 30:21

implications (1) 21:9

important (2) 17:1;25:1

improve (1) 30:13

improvement (2) 33:19;

 37:9

improvement-type (1)

 33:14

incident (1) 31:4

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(2) day - incident

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 306 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

including (1) 24:6

individual (4) 10:8;

 12:1;28:9;46:5

individually (1) 24:20

individuals (2) 10:13;

 24:11

Informal (1) 59:8

information (3) 36:16;

 47:8,25

initial (1) 34:4

initially (1) 35:16

input (6) 10:13;14:24;

 26:7,12;36:2,6

instances (1) 18:22

instruct (1) 62:18

interaction (1) 22:15

interactions (1) 22:10

interview (1) 10:5

interviewed (1) 10:14

interviewing (1) 56:12

into (4) 19:2;30:21;

 37:11;62:3

investigation (1) 54:5

invited (1) 30:11

involve (3) 20:25;21:1,

 5

involved (1) 45:11

issue (3) 20:16;27:23;

 51:12

issues (5) 16:20;18:23;

 47:2;61:9,16

J

JACOB (4) 4:1,8;14:9;

 63:16

Janelle (22) 46:9,11,15,

 18,24;47:3,6,21;48:2,4,

 7,12,17,24,24;49:25;

 50:5,6,13,14;51:3;

 52:20

January (1) 14:19

job (21) 6:8,11;7:5;

 10:6;12:2;18:21;23:16,

 18;31:19;32:5;33:11;

 34:12;35:22,25;36:3,7;

 48:8;61:18,19,20,23

jobs (4) 22:19,21;

 34:16;56:12

July (1) 14:9

jumped (1) 30:21

June (4) 14:19;44:12,

 21;45:3

K

Kayla (6) 51:6,14,16,

 20,21,25

kind (1) 37:9

knew (2) 10:2;60:25

knowing (2) 60:21,24

knowledge (11) 13:4,5;

 26:7;30:1;42:24;43:1;

 46:15,18,23;47:24;

 61:22

K's (3) 55:13;57:15;

 61:22

L

lack (1) 40:18

Lake (1) 7:20

last (6) 14:8,9,13;16:6;

 17:8;56:1

lastly (1) 5:11

late (4) 27:22,24,24;

 30:19

lawsuit (1) 4:15

lawyers (1) 57:3

layoff (1) 58:13

leaders (1) 16:24

learned (1) 44:1

learning (1) 18:14

least (3) 35:5;47:17;

 49:15

leave (5) 41:6,8;52:21;

 53:7,11

leaving (2) 27:22;43:15

left (21) 7:2;8:2;18:6;

 26:8,18;32:3;41:7;

 45:20;46:2;48:25;

 49:11;50:8;51:4,5;

 52:14;53:1,9;55:24;

 56:8,23;58:17

legal (3) 16:21;31:7;

 41:24

less (3) 11:17;19:19,20

letting (1) 55:19

level (2) 21:7;35:21

lifetime (1) 30:8

liked (2) 27:3;40:12

limited (1) 18:11

line (4) 14:8;16:21;

 20:9;33:2

Linen (1) 41:13

litigation (3) 56:20,24;

 57:22

little (3) 6:10;16:10;

 42:6

live (2) 5:18,19

lived (2) 5:21;37:19

located (1) 50:19

location (17) 7:20;9:4,

 6,16;26:15;28:5,12;

 39:12;43:20;45:8;

 46:12,16;47:14,19;

 49:17;50:25;54:25

locations (2) 7:19;

 46:19

long (5) 5:21;37:18;

 48:17;55:6;57:9

longer (7) 23:8;24:17;

 26:3,4;53:16;62:12,13

look (5) 13:8,13;15:13;

 55:11;58:22

looked (2) 57:18;58:2

looking (3) 20:7;21:14;

 37:10

lot (2) 42:10;51:20

M

making (2) 27:18;58:16

manage (2) 6:17;9:3

management (5) 22:2;

 30:9,10,10;33:4

manager (43) 6:3,12;

 7:13,14,14,15,15,15,

 24;8:4,5,7,11,12,21,21,

 22,22,24,25;9:15,19,

 20;10:14;11:19;13:21;

 15:2,25,25;16:3,16;

 17:14;26:12,13;30:11,

 22;31:6;34:6;35:20;

 37:25;38:5;45:8;48:18

managers (11) 8:15;

 16:22,23;20:8;21:15,

 25;22:15;24:20;36:20;

 40:20;54:13

manager's (1) 15:8

manner (1) 27:11

many (6) 6:17;8:20;

 9:3;22:9;38:19;55:10

Marked (2) 13:6;15:11

maternity (1) 52:21

matter (1) 37:18

matters (1) 49:15

may (4) 14:16;42:12;

 58:3,3

maybe (2) 11:17;51:24

McNaul (10) 25:18;

 39:2,7,11;53:15;54:24;

 55:23;61:5,7,13

mean (4) 20:5;27:6;

 51:9;56:5

Meaning (1) 40:19

means (1) 14:12

Mechanicsburg (1) 6:6

medical (8) 28:20,23;

 29:2,4,11;60:7,13,16

meet (2) 38:15;46:11

meeting (4) 30:9,12,20;

 31:3

meetings (3) 23:3;

 27:25;35:20

meets (2) 15:9;16:3

mention (2) 30:7;31:9

mentioned (4) 24:9;

 30:19;49:21;50:13

messages (1) 27:10

met (2) 46:13;57:8

microphone (1) 16:9

mid-conversation (1)

 30:20

midyear (2) 18:15;

 20:15

military (1) 7:1

MILLS (111) 4:6,10;8:8,

 17;10:1,18;12:4,25;

 13:7,14;15:6,12;16:14;

 17:9,13,23;18:4,18;

 20:17,24;21:12,20;

 22:12;23:4,15;24:4,12;

 25:15;26:1,16;27:4,13,

 20;28:11,18,25;29:9,

 15;31:5;32:1,8,14,22;

 33:5,17;34:19;35:6,13;

 36:24;37:20,24;38:1;

 39:1,6;40:2,4,7,14;

 42:2,8,19;43:2,16;

 44:10,19,25;45:6,13,

 19,25;46:21;47:4,23;

 48:16,23;49:3,7,10,13,

 23;50:4,15;51:7,23;

 52:7,13,19,25;54:17,

 22;55:5,12,17;56:14;

 57:5,19;58:4,9,15,21,

 25;59:7,10,15,18,20;

 60:10;62:7,10,14;63:8

mini (1) 62:25

Minneapolis (1) 51:2

minute (1) 58:22

minutes (5) 21:13,21;

 40:4;59:14,19

mischaracterizes (2)

 25:12;50:2

missing (5) 27:15,17;

 32:10,18,24

Mitch (6) 31:7;40:9,17,

 21,22;41:3

modified (2) 14:9,13

month (6) 38:25;47:11;

 51:21,24;52:12,18

monthly (2) 38:25;

 39:13

months (9) 5:22;7:5;

 21:18;54:2,8;55:9,10;

 56:1;58:14

more (13) 20:22;21:9,

 15;24:21;25:1,9;28:13,

 16;38:8;47:11,17;52:2,

 5

morning (3) 4:9,11;

 47:18

mostly (2) 23:2;50:24

move (4) 14:21;16:11;

 28:4,7

moved (3) 14:20;24:19;

 56:18

moving (1) 16:8

much (4) 29:14;51:2;

 58:10;63:7

multiple (3) 8:15;27:3;

 35:12

myself (1) 27:11

N

name (9) 4:7,9;13:19;

 14:15;31:7;46:7;49:22;

 50:13;54:14

name's (1) 31:8

near (1) 16:9

need (4) 5:3,6,14;58:23

needed (5) 18:17;

 22:20;34:6;47:10;

 53:11

neighborhood (1) 58:19

new (10) 18:13;27:1;

 30:14,16;34:5,16;35:1;

 45:23;56:12;61:23

next (1) 54:16

nod (1) 5:4

Northwest (2) 12:15;

 48:5

note (1) 42:16

noted (1) 18:15

notes (1) 58:22

notified (1) 57:2

number (2) 15:24;16:7

numbered (1) 17:14

O

Object (4) 9:22;10:17;

 52:3;60:10

Objection (79) 8:6,13;

 11:23;12:24;15:3;

 17:20,25;18:11;20:13,

 20;21:3,17;22:8,25;

 23:10;24:2,8;25:11,21;

 26:10,24;27:8,16;28:6,

 14,21;29:6,12;30:4;

 31:21;32:6,11,20,25;

 33:12;34:13;35:3,10;

 36:21;37:15,23;38:22;

 39:3,24;40:10;41:23;

 43:13;44:7,14;45:5,9,

 16,22;46:20;47:1,22;

 48:14,20;49:1,18;50:1,

 9,20;51:17;52:10,15,

 22;54:10,19;55:2,8,15;

 56:9,25;57:16,25;58:7,

 11;59:5

objections (1) 44:24

objective (1) 21:5

Objectives (1) 14:6

Obviously (2) 13:17;

 30:15

Occasionally (1) 52:4

occasions (1) 27:3

occur (1) 22:24

occurred (3) 23:2,5,7

off (1) 28:20

offer (1) 18:16

office (14) 6:6;8:22;

 11:9;18:3;19:2;28:4,8,

 8,9,10,15;30:10;31:2;

 34:5

often (3) 16:21;42:11;

 51:15

Ogden (1) 7:21

on-board (1) 30:16

on-boarding (2) 30:12,

 15

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(3) including - on-boarding

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 307 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

once (1) 47:11

one (17) 5:1,1,14;8:22;

 15:1;27:25;28:1,7;

 30:7;35:24;42:11;49:9;

 50:14;51:14;54:13;

 62:7;63:4

one-on-ones (1) 23:1

only (5) 5:14;27:23;

 28:2;34:9;57:1

operation (1) 28:17

operations (1) 6:16

opinion (1) 19:5

opportunities (1) 21:8

opportunity (2) 21:6;

 62:20

opposed (2) 37:22;38:4

order (2) 22:19;62:16

organization (2) 11:18;

 18:14

others (1) 61:4

Otherwise (1) 5:10

out (4) 7:12;31:1;51:1;

 63:5

outside (1) 18:2

over (7) 7:22;35:15;

 38:7,13;50:22,22;

 51:19

overlooked (1) 16:21

oversee (3) 6:13,14,15

P

P&L (1) 21:8

package (1) 58:13

page (5) 15:23;16:6,13,

 15;17:14

paper (1) 16:9

PARKER (110) 8:6,13;

 9:22,24;10:17;11:23;

 12:24;13:10;15:3;17:7,

 11,20,25;18:11;20:13,

 20;21:3,17;22:8,25;

 23:10;24:2,8;25:11,21;

 26:10,24;27:8,16;28:6,

 14,21;29:6,12;30:4;

 31:21;32:6,11,20,25;

 33:12;34:13;35:3,10;

 36:21;37:15,23;38:22;

 39:3,24;40:1,3,5,10;

 41:23;42:6,10,16,20;

 43:3,13;44:7,14,24;

 45:5,9,16,22;46:20;

 47:1,22;48:14,20;49:1,

 5,18;50:1,9,20;51:17;

 52:3,10,15,22;54:10,

 19;55:2,8,15;56:9,25;

 57:16,25;58:7,11,18;

 59:5,12,17,19,22;60:2,

 11;62:6,15,17,23;63:3,

 6,9

part (3) 53:12;56:16,17

particular (1) 44:22

parting (1) 53:14

partner (3) 20:2,2;

 22:18

parts (1) 6:15

party (1) 4:14

Paul (2) 51:1,6

payroll (2) 24:13;37:13

pending (1) 5:15

Pennsylvania (3) 5:20;

 6:5,7

people (1) 38:6

performance (21)

 12:20;13:3;14:5;

 15:20;17:2;18:21;

 20:15;26:4,5,8,17,22;

 31:20;32:5;33:11,13,

 19;37:9;48:9;59:3;61:6

period (7) 7:23;11:13;

 14:19;19:25;38:23;

 48:3;50:23

periods (1) 7:22

personality (1) 40:15

personally (2) 21:4;

 38:16

perspective (1) 40:8

Phoenix (27) 7:17,18,

 24;8:5,9,19;9:4,19;

 10:3;11:7,9;21:2;28:5;

 38:19;39:12;43:20,23;

 45:8;46:14,16;47:14,

 19;48:19;49:17;50:8,

 19;54:25

phrase (1) 53:18

physically (1) 27:6

pick (1) 5:6

picture (1) 37:10

pipelines (1) 16:25

place (1) 32:17

plans (2) 37:8,9

plant (4) 8:22;19:1;

 22:1;30:10

play (1) 43:11

Please (2) 4:7;62:16

pleased (2) 18:23;25:8

plus (1) 58:13

point (18) 8:22;13:17;

 14:21;20:9,11,25;

 23:25;28:4,7,22;31:24,

 24;32:2;43:24;45:24;

 51:3;52:20;54:7

position (4) 8:1;10:20;

 44:13;62:4

positions (2) 7:10;

 61:24

positive (1) 22:5

possible (3) 15:1,4;

 32:12

potentially (2) 51:3;

 52:1

prefer (2) 37:21;38:3

premarked (2) 13:9;

 15:14

prepare (6) 31:18;32:3,

 9,23;33:18;57:6

prepared (2) 13:25;

 15:20

Prescott (3) 9:17,20;

 46:22

present (2) 27:7;43:17

pretty (4) 29:14;30:24,

 25;52:18

previous (4) 28:8;

 29:20;38:13;54:2

previously (5) 21:10;

 34:2,7;37:7;62:3

primarily (6) 24:19;

 25:17;49:11;51:4,8;

 54:1

primary (1) 37:4

prior (4) 25:12;42:24,

 25;50:2

probably (5) 38:24;

 47:12,16;51:2;55:25

procedure (2) 32:21;

 33:9

procedures (2) 32:15,

 17

proceeding (1) 4:21

Proceedings (1) 63:11

process (4) 30:14;34:5;

 61:23,25

productive (4) 19:6;

 20:4;22:20;29:23

professional (1) 19:7

program (4) 34:7;59:4,

 6,8

pronounced (1) 20:23

proper (2) 19:6;20:10

provide (1) 36:2

provided (1) 21:8

provision (2) 57:14,21

put (2) 29:17;59:3

putting (1) 54:13

Q

quick (1) 40:1

quite (3) 17:7;27:2;

 51:22

R

Rachel (37) 12:9,10;

 14:3;20:8;21:6;23:12,

 13,13;25:18;26:19,22;

 27:15,21;29:19,22;

 30:2;31:3,12,16;35:18;

 36:10,19,22;38:11,12,

 15;48:11;49:12;51:5,9;

 52:9;60:4,12,15,19,20;

 61:13

raised (1) 54:6

rating (1) 16:3

ratings (4) 15:2,2,8,8

read (8) 15:7;16:18;

 17:3,11;42:13,14,15;

 62:18

really (9) 20:16;29:23;

 34:10;37:5,10,18,19;

 42:9,12

recall (31) 11:1;14:20,

 22;23:21,22;25:22;

 30:22;31:13;32:7,13,

 21;33:14;34:14;35:24;

 44:3;46:7;47:2,5,8,10;

 48:6,15,21;49:21;50:3,

 12;53:1;57:17;58:1;

 59:9;61:12

receive (1) 58:5

Recessed (4) 40:6;

 49:8;58:24;59:21

recognize (1) 15:17

recollection (3) 14:2;

 50:6,11

record (4) 4:7;31:8;

 42:15,17

recruiting (1) 37:6

refer (1) 51:13

regarding (7) 14:1;

 32:4;48:8;56:23;60:5;

 61:4,6

region (4) 12:13,15;

 38:13;48:5

regional (3) 12:1;

 26:12;35:21

regular (2) 38:17;39:5

relationship (4) 17:19;

 18:2;39:2;40:9

relevance (19) 49:18;

 50:1,20;51:17;52:3,10,

 15,22;54:10,19;55:2,8,

 15;57:16,25;58:7,11,

 18;59:5

remember (10) 14:25;

 27:23;28:3;30:7;35:22;

 36:17,22;43:22;50:13,

 16

remote (1) 28:13

reorganization (5) 12:6;

 24:1,17,22;25:10

rephrase (7) 5:9;10:19;

 12:25;37:24;38:2;

 41:17;43:18

replaced (1) 45:21

report (4) 12:1;14:14;

 23:11;38:6

reported (4) 9:15;

 11:19;23:12;26:13

reporter (8) 5:5;16:8,

 12;42:14;62:15;63:2,4,

 7

reporting (2) 14:18;

 20:9

reports (3) 8:24;22:11;

 29:24

represent (1) 4:10

representative (7) 7:13;

 23:23;34:3;37:3,7,22;

 38:3

representatives (3)

 24:6,13,17

representing (1) 43:4

reps (1) 30:15

request (2) 33:22;41:19

Requests (1) 27:11

require (1) 6:8

resources (1) 10:16

respect (7) 12:12;

 15:21;32:23;33:11,19;

 60:6;61:18

respond (1) 27:10

responding (1) 61:1

response (1) 25:20

responsibilities (10)

 12:2;24:10,19;25:9;

 34:1,3,17;36:3,7;46:4

responsibility (1) 61:19

responsive (1) 27:10

restructuring (2) 20:18;

 33:25

reverberated (1) 31:2

review (8) 13:11;15:15,

 20;18:15;20:15;26:8;

 59:3;62:21

reviews (6) 12:20,23;

 13:4;26:4,5,18

right (15) 9:24;11:3,4;

 21:22;24:14,18;38:8;

 50:24;59:12,18;61:17;

 62:12;63:3,6,8

role (15) 18:14;20:1;

 22:18;26:11;27:1;

 34:24;35:1,5,8;36:1,

 12;37:1;38:13;43:11;

 48:12

roles (1) 16:24

rolled (2) 9:10,13

room (1) 31:1

route (2) 7:12,14

Rubinoff (2) 31:7;40:9

ruckus (1) 16:10

rules (1) 5:2

run (1) 20:10

S

Sacramento (1) 46:12

safety (1) 54:15

salaried (1) 33:4

sales (6) 6:14;7:12;

 8:21;30:9,12,14

Salt (1) 7:20

Same (8) 32:6;41:1;

 44:24;46:5;61:12,15;

 62:24;63:6

SAMUEL (3) 4:1,8;

 63:16

saying (1) 36:23

search (1) 7:5

Seattle (1) 7:21

Section (3) 14:5;16:3,

 16

seeing (2) 35:22,24

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(4) once - seeing

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 308 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

sent (1) 47:7

separation (4) 53:8;

 57:13,18,20

September (2) 43:9;

 53:3

service (11) 6:13;7:1,

 11,14;8:21;21:24;

 30:10,13,17,22;31:6

Services (1) 6:20

serving (2) 48:4,17

setting (1) 19:4

Several (3) 52:12;54:8;

 55:9

severance (2) 58:6,12

shake (1) 5:4

share (1) 20:8

shared (1) 23:13

Shortly (1) 26:25

shown (1) 54:6

shows (1) 14:2

side (1) 22:22

Sig (1) 38:11

Siggerud (18) 12:9,10;

 14:3;25:18;26:19,23;

 29:19;30:3;31:12;

 36:10;38:11,15;48:11;

 60:5,12,15,19;61:14

sign (1) 62:18

signed (2) 57:18;58:2

significant (2) 30:14,18

similar (1) 29:21

sit (1) 54:18

slammed (1) 31:1

small (1) 9:16

somebody (1) 56:3

someone (3) 12:23;

 20:3;45:2

Sometime (2) 11:17;

 20:15

Sometimes (1) 5:3

somewhere (4) 7:4;

 16:9;37:19;58:19

sorry (6) 9:9,23;13:15;

 21:21;34:22;52:11

sort (6) 32:4;33:8,18;

 57:21;58:5;63:1

sound (4) 11:3;23:24;

 46:9;63:3

sounds (3) 11:4;24:3;

 53:6

source (1) 42:4

south (1) 30:24

speak (1) 51:16

specialized (2) 12:3;

 24:11

Specialty (1) 41:13

specific (7) 21:16;

 25:22;28:2;29:7;31:4;

 36:17;48:21

specifically (4) 22:3;

 34:9;40:25;42:17

specifics (1) 47:8

specified (1) 35:25

spent (2) 7:5;21:23

spin (1) 54:15

spoken (3) 18:5;55:23,

 25

St (2) 51:1,6

staff (3) 26:12,15;27:12

start (1) 20:12

started (6) 7:12;11:18;

 20:1,16,21;34:16

starting (1) 34:6

state (1) 4:7

stationed (1) 6:4

still (3) 31:23;41:3;59:1

stop (2) 19:11,13

stopped (2) 11:13;48:4

Strike (5) 10:18;23:6,

 17;32:16;54:23

strong (3) 16:19,22;

 17:2

structure (2) 11:22;

 26:14

stuff (1) 37:11

successful (1) 22:20

sued (1) 55:21

supervise (1) 22:10

supervision (6) 23:9,20;

 26:3,9,18;32:3

supervisor (11) 11:11,

 14;12:6,19;13:3;18:9,

 20;19:23;25:17;38:11;

 39:7

support (4) 26:14,14;

 40:18,18

supposed (1) 36:12

sure (13) 14:24;17:13;

 28:22;29:3;36:1;40:2;

 42:7;46:13;47:7;49:7,

 10,20;60:23

sworn (1) 4:3

T

talk (6) 31:3;40:24;

 56:7,19,22;60:12

talked (7) 19:12,13;

 38:12;51:19;56:8,11,

 18

talking (5) 19:1;44:3;

 50:5,24;61:8

team (5) 16:22;18:16;

 21:24;29:23;30:17

teammate (1) 29:24

teams (1) 30:13

technicians (1) 6:14

tendency (1) 5:4

terminate (3) 43:12;

 44:6,21

terminated (6) 41:9;

 43:7,21;44:2,4;58:6

termination (1) 44:16

terminology (1) 33:15

terms (2) 11:20;37:1

testified (6) 4:3,17,20;

 21:13;44:15;60:3

testify (1) 21:18

testimony (2) 25:12;

 50:2

thinking (1) 51:24

though (1) 14:23

thought (5) 21:14;22:6;

 31:9;36:7;45:15

three (3) 7:5;55:25;

 58:14

timely (1) 27:11

times (7) 19:17;27:7;

 35:12;38:19;52:12,18;

 56:1

title (5) 23:16,18,22;

 24:1;46:5

today (1) 43:4

together (2) 30:9;39:5

told (3) 40:22;43:21;

 45:2

took (2) 25:1;34:4

top (1) 16:15

topic (2) 35:12,19

topics (1) 61:13

track (2) 33:3,3

transcript (1) 62:21

transferred (2) 14:16;

 46:4

transition (2) 26:25;

 34:4

travel (1) 6:8

traveled (2) 39:5;46:12

traveling (1) 60:24

tried (1) 36:15

trouble (2) 20:8;21:15

true (1) 54:6

try (2) 5:9;22:18

trying (1) 47:5

Tucson (3) 9:14,20;

 46:22

turn (2) 15:23;16:6

turnover (1) 30:18

two (2) 50:23;57:10

type (1) 57:14

types (2) 30:1;31:10

typically (3) 33:3;39:13;

 51:14

U

ultimately (1) 54:5

under (7) 8:12;9:11,13;

 23:8,19;26:3;41:19

understood (1) 25:24

unemployment (1) 4:22

unhappy (2) 24:24,25

up (11) 5:6;9:10,13;

 12:2;24:10;28:9;35:15;

 42:6;56:13,16;58:23

use (1) 53:18

used (2) 28:9;33:2

uses (1) 33:15

using (1) 34:14

Utah (2) 7:20,21

utilize (1) 33:9

utilized (2) 32:16,18

V

vacation (1) 58:14

value (2) 39:15,22

various (2) 7:22;24:10

verbally (2) 5:3;47:17

versus (2) 20:2;37:10

visibility (1) 35:5

voice (7) 18:20;25:7,

 16;26:22;29:18;31:14;

 48:11

voiced (3) 19:22;30:2;

 31:11

voluntarily (4) 41:8,10;

 53:7,9

volunteer (1) 36:6

W

walked (1) 30:25

Washington (1) 7:22

way (5) 18:23;19:6;

 20:10;40:19;43:3

ways (4) 22:20;30:13;

 53:13,14

weekly (1) 23:1

weeks (1) 58:13

weren't (2) 20:10;22:5

wheel (2) 54:14,15

whenever (1) 5:13

wherein (1) 57:14

whichever (1) 26:13

Williams (20) 4:10;9:2;

 10:2,5,21;14:1;15:21;

 17:19;19:22;28:19;

 33:20;39:14;41:16,19;

 43:25;45:20;47:14;

 56:20,23;61:4

Williams' (13) 12:19;

 26:22;43:7,12;44:6,13,

 21;60:5,7,13,16,19;

 61:6

witness (89) 4:2,18,21;

 8:7,15;9:23,25;11:25;

 13:12;15:4;16:11,13;

 17:22;18:1,13;20:14,

 21;21:4,18;22:9;23:1,

 11;24:3,9;25:14,22;

 26:11,25;27:9,17;28:7,

 15,22;29:7,13;30:6;

 31:22;32:7,12,21;33:1,

 13;34:14;35:4,11;

 36:22;37:16,25;38:23;

 39:4,25;40:12;41:25;

 42:25;43:14;44:9,18;

 45:10,18,23;47:2;

 48:15,21;49:2,9,11,20;

 50:12,22;51:19;52:4,

 12,17,24;54:12,21;

 55:4,9,16;56:11;57:1,

 17;58:1,8,12,19;59:6;

 62:22;63:10

witnesses (1) 5:3

wondering (1) 42:3

word (2) 17:8;42:11

wording (1) 34:15

work (19) 7:4,19;10:9;

 11:7;16:24;24:21;

 26:22;27:15,18,22,22,

 24;28:20;32:10,19,24;

 51:10;60:21,22

worked (9) 7:20;8:16,

 23;11:7;12:10,21;46:2,

 7,13

working (9) 7:16,17;

 8:12;10:3;19:3;31:23;

 47:13;51:12;60:24

works (2) 41:13,14

writing (1) 32:10

written (4) 31:18,19;

 32:4;35:22

wrong (1) 30:23

wrote (2) 17:6,16

Y

year (5) 11:17;12:21;

 14:21;41:7;53:4

years (6) 6:24;7:11,18;

 11:4;50:23;51:19

yesterday (1) 57:8

Yuma (3) 9:16,20;

 46:22

Yup (2) 14:7;15:16

1

1 (1) 14:5

10 (4) 7:18;40:4;58:13;

 59:19

10:02 (1) 40:6

10:15 (1) 49:8

10:22 (1) 49:8

10:34 (1) 58:24

10:35 (2) 58:24;59:21

10:44 (1) 59:21

10:48 (1) 63:11

100 (1) 9:5

129 (1) 15:24

132 (3) 16:7,13;17:15

18 (2) 5:22;56:1

1993 (1) 6:24

1st (1) 14:19

2

20 (2) 6:24;7:11

2003 (1) 7:1

2011 (2) 7:25;11:2

2012 (3) 14:10,19,19

2013 (3) 43:9;44:12;

 45:3

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(5) sent - 2013

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 309 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Jacob Samuel Briscoe

June 22, 2016

2014 (1) 53:3

2015 (3) 6:25;7:2,25

25 (3) 15:11,14,24

26 (3) 13:6,9;14:10

5

5 (1) 40:4

7

75 (1) 6:18

9

9:53 (1) 40:6

90 (1) 9:5

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(6) 2014 - 90

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 310 of 505
EXHIBIT C

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 311 of 505
Rule: Manager 

Due Date: 08/15/2012 

Alanager Evaluation 

Brandy Williams, 

GK perform, 01/01/2012 -06/30/2012 

Author: Rachel Siggerud 

Status: Completed 

Approval: Not Required 

Template 07126/2012 9:40AM 

Weight: 10% 

Created By: 

ti:1,1?„1.,',1'.q-i'„IT • 

Years of Ber. , 1 : 1 Y ' 

D ser it . A.ihieve or excce.i it.; group's revenue pie 

Employee 0- Not m.cci I c,ectations 

Manager 2 - Meets Expectations 

Rating: 

Weight: 10% 

Created By : 

Last Modified By 

Temp lute 

Jacob Briscoe 

07/26/2012 9:40AM 

e or exceeu ii ouucto 111C01)e p 

phiy«. 17.a ing: 2 - Meets E.' 

Manager 1 - Meets Expectations 

Rating: 

Last Modified fly: Jacob Briscoe 07/26/2912 9:41 AM 

I .!cseription Cons 

• Cu:.:orocr 

• NPSQ.0 

NPS® - Not Promoter, Net Promoter Score, and NPS are trademarks of Satmetrix Systems, Inc., Bain & Company, Inc., arid 

Fred Reiehheld 

Employee Rating: 3 - Meets Expectations 

Manager 2 - Meets Expectations 

Rating: 

Weight: 15% 

Created By: Template 

Last Modified By : Jacob Briscoe 

07/26/2012 9:40AM 

07/26/2012 9:4IAM 

G&K000136 

PLAINTIFF'S 

EXHIBIT 

26: 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 312 of 505
scrip r( n 

• Recruit/recruitment metrics 

• Develop 

• Retain (includes RSR/TSR turnover) 

• Poster a diverse workforce 

• Internal promotions 

Employee Rating: 3 - Meets Expectations 

Manager 2 - Meets Expectations 

Rating; 

Weight: 20% 

Created 13y : 

Last Modified By : 

Terrti)late 

Jacob Briscoe 

07126/2012 9:40AM 

07/26/2012 9:41AM 

Description Inch ',Tes: 

• High ethical standards and openness 

• Safety compliance and advocacy 

• Commitment toll 7 W 

• FIR Assessment & Audit compliance 

• Run business activities/projects 

• Executes all other key responsibilities of my position 

• Achieves/ maintains sales headcount 

Employee Rating; 4 - Exceeds Expectations 

Manager 3 - Meets Expectations 

Rating: 

Weight: 15% 

Created By ; 

Last Modified fly: 

Template 

Jacob Briscoe 

07/26/2012 9:40AM 

07/26/2012 9:4 I AM 

Des('ipti M r PY 171 is = directly involved : department ,ind sharpen my skills and 

know ialgc in the 4 , 1 ■■ ,{lary structine, pel 1101 ,0: and expectation guidelines, ani.l goals, My expectation is to be able to 

equally provide a .perecittage of my involvement as an HR support for this department. My goal is to build my relationship 

with all employees and the sales manager to stive in decreasing turnover, retain quality employees, and provide 

knowledgeable 11.,edback on impeding concerns and/or questions. Help to drive a high-performance sales team and culture 

throughout my role and partnership, 

.Employee Rating: 3 - Meets Expectations 

Manager 3 - Meets Expectations 

Rating; 

Weight: 15% 

Created By: 

Last Modified By: 

Template 

Jacob Briscoe 

07/26/2012 9:40AM 

07/26/2012 9:41AM 

• 

'AI:temp safety aware- -.' within the local 1 • vithin platj, 'c. .'ad 

innovativu ways oi portraying company guidelines and satety expectations In a positive and inn environment. Help to make 

an impact and improve the safety results in our local locations. Partner with location leadership to drive down TCIR. and 

DART. 

Employee Rating; 3 - Meets Expectations 

G&K0001 37 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 313 of 505
Manager 2 - Meets Expectations 

Rating: 

Weight: 15% 

Created By : Template 07126/2012 9:40AM 

Last Modified By Jacob Briseou 07/2612012 9:41AM 

erlptIon This objective is dc7ned by you and your manag:F. Your document weights.must equal 100% to save 

properly. 

Employee Rating: Termination No rating 

Manager Termination - No rating 

Rating: 

Weight: 0% 

Crested By : Template 07/26/2012 9:40AM 

' Employee - Meets Exp'ctations 

Manager Rating: 2 - Meets Expootations 

Summary Weight: 100% 

Frn [lope I r. 3 - Meets Expec lion 

Manager Rating: 2 - Meets Expectations 

Significant 

Accomplishments 

and Objectives 

Missed: 

Manager 

Comments: 

Deser ■ ption Use this section to list two or tI i your strengths and two or t ice of your development opportuna..., 

Comment on m.:c successes and ehalleng: in these areas. This section is meant to genera good conversf; in bc! ween 

manager and employee and should be a starting point for an individual development plan. Use this time to discuss 

development; present and future. 

'trengths/OpportunIties I believe a strength amine is being knowledgeable on OK Policy and Procedures, continuosly 

developing myself as an individual and staying up to date on IIR knowledge and changing laws and regulations. Prioritize 

and manage my HR role on it daily basis and complete task and functions. I have built numerous positive and 

communicative relationships on an individual level within the local employees and management environment. I have built a 

strong HR relationship with peers within my region and utilized them on a continous basis for support. 

I believe an opportunity of mine is to continously build n pipeline of candidates and provide bench candidates for the sales 

department in the future. Work more closely with regional FIR recruiting manager on obtaining training and instruction for 

Oxieon result evaluation and defined recruiting aspects for the sales role. 

Employee 

Comments: 

Created By Template 07/26/2012 9:90AM 

G&K000138 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 314 of 505
created by . 

Last Updated By: 

uii'4o/a) I2 i;4u:53AM 

07/24/2013 L 22:38PM 

IVI riacier 

Comments: 

8yetinti 

G&K0001 39 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 315 of 505
EXHIBIT D

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 316 of 505
Template 

Jacob Briscoe 

02/13/2012 11:39AM 

05/03/2012 10:08AM 

Weight: 10% 

Created : 

Last Modified By: 

Role: lvlartager 

Due Date: 02/15/2012 

Author: Jacob Briscoe 

Status: Complr'cd 

Approl :[1: Not Reauired 

Template 

Jacob Briscoe 

02/13/2012 11:39AM 

05/03/2012 10:08AM 

Rating: 

Weight: 10% 

Created By 

Last Modified By : 

The document status is Completed. 

/ i t), 

I111)1. yee - Meets I- .•.pei A' ions 

Manager 2 - Meets Expectations 

Ytir ol'&Ervo U Yi'; 1vionths 

1)1:1'it,101I tci,i Vo or excec . .i Lac. •7u5uo..iull group's Op.',:it.:tg Income plan 

Enirlo: 0-Not tn.- ting Mons 

Manager 0 - Not meeting Expectations 

Rating: 

G&K0001 29 

PLAINTIFF'S 

EXHIBIT 

25 

Pefforniance Doctim K perform 

Manager Evaluation 

Brandy Williams, 

OK perform, 07/01/2011 - 12/31/2011 

Description Consider: 

• Customer satisfaction 

• 11PSO 

NPS® -Not Promoter, Net Promoter Score, and NPS are trademarks of Sattnetrix Systems, inc,, Bain & Company, Inc., and 

Prod Reichheld 

Employee Rating: 2 Meets Expectations 

Manager 3 - Meets Expectations 

Rating: 

Weight: 15% 

Created By: 

Last Modified By: 

Template 

Jacob Briscoe 

02/13/2012 11:39AM 

05/03/2012 10:08AM 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 317 of 505
. .".Wira .rAt OA, 

Deserh .11on Co, 

• Recruit/recruitment metrics 

• Develop 

• Retain (includes RsursR turnover) 

• 'osier a diverse workforce 

rnal promotions 

iployee Rating; 3 Meets Expectations 

ger 3 - Meets Expectations 

Rating; 

Weight: 20% 

Created By: Template 02113/2012 11:39AM 

Last Modified By: Jacob Briscoe 05103/2012 10:08AM 

.--m----- __ ..., 

?Of., 

• 1.1 l st tdards id open:. 

• Safety compliance and advocacy 

• Commitment to 1FW 

• ER Assessment & Audit compliance 

• Run business activities/projects 

• Executes all other key responsibilities of my p0 

• Achieves/ maintains sales headcount 

Employee Rating: 3 - Meets Expectations 

Manager 3 - Meets Expectations 

. 'Rating: 

Weight: 15% 

Created By : 

Last Modified By 

Template 02/13/2012 11:39AM 

Jacob Briscoe 05/03/2012 10:08AM 

`. , 311)11 I ;r FY 12 is to r c directly involv. w. Lie di ,rtment and sharpen my kil and 

rtowiedLtIHWry structure, pear, : miner am • ...Artion guidelines, and ;,; , 1s. My expectition is to be able to 

equally provide a percentage of my involvement as an ER support for this department My goal is to build my relationship 

with all employees and the sales manager to stive in decreasing turnover, retain quality employees, and provide 

knowledgeable lberiback on impeding concerns anti/or questions. Help to drive a high-performance sales team and culture 

throughout my role and partnership, 

Employee Rating; 3 - Meets Expectations 

tiger 3 - Meets Expectations 

Rating: 

Weight: 15% 

Created By 

Lost Modified By: 

■ 

Template 

Jacob Brisecie 

02/13/2012 11:39AM 

05/03/2012 10;08AM 

1ncren ,.. nw the local butt.tt •s e.g. within it, oTT• • l--., et, , to fir:. t, and 

innovative Wr./.9 or rn- traying company goidelin CKpeC J0118 in a positive an 1-Llp to iilake 

an impact and improve the safety results in our local locations. Partner with location leadership to drive down TOR and 

DART. 

Employee Rating: 2 - Meets Expectations 

G&K0001 30 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 318 of 505
Manager - 3 - Meets Expectations 

Rating: 

Weight: 15% 

Created By : Template 02/13/2012 11;39AM 

Last Modified By ; Jacob Briscoe 05/03/2012 10:08AM 

D c,crIptri .1 This objective is defined by you and your manLger. Your document weights must equal 100% to save 

prop,..t 

Employee Rating: 

Manager 

Rating: 

Weight: 0% 

Created By: Template 02/1312012 11:39AM 

Lkyi ■ Ai.ing: 2 - 

. VAnager Iating: 3-Mee' ; Expectations 

, Summary Weight: 100% 

I Employ( Rating; 2 - Meets Expecflions 

, Dildtiagw kdiing: 3 - Meets Expectotions 

Significant 

Accomplishments 

and Objectives 

Manager 

Comments: 

DcwriptiL:u ius s, .:cti...11 to .0 three of your .;.1 -:see of your 

Comment c 5 . uut successes and ct 11eni r• 's in these area , . This sectioil ie mr .at to generate gc,..deonver iiion be veer: 

manager and employee and should be a starting point for an individual (I evelopment plan, 

Strengths/Opportunities I believe a strength of mine is being .knowledi;Lieble on OK Policy and Procedures, continuosly 

developing myself as an individual and staying up to date on HR knowidge and changing laws and regulations. Prioritize 

and manage my HR role on a daily basis and complete task and ftmetions, I. have built numerous positive and 

communicative relationships on an individual level within the local employees and management environment. I have built a 

strong HR relationship with peers within my region and utilized them on a continotis basis for support. 

I believe an opportunity or mine is to continously build a pipeline of candidates and provide bench candidates for the sales 

department in the future. Work more closely with regional HR. recruiting manager on obtaining training and instruction for 

Oxicon result evaluation and defined recruiting aspects for the sales role. 

Employee 

Comments: 

Created By: 

G&K000131 

Twilplute 02/13/2012 II:39AM 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 319 of 505
Ivianager 

Comments: 

Brandy - you are very strong when it comes to your understanding of HR issues and the 

legal aspects that are often over looked by lino managers. You are a strong addition to our 

team and you can help develop the managers in this business become better in their roles 

as leaders. Your work on helping drive our pipelines has been critical and will be an 

important aspect in helping us drive strong business performance. Continue to drive these 

efforts. 

Suctir)1L4-eSiv!atul es 

Cr:J.:y(1 By 131201 11:39:3:JAM 

Last Updated By 05/03/2012 1:25:04PM 

Acknowledgod By 05/03/2012 1:25:04PM 

Completed By: 05/03/2012 12:27:27PM 

G&K0001 32 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 320 of 505
EXHIBIT E

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 321 of 505
Perft? tinAttee DDeurnerit - Gic_perform 

Man ager Evaluation 

Brandy Williams. 

GK pcc Form 07 01 2 '2 - 06'30 211.1 

Author: Ruche& Si ggerud 

Salim Coraptcled 

Appro yd.: Nor Re quired 

The ducufnent status is Complcicd. 

Rotel Manager 

Duc Date: 08.30/2013 

After returning from IVIaternIty Leavein October I am workin g on emersing myself beck into 

the business I have g ained updates from all mana g ers and formed a game plan with each 

department for staffing and support metrics. I have worked on postin g req uisitions for all 

open positions to support currant business needs. I have supported all amplo yeeS during 

open enrollment end the transition to the new model of health plans. My continued goal for 

year end is to reduce turnover in service and sales and meet headcount goats. My goal Is 

to support the new sales manager with now sellers in the business and throu g h smell start 

training and ramp up Also, our team is focusin g on safety and safety improvements in the 

business with monthl y safety meetings scheduled with the plant mana ger. We feet there is 

an opportunity for Improvement with safet y In se rv ice as there have been injuries that could 

have been pmvented with proper safet y measures. We will continue as a teem to plen and 

'nriplernent new safel y measures to decrease Injuries b y additional training and awareness 

and using our newl y implemented wheel of safet y for participation to decrease injuries, 

Mane 

Corm rit*. 

sect.in na-CK pericr m Qbjective l 

, • . 

Desr ri lion This is a taco p rating and will be given to you either by yaur location's :tanager or through en entail for 

corporii.c canployees. 

Ertipliie Raring; 5 - Outstanding 

hlann:;i , r 5 - Outstanding 

RAtinr.: 

Ln:;id By : Tcrripluo.3 0712r1/2013 2 :silo 

Last r.iiFied Li Racliae:1 Sig,genud 07!26/2013 1;0 tPhr 

Deseriution Customer Focus 

lutegric: 

People I velopment 

Opeir ii 

Exeetni , , 

Entplo,, vc limin g : 4 - Exi.:ccds Expectations 

Mat I; 2 • Below Expectations 

Ratio

Weigh: 25 . 

113 Tonp1iL 1)7..;(;.'?. ■■ 1.1 2.1.31Prst 

11cd fly. ii.Ack3c1Siggcrw..1 WI/ ZYT21 , 13 .11,11BM 

Sceti u n 1 - Mid-year Comments, 

•.r • • 

Sigratlant 

Accolopttshments 

and U)jectives 

MIseer I: 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 322 of 505
Boer ;ptina Leadership Devi:hipment. 

Supprat and Upeuti.: LL;IfiletS Mt =id thc coach to win model support newt leaders and help ta gain kowledge nroand 

Performance Management Another goal is to focus and drive leadership development through develr)ping prgrams by 

providlog clavsroom training, iintids on iraring with a tremor or CDOcti, experience or expillire based trainiag, and cross 

functi:)aal rain lag, 

Niy r0:11” glut it to it Tl p Stippurt manager; lvttl Ta Niunagcm;•ot and to tracuiriphslt triune tbrotgh others of OM' team by 

sharper nig skills oa: 

•Effect , ve Management, Skil s 

-Contliot Management 

-Teem :lidding 

thlfittrnce itgegrigintion Skills 

-CL; no conic:anon Sktlls 

-Time \Inn:igen:en' 

-latervlCW SkIlIt 

Ii; '0:1111 

-Plant ii 

-Motivabon Skills 

vu Rating: 3 Meets Expectation's 

Mannityr I - No; Meeting 

Rath, F.xpectattons 

Weii:n 1: 2 LP 

:5 riy Trariplitic 072&'21t13 2.1$.F.tvi 

.;;;; ladrfied By RachaidSiggemd n7r2ti 2013 3:011i lkt 

lit ii Talent Management. 

:. Meat with I itiers monthly to raview an update? block 

2 Llpita:c IDP's üi ill gmen box laical with leaders 

3. le hi-weekly Intretings 0,111 :adcrs to develop assignments for IIPE 

A comi,..ous goal is ill be to support leaders to drive offecitve perfarmance management by providing feedback to empluyeas 

As a 1i..]1i I will work to ensure thin leaders arc working with atnployccs to cuts are they arc an thc right track far c.ontplution 

01 0011:, ',nclivirlual goals are aligned with oor ornanizatcon's goal.tnit Lore valites, and that our ican, and erriployce'.; reettisc 

the sur,ott Iboy need to he successful, I will continue to aya,-..h and provde feedback on effective performance management. 

develnoinern oppportuairics, 114 to identify low performers and address and esidoute the impact on the buslacss needs. 

active ly participate in weekly growth inee.iings to help leaders nionnor and improve has item opportunities and revenue, 

spend n 111C ULV fii;lt in the field with turritoty sellers, route managers, route stiles reps. service null tiger, soleb MarlfigCr, 

Qtc lea, be key tinotvaialsOf tile hastness to build my overall relationship and have a functional grasp and understanding 

to supp,at the financial goals or the 'nosiness arid icam as a whole 

Employ . co. Rating: 3 - Meets Expectations 

Matiasr 2 - Below Expectations 

riarin t;: 

:514 

Fen/plate 0712612913 2:18n1 

Lam iodiricd Ry Ractowl Stggenol Cs:.11.1013 1 22ANI 

Der null Princeting the business: 

eadcrship kro ■ vIcilge of OFCCP 

..lievelo leadership knowledge of F.1:0C roles ikrill cloirn 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 323 of 505
leadreship knowledge on how In itvoid Union issues 

LI. Una Tel* infbrmation mound the NLP,...A and. llte impartanuc within a business 

with leaders to ensure we art OSHA ready 

a. location safety mectingskummitics 

b. Prov:.ic new ideas and actinn plans for sakty improve 171Clf metrics 

,ProviS, knowledge around other irnnortrmi employment laws such as' Civil right": ant, state human riOts act, ADEA, ADA, 

ADA,A 2005, .1:M1„A, Cnlfcrniri Medical Leave Ad. USSERA:Affirmative A elicit. 

Eropl: ett Rating: 3 - Nlerts Expectations 

firtatifi.;ev 

Rut in 

Weir,t!it 

Cre.,-.:1 By 

2 - Below Lxpectations 

Tow Melo 

Raehaei Siggenid 

07126/201.3 

Q25fZ(}iJ 9;22AM 

' 0 

lion this :hjerAire is da Prod by you and your manager. Your document weights must equal 1(}0% to save 

propel l yEmpli , no Rating: 

Maw.. 

Crc.oc,ithy Template 07/2612013 2 HMO 

1)eset;pf inn This nbjee .e is defined by you and ynur manager. Yruir document weights must equal WO% to save 

propel 

Em pt vie Rating: 

Rrj Ii ii 

0' 

By To-apt:nu 117/249:211 2 18PRI 

Empl.. ne Rating: 4- Exceeds 

Expectations 

Marta,-r Rating: 3 Meets Expectations 

Sumn,ry Weight: 10fi% 

Seetti .1 3 - Year-end Overall Review 

f • 

4 - Exceeds 

Expectations 

2 - Below Expectations 

Overall, sales headcount has been achaived by adding talent to the sales team and 

recrtfting and filling TSA's positions for bench strength. We also Increased effectiveness for 

staffing purposes in the service department by hiring new talent and developing a new 

add tional route lids year has been quite a transition and challenge. I have worked 

diligently to ensure that ell leaders end employees were supported through the transition 

process and fully understood and had success with the Employee Solutions Center. have 

transitioned to be more of a strategic business partner with leaders of the business. I hope 

Empi Rating: 

Mann .r Rating: 

Stoll - ant 

Accei-:;Ilehmenta 

and ;actives 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 324 of 505
to continue to gain trust end build releronships with the LA and Phoenix groups. 

Mena., Brandy, 

I am very disappointed to see that you have not completed anything in your GKperform 

document, although we have spoken about .t on several occasions over the past month. As 

you are well aware, based on our previous conversations, your performance Is below 

expectations for the role of HR Generalist. A great part of that deficit is resulting from (ha 

ineffective relationship you have with the Phoen.x leadership team, You tend to make 

excuses to expla Ii constructive feedback and are not receptive to coaching. Some specific 

examp'es are this document, your GKperform being Incomplete, you did not complete the 

gameplan document to set expectations for your support of Phoenix and LA as we had 

discussed, you have exhibited ongoing concerns around managing your calendar and 

accepting Invites, being on time, and often take significant prodding to complete tasks. I'm 

also concerned with the lack of initiative you have demonstrated with respect to bringing 

new ideas to the tatee about how to make the HR Generalist position successful and 

valued. A critical part of this role is creatively seeking to introduce leadership eoeching, 

Identifying areas of opportunity and bringing solutions to the table for discussion. 

The changes in our HR orgenizetion have not necessarily been eesy but so much of what 

can make or break a transition like ours Is the ability of the individual contributors to 

effectively manage through the change and shepherd their leadership team through the 

same. If you are to ha successful in the HR Generalist role, you must build strong working 

relationships with your local leadership team in the same way you have done in the past 

with the employees you interacted with es part of your HRR position. I believe that you have 

the ability to effect change and be a strategic partner in your locations end will continue to 

support you on (hat journey as well as explonng other options should you feel there is 

another role that Is a better fit for your skill set. 

St!etiti • - Dvvelornavni Gnat and Rclycatinii Pruferuneee 

treieri., ,.ian Use this section Co your development goals COI-7VMM on your succtssm and challenucs Please includc if 

you arc !ling to relocate., and if sn, your .e.ii6..raphical prefercnce 

•;;.:c,co is n1t:;1111 ii ge.::1Ualiz berwern manager ond employee find ihould be u suninii point or an 

iodic it; I development plan, 1::;e this ml rue to dis,cus development; present and future. 

t will continue to help obtain high potential talent in the business groups, focus on kcy mi-cries fer 

financink unit objeotvcs for the bri.doess. ( hope Cu inercase my (11/Cra II Init.- jai nntiCriti ■ ndi no, of 

the te.e,ieee., whom: it come, ,o time Prurii mud Loss ;101erritin of the busiticir,;int. I will continue to 

increase Jnt'. drive change Warta itenteri t e oh in ile 1u rgan i, otion I feel ii challenge I wilt continue to 

iniratise upon is ;4) improve positive employee relation 3rrategici, I will base my effong on building 

mutual rospeet, rIni and elluitable trntamli, mutual MASI, and epeit arid hoacct communication by 

being,;.'.untinuously engtNed. I will continue to build relationships by :ell-Toning leuden; in making 

ditektons arid taking risks. I will demonstrate trust in the the competence of (coders end empower EmpiL thcin ci lnke uf the svork they do. 

Ctomm. - oist 

Overall I thoroughly enjoy lily career at C & K and look forward to working with lenders and 

contir.ously provide employee support and development! I look froward to taking or. new task ard 

tcrnporanly helping m support recruiting cunteutly! I'm excited about The year Co come! 

I currently WIJUICI he icllert:sted if the oppunuoiry came upea ii huppo N I mcmi rocas in the coothcor crews 

r cc main port or of !be mid-cenn'al areti. My main interest would be the Dili' plains or seetheee 

(e.g TN, IT, TX, AR, MS, Al„ NC, entli 

Tcruplale 

Dev ent Goal and Relocation Preferences Summary 

Mana r 

Cemxr itst 

SQctig7: 5 - 5illnatures 

n -u Aft,'201,1 2;1 liPNI 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 325 of 505
r 

Created By 07/2612013 2':18:37PM 

Last Updated By . 08/2812013 12:46:43PM 

Acknowledged By 08/28(2013 12:46:43PM 

Completed By 08/2812013 12:42:42P M 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 326 of 505
EXHIBIT F

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 327 of 505
Performilnce D9curnetit - (;; Kserfortn 

114a)lager Evaluation 

Katla Ellison, 

OK pei form, 07101/2012 - 06/30/2013 

Author: it nchael Siggerud 

Status: In Progress 

Approvv it Not Required 

Role: Manager 

Due Date: 08/30/20E3 

Enter rnting5 iInd update comments in the roiew stunt -nary, Iswcll ai thc strengths nod opportunities sections. Save ent rim 

made by clicking the Savc boron, once you have held the enip1oyee review, click the Mark Review Held Minim This wi 

notify die employee they ran Lick nowledgc receipt of the review which completes the process. 

Scction- Mid-year comment 

; 

- 

SIgnIfi ;mit Pay cards: Part of the pilot program, but got a late start due to annual enrollment and the 

Accoti , rillohments holidays. We had some minor .ssuos with system entry at Corporate and a couple hiccups 

Ond 0 1-jectives With employee activation and card distribution. 

Production Pay: I completed the proposal for plant pay to keep us competitive with the Mpis 

union Andy approved, but I haven't heard back from Chuck yet. We discussed rolling it out 

in July after the new fiscal year planning. This objective is not complete yet. 

New Role: I still don't really know a lot about my personal role undere the new HR 

structure, but I have been constantly communicating with all my managers and a little with 

employees to prepare them for the change I have been handing out the HR Solution 

Cantor number if it's on issue I would have to call them I'm having the employee call them 

directly instead. I have been using the Solution Center Instead of call people directly. 

Annual Enrollment: Probebly the biggest change we've had all year. It wee a lot more work 

on my part than It was when we had paper sheets to turn in. I don't think the process was 

as smooth as it should have been. I think we had a lot of communication/understanding 

Issues on how to enroll and what documents needed to be turned in for verifying 

dependents which resulted in me helping a lot of people, t did not make the first goal for the 

HR bonus. I thought the expectations ware unrealistic given the time frame, size of our 

location, and holiday week, Employees were ready to make elections that soon In the 

process and I was not going to force them into rushed decisions. I did meet the 

requirements for the second HR bonus and in the end we had realty good participation 

numbers. 

M arlittpr 

COM in n ran: 

totally agree with your assessment Kaela but would add the following: 

'I. Solid feedback and leadership as it relates to employee issue resolution, union 

advoidance and employee development, 

2. Key role in Gus development and documentation process 

3. Safety lead and incredible assistance. 

Will be MASSIVELY MISSED IN YOUR PRIOR ROLE, 

&CAW] 2 GK perform Objective 

Description This is a group rating and will be given to you either by your location's manner or through an email for 

corporate employees. 

Employ Rating: 4 - Exceeds Expectations 

Mantig; r 4 Exceeds Expectations 

Rating: 

Weighi: 25% 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 328 of 505
Crea:cd fly Terriniiie 02/0412013 56,1!1/44 

Lo 1333:333ific31 By Radiael Siggcrutil 07,r3 lr2Ol 959'\M 

r- 

- 

1)Citr 333:Elfin Cuin El ICr FOCUS 

ILIlgJ 3' 

People Davelopnlent 

Open 

Execution 

Employee Rating: 4 XCCCC1 F.xpeintions 

rstfunner 

Ralf nlis : 

crc;nc,1 Dy 

1. 0 0 NI,13311-333I Fly 

- Ni eels ExpeenRions 

25 

Template 

Rachel Sillgenid 

01:08;2013 8 56A3e1 

37/31 10)3 I 

Doeriptior Suceessfuily transition employ i:eq to pay Cflfd 

331113)/(9'1"3: Ratillg: 3 - NIeets Ex:put:in:ions 

Man :11:333- 3 hleeo Expec:atinns 

IDO l 

Ratio 

Crl! AS Ely 'Ferndale 021)8,1,013 8 Stiiktiii 

3-3.33 '.i,hIk1 Fly Andrew Johrt.or. 9,1108/2013 9.02AM 

' 1 I • 0 

DeSerili3.13311Sirtiptify prnrioe Ii eEl new hire illeerilive pity 

Emphiet: Rating: 3 MeCD Cxpeetations 

Amager 3 Meets Expectations 

Rating:: 

CICOLI 

\Yell; 15"ri 

tly Template R2/08/2013 8 - 56A11 

lost !.43333i133:13 By Antlrev,..ltikinon 02/C 8,1013 9 . 02/01 

'I.. 

Demerip trio Lin cierst and new role so HR Generalist and help effeep ,'ely trarisi1 on employees to it'd: dramatic Ilk Ow nge5. 

Ernpin:re Rating ,. 3 - Meets Expeetztions 

NItaittror 3 - 14.1ets Expectations 

kitting: 

5".4) 

Cs.mla its 1-51111110(5 2 04 . R•56ANI 

Lot P'otliticd By Anther/ Johnson 2/' 1112013 9 02ANI 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 329 of 505
MCCI3 Expectations 

10% 

Tcmnlalc 

f.1..,d1:ied H y RucluicISiv,gornd 

Descr lotion Tratu;i ion employees 10 new paperl ess annual crorillmetit pruccss 

Ernp:oyno Hating: 4 Extends Experliorni 

Nix6,*!tr. N1ti EXpc vlanorls 

Ratiry,: 

10 

Cr1711 fly Tenw!nit, 011th:12013 H 56AM 

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I r, k 4 

DescHotina CompluoV Illock 

ElYilfloycc Rating; 3 , hiceu Expentatium; 

0210;1;20 I :1 ii 5 6 A hl 

0711/7.013 9 59AM 

s Ai 

Empl-yee Rating: 

Man Rating: 

Surrw it Weight; 

4 - Exceeds 

Expectations 

3 - Meets Expectations 

100% 

Sqctic - Y ar- end v ers j1111.±1.02)s.v.. 

qk. . 

Emptcys:e Rating: • Exceeds 

Expectations 

Mana:.,iir Rating: 3 Meets Expectations 

Accinf•plishmente 

and Cj.juctives 

Mane Kaela, 

This year has brought a lot ef change to your role in HR, While it hasn't been easy or 

comfortable, change is a part of shaping who we are as professionals and Individuals and is 

a valuable learning experience regardless of the outcome. 

With respect to your Objectives #'s 1,2 fis 4: you supported these initiatives MU and 

demon'strated a said understanding of our compensation practices and needs in the Twin 

Cities market. 

Your biggest area of opportunity over the past six months had really been around support 

and championing the HR Realignment. I know that the changes were tremendous and that 

we didn't have the ability to involve everyone in the design phase for the new model. Where 

your support has been less than enthusiastic. Our leaders pick up and carry that message 

internally end to their teams. Managing the change successfully with our leaders is a 

significant part of having a successful transition and in order lo do so, I need to you be a 

positive champion for the process while helping to facilitate improvements where they come 

to light. I have seen a positive shift in your leadership since we spoke on this topic arid I 

look forward to your support in the next fiscal year as well. 

Some of your accomplishments that stand out for ma in this second half of the year include 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 330 of 505
oompleting your Master's degree while working full-time (no small feat), developing a full 

twining around "It's My Company Too' and facilitating it throughout the MN businesses, 

developing and presenting your "Giraffe in the Refrigerator' deck and your ongoing work on 

safety culture. I continue to be so impressed by your creativity end initiative! 

I look forward io having you as a part of the Generalist team in FY14 as we continue to 

develop and define the role as a strategic business contributor and partner. 

SciLn 4 - Development Goal anti Relocation Preferences 

.L7 ' • 

Deaction Ilse this section to list your developmcnr gnats Comment on your se ecess es and challenges Please tutu& iF 

you to , willing tu relocate, and if so, your g cogruplucul preferences. 

This s;:t:t km is meant to generale good cot versn ion between manager and ern ployec and should bc . siitirting point for an 

development plan. Use this time to di cu AS development; present and future, 

Em p3 vire 

Cam:rte./its: 

Cr1 By 

Menu r 

Canon:ffits: 

02,i1A.',10'. 1 A StANit 

I 

I would absolutely bless you for a immediate promotion - you are incredible end highly 

talented. I will miss your consisient engagement arid selfishly wish you could remain on my 

teem BUT I realize my loss is the companies gain and businesses like St C'oUd, Mots 

Industrial and Linen will great!y benefit from your expertise 

Best of luck. 

&grit; 5 - QSigoattorn 

Created By Andrew Johnson 0210812-01 8 66 10"AM 

Last Uptiatod By . 07131/2013 1:14:21PM 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 331 of 505
EXHIBIT G

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 332 of 505
Eir-flif 11 IICC DIgli(11101t- Cri( perform 

Man ager Evaluation 

Janelle ilonnotta, 

GK porforrn, 07 01 2012 -06 3!: :113 

Author: It.achrial Siggerud 

Slam: In PrOVESS 

Appravat: Not Required 

Role; Manager 

flu s Date; 08130/2013 

Enter ratings and update cornmunni in thc roview summary, its well as the mrengths and opportunities seetiony. Save conics 

made by. clic:Icing the Savo bounn. Once ycli have held iire employee review, click Ow Murk Review I-kid button. This wilt 

non fy 11w employee they can acknowledge receipt of the 112V1LVA.• MIMI comp! etas iho process 

Sect i n - 'Ii-y car Coniijivnt 

Significant -Recruiting - Ned all positions/needs tilled as requested thrOughout location 

Accomplishments -JJ Kellor - brought JJ Kellar percentage up to 100% for both hiaywardlPittsburg location 

and pojoctives -Safely compliance-Helped to drive Safety Awareness through strategic planning and 

Mann: projects (pad of the safety committee) improved our overall metrics. Under the 2,5 TCIR 

Rating for company wide. 

-Successfully organized and planned events throughout tha midyear, flu clinic, 100% annual 

enrollment rollout. PY2013 event 

-Location organization-effectively assisted weekly/monthly activities for location for 

organization purposes, such as reports (vacaton/payroll), (Learning and Developmentcourse completion) 

Manavr 

Comniinali; 

Work in ProgressNeeds improvement on Pcaml, still work in progress-final goal is to streamline pcard 

approval system arid remove violations .. 

Janette, thanks for organizing important employee functions, le Flu Shots arid Annual 

Enrollment. Payroll accuracy has improved over your tenure There is still room to improve 

sales commission sheets each month so that they are correct the first try You started off 

well with recruiting when you first started but when we needed strong activity most recently 

yOur attention to recruiting softened and today (Fob) It has ceased well before the transition 

of Feb 25th. I want you to speak up when you ere unable to complete a task or directive 

rather than riot do what you are told then explain yourself if it comes up later You pay an 

important role on our team arid everyone counts on your influence and contribution I'm 

looking forward to your Influence on the second half with upcoming changes in your role and 

how you will help us grow. I'm asking all department heads 10 engage you with stronger 

developmental plans for their teams, specific by individual employee that targets reel 

actions to improve skills and raise our team performance. This commitment is ongoing and 

a basic building block to support promotions from within and ultimately grow our 

organlZation. 

Suction 2. CK perform Objectives 

Oescriplhin This is a group rating said will be given to you eittr=r by your location's manave: Dr through an craml fur 

col-pot-01e employees 

Empluyce Rating: I - Not Mee - ng Expectations 

Mar:at:sr I - Not Nick:ling 

Ratint: Expo:rations 

Weight; 25% 

creacea uy :molatc 0:11.v2 , 1[11 $".7 1'NI 

Los( t L,dIIJciI Oy : :tat Ilaulesiy 02'15 1i)it i i .SS M 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 333 of 505
Dexeripion ctistarnes Focus 

1ntE!wiry 

Peopi ..! fIevelopment 

Openn::::s 

Execurint) 

Employee Rating: 3 tslecia Expueta( on 

Mulinger 4 - Exceeds Expectat ons 

Ratiag: 

(2r,:anci Templdt. 02/14/2C t3 

LAI v,),1 r.i ay Rttchac:. ;iggvnLci 07/25f201) 12.56PM 

Descrin it] in Recruiting-New goai, TSP.. arid Scrvice Staff -Inv, 

Employee Rating: 3 - MactS Expectation 

Mimi:ger 3 Meets Expectaliuns 

Rating: 

weigkr: JO% 

Crualca Tuniome 02 14 2C I3 7:5 7 NA 

lied 13 ItacIllaciti;iNcr114 07 251200 12 51■ PNI 

Descrjr“ ion Leaden:41;p deyelop men New Ro:c 

Serve n liason berwcen ernploce end manager in support Men) w:th bringing forw(ird tulent. Provide with Ole 'Doh> 

neCex:( a(y sttccceding 

Employee Ibiting; 3 - Nee :s znectarionS 

filnniager 4 Euxeds Expeennions 

Rnting: 

Weigh ' 

Crew...dB 02 14;1(3 7 371'M ," Tcatr. 21 

Lao N-1,\111Ic4 Ely flaciocl Siggurud 07/23/2013 2 50'0, 1 

Dexcrip ;Oil New aRer Realignment Rode and sales rnicalungs Lean) (non: Atm: the ptnitions to Cuily engaue ink) 

training and ,le:yelapnwn1 

Emplaver Rating:1 - Nicer.; Exist:II:Wk.:rim 

Nlana;:er 3- "vtems F.Kpectntions 

Rnting: 

ercalet1 Ily Tcllplrtll 02 14:20 13 7 571ns) 

Ins'. fly R 11:1 ,...1 Slop:nal 07/252013 2 56PN1 

Description Cornintvz rn improve si y metric; tilroqboat Mean:la improved as a ocation prior (e) be pp:A . 1011.S year 

114:21pini c1, 1 nam! arcric% ,, 110-000 sat'ety 'cam proje‘t, ,:cutonabilily our int:Minn W.V. removed mil of l'ae 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 334 of 505
button, 

CInpin.yce tiny,: .3 • IMecti E..-7 XpeCintiOnt, 

Man,■ ;: r.r- 1 - ltt F.xpcotaiioni 

10',41 

Cri1 f Ey Tcrnpl;lic 

Ily ScrAl iailtiSly 

n21i-l.e2013 7.571M 

02/15.QU1 3 :1 52!AM 

Desv r ip ion Sue cce sRion pinaning4Vurk riven planning partnering up with recali!crS in now IIR Model to vnsurt 5tabk. 

tcanis :nal Iii potions, 

Firaproire Rttkg 3 Mcd3 Expechvions 

Alunagcr 4 . Excectl, Expecrations 

Rail niii 

100 

Cr:w..3 fly . "3"cmphc,: 0211.1.tDi 3 7 I'M 

Laq v.t\lincd Ely Rac hod 07,15(2013 [2 56PM 

Emplriyaa Rating: 3- Meets Expectations 

ManaQ r Rating: 3- Meets Expectations 

Surnmilry Weight: 100% 

Sectiorl 3 - Year-end Overall Review 

Emelt,ru Rating: 3- Meats Expectations 

firlana;1.,.r Rating: 4 - Exceeds 

Expectations 

SignEZiu nt Helped to drive iGrow partidpa lion In location, overall two out of 3 RM' s achieved growth 

Accon , Plishmonts goal and three RSR's as well hit their bonus, 

and Oi ;:lctives 

Missal rI. Safoty metric improvement, 

Facilitated in Onboarcling process. 

Constant recruiting support. 

Manap.c.r 

ConnmiiraN: 

Helped to Identify root cause turnover problems throughout location. 

Janette, I have been very Impressed with your growth as an HR professional since you 

came on board with G8,K. Aithough the HR Realignment was a challenging transition for our 

whole company you have been a very strong partner for your locations both before the 

transition and today and you are a valued part of our regional team! 

I continue to be impressed by the initiative you demonstrate on a frequent basis, including 

(but not limited to) muCh of the work you did around driving the Gain and iGraw initiatives, 

taking developmental HR classes, partnering closely with recruiting to help the businesses 

get to headcount but wilh the right people and really driving the changes around our RSR 

SMART Start/training and on boarding process to ensure that our folks are off to the right 

start! Continue to locus on building your confidence in working with leaders, you are very 

capable and provide tremendous insight end support to your teams end they recognize it! 

With the leadership changes in NorCal, lets continue to focus on building a really strong 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 335 of 505
Corn n 

02/14/2013 -757:001* 

07/2512013 12:56:47Pfsi 

Created By 

Last Updated By 

understanding of our financial picture for the consolidated businesses and becoming more 

integrated into the Sacramento team - you are off to a great start, so let's keep building on 

that progress. 

I truly enjoy having you on my team and look forward to FY14t Thank you for all of your 

diligent and hard work this year! 

Section 41- Development Coal and Reification Prcfcrcacvs 

' , - 1, H 

Dvsvrion u5c1his sect kin to list your thyetopmear goals Comment on your SUcce5; n and cliallenr:es. Please include if 

you are willing to relocate and if so, your graphical preferences. 

This section is mans to gs.ncrate gnod con .iersation between mimager and employee iind should be a Nturtirti point for an 

indivisinal development p an. Use this time to discuss development, present and future. 

Deve.op more es a HR 13uairiess purtner to support the needs of the business throughout. Inspruve the 

overall process and workflow attic businesses through streamlining. 

Empinyte 

Canninentio Continue to participate in ongoing internal training provided by the company as well as external 

resows ea, build knowledge on Ilk 1.3esinchri Partner role and strengthen experience. 

Improve turnover ratings its Northern CA through exit interview assessment, coact stig sit discipline. 

Template 02/ 4/2013 1;57PNI 

Janalte, I are happy that you joined our team. I'd like you to work closer with the 

department head leaders. This is your peer group and much of our success hinges on their 

partnership with you to drive performance across the business. 

Sla.tiVt - eSignfttkireS 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 336 of 505
EXHIBIT H

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 337 of 505
Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

Rachael Siggerud Raskovich - May 11, 2016 1

 UNITED STATES DISTRICT COURT

 FOR THE DISTRICT OF ARIZONA

 Court File No. 2:15-cv-01744-DJH

 - - - - - - - - - - - - - - - - - - - - - -

 Brandy Williams,

 Plaintiff,

 vs.

 G & K Services, Inc., a Minnesota

 corporation, Jane and John Does 1-100,

 Black Corporations 1-100, White

 Partnerships 1-100,

 Defendant.

 - - - - - - - - - - - - - - - - - - - - - -

 - - - - - - - - - - - - - - - - - - - - - - -

 VIDEOTAPED DEPOSITION OF

 RACHAEL SIGGERUD RASKOVICH

 May 11, 2016

 - - - - - - - - - - - - - - - - - - - - - -

 Prepared by:

 By Kelly A. Herrick

 Notary Public

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 338 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

Page 2

 1 APPEARANCES: 

 2

 MILLS + WOODS LAW PLLC

 3 5055 N. 12th Street Suite 101

 4 Phoenix, Arizona 85014 Phone: 80.999.4556

 5 Email: Rmills@millsandwoods.com 

 6 By: Robert T. Mills For the Plaintiff

 7

 

 8 STINSON, LEONARD, STREET 150 South Fifth Street

 9 Suite 2300 Minneapolis, Minnesota 55402 10 Phone: 612.335.1770 Email: Kristin.parker@stinson.com 11

 By: Kristin Parker 12 For the Defendant 

13

 

14 Also present: Joe Mildenberger, Videographer 15 Donna Fox Carrie Hund

16

 

17

 

18

 

19

 

20

 

21

 

22

 

23

 

24

 

25

Page 3

 1 I N D E X 

 2 Examination by Mr. Mills 5 Examination by Ms. Parker 214 3

 

 4

 INDEX OF EXHIBITS

 5

 NUMBER DESCRIPTION PAGE

 6

 Exhibit 01 Compilation exhibit 40

 7

 Exhibit 02 Handwritten notes 111

 8

 Exhibit 03 G&K000302-326 118

 9

 Exhibit 04 G&K000437 144

10

 Exhibit 05 G&K000261 149

11

 Exhibit 06 (Withdrawn)

12

 Exhibit 07 G&K000259-60 165

13

 Exhibit 08 Transcript of conversation from 14 June 26, 2013 171 

15 Exhibit 09 Transcript of conversation from July 17, 2013 179 16

 Exhibit 10 Williams-00088-128 188

17

 Exhibit 11 G&k000273 207

18

 

19

 

20

 

21

 

22

 

23

 

24

 

25

09:19-09:23 Page 4

 1 THE DEPOSITION OF RACHAEL SIGGERUD RASKOVICH

 2 is taken on this 11th day of May, 2016, at

 3 Stinson, Leonard, Street, 150 South Fifth

 4 Street, Suite 2300, Minneapolis, Minnesota,

 5 commencing at 9:22 a.m.

 6 THE VIDEOGRAPHER: We are on the

 7 record. The time on the video monitor is

 8 9:22 a.m.

 9 Here begins Volume 1, Video

10 Number 1, in the deposition of Rachael

11 Raskovich in the matter of Brandy Williams

12 versus G & K Services, et al., in the United

13 States District Court for the District of

14 Arizona.

15 Today's date is May 11, 2016. Our

16 court reporter is Kelly Herrick. My name is

17 Joe Mildenberger, certified videographer

18 representing Coash & Coash.

19 The video deposition is taking

20 place at Stinson Leonard Street Law Firm in

21 Minneapolis, Minnesota.

22 Counsel, please identify yourselves

23 and state whom you represent.

24 MR. MILLS: Bob Mills of

25 Mills + Woods. We represent Plaintiff,

09:23-09:24 Page 5

 1 Brandy Williams.

 2 MS. PARKER: Kristin Parker of

 3 Stinson, Leonard, Street representing G & K

 4 Services as well as Ms. Raskovich.

 5 MS. HUND: Also present, Carrie

 6 Hund.

 7 THE VIDEOGRAPHER: Would the court

 8 reporter please swear in the witness.

 9 RACHAEL SIGGERUD RASKOVICH,

10 A witness in the above-entitled action,

11 after having been first duly sworn,

12 testifies and says as follows:

13 EXAMINATION

14 BY MR. MILLS: 

15 Q. Good morning.

16 A. Good morning.

17 Q. Could you please state your name for the

18 record.

19 A. It's Rachael Raskovich.

20 Q. Were you formerly known as Rachael Siggerud?

21 A. I was.

22 Q. And when did your name change?

23 A. In 2010.

24 Q. 2010?

25 A. Correct.

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(1) Pages 2 - 5

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 339 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:24-09:25 Page 6

 1 Q. Okay. And have you ever given a deposition

 2 before?

 3 A. I have.

 4 Q. Okay. How many times?

 5 A. Once.

 6 Q. And can you give me a general description of

 7 what that case was about?

 8 A. It was an employment case.

 9 Q. Did it involve G & K?

10 A. It did.

11 Q. When was that deposition taken?

12 A. 2010.

13 Q. And where was the case pending?

14 A. In Minnesota.

15 Q. Were you a party to that lawsuit?

16 A. I don't believe so.

17 Q. Was G & K?

18 A. Yes.

19 Q. Do you recall who the lawyers were?

20 A. I don't recall offhand. I'm sorry.

21 Q. Do you know whether Stinson Leonard was

22 involved in it?

23 A. I believe Leonard, Street & Deinard, at the

24 time, was involved.

25 Q. Okay. Do you recall whether it was a

09:25-09:26 Page 7

 1 lawsuit that was brought by an employee of

 2 G & K or a former employee of G & K?

 3 A. Yes, I do.

 4 Q. And what's your recollection as to what the

 5 allegations were in the lawsuit?

 6 A. Oh, my goodness. I believe that it -- I

 7 don't remember. I think it was potentially

 8 wrongful termination. It's been quite a few

 9 years.

10 Q. Did the case get -- strike that.

11 Did the case go to trial, do you

12 recall?

13 A. Yes, it did.

14 Q. Did you testify at trial as well?

15 A. I did.

16 Q. And was that in State Court or Federal

17 Court?

18 A. I believe it was in State Court.

19 Q. Do you recall how that turned out?

20 A. Yes, I do.

21 Q. How?

22 A. G & K did not win.

23 Q. G & K did not win?

24 A. Correct, or the other person did win.

25 Q. Do you recall the name of the Plaintiff?

09:26-09:27 Page 8

 1 MS. PARKER: Objection: Relevance.

 2 THE WITNESS: Yes.

 3 BY MR. MILLS: 

 4 Q. What was the name of the Plaintiff?

 5 A. James Dubiel.

 6 Q. Spell the last name.

 7 A. D-U-B-I-E-L, maybe.

 8 Q. Was it a jury trial?

 9 A. Yes.

10 MS. PARKER: Objection: Relevance.

11 BY MR. MILLS: 

12 Q. Do you recall how much money the jury

13 awarded?

14 MS. PARKER: Objection: Relevance.

15 THE WITNESS: I don't.

16 BY MR. MILLS: 

17 Q. Have you ever testified in any other case

18 other than that one?

19 A. I don't -- no, I have not.

20 Q. Since it's been a little while, I'll go

21 over, just very briefly, a couple of ground

22 rules for the deposition.

23 The first one is if I ask you a

24 question and you don't understand it, just

25 tell me you don't understand and I'll try

09:27-09:28 Page 9

 1 and rephrase it if I can.

 2 A. Okay.

 3 Q. Otherwise, I'll assume that you understood

 4 it when you answer.

 5 And the only other one is, if at

 6 any time you need to take a break, that's

 7 fine. This is not an endurance contest

 8 so -- the only thing I would ask is that, if

 9 there's a question pending, that you answer

10 the question before you take a break.

11 A. Okay.

12 Q. Okay?

13 A. Sounds fair.

14 Q. Are you currently employed, ma'am?

15 A. Yes.

16 Q. By whom?

17 A. St. Jude Medical.

18 Q. Here in Minneapolis?

19 A. St. Paul.

20 Q. And what do you do for them?

21 A. I work in human resources.

22 Q. How long have you worked for St. Jude

23 Medical?

24 A. Since October of 2013.

25 Q. Do you have a job title there?

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(2) Pages 6 - 9

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 340 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:28-09:30 Page 10

 1 A. I do.

 2 Q. What is that?

 3 A. Human resources business partner.

 4 Q. What are your essential job duties there?

 5 A. Provide HR general support to corporate

 6 client groups.

 7 Q. How many people do you supervise at St. Jude

 8 Medical?

 9 A. Two.

10 Q. Where did you work before St. Jude Medical?

11 A. G & K Services.

12 Q. When did you start working for G & K?

13 A. April 2005.

14 Q. What was your job title when you first got

15 hired at St. Jude Medical?

16 A. Human resources representative.

17 Q. What other positions did you hold while you

18 were employed at G & K?

19 A. Senior human resources representative,

20 HR manager, and regional HR director.

21 Q. When did you become a regional director?

22 A. Approximately 2011.

23 Q. Did you work anywhere before G & K?

24 A. Yes.

25 Q. Where did you work?

09:30-09:31 Page 11

 1 A. I worked for a company called Superior

 2 Search.

 3 Q. What's that company -- what does it do?

 4 A. Recruiting.

 5 Q. How long did you work with them?

 6 A. About five months.

 7 Q. And before that?

 8 A. I worked for Menard's, Incorporated.

 9 Q. What do they do?

10 A. Building materials, sales to consumers.

11 Q. And before that?

12 A. I worked for Macy's, Incorporated.

13 Q. What did you do for Macy's?

14 A. I was an intern.

15 Q. Pardon me?

16 A. I was an intern.

17 Q. In what department?

18 A. The computer-based training HR organization.

19 Q. And before that?

20 A. I worked for Famous Dave's of America.

21 Q. What did you do for them?

22 A. I was a server.

23 Q. And before that?

24 A. I worked for Abercrombie & Fitch.

25 Q. Let me ask you this: Have we covered all

09:31-09:33 Page 12

 1 the jobs you've had since college?

 2 A. Yes.

 3 Q. Okay. Why did you leave G & K to go to

 4 St. Jude Medical?

 5 A. I was looking for a different set of

 6 experiences to broaden my HR career.

 7 Q. And did you go to college?

 8 A. Yes, I did.

 9 Q. Where did you go to college?

10 A. I went to the University of Minnesota.

11 Q. When did you graduate?

12 A. In 2004.

13 Q. What's your degree?

14 A. Bachelor's of science in business with a

15 major in human resources and industrial

16 relations.

17 Q. Did you go to law school?

18 A. I did.

19 Q. Where did you go to law school?

20 A. William Mitchell College of Law.

21 Q. When did you graduate from there?

22 A. December of 2010, I believe.

23 Q. What made you decide to go to law school?

24 A. I debated between going back for a Master's

25 in HR from the University of Minnesota and

09:33-09:34 Page 13

 1 going to law school, and ultimately

 2 determined that it was a slightly different

 3 way to enhance my skill set in HR to go to

 4 law school.

 5 Q. And are you licensed to practice law?

 6 A. No.

 7 Q. Have you ever been licensed to practice law?

 8 A. Yes.

 9 Q. In Minnesota?

10 A. Yes.

11 Q. Any other states?

12 A. No.

13 Q. Any other jurisdictions?

14 A. No.

15 Q. And why are you no longer licensed to

16 practice law in Minnesota?

17 A. I don't practice -- I work in HR, so it's

18 irrelevant to what I do.

19 Q. Well, did you let your license lapse?

20 A. Yeah, yep, yep.

21 Q. When did that happen?

22 A. Probably beginning of this year.

23 Q. When you were the regional director of human

24 resources at G & K, could you just give me a

25 general description of what your duties and

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(3) Pages 10 - 13

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 341 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:34-09:36 Page 14

 1 responsibilities were.

 2 A. Sure. I supported a region of G & K

 3 Services in the HR space, including

 4 everything from union negotiations to

 5 organizational development and design,

 6 employee relations, project work.

 7 Q. Anything else?

 8 A. Lots of things. So, I mean, I could

 9 probably get my resume, but it's general HR

10 work, so --

11 Q. And you were -- you were in charge of the

12 Northwest Region; is that correct?

13 A. That's correct.

14 Q. What does the Northwest Region consist of?

15 A. So, it consists of locations in Minnesota,

16 North Dakota, Wisconsin, and South Dakota,

17 and then California and Arizona.

18 Q. And how many people did you supervise when

19 you were the regional director of human

20 resources?

21 A. It varied. The most I supported was eight.

22 Q. At what point did you support eight?

23 A. When I first started in that role.

24 Q. That would have been in about 2011?

25 A. Correct.

09:36-09:37 Page 15

 1 Q. Let me back up one second and ask you:

 2 Other than law school, have you had any

 3 other formal education since college?

 4 A. No.

 5 Q. So, at some point after you became the

 6 regional director of human resources for the

 7 Northwest Region at G & K, there was a

 8 restructuring of the HR department at G & K?

 9 A. That's correct.

10 Q. When was that?

11 A. It was effective in, I believe, the

12 beginning of 2013. The project work started

13 in 2012.

14 Q. And explain to me what the restructuring

15 was.

16 A. It was -- we had a new vice president of HR

17 who came in and decided that it would make

18 sense to evaluate our model, and so we

19 undertook a project to determine the best

20 way to support the employees and the company

21 and the leaders by potentially looking at

22 ways to change the way our HR organization

23 was structured.

24 Q. Who was the new vice president of HR?

25 A. Randy Ross.

09:37-09:38 Page 16

 1 Q. And could you describe for me generally what

 2 the restructuring consisted of.

 3 A. So, we undertook a project -- we met as a

 4 leadership team within the HR organization,

 5 we solicited feedback from our partners in

 6 the field and at corporate to understand the

 7 needs of the organization and the employees

 8 of the company.

 9 We looked at what other

10 organizations our size, as well as larger,

11 were doing, from an HR perspective, and how

12 their HR teams were structured, and then we

13 looked at changes within our own

14 organization based on those -- that work.

15 Q. And how was the -- how was the HR department

16 restructured? How did that actually come

17 about? Or strike that. Let me rephrase the

18 question.

19 What was the result of the

20 restructuring in the HR department?

21 A. We went to a model that was based more on

22 centers of excellence, or COEs, so we had a

23 recruiting team and an employee services

24 team, and then HR generalists, instead of

25 having a person in each location that had to

09:38-09:39 Page 17

 1 be kind of a master of all trades.

 2 Q. Prior to restructuring, did G & K have an H

 3 and R representative -- or an HR

 4 representative at each location where they

 5 do business?

 6 A. There was an HR representative or an HR

 7 administrator at each plant location, yes.

 8 Q. And, then, after the restructuring, there

 9 wasn't necessarily an HR representative at

10 each plant, correct?

11 A. Correct.

12 Q. And at that point you had a structure

13 whereby you would have an HR representative

14 that was responsible for multiple plants,

15 correct?

16 MS. PARKER: Objection to form.

17 I'm not sure what that point is.

18 MR. MILLS: After the

19 restructuring.

20 THE WITNESS: Correct. Well, it

21 wasn't really an HR representative anymore,

22 it was a different role, but they have a

23 scope of multiple locations, yes.

24 BY MR. MILLS: 

25 Q. And what was the different role?

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(4) Pages 14 - 17

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 342 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:39-09:41 Page 18

 1 A. It was an HR generalist role.

 2 Q. So, the HR generalists would be responsible

 3 for multiple locations, correct?

 4 A. Correct.

 5 Q. So, I take it that the restructuring then

 6 resulted in some layoffs of employees at

 7 G & K?

 8 A. I believe it may have.

 9 Q. Do you know how many?

10 A. I don't.

11 Q. Did anybody working with you in the HR

12 department get laid off as a result of the

13 restructuring?

14 A. I believe there was one in the Northwest

15 Region.

16 Q. Do you know what location that person was

17 servicing?

18 A. Yes.

19 Q. What was that?

20 A. St. Cloud, Minnesota.

21 Q. When you were serving as regional director

22 of Human Resources, did you have a

23 supervisor?

24 A. Yes.

25 Q. Who was that?

09:41-09:42 Page 19

 1 A. Pelham Chastang.

 2 Q. Was that during the entire period of time

 3 that you were a regional director?

 4 A. When I started, I would have reported to

 5 Eric McNaul, who was the regional vice

 6 president.

 7 Q. And how many people did you supervise in the

 8 year 2013?

 9 A. Two.

10 Q. And who were they?

11 A. So, at the end of 2013 or the beginning?

12 Q. Let's -- well, let's start at the beginning

13 and then tell me -- explain to me how it

14 changed, if it changed at all.

15 A. Sure. So, it would have been eight at the

16 beginning, and then three following February

17 of 2013, and then two at the end of 2013.

18 Q. And I take it that it went from eight to

19 three as a result of the restructuring?

20 A. That is correct.

21 Q. And the three were Brandy Williams and Kaela

22 Ellison and Janelle Bonacua or --

23 A. Correct.

24 Q. And at the end of 2013, it was just Janelle

25 and Kaela, correct?

09:42-09:43 Page 20

 1 A. Correct.

 2 Q. And those three were all HR generalists?

 3 A. Correct.

 4 Q. How many plants did G & K have in the

 5 Northwest Region when you were acting as

 6 regional director?

 7 A. Eight.

 8 Q. Eight plants?

 9 A. Correct.

10 Q. Did it have business locations other than

11 plants?

12 A. Yes.

13 Q. What were those?

14 A. Branches.

15 Q. What's the difference between a plant and a

16 branch?

17 A. A plant processes the items and then

18 distributes them to the branches, and the

19 branches deliver the products to the

20 customers.

21 Q. How many branches did G & K have in the

22 Northwest Region?

23 A. That is a good question that I,

24 unfortunately, don't have an exact number.

25 Each plant had potentially one to four.

09:43-09:45 Page 21

 1 Q. Do you recall how many total employees G & K

 2 had back in 2013?

 3 A. 7,800.

 4 Q. And how many did it have in the Northwest

 5 Region?

 6 A. About 1,800 to 2,000, I would estimate.

 7 Q. Did each plant have a manager?

 8 A. Yes.

 9 Q. How about the branches, did they have a

10 manager as well?

11 A. Yes.

12 Q. Were there regional managers in addition to

13 the plant, the branch managers?

14 A. Regional managers or regional --

15 Q. Regional managers?

16 A. No, I don't believe so.

17 Q. Who would -- and let's stick with the time

18 period after the restructuring.

19 Who would the plant managers report

20 to? Who were their immediate supervisors?

21 A. I believe the plant managers reported to the

22 general managers.

23 Q. Where were the general managers located?

24 A. In the plants.

25 Q. Each plant had a general manager as well?

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(5) Pages 18 - 21

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 343 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:45-09:46 Page 22

 1 A. Correct.

 2 Q. And, then, who would the general manager

 3 report to?

 4 A. To the regional vice president.

 5 Q. And where was the regional vice president

 6 located?

 7 A. In St. Paul, Minnesota.

 8 Q. All the regional vice presidents were in

 9 St. Paul?

10 A. No.

11 Q. Just for the Northwest Region?

12 A. Correct.

13 Q. How many regions did G & K have?

14 A. Four or five, and Canada.

15 Q. Did you ever work in any region of Canada

16 other than the Northwest Region?

17 A. I did not.

18 Q. Now, in your role as regional director, what

19 was your relationship with the general

20 managers and the managers of the plants?

21 A. I supported them, from an HR perspective,

22 and their employees.

23 Q. Was there ever a point during your tenure at

24 G & K in which the plant managers or general

25 managers reported directly to you?

09:46-09:48 Page 23

 1 A. No.

 2 Q. When was the position of HR generalist

 3 introduced at G & K?

 4 A. February of 2013.

 5 Q. What were the job duties of an HR generalist

 6 when the job was introduced in February

 7 2013?

 8 A. It was a higher level HR role than G & K had

 9 had in the past, so strategically partnering

10 with the locations that the person was

11 assigned to for purposes of working on

12 things like special projects, organizational

13 development and design, partnering with the

14 other COEs, talent development, talent

15 acquisition, staffing, being a part -- the

16 strategic picture for their locations from

17 an HR perspective.

18 Q. When the -- when the position of

19 HR generalist was introduced in February

20 2013, was there a written job description

21 for that position?

22 A. I believe so, but I don't recall.

23 Q. Did you play any role in preparing a written

24 job description for HR generalist?

25 A. I don't remember. I was part of the project

09:48-09:49 Page 24

 1 team, however, and I'm certain I may have

 2 provided input as to what the job duties

 3 should be.

 4 Q. Did you or G & K ever provide any written

 5 materials to the HR generalists --

 6 MS. PARKER: Objection: Form;

 7 compound.

 8 MR. MILLS: I wasn't finished but

 9 I'll rephrase the question.

10 BY MR. MILLS: 

11 Q. Did you ever provide any written materials

12 to the HR generalists as to what their job

13 duties were?

14 A. I don't recall specifically. Honestly, I

15 don't.

16 Q. Do you know whether anybody else at G & K

17 ever provided any written materials to the

18 HR generalists as to what their job duties

19 were?

20 A. It's very possible.

21 Q. Do you recall seeing any such written

22 materials?

23 A. Offhand, no, but it's been three years, so

24 it's very possible.

25 Q. Do you recall, after February 2013, there

09:49-09:50 Page 25

 1 being some confusion among the

 2 HR generalists as to what their duties were?

 3 A. Yes.

 4 Q. What do you recall about that?

 5 A. I recall that it was a new role for G & K

 6 and, as we were trying to learn how to

 7 support the business and approach it in a

 8 different way, there were questions from

 9 both business and from the HR team as to how

10 we approached our roles differently.

11 Q. Do you recall there being concerns expressed

12 to you that the plant managers or the branch

13 managers didn't understand the role of

14 HR generalist?

15 A. Yes.

16 Q. And who expressed those concerns to you?

17 A. Multiple leaders that had questions.

18 Q. Were those things that were expressed to you

19 by the plant managers themselves?

20 A. The plant managers?

21 Q. Um-hmm.

22 A. Not necessarily the plant managers, no.

23 Q. How about the branch managers?

24 A. Branch managers, I don't recall.

25 Q. So, it was the HR generalists, themselves,

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(6) Pages 22 - 25

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 344 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:50-09:51 Page 26

 1 who were telling you that they were

 2 concerned that the managers didn't

 3 understand their role?

 4 MS. PARKER: Objection to form.

 5 THE WITNESS: The HR generalists

 6 did --

 7 BY MR. MILLS: 

 8 Q. Let me rephrase the question. That was a

 9 bad question.

10 It was the HR generalists

11 themselves who were expressing to you

12 concern that the managers didn't understand

13 the role of the HR generalist?

14 A. Yes, they expressed those concerns.

15 Q. And all three of them expressed those

16 concerns to you?

17 A. I don't recall if all three did.

18 Q. Do you recall Kaela expressing those

19 concerns to you?

20 A. I believe Kaela did.

21 Q. And Brandy?

22 A. Yes.

23 Q. Did you at any time ever meet with the --

24 any of the plants or branch managers and

25 explain to them what the role of the HR

09:51-09:53 Page 27

 1 generalist was?

 2 A. I don't recall specifically, but there would

 3 have been roll-up calls as a part of the HR

 4 reliant process.

 5 Q. What kind of calls?

 6 A. Like a roll-up call or introduction call.

 7 Q. And what did those consist of?

 8 A. Talking about how our HR organization was

 9 changing, and specific roles, and how they

10 would access different roles in the future.

11 Q. Do you recall any of those conversations

12 specifically?

13 A. I don't.

14 Q. Do you know whether anybody else at G & K

15 ever had any communication with the managers

16 regarding the role or the functions of the

17 HR generalists?

18 A. I can't speak for anybody else, no, I don't

19 know.

20 Q. Prior to 2013, did you work with Brandy

21 Williams?

22 A. Yes.

23 Q. And what was your relationship with Brandy

24 Williams within G & K prior to -- prior to

25 2013?

09:53-09:54 Page 28

 1 A. She was my direct report.

 2 Q. Your --

 3 A. Direct report.

 4 Q. Okay. Meaning she directly reported to you?

 5 A. Correct.

 6 Q. And do you recall what her job title was

 7 prior to February 2013?

 8 A. HR representative.

 9 Q. How does an HR representative differ from an

10 HR generalist?

11 A. Actually, she may have reported to the

12 general manager. There was a point where

13 the HR representatives reported to the

14 general managers, and then there was a point

15 where they reported to the HR directors, so

16 I'm not exactly recalling when that

17 transition happened, so --

18 Q. So, it's possible that you may not have --

19 or strike that.

20 It's possible that you may have

21 become Brandy's direct supervisor only after

22 she became an HR generalist?

23 A. No.

24 Q. At what -- explain to me, then, during what

25 periods you would have been her direct

09:54-09:55 Page 29

 1 supervisor.

 2 A. I just can't say for -- so, when I started

 3 as an HR representative, I reported to the

 4 general manager. I just don't remember if

 5 Brandy reported to the general manager

 6 because she wasn't in -- I wasn't in the

 7 role when she was hired.

 8 Q. In other words, at some point you held,

 9 basically, the same position that Brandy did

10 as an HR representative?

11 A. Correct.

12 Q. And during that period of time when you held

13 that position, you were reporting to a

14 general manager?

15 A. Correct.

16 Q. And that would have been a general manager

17 at the plant or branch, right?

18 A. Correct.

19 Q. You weren't directly reporting to someone

20 within the HR department, right?

21 A. Correct.

22 Q. And, then, at some point that changed?

23 A. Yes.

24 Q. And then the HR generalists were reporting

25 to someone within the HR department?

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(7) Pages 26 - 29

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 345 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:55-09:56 Page 30

 1 A. Yes.

 2 Q. Okay. Got it.

 3 Did you ever hear any complaints or

 4 concerns expressed by the general managers

 5 that they were no longer having direct

 6 supervision over HR representatives?

 7 A. I don't recall specifically.

 8 Q. Do you recall generally any concerns about

 9 that?

10 MS. PARKER: Objection to form.

11 THE WITNESS: I don't recall

12 specifically. It's possible, but I don't

13 recall any.

14 BY MR. MILLS: 

15 Q. Do you recall what the rationale was for

16 taking direct supervision of the HR

17 representatives away from the general

18 managers?

19 MS. PARKER: Objection: Form and

20 foundation.

21 THE WITNESS: It's a more typical

22 HR structure in the organizations that we

23 studied where the HR reporting lines roll

24 through an HR function.

25 BY MR. MILLS: 

09:57 Page 31

 1 Q. Did you supervise Brandy Williams in any of

 2 her roles other than HR generalist or HR

 3 representative?

 4 A. No.

 5 Q. And, again, you're not sure whether you even

 6 supervised her as an HR representative,

 7 correct?

 8 A. I believe I did. I just don't recall when

 9 the official transition would have happened,

10 but there would have always been a matrix

11 relationship.

12 Q. Would that transition have been part of the

13 restructuring or was that something

14 different?

15 A. I don't believe so. I think it was before

16 that.

17 Q. You think it was before that?

18 A. I believe so.

19 Q. Do you recall how long before that?

20 A. I don't.

21 MS. PARKER: Objection: Asked and

22 answered.

23 THE WITNESS: I don't,

24 unfortunately.

25 BY MR. MILLS: 

09:58-09:59 Page 32

 1 Q. During the time that you were Brandy

 2 Williams' supervisor in any capacity, Brandy

 3 was located in Phoenix, right?

 4 A. Correct.

 5 Q. She worked out of G & K's Phoenix facility?

 6 A. Correct.

 7 Q. Was that a plant or a branch that she worked

 8 out of?

 9 A. It was a plant.

10 Q. And Brandy became an HR generalist at G & K,

11 correct?

12 A. Yes.

13 Q. And she supported -- strike that.

14 Brandy supported facilities in

15 addition to Phoenix, right?

16 MS. PARKER: Objection: Form.

17 THE WITNESS: Correct.

18 BY MR. MILLS: 

19 Q. And she did that in her capacity as an HR

20 generalist, right?

21 A. Yes.

22 Q. And she supported G & K locations in Tucson

23 as well?

24 A. Yes.

25 Q. And Prescott Valley?

09:59 Page 33

 1 A. Yes.

 2 Q. And Yuma?

 3 A. Yes.

 4 Q. And San Diego?

 5 A. Yes.

 6 Q. And Los Angeles?

 7 A. Correct, yes.

 8 Q. And Ontario, California?

 9 A. Yes.

10 Q. And Sun Valley, California?

11 A. Yes.

12 Q. Okay. And this was all during the time that

13 you were her supervisor, correct?

14 A. So, the California locations were only in

15 her role as an HR generalist.

16 Q. Okay. But during the time she was an HR

17 generalist -- or strike that.

18 During the time that you were

19 supervising her as an HR generalist, she was

20 covering all those locations?

21 A. Yes.

22 Q. And during that time that you were Brandy's

23 supervisor, you were located in Minnesota?

24 A. Yes.

25 Q. Did you ever visit the Phoenix location of

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(8) Pages 30 - 33

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 346 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

09:59-10:00 Page 34

 1 G & K?

 2 A. I did.

 3 Q. How frequently would you get out there?

 4 A. Several times a year.

 5 Q. How many, on average?

 6 A. It really depended on the year, three, four,

 7 five.

 8 Q. Is it fair to say that, during the time that

 9 you were supervising Brandy Williams as an

10 HR generalist, that you were supervising her

11 remotely?

12 A. Yes.

13 Q. In other words, you weren't physically

14 onsite observing her job performance on a

15 day-to-day basis, correct?

16 A. Correct.

17 Q. So, Brandy didn't -- during the time that --

18 strike that.

19 During the time that Brandy was an

20 HR generalist, she did not have a direct

21 supervisor onsite in Phoenix, correct?

22 A. Correct.

23 Q. Or at any of the other locations that she

24 was supporting as an HR generalist, correct?

25 A. Correct.

10:00-10:02 Page 35

 1 Q. Do you know how many HR generalists are

 2 supporting the Northwest Region now?

 3 A. Yes.

 4 Q. How many?

 5 A. One.

 6 Q. Who is that?

 7 A. I don't know his name, unfortunately.

 8 Q. But it's not any of the -- it's not any of

 9 the three that you were supervising while

10 you were at G & K?

11 A. Correct.

12 Q. G & K does performance reviews of its

13 employees?

14 A. Yes.

15 Q. Who did Brandy Williams' performance review

16 while she was HR generalist?

17 A. I did the 2013 performance review.

18 Q. Do you know whether anybody else at G & K

19 did a performance review of Brandy's work as

20 an HR generalist?

21 A. I don't know. It's possible there was

22 others.

23 Q. Do you have any idea who else would have --

24 might have done that?

25 A. The general manager may have.

10:02-10:03 Page 36

 1 Q. But, again, the general manager, at that

 2 point in time when she was an HR generalist,

 3 was not her supervisor, right?

 4 A. Correct.

 5 Q. Prior to the time that Brandy became an HR

 6 generalist, who did her performance reviews?

 7 MS. PARKER: Objection:

 8 Foundation.

 9 THE WITNESS: It would have

10 typically been the general manager, if she

11 was reporting to the general manager.

12 BY MR. MILLS: 

13 Q. Did you -- let me ask you this: Did you

14 ever do a performance review of Brandy in

15 any capacity other than as an HR generalist?

16 A. No.

17 Q. Do you recall seeing any written performance

18 reviews that were done by any of the

19 managers or general managers in Phoenix

20 regarding Brandy Williams?

21 A. I don't.

22 Q. And I'm referring to, like, at any period of

23 time, do you recall seeing any of them?

24 A. I just don't recall.

25 Q. When -- prior to the time that Brandy would

10:03-10:04 Page 37

 1 become an HR generalist, where were her

 2 performance reviews have gone within G & K?

 3 MS. PARKER: Objection:

 4 Foundation.

 5 THE WITNESS: I'm not sure I

 6 understand that question.

 7 BY MR. MILLS: 

 8 Q. That's a bad question. Let me ask it

 9 differently.

10 Who was -- who was evaluating her

11 performance reviews at G & K, just in

12 general?

13 MS. PARKER: Objection: Form and

14 foundation.

15 THE WITNESS: I'm also not sure I

16 understand the question, I'm sorry.

17 BY MR. MILLS: 

18 Q. Who evaluated the performance reviews of the

19 HR representatives?

20 MS. PARKER: Objection:

21 Foundation.

22 BY MR. MILLS: 

23 Q. If you know.

24 A. I don't -- I'm sorry, I don't know that I'm

25 understanding your question.

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(9) Pages 34 - 37

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 347 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:04-10:05 Page 38

 1 Q. Let's say that, during the period of time

 2 that Brandy was an HR representative and she

 3 was got a written review from a general

 4 manager --

 5 A. Okay.

 6 Q. -- what happened with that general review?

 7 MS. PARKER: Objection:

 8 Foundation.

 9 THE WITNESS: What happened to it

10 physically?

11 BY MR. MILLS: 

12 Q. Do you know where it went? Do you know who

13 evaluated it? Do you know where it went?

14 Do you know what G & K did with it?

15 MS. PARKER: Objection: Compound.

16 THE WITNESS: They are housed in

17 the system. I don't know. I'm sorry.

18 Maybe I don't understand the question.

19 BY MR. MILLS: 

20 Q. If a general manager did a review of Brandy

21 Williams while she was -- or let me rephrase

22 that.

23 If a manager or a general manager

24 had done a review of Brandy Williams while

25 she was an HR representative, would that

10:05-10:06 Page 39

 1 review have been sent to someone in the HR

 2 department?

 3 MS. PARKER: Objection: Compound;

 4 form; calls for speculation.

 5 THE WITNESS: I don't know.

 6 BY MR. MILLS: 

 7 Q. After the restructuring in February 2013

 8 going forward, Kaela Ellison was working in

 9 Minnesota, right?

10 A. Correct.

11 Q. Did you -- did you see her every day?

12 A. No.

13 Q. Where was her office located in comparison

14 to yours?

15 A. In St. Paul, in an attached building.

16 Q. But you would have seen her more frequently

17 than you saw Janelle or Brandy?

18 A. Sure.

19 Q. Do you recall how much more frequently you

20 would have seen her?

21 A. It depended on my travel schedule and her

22 travel schedule and -- I mean, I really

23 can't recall specifically.

24 Q. During that period of time after February

25 2013 up until the time you left G & K, were

10:06-10:09 Page 40

 1 the HR generalists the only people that you

 2 were supervising?

 3 A. Yes.

 4 Q. Were they the only people that you reviewed?

 5 A. Yes.

 6 Q. Did you ask for reviews of the

 7 HR generalists from anybody else at G & K?

 8 A. So, review -- help me understand what you

 9 mean by "review."

10 Q. Did you ask anybody else at G & K to do

11 performance reviews of anybody that was an

12 HR generalist in the Northwest Region?

13 A. Performance reviews, no.

14 Q. Any other types of reviews?

15 A. Not that I recall, no.

16 MS. PARKER: Just give me a second.

17 I'm going to grab a water.

18 MR. MILLS: Sure. No problem.

19 That's 1.

20 (Exhibit 1 was marked.)

21 BY MR. MILLS: 

22 Q. Okay. I'm going to hand you a document that

23 we've marked as Exhibit 1 and I'll just ask

24 you to take a look at that.

25 My first question is going to be:

10:09-10:10 Page 41

 1 Have you seen that before?

 2 A. I haven't.

 3 Q. Pardon me?

 4 A. I have not.

 5 Q. You haven't seen that document before?

 6 A. No. I don't -- it's, like, lots of pages,

 7 though, so I could review it if you want.

 8 Q. Take a look at the first four pages of the

 9 document. You don't have to -- I mean, you

10 don't have to go on, but just tell me if

11 you're familiar with those.

12 MS. PARKER: Objection: She

13 indicated she has not seen this before.

14 THE WITNESS: I don't recall seeing

15 it specifically, I'm sorry.

16 BY MR. MILLS: 

17 Q. I'll represent to you that this is a

18 document that we received as G & K's

19 position statement in response to a charge

20 of discrimination that was made by Brandy

21 Williams.

22 A. Okay.

23 Q. And it's dated April 1, 2014, you see at the

24 top of the first page.

25 A. Are you asking?

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(10) Pages 38 - 41

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 348 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:10-10:11 Page 42

 1 Q. Yes. Do you see --

 2 A. Yes, I do.

 3 Q. I'm just looking back through my notes.

 4 Were you -- were you gone from

 5 G & K by April 1, 2014?

 6 A. Yes.

 7 Q. By how -- by how many months?

 8 A. Six.

 9 Q. Did anybody at -- did anybody at G & K

10 contact you and explain to you that they

11 were responding to a discrimination charge

12 that was filed by Brandy Williams and ask

13 you for information?

14 MS. PARKER: Objection to the

15 extent that this calls for information

16 seeking -- seeking information regarding

17 attorney/client privileged conversations.

18 THE WITNESS: I recall having a

19 conversation. I don't recall specifically

20 why.

21 BY MR. MILLS: 

22 Q. Do you recall when that conversation

23 occurred?

24 A. I don't.

25 Q. Was it after you had left G & K?

10:11-10:12 Page 43

 1 A. Oh, yes.

 2 Q. And who was the conversation with?

 3 A. It was with Marie Smith.

 4 Q. Who is Marie Smith?

 5 A. She was an employee relations manager.

 6 Q. And how long -- do you recall how long that

 7 conversations lasted?

 8 A. I don't.

 9 Q. What can you tell me as best as you can

10 specifically about the conversation?

11 MS. PARKER: I'll object here to

12 the extent that this calls for information

13 that's protected by the attorney/client

14 privilege or the work product privilege and

15 I'll instruct you not to answer with respect

16 to the specifics of the conversation.

17 THE WITNESS: Could you repeat the

18 question?

19 MS. PARKER: Well, I'm instructing

20 you not to answer.

21 THE WITNESS: Oh, okay.

22 BY MR. MILLS: 

23 Q. Are you going to follow your counsel's

24 instructions?

25 A. Yes.

10:12-10:13 Page 44

 1 MR. MILLS: Okay. Let's mark the

 2 question.

 3 BY MR. MILLS: 

 4 Q. Well, then, let me back up for a second and

 5 ask you this: Did you -- did you draft any

 6 portion of this document, Exhibit 1?

 7 A. I don't know. There's like 50 pages here.

 8 Q. Let me ask you this: Did you draft any

 9 portion of the first four pages of

10 Exhibit 1?

11 MS. PARKER: And, again, I'll

12 object to the extent that this inquires as

13 to attorney/client privileged

14 communications.

15 THE WITNESS: I don't know, not

16 that I remember.

17 BY MR. MILLS: 

18 Q. Is it possible you could have drafted any

19 portion of them?

20 MS. PARKER: Objection: Calls for

21 speculation.

22 THE WITNESS: I didn't sign it, so

23 no, and I didn't work there when it was

24 dated.

25 BY MR. MILLS: 

10:13-10:14 Page 45

 1 Q. Who is Ruth Timm?

 2 A. Ruth Timm is senior corporate counsel per

 3 her signature line.

 4 Q. Did Ruth Timm supervise Brandy Williams?

 5 A. No.

 6 Q. Did Ruth Timm work with Brandy Williams, to

 7 your knowledge?

 8 A. I don't know.

 9 Q. Do you know whether Ruth Timm ever even met

10 Brandy Williams, to your knowledge?

11 A. I don't know. I don't know.

12 Q. Did Marie Smith supervise Brandy Williams?

13 A. No.

14 Q. Do you know whether Marie Smith worked with

15 Brandy Williams?

16 A. I don't know.

17 Q. Where is Marie Smith located?

18 A. I -- not in Minnesota.

19 Q. So, if G & K were looking for information

20 about Brandy Williams and her Complaint,

21 Ruth Timm would probably not be the first

22 choice of someone to go to for that

23 information, right?

24 MS. PARKER: Objection: Form, and

25 calls for speculation.

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(11) Pages 42 - 45

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 349 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:14-10:16 Page 46

 1 THE WITNESS: I don't know. I

 2 can't --

 3 BY MR. MILLS: 

 4 Q. You, as Brandy Williams' supervisor,

 5 would -- you would expect to know a lot more

 6 about that than Ruth Timm, right?

 7 MS. PARKER: Object to form.

 8 THE WITNESS: I think it depends on

 9 what they were looking for.

10 BY MR. MILLS: 

11 Q. Do you recall anybody ever asking you to

12 review the first four pages of Exhibit 1?

13 MS. PARKER: I'm going to object

14 again that this calls for attorney/client

15 privileged communications.

16 THE WITNESS: No.

17 BY MR. MILLS: 

18 Q. If you turn to the second page of the

19 document, right in the middle of the page

20 there's a statement that's underlined, it

21 says Charge, and it says: On May 10, 2013,

22 a performance issue was brought to

23 Ms. Williams' attention stating that she was

24 missing too much work.

25 Do you see that?

10:16 Page 47

 1 A. Yes.

 2 Q. And then the response says, "In June 2013,

 3 Rachael Siggerud, Regional HR Director, did

 4 speak with Ms. Williams regarding her

 5 performance, including providing feedback

 6 from the managers that Ms. Williams

 7 supported."

 8 Did I read that correctly?

 9 A. Yes.

10 Q. Do you know where G & K got that information

11 from?

12 MS. PARKER: I'm going to object

13 again to the extent that this calls for any

14 exposure regarding attorney/client

15 privileged communication, and I also object

16 because it calls for speculation.

17 BY MR. MILLS: 

18 Q. All of my questions are based on what you

19 know. I'm not asking you to speculate.

20 THE WITNESS: Should I answer?

21 MS. PARKER: You can answer to the

22 extent that it doesn't go into

23 attorney/client privileged communications,

24 to the extent that you know.

25 BY MR. MILLS: 

10:16-10:18 Page 48

 1 Q. And this is a document that was filed with

 2 the EEOC, so --

 3 A. I don't know.

 4 Q. Do you recall speaking with Ms. Ruth Timm or

 5 Marie Smith about a conversation that you

 6 had with Brandy Williams regarding feedback

 7 from managers?

 8 MS. PARKER: And I'm going to

 9 object that, again, this is perilously close

10 to asking for the content of attorney/client

11 privileged communications.

12 So, I'm instructing you not to

13 answer with respect to the content -- and

14 I'm about to instruct her to just not answer

15 these questions with respect to granular

16 pieces of information that she may or may

17 not have had attorney/client privileged

18 discussions regarding.

19 MR. MILLS: Well, I'm just trying

20 to find out where the information came from

21 that's in this document. It's something

22 that was filed with the EEOC. Certainly

23 G & K would have had some basis for saying

24 the things that are in here.

25 MS. PARKER: This is all attorney

10:18 Page 49

 1 work product and --

 2 MR. MILLS: How can you say it's

 3 work product? It went to the EEOC. We got

 4 it from the EEOC.

 5 MS. PARKER: The underlying -- the

 6 underlying investigation is work product and

 7 privileged.

 8 MR. MILLS: Okay.

 9 MS. PARKER: So, you can ask her

10 what she knows, but I don't think it's

11 proper to ask her precisely what discussions

12 she had with counsel or those working under

13 the direction of counsel in connection with

14 the preparation of this statement.

15 BY MR. MILLS: 

16 Q. Well, let me ask you -- let me ask you this

17 question: Do you recall having any

18 conversations with anyone at G & K regarding

19 the preparation of Exhibit 1?

20 MS. PARKER: And, again, I'll

21 object to the extent that this calls for

22 inquiry into the attorney/client privileged

23 communications. You can respond just with

24 respect to whether there were conversations

25 about this charge generally.

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(12) Pages 46 - 49

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 350 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:19-10:20 Page 50

 1 THE WITNESS: I don't recall that

 2 they were specifically noted as being a part

 3 of the charge.

 4 BY MR. MILLS: 

 5 Q. How many conversations -- and what's --

 6 what's the "they" that you were referring

 7 to?

 8 A. I -- I don't know. Am I supposed to --

 9 MS. PARKER: You can respond as to

10 who you may have had a conversation with and

11 the number of conversations, just not the

12 content.

13 THE WITNESS: Okay. So, I spoke

14 with Marie Smith one time, I believe, but I

15 don't remember 100 percent because it's been

16 three years, so I do remember speaking with

17 Marie Smith.

18 BY MR. MILLS: 

19 Q. Do you remember speaking with anybody else?

20 A. I honestly don't, I'm sorry.

21 Q. Did you -- do you remember, from the time

22 that you left G & K, do you remember talking

23 to anybody else at G & K regarding Brandy

24 Williams, other than Marie Smith, and other

25 than conversations that you had with

10:20-10:37 Page 51

 1 counsel?

 2 A. Not really, no.

 3 Q. Have you had any contact with Brandy

 4 Williams since you left G & K?

 5 A. I don't think so, no.

 6 Q. And by "contact," I mean any communications,

 7 emails, phone calls, anything.

 8 A. Not that I -- I don't believe so. I think

 9 we were connected on Linked In but --

10 MR. MILLS: We need to change the

11 tape.

12 THE VIDEOGRAPHER: We are off the

13 video record. The time on the video monitor

14 is 10:20 a.m.

15 (A recess was taken.)

16 THE VIDEOGRAPHER: We are back on

17 the video record. The time on the video

18 monitor is 10:37 a.m.

19 BY MR. MILLS: 

20 Q. Okay. We're looking at Exhibit 1. Would

21 you take a look at the second page of that,

22 that's where we were looking at before, same

23 paragraph that we were talking about just

24 before the break.

25 The second sentence reads, quote,

10:37-10:39 Page 52

 1 "A portion of that feedback was that the

 2 managers were concerned that they could not

 3 contact Ms. Williams and, because of this,

 4 the managers perceived her as being

 5 ineffective," end quote.

 6 Did I read that correctly? Did I

 7 read that correctly?

 8 A. Oh, I'm sorry, I couldn't hear you. Yes.

 9 Q. Do you have any idea what managers this is

10 referring to?

11 A. I believe it was the managers in the Phoenix

12 location.

13 Q. Who were they?

14 A. There were a variety, and I can't recall all

15 of their names -- or many of their names.

16 Q. Do you recall someone named Jacob Briscoe?

17 A. Yes.

18 Q. Do you remember any other managers?

19 A. I don't, unfortunately, remember their

20 names.

21 Q. And do you specifically recall any managers

22 expressing concern that they couldn't get

23 ahold of Brandy?

24 A. Yes.

25 Q. And, again, those were the managers at

10:39-10:40 Page 53

 1 Phoenix?

 2 A. Yes.

 3 Q. Did you document any of the concerns that

 4 they expressed?

 5 A. I don't recall. I may have taken notes but

 6 I don't have them.

 7 Q. Is that something you would typically do, if

 8 a manager expressed a complaint or a concern

 9 to you, would you document that somehow?

10 MS. PARKER: Objection: Form.

11 THE WITNESS: Typically, it's

12 possible.

13 BY MR. MILLS: 

14 Q. So, typically you would, or typically you

15 wouldn't?

16 MS. PARKER: Objection: Form.

17 THE WITNESS: Typically -- I guess

18 I can't say typically. I may have. I may

19 have.

20 BY MR. MILLS: 

21 Q. And do you recall the concerns being that --

22 or strike that.

23 Do you recall that the managers at

24 Phoenix were saying that Brandy was coming

25 in late and leaving early?

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(13) Pages 50 - 53

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 351 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:40-10:41 Page 54

 1 MS. PARKER: Objection to form;

 2 characterization.

 3 THE WITNESS: I don't recall

 4 specifically what the concerns were,

 5 unfortunately, at this point.

 6 BY MR. MILLS: 

 7 Q. What -- let me just ask you: What do you

 8 recall, as best as you can, about the

 9 concerns that were being expressed?

10 MS. PARKER: Objection to form.

11 THE WITNESS: I recall that

12 managers were expressing concerns that they

13 could not -- so Brandy wasn't in her office

14 or, if they called, she wasn't answering,

15 and that she wasn't responsive on email,

16 things like that, so that's -- that's what I

17 remember.

18 BY MR. MILLS: 

19 Q. Was the concern around her missing too much

20 work?

21 MS. PARKER: Objection: Form.

22 THE WITNESS: No. No.

23 BY MR. MILLS: 

24 Q. And did you receive any expressions of

25 concern by any manager or any general

10:41-10:43 Page 55

 1 manager from any of the other locations that

 2 Brandy was supporting?

 3 MS. PARKER: Objection to form.

 4 THE WITNESS: I don't recall at

 5 this time.

 6 BY MR. MILLS: 

 7 Q. Is that something you would have documented?

 8 MS. PARKER: Objection to form.

 9 THE WITNESS: It may have been.

10 BY MR. MILLS: 

11 Q. Do you recall any specific conversations

12 that you had with Jacob Briscoe regarding

13 Brandy Williams' performance?

14 A. Specific conversations, no. I remember

15 having conversations.

16 Q. What do you recall about the conversations

17 that you had?

18 A. I recall that Jake had concerns about the

19 role that Brandy was playing in the

20 business, so how she supported the business,

21 what her new generalist role was, that there

22 were times when she was late to meetings, I

23 do recall that, that he felt that the way

24 she approached managers and ride-alongs

25 sometimes was more to find fault and point

10:43-10:44 Page 56

 1 out things that they were doing wrong

 2 instead of partnering.

 3 Q. What was -- what was Jacob Briscoe's title?

 4 A. General manager.

 5 Q. That was during the time that Brandy was an

 6 HR generalist?

 7 A. Yes.

 8 Q. And before Brandy became an HR generalist,

 9 Jacob Briscoe was her direct supervisor,

10 right?

11 A. At some point, I believe so.

12 Q. And did Jacob Briscoe prepare performance

13 reviews of Brandy --

14 MS. PARKER: Objection:

15 Foundation.

16 BY MR. MILLS: 

17 Q. -- prior to the time that she became the

18 HR generalist?

19 A. I don't have any way of knowing.

20 Q. Do you recall ever having seen those?

21 A. I don't.

22 Q. Other than -- and I'm -- I want you to give

23 me your best recollection.

24 Other than Jacob Briscoe, do you

25 recall the names of any other managers or

10:44-10:46 Page 57

 1 general managers within G & K who expressed

 2 concern to you about Brandy Williams being

 3 inaccessible?

 4 MS. PARKER: Objection to form;

 5 compound.

 6 THE WITNESS: I'm sorry, I can't

 7 remember names. I know there were other

 8 managers in Phoenix at the time. I just

 9 don't remember their names.

10 BY MR. MILLS: 

11 Q. Let me ask you this: Do you recall

12 receiving any such expressions of concern

13 from any managers outside of Phoenix?

14 MS. PARKER: Objection to form.

15 THE WITNESS: It's very possible.

16 BY MR. MILLS: 

17 Q. You don't recall anything specifically?

18 MS. PARKER: Objection to form.

19 THE WITNESS: I don't recall a

20 specific person, if that's what you're

21 asking.

22 BY MR. MILLS: 

23 Q. So, you can't give me -- you can't -- strike

24 that.

25 You can't recall the name of any

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 352 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:46-10:47 Page 58

 1 manager outside of Phoenix who expressed

 2 concern regarding Brandy being inaccessible?

 3 MS. PARKER: Objection to form.

 4 THE WITNESS: I'm sorry, it's been

 5 three years and I just don't remember. I

 6 don't remember names.

 7 BY MR. MILLS: 

 8 Q. And you don't remember whether there

 9 actually were any outside of Phoenix who

10 expressed concerns about Brandy being

11 inaccessible, right?

12 A. I don't recall.

13 Q. If you turn to the third page of the

14 document, Exhibit 1, there is -- about the

15 middle of the page, there is a paragraph

16 that begins Response, underlined.

17 And the second sentence of that

18 Response includes the statement that, quote,

19 "In August 2013, it was determined that the

20 Northwest Region was overstaffed by one

21 HR Generalist."

22 Did I read that correctly?

23 A. Yes.

24 Q. Do you recall -- or do you recall there

25 being a determination that the Northwest

10:47-10:49 Page 59

 1 Region was overstaffed?

 2 A. Yes, but prior to August.

 3 Q. When do you recall that determination?

 4 A. In June.

 5 Q. In June?

 6 A. Um-hmm, yes.

 7 Q. So, in June 2013, G & K decided that they

 8 were overstaffed with HR generalists in the

 9 Northwest Region, correct?

10 A. Yes.

11 Q. And was it also in June of 2013 that G & K

12 decided to eliminate a position?

13 MS. PARKER: Objection to form.

14 THE WITNESS: Yes.

15 BY MR. MILLS: 

16 Q. And let me ask you first: Who was involved

17 in the determination that G & K was

18 overstaffed with HR generalists in the

19 Northwest Region?

20 A. Myself and Pelham Chastang and Eric McNaul,

21 to the best of my knowledge.

22 Q. And what brought about that determination?

23 A. It was feedback from the generalists

24 themselves, feedback from the business,

25 feedback from -- as we went through the

10:49-10:50 Page 60

 1 budgeting process, looking at our overall

 2 expenses as well, but a significant amount

 3 came from the generalists.

 4 Q. What feedback from the generalists did you

 5 receive that led to the determination that

 6 you were overstaffed with generalists?

 7 A. That, following the HR reliant, they didn't

 8 have enough work to do.

 9 Q. Who told you that?

10 A. I actually heard that from all three.

11 Q. And did you hear from anyone other than the

12 generalists themselves that the generalists

13 didn't have enough work to do?

14 A. Not specifically that they didn't have

15 enough work to do.

16 Q. What were you hearing?

17 MS. PARKER: Objection to form.

18 THE WITNESS: I think ongoing

19 questions about the clarity about the role

20 would be the best way to categorize it.

21 BY MR. MILLS: 

22 Q. Were you hearing that with respect to all

23 three of the HR generalists that you were

24 supervising?

25 A. Yes.

10:50-10:51 Page 61

 1 MS. PARKER: Objection to form.

 2 BY MR. MILLS: 

 3 Q. And when you say "ongoing questions about

 4 the clarity of the role," does that mean

 5 that the managers were expressing to you

 6 that they didn't really understand what the

 7 role was?

 8 MS. PARKER: Objection to form.

 9 THE WITNESS: More that there were

10 things that the HR representatives did that

11 the HR generalists didn't do, and that there

12 was a small amount of -- there was a small

13 amount of what they used to do that they

14 weren't supposed to do now versus all of the

15 other buckets of work that they weren't

16 doing anymore.

17 BY MR. MILLS: 

18 Q. Can you give me some examples of things that

19 they were saying that the HR representatives

20 used to do that the generalists were not

21 doing?

22 A. Sure. So, in one of our locations, the

23 HR generalist managed the shoe program and

24 the cell phone program. All of the

25 HR generalists managed onboarding -- all of

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 353 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:51-10:52 Page 62

 1 the HR representatives, I should say.

 2 All of the HR representatives used

 3 to perform all of the payroll processing,

 4 they used to all the benefits enrollment,

 5 annual enrollment process, all of the

 6 onboarding for new employees, all of the

 7 recruiting for new employees for their

 8 assigned locations, any type of employee

 9 relations, any type of labor, responses that

10 were needed, depending on the location,

11 pretty much everything, and then managing

12 programs and processes and conducting

13 training.

14 Q. And these are things that the generalists

15 were not doing?

16 A. Correct.

17 Q. Did Jacob Briscoe ever express to you

18 concern or displeasure that Brandy was not

19 doing the things that she used to do as an

20 HR representative?

21 MS. PARKER: Objection to form.

22 THE WITNESS: I don't recall if it

23 was specifically that Brandy wasn't. I

24 recall that there was some of the work that

25 was distributed back to the location

10:52-10:53 Page 63

 1 managers and that wasn't necessarily

 2 favored.

 3 BY MR. MILLS: 

 4 Q. Do you recall that Jacob Briscoe was not

 5 happy about having his responsibilities put

 6 back on the managers?

 7 MS. PARKER: Objection to form.

 8 THE WITNESS: I think that's a fair

 9 statement.

10 BY MR. MILLS: 

11 Q. And do you think that that -- that could

12 explain Mr. Briscoe's concern regarding

13 Brandy's accessibility?

14 MS. PARKER: Objection: Calls for

15 speculation.

16 THE WITNESS: He never said

17 anything like that. It was more just the

18 question of, you know, why -- why are we

19 doing this now instead of someone else?

20 BY MR. MILLS: 

21 Q. Did he ever express to you that he didn't

22 see the need for an HR generalist if they

23 were no longer performing the functions that

24 the representatives did?

25 A. Not that I recall, no.

10:53-10:54 Page 64

 1 Q. Did he ever express to you that he didn't

 2 think that the HR generalists were adding

 3 any value to the company?

 4 A. Generally speaking, no. No.

 5 Q. But, again, he did express to you that he

 6 was not happy that certain of the functions

 7 that Brandy had been performing as a

 8 representative were now put back on him as a

 9 manager?

10 MS. PARKER: Objection to form and

11 characterization of prior testimony.

12 THE WITNESS: So, again, it was a

13 very small portion of what the generalists

14 did that went back to the business, but that

15 was a question, certainly.

16 BY MR. MILLS: 

17 Q. Did he ever say anything to you like, well,

18 you know, if she's no longer going to be

19 doing these things, then what does she do?

20 MS. PARKER: Objection to form.

21 THE WITNESS: Not that I recall,

22 no.

23 BY MR. MILLS: 

24 Q. How frequently did you talk to Jacob

25 Briscoe?

10:54-10:56 Page 65

 1 A. As I sit here today, I recall maybe a couple

 2 times a month, a few times.

 3 Q. And those were typically on the phone?

 4 A. Typically.

 5 Q. Would that be about the same with respect to

 6 the managers at the other plants or

 7 branches?

 8 A. To the best of my recollection, that's

 9 probably about right, perhaps a little more

10 in the St. Paul business.

11 Q. Was there anybody else -- I know we asked --

12 I apologize if I asked you previously.

13 Was there anybody else at G & K,

14 other than the generalists themselves, who

15 expressed to you as part of this process

16 that they didn't think the generalists had

17 enough work to do?

18 A. I don't remember.

19 Q. Do you recall what Mr. Pelham had to say --

20 I'm sorry, that's his first name, right?

21 A. Yes.

22 Q. What's his last name, Pelham --

23 A. Chastang.

24 Q. Chastang.

25 Do you recall what Mr. Chastang had

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 354 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

10:56 Page 66

 1 to say about whether the generalists had

 2 enough work to do?

 3 A. So, when you say "generalists," are you

 4 generalizing about generalists or are you

 5 referring to the generalists in the

 6 Northwest Region? Because my answers would

 7 be different.

 8 Q. That's a fair point. That's a fair point.

 9 My questions -- you can assume that my

10 questions for you are limited to the

11 Northwest Region, okay?

12 A. Okay.

13 Q. And what do you recall Mr. Chastang saying

14 about the HR generalists not having enough

15 work to do?

16 A. He agreed with me.

17 Q. Were you the one that brought up the point

18 that the generalists didn't have enough work

19 to do?

20 A. I don't recall if I specifically raised it

21 but I know we talked about it.

22 Q. What did Mr. McNaul have to say about

23 whether the generalists had enough work to

24 do?

25 A. He agreed with me as well.

10:56-10:57 Page 67

 1 Q. Did either Mr. Chastang or Mr. McNaul

 2 express to you that they had had any

 3 experiences with the generalists that led

 4 them to believe that they didn't have enough

 5 work to do?

 6 A. I -- not that I recall, but you would have

 7 to ask them.

 8 Q. Did either of them work directly with the

 9 HR generalists --

10 MS. PARKER: Objection:

11 Foundation.

12 BY MR. MILLS: 

13 Q. -- in the Northwest Region?

14 A. Yes.

15 Q. And which -- who?

16 A. Who --

17 Q. Did Mr. Chastang work directly with the

18 HR generalists in the Northwest Region?

19 MS. PARKER: Objection:

20 Foundation.

21 THE WITNESS: I believe he -- yes.

22 BY MR. MILLS: 

23 Q. In what way?

24 A. In projects that they were both on or --

25 Q. How about Mr. McNaul, did he work directly

10:57-10:59 Page 68

 1 with the generalists in the Northwest

 2 Region?

 3 MS. PARKER: Same objection.

 4 THE WITNESS: Yes.

 5 BY MR. MILLS: 

 6 Q. In what way?

 7 A. More in the course of business.

 8 Q. And who all was involved in the

 9 determination to eliminate one of the

10 HR generalist positions?

11 A. I was involved, Pelham was involved, Eric

12 was involved. I don't recall if anybody

13 else was at this time.

14 Q. I think you had said that that decision was

15 made in June 2013 as well?

16 A. Yes.

17 Q. Do you know whether any of the other regions

18 eliminated HR generalist positions?

19 MS. PARKER: Objection:

20 Foundation.

21 THE WITNESS: I don't recall, but

22 the Northwest had more than all of the other

23 regions.

24 BY MR. MILLS: 

25 Q. What did the other regions have, as best you

10:59-11:00 Page 69

 1 can recall?

 2 A. One or two, to the best of my recollection.

 3 Q. And how did the decision come about to

 4 eliminate a position?

 5 MS. PARKER: Objection to form.

 6 BY MR. MILLS: 

 7 Q. What was the process whereby you came by

 8 that decision?

 9 MS. PARKER: Same objection.

10 THE WITNESS: So, we just simply

11 discussed that there had been feedback that

12 -- from the generalists themselves that they

13 were not -- they didn't have enough work to

14 do, that they were bored, that -- that --

15 and then we reflected on our structure

16 overall, and whether it made sense to have

17 three people supporting all of the plants or

18 whether it was more appropriate to have two,

19 and if we thought that that would

20 potentially solve kind of the hours or the

21 work -- the amount of work that was needing

22 to be completed and filling out their days a

23 little bit more.

24 And, remember, it was a completely

25 different role than what it had been before,

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 355 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:00-11:01 Page 70

 1 so we went into it thinking that it would be

 2 better to be nice and heavy and have plenty

 3 of HR generalist support, but then realized

 4 that, in fact, we probably overestimated how

 5 many we needed, and that was unfortunate.

 6 BY MR. MILLS: 

 7 Q. During -- from February 2013 on, were the

 8 HR generalists themselves supervising any

 9 employees?

10 A. I don't believe so.

11 Q. Who was involved in the decision as to which

12 HR generalist position to eliminate?

13 A. That would have been myself and Pelham and

14 Eric again.

15 Q. Anybody else involved in that?

16 A. Not that I recall today.

17 Q. And when was the decision made as to whose

18 position to eliminate?

19 MS. PARKER: Objection: Asked and

20 answered.

21 THE WITNESS: In the June 2013

22 timeframe.

23 BY MR. MILLS: 

24 Q. So, it's your testimony that, in June 2013,

25 you decided to eliminate Brandy Williams'

11:01-11:02 Page 71

 1 position?

 2 MS. PARKER: Objection: Asked and

 3 answered.

 4 THE WITNESS: If I recall

 5 correctly, yes.

 6 BY MR. MILLS: 

 7 Q. Did you tell Brandy Williams in June 2013

 8 that you had decided to eliminate her

 9 position?

10 A. No.

11 Q. In fact, she wasn't terminated until

12 September, correct?

13 A. That is correct.

14 Q. Are you aware -- or strike that.

15 Are you aware of any documentation

16 of a decision having been made in June 2013

17 to eliminate Brandy Williams' position as an

18 HR generalist?

19 MS. PARKER: Objection to form.

20 THE WITNESS: Not that I know of,

21 no.

22 BY MR. MILLS: 

23 Q. You certainly didn't document it, right?

24 MS. PARKER: Objection to form.

25 THE WITNESS: Not that I recall,

11:02-11:04 Page 72

 1 no.

 2 BY MR. MILLS: 

 3 Q. So, if the decision were made in June 2013

 4 to eliminate Brandy's position of

 5 HR generalist, why is it that her job was

 6 not terminated until September 2013?

 7 MS. PARKER: Objection to form.

 8 THE WITNESS: So, the decision was

 9 made, but not a decision on the timing, and

10 then there was an opportunity for Brandy to

11 actually try a different role within

12 St. Jude Medical at her request, so we

13 wanted to give her a full opportunity to

14 explore that position and see if it would be

15 a good fit potentially longer term, which

16 would then result in us not having to

17 terminate her.

18 BY MR. MILLS: 

19 Q. You said at St. Jude Medical.

20 A. I'm sorry, at G & K Services.

21 Q. And that position was a recruiting position?

22 A. That is correct.

23 Q. But that position didn't come up until the

24 end of July, right?

25 MS. PARKER: Objection to form.

11:04 Page 73

 1 THE WITNESS: I don't recall

 2 specifically when those discussions started

 3 happening.

 4 BY MR. MILLS: 

 5 Q. And you don't recall anybody at G & K ever

 6 saying anything to Brandy like, hey, you

 7 need to start looking for another job?

 8 MS. PARKER: Objection to form.

 9 THE WITNESS: No, not that I

10 recall.

11 BY MR. MILLS: 

12 Q. Well, certainly at the end of September you

13 did?

14 MS. PARKER: Objection to form.

15 Bob, I have a lot of leading questions, but

16 we're not in background anymore.

17 MR. MILLS: Well, I'm entitled to

18 lead this witness. I mean, how am I not

19 entitled to lead? You can make your

20 objections but --

21 THE WITNESS: I don't recall ever

22 telling anybody that they needed to start

23 looking for another job.

24 BY MR. MILLS: 

25 Q. Even after you made -- even after, according

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 356 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:04-11:07 Page 74

 1 to your testimony, you had made the decision

 2 that Brandy was going to go, correct?

 3 A. Correct.

 4 Q. Let's go to the very -- look at Exhibit B to

 5 the -- to Exhibit 1. I know this is getting

 6 confusing. There's a chart called

 7 Generalists. Got it?

 8 A. I do.

 9 Q. Okay. Just take a look at that and tell me

10 if this accurately reflects the structure of

11 the generalists at G & K in 2013.

12 A. So, when you say "generalists," are you

13 referring to the Northwest?

14 Q. To the Northwest, yes.

15 A. Yes, this is an accurate representation.

16 Q. All right. Let's take a look back at --

17 towards the end of the document. I want to

18 direct your attention to the -- not the last

19 page, but the fifth from the last page.

20 A. Okay.

21 Q. Okay. And the top of the page reads

22 "Performance Document - GK perform," right?

23 A. Yes.

24 Q. And is this the standard form that G & K

25 used for performance evaluations of the

11:07-11:08 Page 75

 1 HR generalists?

 2 MS. PARKER: Objection to form.

 3 THE WITNESS: It appears to be.

 4 BY MR. MILLS: 

 5 Q. This is something that you have worked with

 6 before?

 7 A. Yes.

 8 Q. If you turn to the second page of that

 9 evaluation, at the very top it says,

10 "Description Leadership Development."

11 Do you see that?

12 A. Yes.

13 Q. And then there's some texts -- or some text

14 that reads, quote, "Support and Update

15 Leaders around the coach to win model,

16 support new leaders and hope to gain

17 knowledge around Performance Management.

18 Another goal is to focus and drive

19 leadership development through developing

20 programs by developing classroom training,

21 hands on training with a mentor or coach,

22 experience or exposure based training, and

23 cross functional training," correct?

24 Did I read that correctly?

25 A. Yes, you did.

11:08-11:09 Page 76

 1 Q. And it goes on and lists some -- quote, "My

 2 main goal is to help support managers with

 3 Talent Management and to accomplish more

 4 through others of our team by sharpening

 5 skills on," and there's then there's a list

 6 of several specific tasks, right?

 7 A. Correct.

 8 Q. And this text beginning after the heading

 9 "Description Leadership Development" down to

10 "Employee Rating," that was written by

11 Brandy Williams, right?

12 A. I don't know.

13 Q. Well, this is -- if you take a look back at

14 the first page, this is an evaluation of

15 Brandy Williams, right?

16 A. Correct.

17 Q. And these objectives, the text that was

18 objectives, these were written by the

19 generalists themselves, right?

20 MS. PARKER: Objection:

21 Foundation.

22 THE WITNESS: That would be the

23 typical process but I can't say whether

24 Brandy wrote that or not. Brandy would have

25 to state that.

11:09-11:11 Page 77

 1 BY MR. MILLS: 

 2 Q. You didn't write them, did you?

 3 A. Not that I recall.

 4 Q. Did you typically ask the HR generalists to

 5 write their own objectives for the fiscal

 6 year?

 7 A. Yes.

 8 Q. If you back up to the document toward the

 9 end, it's called Exhibit H. And I

10 apologize, I think that Brandy's review is

11 part of Exhibit H attached to this document.

12 A. About where might that be?

13 Q. That's about, oh, 12, 15 pages from the end.

14 A. Okay.

15 Q. And, again, the page is entitled

16 "Performance Document - GK perform,"

17 correct?

18 A. Correct.

19 Q. This appears to be an evaluation of Janelle

20 Bonacua, correct?

21 A. Correct.

22 Q. Take a look at the second page of that

23 document. Right in the middle of the page

24 there's a heading that says Description

25 Leadership development New Role," right?

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Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:11-11:12 Page 78

 1 A. Yes.

 2 Q. And the text says, quote, "Serve as a

 3 liaison between employee and manager to

 4 support them with bringing forward talent.

 5 Provide with the tools necessary for

 6 succeeding," unquote.

 7 Did I read that right?

 8 A. Yes.

 9 Q. What tools was she referring to?

10 MS. PARKER: Objection to

11 foundation.

12 THE WITNESS: That would be a

13 variety of internal tools that we already

14 had at G & K at the time, as well as new

15 tools that the generalists identified or

16 developed.

17 BY MR. MILLS: 

18 Q. Did you write this text?

19 A. Not that I recall.

20 Q. And how do you know that those are the tools

21 that Janelle was referring to?

22 A. I'm speculating.

23 Q. What does it mean to serve as a liaison

24 between employee and manager to support them

25 with bringing forward talent?

11:12-11:13 Page 79

 1 MS. PARKER: Objection:

 2 Foundation.

 3 THE WITNESS: I think the question

 4 is unclear. Do you want my opinion or do

 5 you want what Brandy meant when she wrote

 6 it?

 7 BY MR. MILLS: 

 8 Q. Well, Brandy didn't write this portion,

 9 right --

10 A. I'm sorry, Janelle.

11 Q. -- Janelle.

12 What was your understanding as of

13 the time that you reviewed Janelle as to

14 what she meant by that?

15 A. So, working with our leadership group and

16 with our employees to identify

17 high-potential talent, to identify

18 development needs. This is all

19 organizational effectiveness.

20 Q. Did you ever ask Janelle what she meant by

21 that?

22 A. I don't recall, I may have.

23 Q. What specifically did she do to act as a

24 liaison? I'm referring to Janelle.

25 A. On an ongoing basis or -- generally?

11:13-11:14 Page 80

 1 Q. What's being referred to here in this

 2 review?

 3 A. It's been a lot of time so, unfortunately, I

 4 don't remember what specifically this might

 5 have referred to.

 6 Q. Do you know whether you ever would have

 7 specifically known what she was doing?

 8 A. Certainly.

 9 MS. PARKER: Objection to form.

10 BY MR. MILLS: 

11 Q. And your -- your rating of Janelle -- strike

12 that.

13 Under these various goals in this

14 review where it says Manager Rating, do you

15 see that?

16 A. Yes.

17 Q. Those are the ratings that you assigned?

18 A. I don't know that I can confirm that.

19 Q. You don't know whether you were the one

20 rating her?

21 A. I don't, because I don't know what I'm

22 looking at as far as there were -- this was

23 a cross-over year, so I don't know that I

24 gave her these ratings versus ratings from

25 earlier in the year.

11:14-11:16 Page 81

 1 Q. Do you remember seeing this document before,

 2 Exhibit H to Exhibit 1?

 3 A. I don't, but it's been several years, so --

 4 Q. Do you recall what basis you might have had

 5 for indicating that Janelle exceeds

 6 expectations on the objective of leadership

 7 development?

 8 MS. PARKER: Objection to form.

 9 THE WITNESS: It would have been

10 based on her activities throughout the

11 course of the time that she was an HR

12 generalist.

13 BY MR. MILLS: 

14 Q. Will you turn back to the page we were

15 looking at before with Brandy Williams under

16 Leadership Development towards the end.

17 A. Okay. Where are we?

18 Q. We are the fifth -- or fourth page from the

19 end.

20 A. Okay.

21 Q. Very top of the page says Description

22 Leadership Development.

23 Are you there?

24 A. Yes.

25 Q. And the Manager Rating was 1 - Not Meeting

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 358 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:16-11:17 Page 82

 1 Expectations.

 2 Do you see that?

 3 A. Yes.

 4 Q. Is that a rating that you gave?

 5 A. Again, I don't recall.

 6 Q. It's possible that you didn't give her that

 7 rating?

 8 A. It's possible that I didn't. I don't know,

 9 without having a system record, if these are

10 the ratings I assigned.

11 Q. Do you recall whether you would have had any

12 basis for saying that Brandy was not meeting

13 expectations with respect to the objectives

14 that she listed under Leadership

15 Development?

16 MS. PARKER: Objection to form.

17 THE WITNESS: Yes.

18 BY MR. MILLS: 

19 Q. And what do you recall?

20 A. I recall that Brandy struggled with any type

21 of development, actually, of the leadership

22 team, and that was -- she didn't do anything

23 to identify new programs or look for

24 curriculum, or materials, or ways to really

25 insert herself into the business, and kind

11:17-11:18 Page 83

 1 of develop using the tools and materials

 2 that were in place at the time at G & K, or

 3 those that she identified.

 4 Q. Did you ever talk to her about those things?

 5 A. Yes.

 6 Q. Did you ever document your conversations

 7 with her?

 8 A. I don't recall.

 9 Q. Did you ever talk to Brandy and tell her

10 that she was not meeting expectations

11 regarding Support and update leaders around

12 the coach to win model?

13 A. I don't recall specifically if we talked

14 about coach to win.

15 Q. Do you recall any manager ever expressing to

16 you any criticism or concern that Brandy was

17 not meeting expectations regarding Support

18 and update leaders around the coach to win

19 model?

20 MS. PARKER: Objection to form.

21 THE WITNESS: I don't remember what

22 the coach-to-win model is, but specific to

23 these other things, I do.

24 BY MR. MILLS: 

25 Q. Okay. Tell me what you recall.

11:18-11:19 Page 84

 1 A. I recall that I received feedback that, when

 2 she went on ride-alongs with the managers,

 3 that she looked for things to criticize,

 4 that she struggled with building

 5 relationships with the leaders, that she

 6 came from a place of putting people on the

 7 offensive by picking out things that they

 8 weren't doing well instead of coming in and

 9 listening, so jumping to conclusions.

10 Q. And those are things you heard from Jacob

11 Briscoe?

12 MS. PARKER: Objection to form.

13 THE WITNESS: Yes.

14 BY MR. MILLS: 

15 Q. Anybody else?

16 A. Yes.

17 Q. Who?

18 A. The other managers in Phoenix, as well as

19 managers in Los Angeles.

20 Q. Who in Los Angeles?

21 A. Angie Graczyk.

22 Q. What did Angie tell you?

23 A. That she did not find value in the work that

24 had been done -- or the work that Brandy was

25 doing or supposed to be doing with her

11:19-11:21 Page 85

 1 group, which included the same bucket of

 2 work we're talking about here (indicating).

 3 Q. Other than Phoenix and Angie, any other

 4 feedback from any of the other managers

 5 regarding any of the things that are listed

 6 in the text under Leadership Development?

 7 MS. PARKER: Objection to form.

 8 THE WITNESS: So, Phoenix and Angie

 9 are all that I can recall right now.

10 BY MR. MILLS: 

11 Q. Did you ever document anywhere Angie's

12 conversation with you in that regard?

13 A. I may have made some notes but I don't

14 recall today.

15 Q. And look down in the next category, it says

16 "Description Talent Management."

17 A. Yes.

18 Q. Did you write in the text below that

19 heading?

20 A. I don't know. I don't recall.

21 Q. Do you recall ever having any discussion

22 with Brandy and telling her that she was

23 not -- or that she was below expectations

24 with respect to Meeting with leaders monthly

25 to review and update 9 block?

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(21) Pages 82 - 85

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 359 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:21-11:22 Page 86

 1 MS. PARKER: Objection to form.

 2 THE WITNESS: Specifically, no, I

 3 don't recall.

 4 BY MR. MILLS: 

 5 Q. What's 9 block?

 6 A. It's a way to place employees on a grid

 7 that, basically, assesses performance and

 8 potential.

 9 Q. How did -- how did G & K use these

10 performance ratings?

11 MS. PARKER: Objection:

12 Foundation. You can answer as far as you

13 know.

14 THE WITNESS: I don't know what

15 they were used for.

16 BY MR. MILLS: 

17 Q. Do you know whether they were used in

18 connection with terminating Brandy Williams'

19 employment with G & K?

20 A. The ratings, no, I don't know.

21 Q. Is the manager rating on these evaluations

22 based upon whether the employee has met the

23 objectives that the employee set for

24 herself?

25 A. Yes. Also, though, if you're referring to

11:23-11:24 Page 87

 1 the overall rating -- or are you referring

 2 just to sections?

 3 Q. I'm referring to both.

 4 A. So, there are business objectives as well,

 5 and those are not objectives that the

 6 employee sets themselves.

 7 Q. But you would agree with me that the

 8 description under Leadership Development in

 9 Brandy's evaluation, the objectives, are

10 vastly different than the description of the

11 objectives under Leadership Development in

12 Janelle's evaluation, right?

13 MS. PARKER: Objection to form.

14 THE WITNESS: They are different,

15 sure.

16 BY MR. MILLS: 

17 Q. Well, Brandy's objections are far more

18 detailed, right?

19 MS. PARKER: Objection to form.

20 THE WITNESS: Yes.

21 BY MR. MILLS: 

22 Q. Therefore, more focused, right?

23 A. Yes.

24 MS. PARKER: Objection to form.

25 BY MR. MILLS: 

11:24 Page 88

 1 Q. And they are more onerous than the ones that

 2 are in Janelle's, right?

 3 MS. PARKER: Objection to form.

 4 THE WITNESS: I don't know that

 5 "onerous" is the right word.

 6 BY MR. MILLS: 

 7 Q. All Janelle's says is "serve as a liaison,"

 8 right?

 9 A. There's more detail in Brandy's. It doesn't

10 necessarily mean it's more onerous.

11 Q. Would you agree with me that an employee who

12 includes a more detailed objective will have

13 a more difficult time meeting that objective

14 than an employee who puts down a very vague

15 objective?

16 MS. PARKER: Objection to form.

17 THE WITNESS: No.

18 BY MR. MILLS: 

19 Q. Why not?

20 A. Because it's about the spirit of the

21 objective.

22 Q. What do you know about the spirit of

23 Janelle's objective?

24 A. I can speak to Brandy putting a list of

25 things in here, and you don't go through and

11:24-11:26 Page 89

 1 checkmark yes, you did this, and no, you

 2 didn't, and if you didn't do one of them,

 3 then you don't meet expectations. That's

 4 not how it works.

 5 Q. So, how does it work?

 6 A. It's a balancing act. You look through the

 7 objectives. These are some things that

 8 could be considered. They are tools. These

 9 are common tools, though, that we would

10 expect all of our generalists to work with

11 our leaders to develop.

12 Q. What are the business objectives that you

13 say you considered?

14 A. The business objectives are listed at the

15 beginning of the form.

16 Q. Where?

17 A. Under GK Objectives, I believe.

18 Q. Okay. Which are the -- which are the

19 business -- you're going to have to help me

20 with this one.

21 Which are the GK business

22 objectives?

23 A. If you like, I can go through and find

24 them --

25 Q. Let's just focus on Brandy's evaluation, the

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(22) Pages 86 - 89

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 360 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:26-11:27 Page 90

 1 one we were just looking at, okay?

 2 And it says GK performance

 3 objectives on the first page?

 4 A. Yes.

 5 Q. Okay.

 6 A. So, there are objectives that are not in

 7 this copy.

 8 Q. So, is this document incomplete?

 9 A. There are objectives that relate to the

10 business, revenue and operating income and

11 other measures.

12 Q. Well, where?

13 A. I don't know. I didn't produce the

14 document.

15 Q. I didn't either. I mean, where -- I'm

16 really trying to understand what's missing

17 from this document.

18 You said that there were objectives

19 that don't appear on this document.

20 What's not in here that you recall

21 being in the reviews that you did?

22 A. I recall there being performance objectives

23 for the business, so anybody that was a part

24 of the business had the same rating, so

25 things like revenue, operating income, NPS,

11:27-11:28 Page 91

 1 I think, maybe was part of it.

 2 Q. But you don't see any of that in this

 3 performance review form, right?

 4 A. Not in this one, no.

 5 Q. Do you know whether it would have been in

 6 the performance review as it was originally

 7 prepared regarding Brandy Williams?

 8 A. I don't know.

 9 Q. You would have expected it to be, wouldn't

10 you?

11 A. Well, I don't know. I don't -- again, I

12 don't know exactly what this is

13 (indicating).

14 MS. PARKER: Rachael, do you need

15 to take some time to read it more

16 thoroughly?

17 THE WITNESS: I think that would be

18 helpful.

19 MR. MILLS: Okay, that's fine.

20 THE WITNESS: It's a 50-page packet

21 so --

22 BY MR. MILLS: 

23 Q. Yeah, but I'm really -- right now, I'm just

24 focused on these performance reviews at the

25 very end that's Exhibit H. If you want to

11:28-11:29 Page 92

 1 take a couple minutes and read through

 2 those, that's fine with me.

 3 A. Okay. (Perusing.) It's the copy.

 4 Q. It's what?

 5 A. It's the quality of the copy that's missing.

 6 Q. What does that mean?

 7 A. There's stuff that's not on here that's

 8 missing.

 9 Q. Can you tell where it's missing from?

10 A. Under Section 2 - GK Perform, there's no

11 headings. As far as I can tell, there's

12 potentially --

13 Q. Well, I can -- yeah, I mean, I can see under

14 GK Perform Objectives, there's like -- right

15 underneath it there's some -- I don't know,

16 a blob or something that's --

17 A. "Description This is a group rating and will

18 be given to you either by your location's

19 manager or through an email for corporate

20 employees."

21 Clearly, that refers to something

22 but it's not on here, so I don't know what

23 that means.

24 Q. And the same would be true under -- or in

25 connection with Customer Focus?

11:29-11:31 Page 93

 1 A. I believe so, yes.

 2 Q. So, would it be wrong to base an employee's

 3 performance evaluation solely on the

 4 objectives that the employee set for herself

 5 for the fiscal year?

 6 MS. PARKER: I'm going to object to

 7 form.

 8 THE WITNESS: Wrong in what

 9 respect?

10 BY MR. MILLS: 

11 Q. Would you agree with me that a performance

12 rating of an employee should be objective?

13 A. Yes.

14 Q. And would you also agree with me that, if

15 you were to base the rating solely on what

16 -- the objectives that the employee set for

17 herself, that's not objective?

18 MS. PARKER: Objection to form.

19 THE WITNESS: I don't know that

20 it's not objective. So, again, there's --

21 if somebody puts an exhaustive list of

22 things down, I'm not going to say that, if

23 they didn't meet one of those list of 10

24 things that's minor, that they should be not

25 meeting expectations.

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(23) Pages 90 - 93

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 361 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:31 Page 94

 1 BY MR. MILLS: 

 2 Q. But you would agree with me that various

 3 employees can put very different statements

 4 of objectives for their fiscal year

 5 performance review, right?

 6 MS. PARKER: I'm going to object to

 7 form.

 8 THE WITNESS: Yes.

 9 BY MR. MILLS: 

10 Q. And that any given employee's performance

11 rating for the fiscal year shouldn't be

12 based solely on what that employee set as

13 her own objectives, right?

14 MS. PARKER: Objection to form. I

15 think this mischaracterizes prior testimony.

16 THE WITNESS: Can you repeat that

17 question?

18 BY MR. MILLS: 

19 Q. Yeah. And any individual employee's

20 performance rating for the year shouldn't

21 just be based on the objectives that she

22 wrote down for herself at the beginning of

23 the year, right?

24 MS. PARKER: Same objection.

25 THE WITNESS: What else would it be

11:31-11:32 Page 95

 1 based on?

 2 BY MR. MILLS: 

 3 Q. Well, you just told me that there were

 4 company objectives that were missing from

 5 this document, right?

 6 A. Well, they are, I'm assuming, on this

 7 document, but the copy isn't reflecting

 8 them.

 9 Q. You wouldn't base an employee's rating

10 solely on what the employee set as her

11 objectives at the beginning of a fiscal

12 year, would you?

13 A. Solely on their objectives, no, because the

14 company objectives are part of the overall

15 rating.

16 Q. Why wouldn't you base it solely on the

17 employee's objectives?

18 MS. PARKER: Again, objection to

19 form.

20 THE WITNESS: Because the company

21 objectives are part of the overall

22 calculated rating.

23 BY MR. MILLS: 

24 Q. As the company objectives that might --

25 strike that.

11:32-11:33 Page 96

 1 It's also because, if you based

 2 this solely on the employee's objectives

 3 alone, that would not be an objective

 4 evaluation, right?

 5 MS. PARKER: Objection to form. It

 6 mischaracterizes her prior testimony.

 7 THE WITNESS: I think that

 8 doesn't -- I'm not sure I understand.

 9 BY MR. MILLS: 

10 Q. How would you rate an employee who didn't

11 put anything down as their objectives for a

12 fiscal year?

13 MS. PARKER: Objection: Calls for

14 speculation.

15 BY MR. MILLS: 

16 Q. That they exceed expectation?

17 A. It's a business, exceeded expectations, and,

18 hypothetically, an employee had absolutely

19 no goals written down, hypothetically, the

20 way the system works, the person could

21 potentially have exceeds expectations.

22 Q. But that's regardless of the objectives that

23 he wrote down, or she wrote down, for

24 herself, right?

25 MS. PARKER: Again, I'm going to

11:33-11:34 Page 97

 1 object that this calls for speculation.

 2 This is not a circumstance that we have.

 3 There's --

 4 THE WITNESS: This is -- I'm

 5 unclear about what you're asking.

 6 BY MR. MILLS: 

 7 Q. Let me just ask you this really

 8 specifically: You evaluate -- you did a

 9 performance rating of Brandy Williams,

10 didn't you?

11 A. I believe so, yes.

12 Q. Okay. Did you base that on -- did you --

13 strike that.

14 Did you base your performance

15 rating of Brandy Williams on her

16 descriptions of her objectives as are stated

17 in the GP Perform document?

18 MS. PARKER: Objection: Form.

19 THE WITNESS: Did I rate her on her

20 descriptions? No. I rated her on her

21 performance against the objectives that she

22 set.

23 BY MR. MILLS: 

24 Q. Anything else?

25 A. Did I rate her on anything else? No.

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(24) Pages 94 - 97

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 362 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

11:34-11:35 Page 98

 1 Q. Did you rate her -- did you rate her on

 2 anything other than objectives that she set

 3 for herself?

 4 A. Did I personally? No.

 5 Q. So, but your rating of Ms. Williams was

 6 based -- for example, under the category

 7 Leadership Development, would have been

 8 based solely on her own statement of

 9 objectives and how well she was able to

10 achieve her own stated objectives?

11 MS. PARKER: Form; asked and

12 answered.

13 THE WITNESS: Yes. So, this is her

14 objective. I rated her against her

15 objective.

16 BY MR. MILLS: 

17 Q. And nothing else?

18 A. For the objective, correct.

19 Q. So, under Leadership -- I just want to make

20 sure this is crystal clear for the record.

21 So, under Leadership Development,

22 if you rated Brandy Williams, and that is,

23 in fact, your rating as not meeting

24 expectations, that's based solely on

25 Brandy's description of her objectives for

11:35-11:36 Page 99

 1 the fiscal year ending June 30, 2013 --

 2 MS. PARKER: Objection to form.

 3 BY MR. MILLS: 

 4 Q. -- that is appearing in the text below the

 5 heading Description Leadership Development,

 6 correct?

 7 MS. PARKER: This question has been

 8 asked and answered; it mischaracterizes her

 9 prior testimony. It's not crystal clear.

10 Her prior testimony --

11 BY MR. MILLS: 

12 Q. You can answer the question.

13 A. I think you are misstating what I said,

14 so --

15 Q. Help me out.

16 A. -- you're trying to tell me -- or you're

17 trying to get me to say right now that I

18 rated her on exactly what is written here,

19 and I've told you, this -- her bucket is

20 Leadership Development, okay, that is the

21 bucket of the goal.

22 If somebody, for instance, misses

23 one thing on here, so she wrote a really

24 specific list, I'm not going to penalize

25 somebody if they achieve every single thing

11:36-12:37 Page 100

 1 on this list except for one because that's

 2 overly harsh.

 3 Q. But are you using any other criteria to

 4 evaluate Brandy's performance other than the

 5 objectives that she, herself, wrote in this

 6 form?

 7 MS. PARKER: Again, objection to

 8 form.

 9 THE WITNESS: Am I using -- I can

10 see the ratings that I gave here. I haven't

11 had time to review the document. Is there

12 anything else listed in there --

13 BY MR. MILLS: 

14 Q. Please sit and read it --

15 A. -- description?

16 Q. I want you to sit and read it because I want

17 this to be very clear.

18 MR. MILLS: Actually, we need to

19 change the tape so it's a perfect

20 opportunity.

21 THE VIDEOGRAPHER: We're off video

22 record. The time on the video monitor is

23 11:37 a.m.

24 (A recess was taken.)

25 THE VIDEOGRAPHER: We are back on

12:37-12:38 Page 101

 1 video record. The time on the video monitor

 2 is 12:37 p.m.

 3 MR. MILLS: Good afternoon.

 4 Before we broke, we had had a

 5 question regarding the review of Brandy

 6 Williams. I'm going to ask the court

 7 reporter if you could go back and read that

 8 back because I think, in response to the

 9 question, you indicated you needed to look

10 at the document, so --

11 (Question read back as requested as

12 follows:

13 "Q. But are you using any other

14 criteria to evaluate Brandy's performance

15 other than the objectives that she, herself,

16 wrote in this form?")

17 MS. PARKER: Is there an answer?

18 Or was there an answer?

19 (Testimony read back as requested

20 as follows:

21 "MS. PARKER: Again, objection to form.

22 "THE WITNESS: Am I using -- I can see

23 the ratings that I gave here. I haven't had

24 time to review the document. Is there

25 anything else listed in there --

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(25) Pages 98 - 101

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 363 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

12:38-12:39 Page 102

 1 "Q. Please sit and read it --

 2 "A. -- description?")

 3 BY MR. MILLS: 

 4 Q. So, I'll re-ask the question now.

 5 Were there any other criterion

 6 other than the objectives that Brandy wrote

 7 herself in her performance review that you

 8 used in order to rate her performance?

 9 A. Yes. So, after having a chance to review,

10 Brandy didn't rate her -- she didn't write

11 any comments in here, so she actually did

12 not complete her GP Perform, so that was

13 something that she and I talked about on

14 multiple occasions, so that would have

15 started the overall rating that I gave her.

16 The other comments in here, I

17 think, tie back to the objectives that she

18 gave herself.

19 So, again, like I mentioned, it's

20 more of the totality of the performance, not

21 necessarily checking off a box to say yes,

22 you did these 10 things, because each

23 person -- I have the same expectations for

24 each generalist, but they might write it

25 differently in here.

12:39-12:40 Page 103

 1 I expect them all to work through

 2 leadership development and coaching and to

 3 develop materials and training and support

 4 their team.

 5 Q. Were there any objective criteria, other

 6 than the objectives that Brandy, herself,

 7 wrote down that you used to give her a

 8 rating?

 9 MS. PARKER: Objection to form.

10 THE WITNESS: Can you define

11 "objective" as you're asking the question?

12 BY MR. MILLS: 

13 Q. My understanding -- and you can correct me

14 if I'm wrong.

15 My understanding of your testimony

16 is that you looked at the objectives that

17 Brandy wrote down for herself --

18 A. Sure.

19 Q. -- for the fiscal year.

20 And then you rated her based on

21 whether she met those objectives or not,

22 right?

23 MS. PARKER: I object that this

24 mischaracterizes the testimony. I think the

25 testimony was that that was only one part.

12:40-12:41 Page 104

 1 THE WITNESS: Correct, so I rated

 2 her against the be objectives that she

 3 wrote, and then against things like the fact

 4 that she didn't complete her review.

 5 There were also a category of

 6 objectives that are related to the

 7 business's performance as well.

 8 BY MR. MILLS: 

 9 Q. If I were to want to look at those

10 categories of objectives for the business

11 itself, where would I find them?

12 A. They would be on here if the copy came

13 through.

14 Q. Do you believe that they've been redacted

15 from this document?

16 A. No, I don't.

17 Q. Why not?

18 A. I don't know. It doesn't say that they've

19 been redacted.

20 Q. But they don't appear on this document,

21 right?

22 A. Well, they are here. The copy is just --

23 the photocopy quality is not good so you

24 can't see it.

25 There are headings here that you

12:41-12:42 Page 105

 1 can't see, and I believe those to be, to the

 2 best of my recollection, where the business

 3 objectives would sit.

 4 Q. When you said that Brandy didn't provide any

 5 comments on this, if you look at the first

 6 page of her performance review --

 7 A. Yes.

 8 Q. -- there's a section Mid-year Comments?

 9 A. Correct.

10 Q. Is the text of that section something that

11 was drafted by Brandy, to your knowledge?

12 A. So, if this is midyear comments, this is not

13 what I was referring to in the year-end

14 evaluation.

15 So, this is before -- this would be

16 before the job changed, so this would have

17 been relevant to her job as an HR

18 representative.

19 Q. What criteria did you and the others at

20 G & K use to determine that Brandy Williams'

21 position, in particular as a G & K

22 generalist, would be eliminated?

23 MS. PARKER: Objection:

24 Mischaracterizes prior testimony.

25 BY MR. MILLS: 

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(26) Pages 102 - 105

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 364 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

12:42-12:43 Page 106

 1 Q. Do you understand my question?

 2 A. I believe so. Maybe not.

 3 MS. PARKER: Maybe I didn't

 4 understand it.

 5 BY MR. MILLS: 

 6 Q. All right. You had testified before

 7 lunch --

 8 A. Yes.

 9 Q. -- that a determination was made, I believe

10 in June, according to your testimony, that

11 Brandy Williams' position was going to be

12 eliminated, right?

13 A. Correct, yes.

14 Q. Okay. My question to you now is: What

15 criterion did you and others at G & K use to

16 make the determination that it was her

17 position that was going to be eliminated?

18 A. Okay. I think I understand.

19 So, based on the way the region was

20 laid out, there was a generalist in

21 Minnesota, and there are four plants in

22 Minnesota, and there was a generalist in

23 Northern California, and that was Janelle,

24 and there were two plants in Northern

25 California, and all of their associated

12:43-12:44 Page 107

 1 branches.

 2 And then there was the Phoenix

 3 plant and the LA plant, so kind of

 4 collectively split between the three.

 5 Kaela sat in St. Paul, and that is

 6 the business that she has supported since

 7 she started with G & K, and there were some

 8 unique things about those businesses

 9 specifically related to labor agreements and

10 some of the unions, she knew the business

11 really well, the business relied on her.

12 And so, she also sat there, so she

13 could pretty much be at any of the three

14 Twin Cities plants or the St. Cloud plants

15 as needed without having to get on an

16 airplane.

17 So, geographically, it made logical

18 sense for Kaela to stay in St. Paul. And

19 then, with Janelle sitting in one of the two

20 Northern California plants, obviously,

21 that's a benefit, but also Janelle had

22 worked in HR in California for a number of

23 years.

24 And, as I'm guessing you're aware,

25 being a neighbor of California, California

12:44-12:45 Page 108

 1 employment law can be a little tricky,

 2 however, they call it the great country of

 3 California.

 4 So, for me, having somebody who was

 5 very familiar with California employment

 6 law, and had a long history of working with

 7 California and employment issues, and such,

 8 was also really important.

 9 So, it made sense, as we looked at

10 how to divide the region up, that Janelle

11 would pick up California, which would

12 include Los Angeles and its branches, and

13 then Phoenix would just be the outlier, and

14 Brandy -- or Kaela would pick up Phoenix.

15 Q. Were there any criteria -- strike that.

16 Were there any other criteria that

17 you or anybody else at G & K used to

18 determine that Brandy's position would be

19 the one eliminated?

20 A. That was the primary criteria. Secondary to

21 that, she struggled more than the others

22 with the generalist role. Her performance

23 wasn't where -- her performance wasn't

24 necessarily meeting expectations.

25 Q. Do you recall what the Performance

12:45-12:46 Page 109

 1 Improvement Program was at G & K?

 2 A. Yes.

 3 Q. And what was it?

 4 A. What was it at G & K?

 5 Q. Yes.

 6 A. It was a Performance Improvement Program

 7 that people who weren't performing could be

 8 placed on a written Performance Improvement

 9 Plan.

10 Q. Was that typically something that was done

11 before an employee was terminated due to

12 performance?

13 A. Typically, yes, although if somebody did

14 something that was extremely egregious,

15 there wouldn't be a performance improvement

16 process.

17 Q. Let me put it this way: Was it G & K's

18 policy to put someone on a Performance

19 Improvement Program before terminating them?

20 MS. PARKER: Objection to form.

21 THE WITNESS: If someone was

22 terminated with poor performance, typically

23 yes.

24 BY MR. MILLS: 

25 Q. Was Brandy Williams ever put on a

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 365 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

12:46-12:48 Page 110

 1 Performance Improvement Plan?

 2 A. No.

 3 Q. To your knowledge, was Brandy Williams ever

 4 written up for being absent or tardy at

 5 G & K?

 6 A. Not that I know of.

 7 Q. And how many -- how many plants or branches

 8 was Janelle supporting in Northern

 9 California during the same time that Brandy

10 was an HR generalist?

11 MS. PARKER: Objection to form.

12 Plants and branches, I'm not sure if you

13 mean that conjunctively or disjunctively.

14 MR. MILLS: I mean it conjunctively

15 because --

16 BY MR. MILLS: 

17 Q. Strike that.

18 This morning we talked about there

19 being a difference between a plant and a

20 branch, right?

21 A. Yes.

22 Q. How many total plants and branches combined

23 were there in the Northern California area

24 that Janelle was servicing during the same

25 time that Brandy was servicing Phoenix?

12:48-12:50 Page 111

 1 MS. PARKER: Objection to form.

 2 THE WITNESS: There were two plants

 3 and at least two branches, but I can't

 4 recall if there were more than that.

 5 BY MR. MILLS: 

 6 Q. But you would agree with me that, during the

 7 time that she was an HR generalist in the

 8 Northwest Region, that Brandy Williams was

 9 supporting more than three locations?

10 MS. PARKER: Objection to form.

11 THE WITNESS: "Locations"

12 defined --

13 BY MR. MILLS: 

14 Q. As a branch or a plant.

15 A. Yes.

16 Q. She was supporting more than three?

17 A. Yes.

18 MS. PARKER: Again, objection to

19 form.

20 BY MR. MILLS: 

21 Q. Let's move on.

22 MR. MILLS: Let's mark this as 2, I

23 guess.

24 (Exhibit 2 was marked.)

25 BY MR. MILLS: 

12:50-12:52 Page 112

 1 Q. Ma'am, I've handed you a document that's

 2 been marked as Exhibit 2. And I'm going to

 3 call your attention to the first one, two,

 4 three, four pages of the document. It's

 5 Bates numbered G & K 448 through 451. If

 6 you could take a minute to look at those.

 7 A. (Perusing.) Just through 451?

 8 Q. Let's focus on the first few pages for now.

 9 Do you recognize the handwriting?

10 A. I do.

11 Q. Is it yours?

12 A. It is.

13 Q. Okay. These are your notes?

14 A. Yes, they are.

15 Q. Okay. And are these notes that you made

16 during your tenure at G & K?

17 A. I believe so, yes.

18 Q. And why did you make these notes?

19 A. I just made them in the course of business.

20 Q. Do you typically take notes -- or strike

21 that.

22 Did you typically take notes during

23 the course of your business at G & K?

24 A. Yes.

25 Q. Did you do that every day?

12:52-12:53 Page 113

 1 A. I don't recall if I made notes every day.

 2 Q. What types of things would prompt you to

 3 take notes?

 4 A. I would take notes from the one-on-ones that

 5 I had with employees, if I had a meeting

 6 with a manager, I would take notes about

 7 employee calls, just general things that I

 8 thought were relevant.

 9 Q. What's one-on-one?

10 A. One-on-one is a meeting with one other

11 employee, typically someone that reports to

12 you but one-on-one meeting.

13 Q. Would you turn to the second page of the

14 exhibit Bates numbered 449?

15 A. Yes.

16 Q. And the writing appears to say "Kaela

17 one-on-one," right?

18 A. Correct.

19 Q. Is that referring to Kaela Ellison?

20 A. Yes.

21 Q. And that's dated June 13, 2013?

22 A. Yes, it is.

23 Q. Okay. And then there is a paragraph

24 numbered 1 that reads -- and correct me if I

25 get this wrong -- quote, "Bored, miss the

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 366 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

12:54-12:55 Page 114

 1 connection to our employees, don't feel like

 2 I have an impact, managers don't know what I

 3 do. I hate my job."

 4 Did I read that right?

 5 A. Yes.

 6 Q. Are those statements that Kaela was making

 7 to you?

 8 A. They would be kind of the general -- general

 9 statements that she was making.

10 Q. Did you have any response to Kaela telling

11 you that she was bored?

12 A. Other than I know we looked at -- so, again,

13 specifically to this Note Number 1 at this

14 particular time, I don't remember.

15 Q. Had Kaela told you on other occasions that

16 she was bored?

17 A. Yes.

18 Q. How frequently did she do that?

19 A. Pretty much weekly.

20 Q. And did you ever tell her anything that she

21 could do to alleviate her boredom?

22 A. Yes.

23 Q. What did you say?

24 A. I asked her to continue looking for

25 additional opportunities to engage with the

12:55-12:56 Page 115

 1 business, to get out and meet with the

 2 managers, to go on ride-alongs, to engage,

 3 to understand what the business needs were,

 4 and then to come up with suggestions that

 5 she had to address those needs, either with

 6 the existing tools that were in place or

 7 tools that she created.

 8 Q. Did you say anything to Kaela that you

 9 recall in response to her statement that she

10 hated her job?

11 A. Did I?

12 Q. Yes.

13 A. I don't recall.

14 Q. Did it concern you that she said that she

15 hated her job?

16 A. Not necessarily. So, it was one-on-one with

17 an employee, and I encouraged my employees

18 to be very candid with me.

19 So, if there's something that, you

20 know, that they can tell me that we can work

21 to fix, then yes, but I think you always

22 need to remember --

23 Q. Do you recall whether she told you why she

24 hated her job?

25 A. The things listed in this paragraph.

12:56-12:57 Page 116

 1 Q. Including that she was bored?

 2 A. She was bored, the job had changed. So,

 3 remember, this is the generalist job, not

 4 the HR representative job.

 5 Q. And the managers didn't know what she was

 6 doing?

 7 A. She felt that.

 8 Q. Had you heard any feedback from her managers

 9 that they didn't feel like they understood

10 what her role was as an HR generalist?

11 A. I don't recall that I heard specifically

12 from her managers that they didn't know.

13 I may have heard -- there was

14 general feedback from managers in the region

15 that they didn't understand what the

16 generalist role was.

17 Q. Did Kaela ever express to you that she

18 didn't understand what her role was as an HR

19 generalist?

20 A. I don't remember if she said she didn't

21 understand. I know the entire time we went

22 through the HR realignment, kind of,

23 post-implementation we were all kind of

24 seeking to understand and, really, define

25 what those roles are.

12:57-12:58 Page 117

 1 It's one thing to say this is what

 2 you do on paper, and it's a completely

 3 different things to kind of shift a mind-set

 4 and start kind of showing up in a different

 5 way and acting in a different way and

 6 working in a different way than you have in

 7 the past.

 8 Q. Did Kaela ever express to you that she felt

 9 that the managers were unhappy because they

10 didn't understand what her role was as an HR

11 generalist?

12 A. No, not specifically, no.

13 Q. Or anything suggesting that generally?

14 MS. PARKER: Objection to form.

15 THE WITNESS: Not that I remember.

16 BY MR. MILLS: 

17 Q. Did Brandy Williams ever tell you that she

18 was bored with her job?

19 A. I don't ever recall her using the word

20 "bored."

21 Q. Do you recall Brandy Williams ever telling

22 you that she hated her job?

23 A. In those specific words, no.

24 Q. In similar words?

25 A. Yes.

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 367 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

12:58-12:59 Page 118

 1 Q. What do you recall?

 2 A. I recall her expressing, on multiple

 3 occasions, that she felt that people didn't

 4 know what she did, and that she didn't feel

 5 like she was contributing to the business,

 6 and she didn't know if she was happy. Yes,

 7 in those words, yes.

 8 Q. And did she express to you that her

 9 unhappiness was based on what she was

10 hearing from other people?

11 A. No, not that I recall.

12 Q. Do you recall Brandy telling you that she

13 felt like the managers didn't understand

14 what her role was as an HR generalist?

15 MS. PARKER: Objection to form.

16 THE WITNESS: I don't remember it

17 specifically but it wouldn't surprise me.

18 BY MR. MILLS: 

19 Q. But Kaela had expressed similar concern that

20 managers didn't understand what this new

21 role was?

22 A. Yes, yes.

23 (Exhibit 3 was marked.)

24 BY MR. MILLS: 

25 Q. I'm handing you a document that's been

01:00-01:01 Page 119

 1 marked as Exhibit 3, and I'm going to ask

 2 you to take a quick look at it and tell me

 3 if you can identify this document as

 4 containing your handwritten notes.

 5 MS. PARKER: So, I'm -- maybe this

 6 is supposed to be separate. I have another

 7 document. (Handing.)

 8 MR. MILLS: Yeah, that doesn't go

 9 with that.

10 MS. PARKER: And I was just going

11 to ask, because I wonder if Exhibit 2 -- was

12 it supposed to have all these emails in it?

13 MR. MILLS: Yes, because we were --

14 yeah.

15 MS. PARKER: Okay. We didn't get

16 to how they belong together.

17 MR. MILLS: No.

18 THE WITNESS: Can I ask you

19 something super quick?

20 MS. PARKER: On -- off the record?

21 THE WITNESS: Yeah. Is that

22 possible and something that I just -- I saw

23 in here that I don't know if it should be in

24 here, if these are going to be public or

25 published.

01:01-01:05 Page 120

 1 MS. PARKER: We have a concern

 2 about redaction -- is it in --

 3 THE WITNESS: It was in the first

 4 set, too.

 5 THE VIDEOGRAPHER: We're off the

 6 video record. The time on the monitor is

 7 1:01 p.m.

 8 (Discussion off the record.)

 9 THE VIDEOGRAPHER: We are back on

10 the video record. The time on the monitor

11 is 1:04 p.m.

12 MS. PARKER: All right. So, our

13 off-the-record discussion was with respect

14 to G & K 000450, the third page of

15 Exhibit 2.

16 And we are requesting to redact the

17 paragraph numbered 2, which is regarding an

18 individual who is not Kaela and contains

19 some confidential personnel information, and

20 I think we have a stipulation.

21 MR. MILLS: I will stipulate on the

22 record to that.

23 MS. PARKER: Thank you.

24 MR. MILLS: So, let's move on to

25 Exhibit 3.

01:05-01:06 Page 121

 1 BY MR. MILLS: 

 2 Q. And my question is: Are these your -- is

 3 this a copy of your handwritten notes?

 4 A. It looks to be, yes.

 5 Q. Have you had an opportunity to review them

 6 prior to the deposition?

 7 A. To some extent, yes. I would say I don't

 8 have them memorized, though.

 9 Q. By the way, what did you do to prepare for

10 your deposition?

11 A. Well, I turned over my notebook that I

12 found, which is where these notes were, and

13 then I just met with Kristin and Jenny.

14 Q. How long did you meet with them?

15 A. Probably about a half day.

16 Q. Can you tell by looking at these notes when

17 they start? And by that I mean, what's the

18 earlier date you see in here on your notes?

19 A. Do you want me to go through them all and

20 look or are they in chronological order?

21 Q. I don't know. I mean, there are some --

22 A. Okay. I would have to -- honestly, I would

23 have to go through and look at them all to

24 see if they are in order.

25 MS. PARKER: You can take your

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 368 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

01:06-01:13 Page 122

 1 time.

 2 BY MR. MILLS: 

 3 Q. I would kind of like you to do that because

 4 there's some pages that don't have any date

 5 on them so I want to know -- I kind of want

 6 to know what the timeframe is that we're

 7 dealing with here.

 8 A. Okay. (Perusing.)

 9 MS. PARKER: While Ms. Siggerud is

10 reviewing this document, it's been brought

11 to my attention there are two additional

12 instances that are similar to the redaction

13 we just discussed.

14 MR. MILLS: Okay.

15 MS. PARKER: On G & K page 000310,

16 the last line of paragraph 7 contains

17 medical information. It's literally the

18 last line on that page.

19 MR. MILLS: I will stipulate that

20 can come out.

21 MS. PARKER: Great. And then page

22 319, there is this -- the paragraph 1, the

23 first two lines contain medical information.

24 There's other confidential information in

25 that paragraph 1.

01:13-01:14 Page 123

 1 MR. MILLS: I'm sorry, what page

 2 are you on, 3 --

 3 MS. PARKER: 319, and the numbers

 4 are a little bit hard to read, I apologize.

 5 This is the note 7/2/13, Brandy one-on-one,

 6 that same discussion of an employee's

 7 medical condition -- you know, the

 8 employee's name -- the last name is

 9 redacted, I think we could just redact the

10 employee's first name.

11 MR. MILLS: Can I ask the witness a

12 question?

13 MS. PARKER: Sure.

14 BY MR. MILLS: 

15 Q. Ma'am, this information on page Bates

16 numbered 319 in paragraph 1, is this your

17 documentation of a conversation you had with

18 Brandy Williams?

19 A. It would have been out of a conversation, so

20 I don't know if I was taking notes or

21 capturing what I was sharing with her or

22 what she was sharing with me.

23 Q. Okay. But this individual that's referenced

24 in paragraph 1, is that an employee --

25 A. Yes.

01:14-01:15 Page 124

 1 Q. -- of G & K?

 2 A. Yes.

 3 Q. And that would have been a topic of your

 4 discussion with Brandy?

 5 A. Yes.

 6 MR. MILLS: I'll stipulate that

 7 that can come out.

 8 MS. PARKER: Thank you.

 9 THE WITNESS: All right. I think

10 they are in order. The only one I don't

11 100 percent have a date on --

12 BY MR. MILLS: 

13 Q. What's the Bates number on that page?

14 A. 313.

15 Q. 313. Okay. And you think that, other than

16 that, that these notes are in chronological

17 order?

18 A. I believe so.

19 Q. What's the earliest date on any of these

20 notes?

21 A. On any of these notes, May 1st of 2013.

22 Q. Okay. And that reflects one-on-one with

23 Brandy?

24 A. That is correct.

25 Q. Why do they start in May of 2013?

01:15-01:16 Page 125

 1 A. I don't know without having the notebook.

 2 It may have been the beginning of a new

 3 notebook.

 4 Q. Did you have notes regarding Brandy prior to

 5 May 2013?

 6 A. I would have, yes.

 7 Q. Do you know where those are?

 8 A. I do not.

 9 Q. I mean, do you have them in your possession?

10 A. I do not.

11 Q. Did you give them to counsel?

12 A. No.

13 Q. How many notes did these -- or how many

14 notebooks did these notes that constitute

15 Exhibit 3 come out of?

16 A. One.

17 Q. And did you have that notebook in your

18 possession?

19 A. I did.

20 Q. And what happened to the other notebooks?

21 A. I have no idea. They were probably thrown

22 away.

23 Q. Did you -- well, did you leave them at

24 G & K?

25 A. Some may have been left at G & K, some I

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 369 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

01:16-01:17 Page 126

 1 probably took with and threw away at a later

 2 date when I cleaned my house.

 3 Q. Why did you take notes?

 4 A. I take notes to keep -- just to kind of keep

 5 my thoughts relevant, so if I need to go

 6 back and look at something, then I can

 7 remember it, so --

 8 Q. Do you know why you would have thrown away

 9 any of the notebooks?

10 A. Because they -- I didn't need them anymore.

11 Q. Why did you -- why did you happen to have

12 this one out of which we have Exhibit 3?

13 A. I didn't realize I had it until I cleaned my

14 basement, and then I found it. So, I really

15 didn't think I had it anymore.

16 Q. Were you looking for it?

17 A. No, I wasn't, actually.

18 Q. Had anybody asked you to look for it?

19 A. No, I don't think so, no.

20 Q. And what did you do when you found it?

21 A. When I found it, I let -- I don't know if I

22 should --

23 THE WITNESS: I spoke with G & K

24 about it.

25 MS. PARKER: Not -- again, not like

01:17-01:19 Page 127

 1 the whole discussion but the fact that

 2 you --

 3 THE WITNESS: I notified G & K that

 4 I had found notes.

 5 BY MR. MILLS: 

 6 Q. Why did you notify them about that?

 7 A. I notified them of that because I was aware

 8 of conversations that I had had with Marie

 9 Smith dating back to the date, early April,

10 or before, asking if I had any notes.

11 Q. Do you recall when it was that you gave the

12 notebook to G & K?

13 A. Exactly, no.

14 Q. Did you become aware at some point that

15 Brandy Williams had filed a lawsuit against

16 G & K?

17 A. Yes.

18 Q. When did you learn that?

19 A. Within the past couple of months, or so.

20 Q. Before or after you found the notebook?

21 A. After, it was after I found the notebook.

22 Q. And after you turned it over to G & K?

23 A. No. I turned -- I found out that I had the

24 notebook, and I let G & K know that I had

25 found it because Marie Smith had asked about

01:19-01:20 Page 128

 1 it kind of a couple years ago and I was

 2 unsure of the status of the EEOC charge or

 3 anything, so I let them know that I had it,

 4 and then they requested that I give it to

 5 them, so I did.

 6 Q. And they requested it after you learned the

 7 lawsuit had been filed?

 8 A. I don't remember when I found -- yeah, I

 9 assume so. I just -- I don't remember the

10 exact timing.

11 Q. Is it possible that you left some of your

12 notebooks at G & K when you left?

13 A. It's possible.

14 Q. Where would they be if you had left them

15 there?

16 A. They would have been in my office.

17 Q. I guess the better question is: Where would

18 you have left them?

19 A. I can tell you if I did leave them, it would

20 have been in my office.

21 Q. Do you know who took over your position at

22 G & K when you left?

23 A. It was empty for a while.

24 Q. The regional manager's position was empty

25 for a while?

01:20-01:22 Page 129

 1 A. The regional director, yes.

 2 Q. Regional director, sorry. Is there anybody

 3 in that position now?

 4 A. I think there is, yes.

 5 Q. Do you know who that is?

 6 A. I think her name is Julie.

 7 Q. Did you recall Brandy telling you that she

 8 felt like she wasn't getting any feedback

 9 from Jake Briscoe in Phoenix?

10 A. At any particular point or --

11 Q. At any -- at any time.

12 A. I don't recall her saying that. If it's in

13 my notes, it's possible that she did and I

14 just don't remember it.

15 Q. Do you recall ever having a conversation

16 with Jake Briscoe about giving feedback to

17 Brandy in her role as an HR generalist?

18 A. I don't remember. If there's a more

19 specific instance you're asking about, I

20 might be able to give more information.

21 Q. Did either Janelle or Kaela ever express to

22 you concern that they weren't getting

23 feedback from managers?

24 A. I don't recall. I honestly just don't

25 remember as of today, unless it's in my

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 370 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

01:22-01:23 Page 130

 1 notes, then I could refresh myself. I don't

 2 know. Is it feedback about something

 3 specific?

 4 Q. About their -- about their role as an HR

 5 generalist.

 6 MS. PARKER: Objection to form.

 7 THE WITNESS: So, I think -- I

 8 mean, that's kind of what we've talked about

 9 in the past today, so getting feedback about

10 things like lack of role clarity; is that

11 kind of what you're asking?

12 BY MR. MILLS: 

13 Q. Did you ever have any conversations about --

14 with any of the managers about what they

15 would -- what they wanted to see the

16 HR generalists doing?

17 MS. PARKER: Objection to form.

18 THE WITNESS: Yes.

19 BY MR. MILLS: 

20 Q. Okay. And do you recall what managers you

21 had that conversation with?

22 MS. PARKER: Objection to form.

23 THE WITNESS: Yes.

24 BY MR. MILLS: 

25 Q. Okay. Who?

01:23-01:25 Page 131

 1 A. I had a conversation with Rich Pland.

 2 Q. Where is he?

 3 A. He is in Sacramento.

 4 Q. Okay.

 5 A. And I had a conversation with Charles

 6 Wilson.

 7 Q. Okay. Where was he?

 8 A. St. Paul. I had multiple conversations with

 9 Eric McNaul.

10 Q. Okay.

11 A. Conversations with Angie Graczyk.

12 Q. Okay.

13 A. With Jake.

14 Q. Jake Briscoe?

15 A. Correct. With Loren Bayer.

16 Q. Where was that?

17 A. St. Cloud.

18 Q. Okay. Anybody else that you can recall?

19 A. Yes, Greg Gibson.

20 Q. Okay. Where was he?

21 A. Minneapolis.

22 Q. Anybody else?

23 A. Robert de St. Aubin.

24 Q. Where was he?

25 A. Minneapolis.

01:25-01:26 Page 132

 1 Q. Okay. Anybody else you can recall?

 2 A. I can recall a lot of people. Generally, we

 3 talked about what the role should be and how

 4 we wanted the role to --

 5 Q. All right. Let me ask you this: What

 6 feedback were you getting from them, from

 7 the managers, as to what they thought the

 8 HR generalists should be doing?

 9 MS. PARKER: Objection: Form;

10 compound; and not defined as to time.

11 THE WITNESS: I got a variety of

12 feedback.

13 BY MR. MILLS: 

14 Q. Can you give me some examples.

15 A. Sure. I got --

16 MS. PARKER: Objection to form.

17 THE WITNESS: -- feedback that what

18 the business really needed was a higher

19 level HR role, more of a strategic partner,

20 somebody who could move the needle on things

21 like org design, partnering with recruiting,

22 staffing models, helping with talent

23 development, leadership coaching, driving a

24 service-excellence culture, so --

25 BY MR. MILLS: 

01:26-01:28 Page 133

 1 Q. Did you have any discussions with the

 2 HR generalists about what the -- what you

 3 were hearing from the managers?

 4 MS. PARKER: Objection: Form.

 5 BY MR. MILLS: 

 6 Q. In terms of what they would like to see in

 7 their role as an HR generalist?

 8 MS. PARKER: Same objection.

 9 THE WITNESS: Yes.

10 BY MR. MILLS: 

11 Q. And what -- what were those conversations?

12 A. Much the same as what I just said, so --

13 Q. I want you to turn to page Bates number 314,

14 Exhibit 3.

15 And can you tell me what the date

16 is in connection with these notes?

17 A. I don't have an exact date. This is

18 preparation for one-on-one that I had with

19 Brandy, I believe it was in June. I believe

20 it's a call that she recorded, so I expect

21 that you have the date somewhere.

22 Q. Does June 26th sound right?

23 A. It does.

24 Q. And if you look down like the one, two,

25 three, fourth paragraph, you write, How your

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 371 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

01:28-01:29 Page 134

 1 partners/ -- or I'm sorry, How your partners

 2 perceive you.

 3 Did I read that right?

 4 A. Yes, "and I."

 5 Q. "How your partners and I perceive you,"

 6 thank you.

 7 And are you recording here what you

 8 told Brandy during your one-on-one?

 9 A. No. I was preparing for what I wanted to

10 talk with her about during that one-on-one.

11 Q. And you wanted to talk to her about that

12 managers don't know where she is and issues

13 with getting to her on the phone?

14 A. So, it was a perception. So, how they

15 perceived her. There was a perception that

16 they couldn't get her on the phone or they

17 couldn't find her or she wasn't responsive.

18 Q. Was there also a perception that she was

19 coming in late and leaving early?

20 A. Yes, per the notes, there was.

21 Q. And did you talk to Brandy about that, her

22 coming in late and leaving early was causing

23 friction with the managers in Phoenix?

24 MS. PARKER: Objection to form.

25 THE WITNESS: Not coming in late

01:29-01:30 Page 135

 1 and leaving early. More that they didn't

 2 know when she was there.

 3 So, it wasn't a consistent

 4 schedule, so there wasn't any kind of

 5 out-of-office -- or they weren't sure if she

 6 was in a branch that day, or if she was

 7 going to be in Phoenix, so it was just an

 8 accessibility question.

 9 BY MR. MILLS: 

10 Q. Was that the typical concern that you heard

11 from the managers in Phoenix?

12 MS. PARKER: Object to the form.

13 THE WITNESS: No, that was one of

14 the concerns, but that was probably not the

15 biggest one, no.

16 BY MR. MILLS: 

17 Q. What was the biggest concern?

18 A. The biggest concern was really around her

19 partnership and being able to kind of step

20 up into that more strategic role.

21 Q. And what specifically were you hearing from

22 any of the managers in Phoenix about that?

23 A. That they didn't necessarily see her as a

24 resource, that they felt that she was -- she

25 would come out and go on route rides, but

01:30-01:31 Page 136

 1 then she would turn around and kind of try

 2 to pick apart what was wrong versus my

 3 expectation which was go out and listen and

 4 understand and be a facilitator.

 5 It's not her job to solve the

 6 problems. It's her job to kind of help

 7 connect the business, to help support the

 8 business, to help guide your leaders in

 9 finding a resolution.

10 So, if a manager says, hey, I have

11 this issue, I'm really struggling with XYZ,

12 it's not the HR generalist's job to go tell

13 that person's manager.

14 It's the HR generalist's job to

15 say, hey, let's talk about how you can

16 strengthen your leadership skills. Let's

17 talk about how that conversation might go.

18 Q. Who specifically told you that?

19 A. Told me what?

20 Q. What specific managers were telling you

21 about Brandy?

22 MS. PARKER: Objection to form.

23 THE WITNESS: So -- sorry.

24 BY MR. MILLS: 

25 Q. Go ahead.

01:31-01:32 Page 137

 1 A. Jake gave me that feedback, other managers

 2 in the Phoenix business, which now, as I'm

 3 reading, Mitch Rubinoff is another person

 4 who had some feedback.

 5 Q. What was Mitch's last name?

 6 A. Rubinoff, I think.

 7 Q. Did you ever talk directly with Mitch?

 8 A. I did.

 9 Q. How frequently would you speak with him?

10 A. Infrequently.

11 Q. Less frequently than with Jake?

12 A. Yes.

13 Q. Did you ever talk to Mitch about Brandy

14 Williams?

15 A. I -- yes, I believe I did.

16 Q. Do you recall how many times?

17 A. I don't.

18 Q. Was it more than one?

19 A. I honestly don't recall.

20 Q. Do you recall what was said?

21 A. I wanted to set expectations with him, so

22 yes, I do. I was trying to set expectations

23 with him about including Brandy, and how I

24 expected her role in the business to kind of

25 transpire to unfold, so this is -- you know,

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(34) Pages 134 - 137

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 372 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

01:32-01:34 Page 138

 1 me now is leading this group of generalists

 2 into this new space, so setting my

 3 expectations for how I thought the role

 4 should participate in the business and how I

 5 wanted them, in turn, to interact with her

 6 and to not be surprised if she says she

 7 wants to come on a route ride, or if your

 8 partner wants to come to a staff meeting and

 9 they haven't been there before, and just an

10 expectation that we were going to be

11 elevating the activities.

12 Q. Do you recall how Mitch responded to what

13 you were telling him?

14 A. He responded favorably.

15 Q. Look at the -- going back to Exhibit 3, and

16 on page Bates number 314 again, the

17 paragraph just above the one that we were

18 talking about, and you write here, quote, "I

19 want you to be successful here but I need to

20 talk through some things that I think are

21 standing in your way," unquote.

22 Did I read that correctly?

23 A. Yes.

24 Q. And those -- here you're documenting

25 something you want to talk to Brandy about,

01:34-01:36 Page 139

 1 right?

 2 A. Yes.

 3 Q. By this time, June 26th, you had already

 4 decided that you were going to eliminate her

 5 position; isn't that true?

 6 A. We had decided that we were going to

 7 eliminate the position in the June

 8 timeframe. I don't know exactly when. I

 9 can't give a specific answer.

10 Q. It's likely that it was prior to June 26th,

11 though, right?

12 A. I can't say for certain. I don't know the

13 exact date.

14 Q. Can you turn to page Bates numbered 322.

15 A. Okay.

16 Q. And can you tell me what -- generally what

17 these notes are about? And the reason I'm

18 asking is because it doesn't have one of

19 the -- I don't see a name associated with

20 them, so --

21 A. So, it looks to be notes about the LA office

22 redesign, hosting for a role, and then notes

23 from a conversation which I believe was with

24 Brandy.

25 Q. Where do those begin?

01:36-01:38 Page 140

 1 A. They begin with -- well, I think the entire

 2 conversation was with Brandy.

 3 Q. How can you tell that?

 4 A. Because she recorded it and I have seen the

 5 transcript.

 6 Q. And this is on July 17, 2013?

 7 A. That's the date that I have on the top, yes.

 8 Q. Okay. Did you recall Brandy telling you

 9 that she was very stressed about her role as

10 an HR generalist?

11 A. I remember her being stressed, yes.

12 Q. Do you recall her telling you why she was

13 stressed?

14 A. She felt like she wasn't making any progress

15 in her role.

16 Q. Did she say that people were -- strike that.

17 Did she express to you any stress

18 that people had been treating her

19 differently recently?

20 MS. PARKER: Objection to form.

21 THE WITNESS: She said that she

22 felt that people were treating her

23 differently based on -- let's see, based on

24 her medical issues.

25 BY MR. MILLS: 

01:38-01:39 Page 141

 1 Q. And did you have an understanding as to why

 2 they were treating her differently?

 3 MS. PARKER: Objection to form and

 4 mischaracterizing prior testimony.

 5 THE WITNESS: So, she never did

 6 give me anything specific to back up her

 7 concerns that others were treating her

 8 differently or perceiving her differently

 9 because of stated medical issues, which also

10 wasn't defined.

11 BY MR. MILLS: 

12 Q. Did you do any investigation into her claim

13 that she was being treated differently

14 because of her medical issues?

15 A. I tried to understand, not in necessarily

16 this conversation, but tried to understand

17 kind of what that meant, so what did she

18 mean by that she was being treated

19 differently, and she couldn't really give me

20 any specific things to investigate.

21 MR. MILLS: Sorry, we have to

22 change the tape.

23 THE VIDEOGRAPHER: We're off video

24 record. The time on the video monitor is

25 1:39 p.m.

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(35) Pages 138 - 141

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 373 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

01:47-01:53 Page 142

 1 (A recess was taken.)

 2 THE VIDEOGRAPHER: We are back on

 3 the video record. The time on the video

 4 monitor is 1:52 p.m.

 5 BY MR. MILLS: 

 6 Q. Okay. Do you recall Brandy Williams going

 7 into a temporary role in recruiting in the

 8 summer of 2013?

 9 A. I do.

10 Q. And did you tell Brandy, at the time that

11 she went into the recruiting role, that when

12 that temporary position was over, that she

13 could come back and be an HR generalist?

14 A. I don't recall if we said come back and be

15 an HR generalist. I think there was also a

16 possibility that she might stay permanently

17 in a recruiting role.

18 Q. But do you -- but you told her that, if she

19 didn't stay in the recruiting role, that she

20 could come back and be an HR generalist,

21 right?

22 MS. PARKER: Objection.

23 THE WITNESS: Yes.

24 BY MR. MILLS: 

25 Q. Is it yes?

01:53-01:55 Page 143

 1 A. Yes.

 2 Q. And, again, you would have told her that

 3 after you had, according to your testimony,

 4 determined that you were going to eliminate

 5 her position?

 6 A. Yes.

 7 Q. Why would you tell her that?

 8 A. Because there hadn't been a date set for a

 9 position elimination, so we had determined

10 that we were going to eliminate it, it would

11 likely be Brandy, based on geography, but

12 there hadn't been a final date set.

13 Q. Does that typically happen at G & K where

14 you have an open-ended termination date?

15 A. Not necessarily an open-ended termination

16 date.

17 Q. You testified that you guys had decided in

18 June to eliminate her position.

19 A. Correct.

20 Q. But here we are in July going into August

21 and there is still no -- is it still your

22 testimony that there was no decision as to

23 when she was going to be terminated?

24 A. Yes.

25 MS. PARKER: And I'll object just

01:55-01:57 Page 144

 1 on the kind of double negative -- the form.

 2 BY MR. MILLS: 

 3 Q. Is that correct?

 4 A. Yes, I think.

 5 (Exhibit 4 was marked.)

 6 BY MR. MILLS: 

 7 Q. I've handed you what's been marked as

 8 Exhibit 4. It's Bates number G & K 000437.

 9 You've seen this document before?

10 A. Yes.

11 Q. And this is a letter from Brandy Williams to

12 G & K, specifically addressed to you, dated

13 July 8, 2013, correct?

14 A. What was the date again?

15 Q. July 8, 2013.

16 A. Yes.

17 Q. The first sentence of the body of the

18 letter, she writes, quote: I know you are

19 aware that I have been experiencing

20 significant health problems since the birth

21 and delivery of my son on July 11, 2012 and

22 they have taken me away from the business,

23 end quote.

24 You were aware that Brandy had been

25 experiencing health problems for some time,

01:57-01:58 Page 145

 1 right?

 2 A. Yes.

 3 Q. What was your understanding of the health

 4 problems that she was experiencing?

 5 A. I didn't have a specific understanding, just

 6 that it was related to the birth of her son.

 7 Q. Do you recall Brandy ever explaining to you

 8 specifically what was going on with her

 9 health?

10 A. I remember her, on a couple of occasions,

11 sharing some detailed information. I don't

12 know that we ever sat down and had a really

13 in depth conversation about all of the

14 nuances, but that would have --

15 Q. Just tell me as best you can what you can

16 recall specifically about what she told you

17 about her health conditions.

18 A. I just remember it being related generally

19 to -- we'll call it pelvic health.

20 Q. Anything else?

21 A. That was -- so, that was what she and I

22 talked about was just ongoing kind of

23 medical concerns related to the birth of her

24 son in the kind of pelvic health category.

25 Q. Did you have any reason to doubt that she

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(36) Pages 142 - 145

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 374 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

01:58-01:59 Page 146

 1 was actually experiencing these health

 2 problems?

 3 A. No, no, not at all.

 4 Q. And you are aware that she was being treated

 5 during this timeframe, July 2013?

 6 A. I was -- yes, I was aware that she had

 7 medical appointments and things like that,

 8 yeah.

 9 Q. And you are aware that, from time to time,

10 she had to miss work to go to medical

11 appointments?

12 A. Yes.

13 MS. PARKER: Objection to form with

14 respect to when.

15 BY MR. MILLS: 

16 Q. After the birth of her son.

17 A. Yes.

18 MS. PARKER: Same objection.

19 It's -- there's a relatively lengthy period

20 of time.

21 BY MR. MILLS: 

22 Q. And you were also aware, as of the time of

23 this letter, July 8, 2013, that Brandy had

24 been experiencing a significant amount of

25 mental stress, right?

01:59-02:01 Page 147

 1 A. Just -- well, I could look at the date of

 2 the notes. Would that -- okay.

 3 Q. Yeah, feel free to refer to whatever you

 4 want to.

 5 A. Was it 6/26? Was that the date of that

 6 conversation or was it later? The one

 7 where -- actually, I think it was the 7/17

 8 call, so that would have been after this

 9 letter.

10 Q. She states in this letter at the very last

11 sentence of the first paragraph, quote,

12 "This has also taken a toll on me mentally

13 as well and I am also working with a mental

14 health provider for support," period

15 unquote, correct?

16 A. That's what it says, yes.

17 Q. Do you recall Brandy telling you prior to

18 the time of this letter that she was

19 experiencing mental health issues as well?

20 A. I, honestly, I don't remember as we sit here

21 today.

22 Q. And then, in the letter, Brandy goes on and

23 requests an ADA accommodation, correct?

24 A. Yes, that is what it says.

25 Q. ADA, meaning the Americans With Disabilities

02:01-02:02 Page 148

 1 Act, correct?

 2 A. That's what this says, yes.

 3 Q. You've had other employees make ADA

 4 requests?

 5 A. Yes.

 6 Q. At G & K -- other employees at G & K have

 7 made ADA requests?

 8 A. Yes.

 9 Q. Who typically handled the ADA requests at

10 G & K?

11 A. So --

12 MS. PARKER: Objection to

13 foundation.

14 THE WITNESS: So, it would have

15 been the employee relations group at -- so

16 that -- yeah, so it would have been the

17 employee relations group at this time.

18 BY MR. MILLS: 

19 Q. And do you recall who specifically at the

20 employee relations group would have handled

21 ADA requests?

22 A. It would have been somebody in the group.

23 There were multiple employees.

24 Q. How many employees were in the group at that

25 time?

02:02-02:04 Page 149

 1 A. At least two, but maybe more.

 2 Q. Do you remember names?

 3 A. Well, Nikki Kietzer, and then Marie Smith.

 4 Q. Okay. But you're not the one who would

 5 typically handle an ADA request?

 6 A. No, no.

 7 Q. Did it annoy you that Brandy Williams had

 8 requested an ADA accommodation?

 9 MS. PARKER: Objection: Form.

10 THE WITNESS: Of course not, no.

11 BY MR. MILLS: 

12 Q. Were you angry that she had requested an ADA

13 accommodation?

14 MS. PARKER: Objection.

15 THE WITNESS: Absolutely not.

16 (Exhibit 5 was marked.)

17 BY MR. MILLS: 

18 Q. Ma'am, we've handed you a document that's

19 been marked as Exhibit 5, and I'll ask if

20 you can identify that as an email that you

21 sent to Marie Smith on or about July 8,

22 2013.

23 A. That is what the time stamp says, yes.

24 Q. Again, July 8th is the date of Brandy's

25 letter making the ADA request, Exhibit 4?

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(37) Pages 146 - 149

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 375 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

02:04-02:05 Page 150

 1 A. Yes.

 2 Q. And in the first paragraph you refer to,

 3 quote, "some strong performance

 4 conversations with Brandy lately," unquote;

 5 is that right?

 6 A. That is what it says.

 7 Q. Then you go on to say, "I also believe that

 8 she is out of FMLA time"; is that right?

 9 A. That is what it says.

10 Q. And FMLA is the Family Medical -- Family

11 Medical Leave Act, correct?

12 A. Correct.

13 Q. And then you state to Marie that, "she has

14 been consistently missing work or coming in

15 late," right?

16 A. That is what it says.

17 Q. Then in the next paragraph -- and this is

18 you writing this, right, the text of this

19 email is -- you wrote this?

20 A. Yes.

21 Q. Okay. The next paragraph you write, quote,

22 "I would like to manage this request very

23 closely and would like your assistance in

24 determining the best way of doing so."

25 Did I read that right?

02:05-02:06 Page 151

 1 A. Yes.

 2 Q. And the reason you wanted to manage this

 3 request very closely is that you were

 4 unhappy with Brandy for having made an ADA

 5 accommodation request; isn't that true?

 6 MS. PARKER: Objection to form;

 7 argumentative; mischaracterizes.

 8 THE WITNESS: Absolutely not.

 9 BY MR. MILLS: 

10 Q. But you just testified a few moments ago

11 that you're not typically involved in ADA

12 requests; isn't that true?

13 MS. PARKER: Objection to form.

14 BY MR. MILLS: 

15 Q. Isn't that what you said?

16 A. As the manager of an employee, the manager

17 is typically involved.

18 Q. But you testified earlier -- and I can have

19 the court reporter read it back -- that

20 you're not typically involved in handling

21 ADA requests, right?

22 A. Other than in my role as a manager, yes.

23 Q. How many other employees -- strike that.

24 How did you plan to, quote, "very

25 closely manage Brandy's ADA accommodation

02:06-02:07 Page 152

 1 request"?

 2 A. I don't know that I was asking to manage it

 3 closely, or if I was asking for Marie's

 4 assistance.

 5 Q. Well, that's what you said, isn't it, quote,

 6 "I would like to manage this request very

 7 closely."

 8 Aren't those your words?

 9 A. This is written here.

10 Q. Those are your words, right?

11 A. They are.

12 Q. You chose those words, right?

13 A. I did.

14 Q. And words mean things, don't they?

15 A. They do.

16 Q. And when you say, "I want to manage this

17 request very closely," you're conveying

18 something to Marie, weren't you?

19 A. I was.

20 Q. You're conveying to her that you want to be

21 very involved in this request, right?

22 MS. PARKER: Objection to form;

23 mischaracterizes the prior testimony.

24 You're not even reading the full sentence.

25 She just said she was asking Marie for

02:07-02:08 Page 153

 1 assistance.

 2 MR. MILLS: Yeah, she --

 3 BY MR. MILLS: 

 4 Q. You want Marie to help you in managing this

 5 request very closely, don't you?

 6 A. I would like Marie's consultive advice.

 7 Q. In how to manage this request very closely;

 8 isn't that true?

 9 A. In her request. This is a request. It

10 isn't the ongoing accommodation.

11 Q. Why did you feel the need to manage this

12 request very closely?

13 A. Because, as the first paragraph states,

14 there had been a number of situations where

15 Brandy had been coming in late or missing

16 work without any notice for unrelated

17 reasons.

18 Q. How did you know that they were unrelated

19 reasons?

20 A. Because she told me that they were. As it

21 says in here, "she has been consistently

22 missing work or coming in late without

23 notice and for reasons unrelated to her

24 medical condition. (No babysitter, sick

25 aunt/cancelled flight, flat tire, etc.)"

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(38) Pages 150 - 153

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 376 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

02:08-02:09 Page 154

 1 Q. Did you document anywhere in your notes or

 2 anywhere else, or in her personnel file,

 3 that she had missed work because of no

 4 baby-sitter, sick aunt, cancelled flight,

 5 flat tire, et cetera?

 6 A. She fell off her bike as well. Yes, I did.

 7 Q. Where?

 8 A. It was in my Lotus Notes calendar.

 9 Q. In your what?

10 A. My Lotus Notes calendar.

11 Q. Do you still have those?

12 A. I do not.

13 Q. Do you know where they are?

14 A. I have no idea.

15 Q. Do you know whether they still exist?

16 A. I do not know.

17 Q. And if I wanted to look at those, who should

18 I ask?

19 A. The IT department.

20 Q. At G & K?

21 A. Yes.

22 Q. Did you ever manage any other ADA

23 accommodation requests?

24 A. Yes.

25 Q. Under what circumstances would you do that?

02:09-02:10 Page 155

 1 A. As the regional HR director prior to the HR

 2 realignment.

 3 Q. How many times had you managed an ADA

 4 request?

 5 A. Multiple times.

 6 Q. But your intent was to manage Brandy's ADA

 7 request more closely than you would manage a

 8 request for an ADA accommodation from some

 9 other employee, right?

10 A. I can't speculate as to that. So, the

11 process clearly had changed since prior to

12 the HR realignment, and this is the first

13 ADA request that I received from anybody in

14 my region following the HR realignment.

15 Q. This was the first ADA request you had seen

16 since the realignment?

17 A. Following the realignment, yes.

18 Q. The realignment in February 2013, right?

19 A. I believe this is the first -- I believe it

20 was.

21 Q. The realignment was in February; this

22 request was in July, right?

23 A. I believe it was the first one. There may

24 have been others but I believe it was the

25 first one.

02:10-02:11 Page 156

 1 Q. And up until that point you don't recall

 2 having been involved in any other ADA

 3 requests, do you?

 4 A. That's not what I said. What I said was

 5 following the realignment, so I was

 6 previously involved in managing ADA claims.

 7 Q. Okay. From the time of the realignment up

 8 until July 2013, you hadn't been involved in

 9 any other ADA requests; is that true?

10 A. Correct, but I wasn't managing any other

11 employees that requested an ADA

12 accommodation.

13 Q. So, after the realignment, the first ADA

14 request you received was from Brandy

15 Williams, correct?

16 A. As far as I can remember, sitting here

17 today, yes.

18 Q. And that's typically something that you

19 would pass off to either Marie Smith or

20 Nikki Kietzer, right?

21 MS. PARKER: Objection as to form.

22 THE WITNESS: That's the way the

23 process, I believe, was designed to work.

24 BY MR. MILLS: 

25 Q. But this one you wanted to manage yourself

02:11-02:12 Page 157

 1 very closely, right?

 2 MS. PARKER: Objection to form.

 3 THE WITNESS: No, I didn't say that

 4 I wanted to manage it myself.

 5 BY MR. MILLS: 

 6 Q. Well, you said -- again, these are you are

 7 your words: "I would like to manage this

 8 request very closely," correct?

 9 MS. PARKER: Objection to form.

10 THE WITNESS: That's what the words

11 say but I wasn't implying that I, myself,

12 wanted to manage it.

13 BY MR. MILLS: 

14 Q. Well, the I -- the, quote-unquote, "I" is

15 referring to you, isn't it?

16 MS. PARKER: Objection to form;

17 argumentative.

18 THE WITNESS: "I" is me, yes.

19 BY MR. MILLS: 

20 Q. "I" is not Marie, right?

21 MS. PARKER: Objection to form.

22 THE WITNESS: There is an "I" in

23 Marie.

24 BY MR. MILLS: 

25 Q. The "I" is not referring to Marie, is it?

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(39) Pages 154 - 157

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 377 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

02:12-02:13 Page 158

 1 A. So, it wasn't referring to I am asking to

 2 manage this request very carefully. I'm

 3 saying, I would like us as, as an

 4 organization, as an entity, as you, as

 5 whomever, to manage this request carefully.

 6 Q. Did you ever say that about any other

 7 employees?

 8 A. I didn't manage any other -- I hadn't

 9 submitted any other ADA accommodation

10 requests to Marie in the new process, as far

11 as I recall.

12 Q. Then you go on to say in the next sentence,

13 quote, "In light of my last conversation

14 with Brandy, I would like to look at having

15 her work at least 8 hours in the office

16 either before or after her appointments

17 because I have previously experienced

18 situations where an appointment 'first thing

19 in the morning' means she doesn't roll in

20 until noon."

21 Then you say, "Think that is

22 acceptable?"

23 Did I read that correctly?

24 A. Yes, I think that's what it says.

25 Q. Well, wouldn't having her work at least

02:13-02:14 Page 159

 1 eight hours before or after her appointments

 2 defeat the purpose of the accommodation?

 3 A. Not necessarily.

 4 Q. What was the accommodation that Brandy was

 5 asking for?

 6 A. I believe that she was asking for time off

 7 to attend appointments.

 8 Q. Okay. And G & K, in fact, granted her

 9 request for an accommodation, right?

10 A. Yes, we've been granting it all along.

11 Q. Okay. And the accommodation was that she

12 would need to take, say, an hour and go to a

13 doctor's appointment, right?

14 A. It would be whatever time was needed to go

15 to the doctor's appointment.

16 Q. But wouldn't having her work eight hours

17 before or after that appointment defeat the

18 purpose of the accommodation?

19 A. Not necessarily. Exempt employees aren't

20 held to an eight-hour schedule.

21 Q. Was Brandy an exempt employee?

22 A. Yes.

23 Q. So, she wasn't held to an eight-hour

24 schedule, right?

25 A. Exactly.

02:14 Page 160

 1 Q. So, forcing her to work eight hours before

 2 or after an appointment would be treating

 3 her different than other exempt employees;

 4 isn't that true?

 5 MS. PARKER: Objection to form.

 6 THE WITNESS: I don't know. We --

 7 I was asking Marie for her advice. I didn't

 8 know.

 9 BY MR. MILLS: 

10 Q. You didn't have any other exempt employees

11 that you required to work eight hours, did

12 you?

13 MS. PARKER: Objection to form.

14 THE WITNESS: That are required to

15 work eight hours period?

16 BY MR. MILLS: 

17 Q. Um-hmm.

18 A. That's --

19 Q. You just told me that it wasn't a

20 requirement.

21 A. Employees aren't -- exempt employees aren't

22 held to an eight-hour schedule. Exempt

23 employees are expected to work the number of

24 hours needed to get the work done.

25 So, typically in this business

02:14-02:15 Page 161

 1 means like 55 hours a week, so --

 2 Q. But you're proposing her to have -- require

 3 Brandy to work eight hours, right?

 4 A. I was asking if we could have her work on

 5 either side of the appointment, but I was

 6 asking Marie for her opinion.

 7 Q. You wanted to have her work eight hours

 8 either before or after the appointment,

 9 didn't you?

10 A. No. I was asking Marie for her opinion.

11 Q. But this wasn't Marie's idea to have Brandy

12 work eight hours before or after an

13 appointment, was it?

14 MS. PARKER: Objection:

15 Argumentative; asked and answered.

16 THE WITNESS: No, it was my

17 question.

18 BY MR. MILLS: 

19 Q. It was your idea, right?

20 A. It was a question to Marie asking for her

21 advice.

22 Q. You're the one that posed the question,

23 right?

24 A. Yes.

25 Q. You're the one that came up with the idea of

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 378 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

02:15-02:16 Page 162

 1 having Brandy work eight hours before or

 2 after an appointment, right?

 3 MS. PARKER: Objection: Asked and

 4 answered.

 5 THE WITNESS: It was a question of

 6 whether or not that was appropriate.

 7 BY MR. MILLS: 

 8 Q. And you're asking this question regarding

 9 Brandy at the same time that Kaela is

10 telling you that she's bored; isn't that

11 true?

12 A. I would have to look back at a timeline.

13 Q. And that she doesn't have enough work to do;

14 isn't that right?

15 A. I believe Kaela started telling me she was

16 bored much earlier than July 8th.

17 Q. Things didn't get better, did they?

18 A. What things?

19 Q. With Kaela.

20 MS. PARKER: Objection to form.

21 THE WITNESS: What --

22 BY MR. MILLS: 

23 Q. In terms of her boredom.

24 A. I don't know how to answer that. Could you

25 rephrase the question?

02:16-02:18 Page 163

 1 Q. No.

 2 Before I go on, let's back up.

 3 Can you take another look at

 4 Exhibit 1. I had written down a question I

 5 forgot to ask.

 6 And, again, referring to the Brandy

 7 Williams review at the very end of the

 8 document. It's part of, I think, Exhibit H

 9 to that document.

10 A. Okay.

11 Q. Can you tell when you did Brandy's review?

12 A. I actually can't. I'm not sure how the

13 system stamp works.

14 Q. Okay. Okay. Let's see. There are -- if

15 you turn to like the last page of that

16 document, there's just a block at the top

17 that says, created by, last updated.

18 Do you see that?

19 A. Yes.

20 Q. Does that give you any more insight as to

21 when you would have done the review of

22 Brandy?

23 A. Honestly, no. There's no names in here and

24 I don't -- I can't even begin to try to

25 understand how the system works.

02:18-02:21 Page 164

 1 Q. Turn to the third to the last page. Up

 2 towards the top, the top paragraph, there's,

 3 at the bottom of that, a statement "Created

 4 by template on July 26, 2013."

 5 Do you see that?

 6 A. Yes, yep.

 7 Q. Then it becomes -- then the next line is

 8 "Last modified by Rachael Siggerud

 9 August 28, 2013."

10 A. Yes, I do see that.

11 Q. Okay. Is August 28th when you would have

12 completed your review of Brandy?

13 A. I honestly don't know. What I don't know is

14 whether that was sending a review to a

15 different status, if it was updating -- I

16 honestly don't have any idea. This doesn't

17 mean anything to me by looking at it.

18 (Exhibit 6 was marked.)

19 BY MR. MILLS: 

20 Q. Okay. I've handed you what's been marked as

21 Exhibit 6 and I'll ask you if you can

22 identify that document.

23 A. Identify it in what respect?

24 Q. Have you seen this before?

25 A. No.

02:21-02:22 Page 165

 1 Q. Okay. Did you play any role, to your

 2 knowledge, in the preparation of this

 3 document?

 4 A. No.

 5 Q. The document appears to be a G & K job

 6 description, correct?

 7 A. It appears to be.

 8 Q. And then towards the top it says: Effective

 9 date: May 17, 2014, HR generalist, correct?

10 A. That's not what mine says.

11 Q. Okay. What does your say?

12 A. Well, it says --

13 Q. You know what, I gave you the wrong exhibit.

14 MS. PARKER: This one is different.

15 MR. MILLS: What I handed you is

16 different from what I'm looking at. Never

17 mind.

18 THE WITNESS: There you go.

19 MS. PARKER: So, which one do you

20 want her to have?

21 MR. MILLS: Exhibit -- what will

22 be 7.

23 (Exhibit 7 was marked.)

24 MS. PARKER: Sorry, I need a copy

25 of Exhibit 7.

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(41) Pages 162 - 165

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 379 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

02:22-02:23 Page 166

 1 MR. MILLS: I think -- can I see

 2 what you have?

 3 MS. PARKER: I have Exhibit -- oh,

 4 maybe this is Exhibit 7.

 5 MR. MILLS: This is actually what's

 6 going to be Exhibit 7.

 7 MS. PARKER: So, I don't have 6.

 8 MR. MILLS: Okay.

 9 THE WITNESS: (Perusing.)

10 MS. PARKER: So, we're on 7?

11 MR. MILLS: We're on 7, yeah. 6 is

12 withdrawn.

13 BY MR. MILLS: 

14 Q. All right. Now, could you take a look at

15 Exhibit 7 and tell me if you recognize this

16 document.

17 A. I still don't, I'm sorry.

18 Q. To your knowledge, did you play any role in

19 the creation of this document?

20 A. Not that I recall.

21 Q. And it appears to be a G & K job

22 description?

23 A. It does.

24 Q. And it has an effective date of May 17, 2014

25 and refers to an HR generalist, right?

02:23-02:25 Page 167

 1 A. That is what this says (indicating).

 2 Q. And then it says, "Prepared by," and there's

 3 nothing next to that, but it does have a

 4 date of April 29, 2014, correct?

 5 A. That's what it says here.

 6 Q. And you were gone from G & K by April 29,

 7 2014?

 8 A. Yes.

 9 Q. If you go down about the middle of the page,

10 there's a section that begins, "Essential

11 Job Functions and % of Time Spent On Each,"

12 correct?

13 A. I see that section, yes.

14 Q. And then there's a list of essential job

15 functions after that?

16 A. Yes, there are.

17 Q. Had you seen a written job description for

18 the position of HR generalist prior to the

19 time you left G & K?

20 A. I don't recall.

21 Q. Had you seen anything like this document

22 pertaining to an HR generalist prior to the

23 time you left G & K?

24 A. I don't recall.

25 Q. Had you seen other job descriptions for

02:25-02:26 Page 168

 1 other jobs at G & K during your tenure?

 2 A. Yes.

 3 Q. But you don't recall seeing anything

 4 specific to an HR generalist?

 5 A. Not that I recall, no.

 6 Q. Is it possible that there was no written job

 7 description for an HR generalist prior to

 8 April 29, 2014?

 9 A. I have no way of knowing that.

10 Q. It's possible, that's true?

11 A. Anything is possible, I guess, right? I

12 don't know, though. I don't know. I would

13 assume that there were other roles that were

14 recruited for at some point, so there

15 probably was one.

16 Q. Was one --

17 A. A job description. I just don't know.

18 Q. Did you play any -- or strike that.

19 During your tenure at G & K, did

20 you play any part in preparation of job

21 descriptions for the company?

22 A. During my entire tenure, yes.

23 Q. And just -- what did you do?

24 A. I would have updated job descriptions from

25 time to time. The HR representative job,

02:26-02:28 Page 169

 1 which was the pre-HR realignment job, was

 2 responsible for recruiting, for talent

 3 acquisition.

 4 So, in that role, then, things like

 5 posting job descriptions, ensuring that they

 6 were updated, had the correct heading,

 7 things like that would have been part of

 8 that role.

 9 Q. Okay. If you look at the -- refer back to

10 the Essential Job Functions in the middle of

11 the page on Exhibit 7.

12 I'd like for you to read those

13 over, if you haven't had a chance to read

14 them yet, and my question to you when you're

15 done is going to be: Are you aware of

16 anything about Brandy Williams' medical

17 condition that would have prevented her from

18 performing any of these tasks?

19 MS. PARKER: Objection:

20 Foundation. Objection: Form.

21 THE WITNESS: (Perusing.)

22 BY MR. MILLS: 

23 Q. Have you had a chance to read over them?

24 A. Yes.

25 Q. Okay. My question is: Are you aware of

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 380 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

02:28-02:51 Page 170

 1 anything about Brandy Williams' medical

 2 condition that would have prevented her from

 3 performing any of these essential job

 4 functions?

 5 MS. PARKER: Same objections.

 6 THE WITNESS: I don't think that's

 7 something I can answer because this is

 8 beyond the time when I worked at G & K

 9 Services, so --

10 BY MR. MILLS: 

11 Q. Was there anything about Brandy Williams'

12 medical condition that prevented her from

13 performing the essential job functions of an

14 HR generalist during your tenure as -- as

15 the regional director of the Northwest

16 Region?

17 MS. PARKER: Objection to

18 foundation.

19 THE WITNESS: No, not that I know.

20 MR. MILLS: Can we go off the

21 record for a second.

22 THE VIDEOGRAPHER: We're going off

23 the record. The time on the video monitor

24 is 2:29 p.m.

25 (A recess was taken.)

02:51-02:52 Page 171

 1 (Exhibit 8 was marked.)

 2 THE VIDEOGRAPHER: We are back on

 3 video record. The time on the video monitor

 4 is 2:51 p.m.

 5 BY MR. MILLS: 

 6 Q. Ma'am, do you recall having a telephone

 7 conversation with Brandy Williams on

 8 June 26, 2013?

 9 A. I do now.

10 Q. Okay. Are you aware that that conversation

11 was recorded?

12 A. No, I was not.

13 Q. Are you aware of that now?

14 A. Yes, I am.

15 Q. Have you listened to the recording?

16 A. I have not.

17 Q. Have you seen a transcript of the recording?

18 A. I have seen this (indicating) transcript and

19 then I believe some other version.

20 Q. Okay. We've put in front of you Exhibit 8,

21 which is -- I will represent to you is a

22 transcript of a recording that we, at my

23 office, had done, so --

24 MS. PARKER: Before we get into

25 Exhibit 8, I'd just like to put our

02:52-02:53 Page 172

 1 objection on the record to using this

 2 transcription.

 3 This transcript that's Exhibit 8 is

 4 28 pages of reported conversation, which we

 5 received a corrupted file last night, and

 6 the corrected file -- I'm not sure if I even

 7 received it before this, so I'm just now

 8 looking at the transcript for the first

 9 time.

10 We did review the recording and had

11 some notes of the recording, but I haven't

12 had a chance to compare them to determine

13 whether there are any discrepancies in terms

14 of the way it was transcribed.

15 And, as we know, transcription is

16 an art, and I think that it would be more

17 accurate and preferable to use the

18 recording. I understand you're not prepared

19 to do that today, but I think that would be

20 better.

21 And not listening to the recording

22 may elicit a different recollection of how

23 the conversation occurred.

24 BY MR. MILLS: 

25 Q. As we -- as I reference things in here, if

02:53-02:55 Page 173

 1 you see anything that you think -- or

 2 strikes you as being inaccurate, you know,

 3 just tell me. Don't feel like --

 4 MS. PARKER: Again, this is a

 5 three-year old conversation.

 6 THE WITNESS: I wouldn't have any

 7 way, probably, of telling if there's

 8 something specific that's inaccurate.

 9 MS. PARKER: And we miss the

10 subtleties of tone when we don't have the

11 audio recording.

12 BY MR. MILLS: 

13 Q. I've put in front of you Exhibit 8 which, as

14 I represented to you, is our transcription

15 of a telephone conversation between you and

16 Brandy Williams on June 26, 2013.

17 And I want to draw your attention

18 to page 5, beginning at line -- line 8.

19 MS. PARKER: Does the -- are we

20 going to pick up the sound on the recording?

21 MR. MILLS: Use my mic.

22 MS. PARKER: So, I wanted to make

23 sure that the sound of the audio would be

24 picked up on the recording, and right now we

25 are using a microphone to pick it up and so

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(43) Pages 170 - 173

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 381 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

02:55-02:57 Page 174

 1 just let us know if the sound quality is --

 2 if you can't hear it.

 3 THE VIDEOGRAPHER: We're off the

 4 video record. The time on the video monitor

 5 is 2:55 p.m.

 6 (Discussion off the record.)

 7 THE VIDEOGRAPHER: We are back on

 8 the video transcript. The time is 2:56 p.m.

 9 (Audio played.)

10 MS. PARKER: We can't find it on

11 the recording, so --

12 MS. FOX: You can't search

13 line-by-line on the recording --

14 MR. MILLS: So it doesn't do any

15 good.

16 MS. PARKER: Are we reading it?

17 BY MR. MILLS: 

18 Q. I'll read it into the record. Beginning

19 with line 8 you state, "some of the

20 perceptions that I've been consistently

21 hearing is that there's -- you know, it's

22 that people don't really know where you are.

23 You know, the issue is getting a hold [sic]

24 of you."

25 My question is: Who have you

02:57-02:59 Page 175

 1 been -- who had you been purportedly hearing

 2 that from?

 3 A. So, I know it would have been management,

 4 leaders within the -- the Phoenix location.

 5 I'm not sure if it extended to Los Angeles.

 6 It was something I had also been

 7 struggling with. She and I had talked about

 8 it in the past. She didn't answer her work

 9 phone. She wouldn't answer her work cell

10 phone.

11 Q. And then you go on and state that you're

12 hearing that she comes in late and leaves

13 early, correct?

14 A. So, that's what -- do you want me to read

15 it, or are you reading it, or --

16 Q. I'm just asking you the question. I mean,

17 that's --

18 A. Okay, so, as I was talking about some of the

19 perceptions that the business had of her,

20 one of the perceptions that the business had

21 was that she was coming in late and leaving

22 early.

23 Q. And do you know whether she was, in fact,

24 coming in late or leaving early?

25 A. I don't know how many times. I know there

02:59-03:00 Page 176

 1 were times where she was coming in late and

 2 leaving early.

 3 Q. Do you recall specifically which managers at

 4 Phoenix were telling you that Brandy was

 5 coming in late and leaving early?

 6 A. I don't know that I could recall

 7 specifically. I know I had multiple

 8 conversations, though, about that particular

 9 topic.

10 Q. Do you recall anybody other than Jake

11 Briscoe?

12 A. I believe that Mitch and I also had a

13 conversation about it.

14 Q. Do you recall Brandy telling you that Jake

15 had moved her office to a location within

16 the Phoenix facility where she wasn't around

17 the managers all day?

18 A. I don't recall her saying that specifically.

19 I recall her office moving, but it was still

20 in the office area, though.

21 Q. Do you recall Brandy telling you that she

22 was actually physically present, but that

23 people didn't see her because her office had

24 moved?

25 A. She talked about that, yes, in this

03:00-03:02 Page 177

 1 conversation, I believe.

 2 Q. Did you ever talk to Jake about that?

 3 A. Yes.

 4 Q. Or to Mitch?

 5 A. Um-hmm.

 6 Q. And what did they say?

 7 A. That they were -- they stood by the fact

 8 that they would go and she wasn't there, or

 9 that she would leave early, or she wouldn't

10 be there in the afternoon if they had things

11 that they needed to talk with her about.

12 Q. Any other complaints or concerns about

13 Brandy from the folks in Phoenix other than

14 that she was late to meetings or that she

15 was coming in late, leaving early?

16 A. That's sort of a general question. Other

17 complaints about anything or related to this

18 paragraph?

19 Q. Did you discuss with Brandy that there were

20 any -- any concerns by managers in Phoenix

21 about anything other than her coming in

22 late, leaving early, missing meetings,

23 things like that --

24 MS. PARKER: Objection.

25 BY MR. MILLS: 

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 382 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:02-03:03 Page 178

 1 Q. -- inaccessibility?

 2 MS. PARKER: Asked and answered.

 3 THE WITNESS: I guess, could you

 4 provide more clarity as to the specific

 5 timeframe or --

 6 BY MR. MILLS: 

 7 Q. At the time you were having this

 8 conversation with her on June 26th.

 9 A. Okay, that's helpful.

10 I believe that this actually is the

11 conversation that my notes referred to. So,

12 if I recall correctly, we talked about -- a

13 lot about perceptions, right, so perceptions

14 kind of being reality, so whether or not

15 you're 15 minutes or 20 minutes late or 5

16 minutes late, there's a perception that it

17 doesn't matter, it's not important enough to

18 you to be here on time.

19 I believe we talked about

20 partnering and trying to be a good partner

21 to the business, and to understand their

22 needs, but without kind of picking them

23 apart and coming in all of a sudden with

24 something that they are doing wrong and

25 jumping straight to saying, you know, that

03:03-03:04 Page 179

 1 they should change what they are doing, more

 2 about listening, and that would help them

 3 feel more comfortable, having her out and

 4 spending time with the business.

 5 Other than that, I would have to,

 6 honestly, probably read the whole transcript

 7 in order to say if there were other things

 8 that we talked about, or refer back to my

 9 notes.

10 Q. Is it fair to say that the principal

11 concerns or complaints that you say you

12 heard from the managers in Phoenix had to do

13 with Brandy's accessibility?

14 A. No, not at all.

15 MR. MILLS: All right. Let's mark

16 this one.

17 (Exhibit 9 was marked.)

18 BY MR. MILLS: 

19 Q. Okay. Handing you a document that's been

20 marked as Exhibit 9, and I'm going to

21 represent to you that this is also a

22 transcript of an audio recording of a

23 telephone conversation.

24 Do you recall having a telephone

25 conversation with Brandy Williams on

03:04-03:06 Page 180

 1 July 17, 2013?

 2 A. I do now.

 3 Q. Have you listened to the audio recording of

 4 that conversation?

 5 A. I have not.

 6 Q. And, let's see. Do you recall Brandy

 7 telling you that she was not being well

 8 perceived in Phoenix because of her health

 9 issues and her requests for an ADA

10 accommodation?

11 A. She -- go ahead.

12 MS. PARKER: Objection: Form.

13 BY MR. MILLS: 

14 Q. Go ahead.

15 A. I believe she said that, yes.

16 Q. And how did you respond to that?

17 A. I asked her for more information because the

18 business in Phoenix had no reason to know

19 anything about her medical issues,

20 absolutely none, unless she told them, which

21 she said she didn't, so certainly they had

22 no reason.

23 We talked about how she could put

24 meetings on her calendar that just said

25 offsite meeting, so anybody that had

03:06-03:07 Page 181

 1 visibility to her calendar wouldn't know

 2 what -- but she was unable to give any

 3 specifics or reasons why she felt that way.

 4 Q. Did you ever discuss with Jake, or any of

 5 the other managers in Phoenix, Brandy's

 6 concern that she was being perceived less

 7 favorably because of her medical condition

 8 and because of her request for an ADA

 9 accommodation?

10 A. I don't know that I specifically asked about

11 that because I don't know that the business

12 knew about her medical condition, and I

13 don't think that that's appropriate for a

14 manager to share with anybody else.

15 So, if she hadn't shared that

16 information, I certainly wasn't going to

17 share it and open a door that should have

18 been closed.

19 Q. Do you recall Brandy telling you during this

20 conversation that she was stressed out?

21 A. I recall from -- after, yes, reading the

22 transcript, I do.

23 Q. Do you recall Brandy telling you that she

24 felt like she was being pushed out of the

25 business?

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 383 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:07-03:08 Page 182

 1 A. From reading the transcript, yes, that's in

 2 here.

 3 Q. Do you have a general recollection of that?

 4 A. I have a general recollection of the call.

 5 Honestly, that's all I have, but I don't

 6 remember all of the specifics, no.

 7 Q. Brandy didn't tell you during this phone

 8 call that she wanted to resign, did she?

 9 A. She didn't say that she wanted to resign but

10 she started making overtures that made me

11 concerned about whether she wanted to still

12 be part of the team, whether she wanted to

13 be in the HR generalist role, and it was

14 things like -- and they are in here, but I'm

15 not sure that this is the right fit for me.

16 Obviously, in the transcript, it

17 talks about her concerns about her health,

18 the struggles that she had had to kind of

19 make some headway with the Phoenix team, and

20 continue to make relationships, but she

21 opened the door to kind of saying she didn't

22 know if it was the right fit.

23 Q. Well, I think, as I read the transcript,

24 what she was telling me -- what she's saying

25 is that she's -- she's concerned that others

03:08-03:10 Page 183

 1 think that she's not the right fit; is that

 2 correct?

 3 MS. PARKER: Objection to form.

 4 THE WITNESS: That's not how I read

 5 the transcript, but --

 6 BY MR. MILLS: 

 7 Q. Well, if you look at -- let's go to page 13,

 8 beginning on line 6, the sentence that

 9 begins in that line.

10 And this is Brandy speaking, quote,

11 "Because I kinda feel like with, you know,

12 my health issues and the accommodations that

13 I've asked for might not be that well

14 perceived by everyone. And then I feel,

15 like, with that, that you guys might not

16 have confidence in me that I'm a good fit

17 anymore."

18 Did I read that right?

19 MS. PARKER: And I'll object to

20 form, and that -- just renew the objections

21 I made to Exhibit 8, that this, actually, in

22 this case, is a 38-page transcript -- or

23 37-page transcript, and that we received

24 this just last night, and there's a lot more

25 context to the whole thing.

03:10-03:11 Page 184

 1 So, between that and not having the

 2 recording, I think it's challenging to take

 3 excerpts.

 4 But, with that, you can answer.

 5 THE WITNESS: I'm sorry, what was

 6 the question?

 7 BY MR. MILLS: 

 8 Q. Let me ask you a different question.

 9 Do you recall, at any time during

10 this conversation, Brandy saying to you that

11 she didn't think she was a good fit at G & K

12 anymore?

13 A. I recall Brandy talking about whether or not

14 she -- if I remember correctly, again, so I

15 don't have the specific words in front of me

16 -- I can find them, I'm sure -- but feeling

17 like she wasn't sure that it was the right

18 fit for her -- it was the role -- I don't

19 know necessarily that it was G & K, but it

20 was the role, the business, that she didn't

21 know if it was the right fit for her on an

22 ongoing basis.

23 Q. Do you recall her telling you why she felt

24 that way?

25 A. It was -- I think it had to do with her

03:11-03:12 Page 185

 1 stress. She felt stressed, she felt like

 2 her health was important, and that maybe her

 3 health was, you know, not recovering, or

 4 that she wasn't able to recover because of

 5 stress and --

 6 Q. Do you recall her telling you that she was

 7 stressed because she was worried about

 8 losing her job?

 9 A. No, I don't recall her ever saying that.

10 Q. Do you recall her saying to you that she

11 felt like she was being pushed out of the

12 company?

13 A. I don't recall her specifically saying that,

14 but if she did, I'm sure I would have

15 responded. People can say a lot of things,

16 but it's about kind of helping understand

17 the context of the statements and what it

18 means.

19 Q. What -- do you remember saying any -- or --

20 strike that.

21 Do you remember saying anything to

22 Brandy about whether she was being pushed

23 out of the company?

24 A. I don't remember. I could read the

25 transcript and tell you. You know, at the

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(46) Pages 182 - 185

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 384 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:12-03:14 Page 186

 1 time, I would -- I mean, but I'm sure I

 2 spoke about it, but I don't know what

 3 exactly specifically I said.

 4 Q. Let's take a look at page 30, beginning with

 5 Brandy's comments beginning on line 21. Did

 6 you find it?

 7 A. Yes, I found line 21.

 8 Q. Okay. I'm just going to read it. You can

 9 follow along. "MS. WILLIAMS:" Quote, "Yes.

10 It's a very big dis- -- a very business

11 disconnect. Because how can people not know

12 I'm here if they never come to this office.

13 "I mean, you know, honestly, this

14 all went downhill when Jake decided to move

15 me out of this office because no one comes

16 up front. And if no one comes up front, no

17 one knows that I'm here in this office and

18 they perceive that I'm not here. But when I

19 was in the back it was never an issue of

20 whether Brandy's here because I was there, I

21 was interacting with every single person,

22 every single day. Everyone knew where to

23 find me. And it's like since I've been

24 taken out of the realm of things, I felt

25 like that's where this dilemma has

03:14-03:15 Page 187

 1 occurred."

 2 Did -- would you agree with me

 3 that, if a person's office is away from

 4 where the managers are, that that might

 5 affect their perception of whether the

 6 person is there?

 7 A. Generally speaking?

 8 Q. Yes.

 9 A. Yes.

10 Q. Do you know where Brandy's office was in

11 relation to where the manager's offices

12 were --

13 A. Yes --

14 Q. -- at the Phoenix location?

15 A. -- I do.

16 Q. Where was it?

17 A. It was kitty corner to the general manager's

18 office and kitty corner to the office

19 manager. It was also next to the hallway

20 that led to the plant.

21 Q. And was this -- were you aware at some point

22 of a move that Jake had moved your office

23 from someplace to another place within the

24 facility?

25 A. So, that was the final office location,

03:15-03:27 Page 188

 1 which I believe was the office location for

 2 the prior HRR as well.

 3 I think before that her office was

 4 in the service room, so in the room where

 5 just the service team sat. So, there was no

 6 office employees in there, not near the

 7 general manager, not very near the plant

 8 manager. So, it was very, kind of,

 9 singularly focused on just the service team.

10 So, the front office location was

11 actually more accessible to a wider group of

12 managers without having to go back into the

13 service room.

14 THE VIDEOGRAPHER: We're off video

15 record. The time is approximately 3:16 p.m.

16 (Discussion off the record.)

17 (Exhibit 10 was marked.)

18 THE VIDEOGRAPHER: We are back on

19 video record. The time on the video monitor

20 is 3:27 p.m.

21 BY MR. MILLS: 

22 Q. Okay. I've placed in front of you an

23 exhibit, Exhibit 10.

24 Have you seen this before?

25 A. No.

03:27-03:29 Page 189

 1 Q. It's a document that's Bates numbered

 2 beginning Williams-000088 through 128.

 3 And I'm going to -- I guess the way

 4 I should ask it is: Have you seen any of

 5 the first pages of the document Bates

 6 numbered 88 through 93?

 7 A. Not that I recall.

 8 Q. Turn to page Bates number 99. And page

 9 Bates number 99 appears to be an email from

10 you to Brandy Williams, cc: Michael

11 Hammond, dated August 14, 2013, correct?

12 A. That is correct.

13 Q. Who is Michael Hammond?

14 A. Michael Hammond is -- or was a member of the

15 recruiting organization. He was a

16 recruiting manager.

17 Q. And in this email, you state, "Hi Brandy, I

18 just wanted to share some feedback from the

19 NorthWest RDO called today."

20 What is the NorthWest RDO?

21 A. It's not a thing, it's a call. RDO is

22 regional director of operations.

23 Q. Okay. And in here you tell Brandy that

24 "Tony said that he has been very happy with

25 the increased recruiting support in the

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(47) Pages 186 - 189

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 385 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:29-03:31 Page 190

 1 region and Frank Gomez specifically said

 2 that you do a great job of communicating

 3 with him in real time. Thank you for your

 4 help - It's clearly having a positive impact

 5 on our region!" Correct?

 6 A. That is what it says.

 7 Q. And that's what you wrote to Brandy?

 8 A. I think I did, yes.

 9 Q. Turn to the next page Bates numbered 100.

10 And this is dated -- it's a memorandum dated

11 September 24, 2013.

12 Have you seen this before?

13 A. I believe I have, although I can't recollect

14 it specifically, but --

15 Q. Did you prepare this memorandum?

16 A. No, I did not.

17 Q. Do you know who did?

18 A. I don't specifically know.

19 Q. At what point -- or strike that.

20 At some point, was there a decision

21 made about the date on which Brandy was

22 going to be terminated from G & K?

23 A. Yes.

24 Q. When did that occur?

25 A. Approximately two weeks prior to her final

03:31-03:33 Page 191

 1 day.

 2 Q. So, that would have been in September 2013?

 3 A. Yes.

 4 Q. And who was involved in making the

 5 determination as to the date that her

 6 termination would occur on?

 7 A. If I remember accurately, it would have been

 8 in making the actual decision, me, myself,

 9 Pelham Chastang, and Eric McNaul.

10 Q. And why was that particular date selected?

11 A. I don't recall why that particular date was

12 selected. I really don't.

13 Q. When did you tell Brandy that her employment

14 at G & K was going to be terminated?

15 A. It would have been on her last day of

16 employment.

17 Q. Which was September 24th? 23rd?

18 A. I don't recall.

19 Q. Okay. Who was it that informed Brandy that

20 her employment was terminated?

21 A. Eric McNaul and me.

22 Q. And where -- where did you inform her of

23 that?

24 A. In Phoenix.

25 Q. Did you fly out to Phoenix for that purpose?

03:33-03:34 Page 192

 1 A. I don't recall if it was specifically for

 2 that purpose alone, but we did go to

 3 Phoenix.

 4 Q. Eric was stationed in Minneapolis -- or

 5 St. Paul?

 6 A. Yes.

 7 Q. Do you recall that it was September 29th was

 8 Brandy's last day?

 9 A. I don't recall.

10 Q. Was there anybody else present during the

11 meeting you had with Brandy to tell her that

12 her employment was terminated?

13 A. No.

14 Q. And where specifically did that conversation

15 take place?

16 A. In the conference room in the Phoenix plant.

17 Q. Take a look at the next page, Bates number

18 101. It's a document that is entitled

19 Confidential Separation Agreement and

20 General Release, correct?

21 A. That is the heading, yes.

22 Q. Is this something that you presented to

23 Brandy at the meeting in which you told her

24 that her employment was terminated?

25 A. It looks like what I presented.

03:34-03:36 Page 193

 1 Q. Is this a form of a -- strike that.

 2 Is this a form Separation Agreement

 3 and General Release that's used by G & K?

 4 A. I believe it is, but I can't -- I didn't

 5 prepare them, so I don't know.

 6 Q. Did you have any input in the preparation of

 7 this -- this document?

 8 A. I don't believe so, no.

 9 Q. Had you been present before when other

10 employees of G & K were terminated from the

11 company?

12 A. Yes.

13 Q. How many times?

14 A. A fair number, upwards of probably 150.

15 Q. And were all employees who were terminated

16 from the company asked to sign a Separation

17 Agreement and General Release?

18 A. No, only those whose positions were

19 eliminated.

20 Q. Had you been present before at the

21 termination of employees whose positions had

22 been eliminated?

23 A. Yes.

24 Q. How many times?

25 A. Probably 20, 30.

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(48) Pages 190 - 193

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 386 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:36-03:37 Page 194

 1 Q. And were those employees asked to sign a

 2 Separation Agreement and General Release?

 3 MS. PARKER: Objection to

 4 relevance. You can answer.

 5 THE WITNESS: Okay, yes.

 6 BY MR. MILLS: 

 7 Q. Did G & K have different forms that it used

 8 for a Separation Agreement and General

 9 Release?

10 MS. PARKER: Objection to

11 relevance.

12 THE WITNESS: I have no idea.

13 BY MR. MILLS: 

14 Q. If you take a look at page Bates number 103,

15 there's a very long paragraph at the top of

16 the page that's actually a continuation of

17 the paragraph that begins on the previous

18 page.

19 And I'm going to read just a

20 portion of it beginning 10 lines down from

21 the top.

22 And it reads, quote, "This total

23 and complete release and waiver includes,

24 without limitation, claims which have or

25 could arise under the National Labor

03:37-03:38 Page 195

 1 Relations Act, Title VII of the Civil Rights

 2 Act of 1964, the Employment Retirement" --

 3 "the Employee Retirement Income Security Act

 4 of 1974, the Age Discrimination in

 5 Employment Act of 1967 as amended by the

 6 Older Workers Benefit Protection Act, the

 7 Equal Pay Act, 42 U.S.C. Section 1981, the

 8 Sarbanes-Oxley Act, the Dodd-Frank Wall

 9 Street Reform and Consumer Protection Act,

10 the Fair Credit Reporting Act, the

11 Vocational Rehabilitation Act, the Family

12 and Medical Leave Act, the Workers

13 Adjustment and Retraining Notification Act,

14 the Fair Labor Standards Act, the Lily

15 Ledbetter Fair Pay Act of 2009, the

16 Americans with Disabilities Act, the

17 Rehabilitation Act of 1973, the Genetic

18 Information Nondiscrimination Act,

19 Immigration Reform and Control Act of 1986,

20 the Civil Rights Act of 1991, the

21 Occupational Safety and Health Act, the

22 Consumer Credit Protection Act, the American

23 Recovery and Reinvestment Act of 2009, the

24 Asbestos Hazard Emergency Response Act, the

25 Employee Polygraph Protection Act, the

03:38-03:39 Page 196

 1 Uniformed Services Employment and

 2 Reemployment Rights Act."

 3 Were other employees of G & K whose

 4 positions had been eliminated asked to

 5 release claims under all these statutes?

 6 MS. PARKER: Objection:

 7 Foundation; relevance.

 8 THE WITNESS: I would have to look

 9 at all of their individual agreements to see

10 if they matched exactly, but this is

11 pretty -- pretty standard language.

12 BY MR. MILLS: 

13 Q. Do you know who came up with this language?

14 MS. PARKER: Objection: Relevance;

15 foundation; and to the extent it would call

16 for any sort of inquiry into attorney/client

17 privilege.

18 THE WITNESS: I have no idea.

19 BY MR. MILLS: 

20 Q. Did Brandy sign this general release?

21 A. I don't believe so.

22 Q. Did any other employees of G & K ever sign a

23 general release like this?

24 MS. PARKER: Objection: Relevance;

25 foundation.

03:39-03:40 Page 197

 1 THE WITNESS: Yes.

 2 MS. PARKER: You can answer if you

 3 know.

 4 THE WITNESS: Yes.

 5 BY MR. MILLS: 

 6 Q. Did any refuse?

 7 MS. PARKER: Objection: Relevance;

 8 foundation. You can answer if you know.

 9 THE WITNESS: Not that I know of.

10 BY MR. MILLS: 

11 Q. What did -- what did Eric McNaul say to

12 Brandy during the meeting in which you

13 informed her that her employment was being

14 terminated?

15 A. I don't specifically recall.

16 Q. Who is the one that told her that this was

17 happening? Was that you?

18 A. I believe it was me.

19 Q. Do you remember what you said?

20 A. I don't specifically recall, no.

21 Q. Do you recall how Brandy reacted?

22 A. I recall that she didn't really have much of

23 a reaction at all.

24 Q. Did you tell her when the decision had been

25 made to eliminate her position?

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(49) Pages 194 - 197

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 387 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:40-03:43 Page 198

 1 A. I don't recall specifically, no.

 2 Q. Do you recall telling Brandy why she was

 3 being let go from G & K?

 4 A. Specifically, no, but typically a

 5 conversation like that just includes general

 6 information that a position -- your position

 7 has been eliminated.

 8 Q. Do you recall her asking why it had been

 9 eliminated?

10 A. No, I don't recall her asking.

11 Q. Do you recall anything else about that

12 conversation with Brandy and Eric in which

13 Brandy was informed that her position was

14 being terminated?

15 A. I don't -- I don't recall anything else. It

16 was very short.

17 Q. Was Brandy escorted out of the office?

18 A. I don't recall.

19 Q. Were employees typically escorted out of the

20 office when she was informed that their --

21 A. Typically, yes.

22 Q. -- position was terminated?

23 A. Typically, yes.

24 Q. Take a look at page Bates numbered 126.

25 It's toward the very end. And this appears

03:43-03:44 Page 199

 1 to be an email from Brandy to you dated

 2 July 29, 2013, correct?

 3 A. It appears to be, yes.

 4 Q. And in here she's asking you what the

 5 temporary change -- or I'll just read it,

 6 beginning the second sentence, she says,

 7 quote, "I was curious what this temporary

 8 change of what my GK Perform should include.

 9 Should I make changes away from what we

10 discussed before of protecting business,

11 etc??"

12 Do you know what she means by

13 "protecting the business"?

14 A. Protecting the business, if I remember

15 correctly, was there were some main kind of

16 general goals for the HR organization that

17 must protect the business. It's like

18 customer focus, protect the business.

19 Q. What does it mean to protect the business?

20 Let me rephrase that.

21 In the context of G & K, what did

22 it mean to, quote-unquote, "protect the

23 business"?

24 A. That, I probably can't comment on anymore.

25 It's been a really long time.

03:45-03:46 Page 200

 1 Q. Did you know at one time?

 2 A. I'm sure I did.

 3 Q. Was it -- was it a job duty or

 4 responsibility of the HR generalists to

 5 quote-unquote, "protect the business"?

 6 A. So, protect the business was an umbrella,

 7 and, again, I'm not sure it even just

 8 applied to HR, but it would have been, you

 9 know, kind of, what can you do in your role

10 to protect the business, right?

11 So, that means lots of different

12 things, but with respect to kind of her

13 particular goals, I don't remember what it

14 meant in the HR context. This is shortly

15 before I left as well, so --

16 Q. Did protecting the business include the

17 HR generalists reporting back to you or

18 anybody else within G & K about the

19 performance of the managers?

20 MS. PARKER: Objection:

21 Foundation. She said she didn't know.

22 THE WITNESS: I don't remember.

23 BY MR. MILLS: 

24 Q. Do you recall any of the managers

25 complaining or expressing concern that they

03:46-03:48 Page 201

 1 were being overseen the HR generalists?

 2 A. No.

 3 Q. Do you recall anyone expressing any concern

 4 or complaint that the HR generalists were,

 5 essentially, spying on the managers?

 6 A. Heavens, no. No.

 7 Q. How closely did you work with Eric McNaul?

 8 A. It was part of the Regional Leadership Team.

 9 Q. Did you work -- I'm sorry, go ahead.

10 A. So, I sat in the same office.

11 Q. Did you work with him every day?

12 A. Not every day, but most days.

13 Q. And he oversaw your activities?

14 A. Can you clarify what you mean by "oversaw"?

15 Q. Did he supervise your activities?

16 A. At what point?

17 Q. After February 2013.

18 A. No, he did not.

19 Q. That would have been Pelham at that point?

20 A. Correct.

21 Q. Why was Eric McNaul involved in the decision

22 to eliminate Brandy's position?

23 A. She was still part of the regional

24 leadership -- the regional HR organization.

25 Q. Did Eric know Brandy personally?

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(50) Pages 198 - 201

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 388 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:49-03:50 Page 202

 1 A. I don't know.

 2 Q. Did Pelham?

 3 A. I don't know. You'd have to ask them.

 4 Q. Did either Eric or -- strike that. Let's

 5 start with Eric.

 6 Did Eric ever tell you anything

 7 about Brandy?

 8 A. Anything --

 9 Q. Anything.

10 A. I assume so, at some point.

11 Q. Like what?

12 A. I have no idea. She was a part of my team,

13 so --

14 Q. Did Eric ever say anything to you about

15 Brandy's performance at G & K?

16 A. I don't recall.

17 Q. Is it possible that he did?

18 A. It's possible.

19 Q. And how frequently did Eric get out to

20 Phoenix?

21 A. I don't know.

22 Q. Do you know whether Eric talked to Jake or

23 any of the other managers in Phoenix?

24 A. I expect that he did.

25 Q. During what time period?

03:50-03:51 Page 203

 1 A. Well, when he managed them.

 2 Q. Prior to the restructuring?

 3 MS. PARKER: Objection:

 4 Foundation.

 5 THE WITNESS: Yes.

 6 BY MR. MILLS: 

 7 Q. What about after the restructuring?

 8 A. Yes.

 9 Q. Okay. Did Pelham ever tell you anything

10 about Brandy?

11 A. I don't recall.

12 Q. As part of the process of determining that

13 Brandy's position at G & K would be

14 eliminated, was anybody else other than you

15 and Pelham and Eric consulted?

16 A. Not that I recall.

17 Q. Are you aware of Brandy at any time

18 reapplying for a position at G & K after

19 September 2013?

20 MS. PARKER: (Indicating.)

21 THE WITNESS: I thought you were

22 going to say something.

23 MS. PARKER: No, that wasn't a

24 signal, or objection.

25 THE WITNESS: I am aware but I'm

03:51-03:53 Page 204

 1 aware through this (indicating) process, so

 2 I don't know if I can say that or not.

 3 BY MR. MILLS: 

 4 Q. Is it something that you learned through

 5 consultation with counsel?

 6 A. Yes.

 7 Q. Okay. Then I'll leave it alone.

 8 Was Eric McNaul involved in any way

 9 in Brandy's request for an ADA accommodation

10 in July 2013?

11 A. No.

12 Q. How about Pelham, was he involved?

13 A. Not that I recall.

14 Q. Was there anybody else, other than you and

15 Marie and -- who is the other individual you

16 mentioned earlier? Nikki? Anyone other

17 than you or Marie or Nikki that was involved

18 in that request?

19 A. I don't know. I don't know.

20 Q. Did you ever have any conversation with any

21 of the managers at Tucson regarding Brandy's

22 performance?

23 A. I don't recall specifically.

24 Q. Would you have documented those

25 conversations if they occurred?

03:53-03:54 Page 205

 1 A. I may have.

 2 Q. Do you recall having any conversations with

 3 any of the managers at Yuma regarding Brandy

 4 Williams?

 5 A. I don't think there was a manager in Yuma.

 6 Q. What was in Yuma?

 7 A. One route.

 8 Q. Was there a physical facility in Yuma?

 9 A. There -- actually, I don't even know if

10 there was. There may have been, but it was,

11 I think, one route, maybe two. It was not

12 even a branch, really.

13 Q. How about in the -- in Prescott Valley, did

14 you talk to any of the managers there about

15 Brandy's performance?

16 A. I don't recall that there was a manager

17 there either. I could be wrong. It was

18 similar to Yuma where it was a very, very

19 small location.

20 Q. How about San Diego, did you ever talk to

21 any of the managers there about Brandy's

22 performance?

23 A. I don't recall.

24 Q. Would you have documented that if you did?

25 A. Very likely, yes.

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(51) Pages 202 - 205

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 389 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

03:54-03:56 Page 206

 1 Q. And is that also true with Ontario,

 2 California?

 3 A. Yes.

 4 Q. And Los Angeles?

 5 A. Yes.

 6 Q. And how about Sun Valley, do you recall

 7 having any conversations with any of the

 8 managers at Sun Valley?

 9 A. I don't.

10 Q. About Brandy?

11 A. I was going to say -- I don't.

12 Q. Would you likely have documented those

13 conversations if you had them?

14 A. I may have.

15 Q. Okay. Do you recall the names of any of the

16 managers at Ontario or Sun Valley?

17 A. George, but I don't know if that's right. I

18 don't know.

19 Q. You don't recall last name?

20 A. I don't even know if it was George. That

21 came into my head, so I could be totally

22 wrong.

23 Q. How about Tucson?

24 A. I can't remember his name.

25 Q. You don't remember the name?

03:56-03:57 Page 207

 1 A. I don't, honestly. I'm sorry, I don't. If

 2 you know it and you tell me, I can tell you

 3 if it's right.

 4 (Exhibit 11 was marked.)

 5 BY MR. MILLS: 

 6 Q. Okay. I've handed you a document that we've

 7 marked as Exhibit 11. It appears to be an

 8 email from you to Marie Smith dated

 9 September 13, 2013, correct?

10 A. Yes.

11 Q. Could you tell me what this email is about.

12 A. Yes. This is me reaching out to Marie

13 Smith. Marie would have been part of the

14 process of the position elimination for

15 Brandy.

16 This is probably about the time

17 that we decided the specific date, so it

18 would have been the middle of September, and

19 just talking about her role in recruiting

20 and whether or not there was going to be a

21 permanent offer and, again, asking for her

22 advice as the employee relations manager.

23 Q. What advice were you asking her for?

24 A. So, we had decided the date, that it would

25 be a couple of weeks out from here. I was

03:57-03:59 Page 208

 1 asking her if recruiting wasn't prepared to

 2 make her a permanent job offer, if we should

 3 still move forward with the original date

 4 that we had scheduled in late September or

 5 whether we should wait to see if, on a

 6 temporary role, or in a temporary role, she

 7 performed and they chose then -- I don't

 8 know, I'm reading it, but -- so, asking

 9 about whether or not -- if we should wait or

10 delay.

11 Q. If recruiting had offered Brandy a permanent

12 position, would you still have terminated

13 her?

14 A. I would have eliminated her position, but

15 she would no longer have been in it.

16 Q. Could she have continued working in

17 recruiting if they had offered her a

18 permanent position?

19 A. Presumably, yes, and if she had accepted it.

20 Q. Did you have any involvement in the decision

21 whether to offer Brandy a permanent position

22 in recruiting?

23 A. No, I just encouraged them to make an offer.

24 Q. Do you know who was involved with that

25 decision?

03:59-04:00 Page 209

 1 A. It would have probably been Theresa

 2 Schneider, who was the director responsible

 3 for all of recruiting, probably Michael

 4 Hammond, maybe others.

 5 Q. Do you know whether they made her -- made

 6 Brandy an offer of permanent employment?

 7 A. Yes.

 8 Q. What do you know about that?

 9 A. I know that they did not.

10 Q. Do you know why?

11 A. I know that they were not comfortable making

12 a permanent offer at this point, and so --

13 or at the point where this, kind of,

14 happened, so based on that, potentially

15 based on whatever Marie responded, that it

16 didn't make sense to try to have her stay on

17 in a temporary role after eliminating the

18 position. I don't know how that would have

19 worked.

20 Q. Did they hire anybody in a permanent

21 position in recruiting at the time that they

22 let Brandy go?

23 MS. PARKER: Objection:

24 Foundation.

25 THE WITNESS: I don't know.

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(52) Pages 206 - 209

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 390 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

04:00-04:18 Page 210

 1 MR. MILLS: Give me a couple

 2 minutes. I'll look through my notes.

 3 THE VIDEOGRAPHER: We're off the

 4 video record. The time on the monitor is

 5 4:01 p.m.

 6 (A recess was taken.)

 7 THE VIDEOGRAPHER: We're back on

 8 video record. The time on the monitor is

 9 4:17 p.m.

10 BY MR. MILLS: 

11 Q. Okay. At the time of the restructuring that

12 occurred in late 2012 effective in February

13 2013, did you have any involvement in the

14 decision to have HR generalists as opposed

15 to HR representatives?

16 A. No.

17 Q. Do you know who was involved in making that

18 decision?

19 A. It was -- it was just, sort of, we went into

20 the project knowing that we weren't going to

21 have, kind of, that traditional HR

22 representative role anymore, so that was

23 sort of the goal is to figure out how to

24 restructure, but having the HR at the end

25 was never an option.

04:18-04:19 Page 211

 1 Q. Do you know who was involved in making the

 2 decision to go with HR generalists going

 3 forward?

 4 A. I don't know if it was Randy who -- Randy

 5 Ross who made the decision, or if it was

 6 more of a collective group of us that

 7 discussed how the model should look.

 8 Q. And do you know who was involved in the

 9 decision as to how many HR generalists there

10 needed to be going forward?

11 A. I do.

12 Q. Who was that?

13 A. It was a combination of the HR leadership

14 team between all the functions and all of

15 the field directors and Randy and our

16 consultant and all sorts of people.

17 Q. Were you involved in that decision?

18 A. Yes.

19 Q. Was Eric involved in that decision, Eric

20 McNaul?

21 A. I don't know if he was involved in the

22 decision per se. He had an opinion.

23 Q. And do you recall what his opinion was?

24 A. That we felt that we wanted to have more

25 than we were allotted, so to speak, or that

04:19-04:21 Page 212

 1 we wanted to have three instead of the

 2 recommended two.

 3 Q. Who had recommended two?

 4 A. So, all the other regions had two, and we

 5 pushed hard to have three, just based on our

 6 feelings about HR, that HR is good.

 7 Q. Were there more plants or more branches in

 8 the Northwest Region as opposed to other

 9 regions?

10 A. That, I don't know.

11 Q. And did you personally push for three

12 HR generalists in the Northwest Region?

13 A. I did.

14 Q. What was that based on?

15 A. We had eight HR representatives or HR

16 administrators, so each of our plants had

17 their own person, and it was -- our

18 leadership in the Northwest Region valued

19 their HR partners having their person, and

20 so we were concerned that, if we went to

21 two, in a completely new role, in a

22 different model, and the way access to HR

23 services changed, that it would have a

24 detrimental effect on our leaders and on our

25 employees being able to not access HR.

04:21-04:22 Page 213

 1 So, before you had an HRR with a

 2 very general set of duties, but a much

 3 smaller span of control, maybe 300

 4 employees, 400 max, and now we're going to a

 5 space where you have several hundred to more

 6 than a thousand, so it's very different.

 7 And we wanted to make sure that we

 8 didn't limit our employees being able to

 9 access the HR organization.

10 Q. How many regions are there within G & K?

11 A. The same thing I said this morning, I don't

12 know, four or five and Canada, but I don't

13 really remember how many there were then.

14 Q. Do you know how many -- strike that.

15 Do you know how many HR generalists

16 there are within each region now?

17 MS. PARKER: Objection:

18 Foundation.

19 THE WITNESS: Other than the

20 Northwest, I don't.

21 BY MR. MILLS: 

22 Q. Do you know whether any region has more than

23 one?

24 A. I don't.

25 MS. PARKER: Give me a second.

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(53) Pages 210 - 213

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 391 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

04:23-04:24 Page 214

 1 (Discussion off the record.)

 2 MR. MILLS: Okay. I think we're

 3 done. Thank you very much.

 4 MS. PARKER: I have a few

 5 questions.

 6 EXAMINATION

 7 BY MS. PARKER: 

 8 Q. This will be pretty short.

 9 Ms. Raskovich, earlier today you

10 were -- you testified about the timing of

11 the decision to eliminate the position and

12 the decision to eliminate Ms. Williams'

13 position being in June, and you testified

14 that there was a period of delay when you

15 did not know that -- the time when that

16 elimination would occur.

17 Do you recall why there was no date

18 set initially for the elimination of the

19 position?

20 A. I don't recall specifically, but it's not

21 atypical.

22 Q. Do you recall any factors that went into the

23 decision to not set a decision at the

24 moment?

25 A. No, I don't.

04:24-04:26 Page 215

 1 Q. I'd like to direct your attention back to

 2 Exhibit 5. I'm sorry, strike that.

 3 I will go there, but just to follow

 4 up, do you recall also testifying that, at

 5 the end of August, you still did not have a

 6 date for Ms. Williams -- for the position

 7 elimination?

 8 A. Yes, that's correct.

 9 Q. At the end of August, were there any

10 considerations going into the timing of the

11 elimination and not having set a date?

12 A. I think we were hopeful that the recruiting

13 role would be something that Brandy would

14 find success in and that she would

15 ultimately transition into.

16 Q. All right. Let's go to Exhibit 5.

17 MR. MILLS: Go ahead. We'll find

18 it.

19 BY MS. PARKER: 

20 Q. And do you recall being asked some questions

21 about your statement in here that you wanted

22 to manage the request closely and determine

23 the best way of doing so?

24 A. Yes.

25 Q. Do you recall whether you ever denied

04:26-04:27 Page 216

 1 Ms. Williams permission to have a medical 

 2 appointment subsequent to this email? 

 3 A. No. Well, I do remember, but I did not. 

 4 Q. You're saying you did not ever deny her 

 5 permission to attend an appointment? 

 6 A. Correct, yes. 

 7 Q. Prior to this email, had you denied her 

 8 permission to attend an appointment? 

 9 A. No. 

10 Q. Did you ever enforce the eight-hour 

11 suggestion that you had in this email? 

12 A. No. 

13 MS. PARKER: No further questions. 

14 MR. MILLS: Nothing. 

15 THE VIDEOGRAPHER: We are off video 

16 record. The time is approximately 4:27 p.m. 

17 (At 4:27 p.m. the deposition was 

18 recessed.) 

19

 

20

 

21

 

22

 

23

 ___________________________ 24 Rachael Siggerud Raskovich 

25

Page 217

 1 STATE OF MINNESOTA 

 2 CERTIFICATE COUNTY OF WASHINGTON

 3

 I, Kelly A. Herrick, hereby 4 certify that I reported the deposition of RACHAEL SIGGERUD RASKOVICH on the 11th day

 5 of May, 2016 in Minneapolis, Minnesota, and that the witness was by me first duly sworn 6 to tell the truth and nothing but the truth concerning the matter in controversy 7 aforesaid; 

 8 That I was then and there a notary public in and for the County of Washington, 9 State of Minnesota; that by virtue thereof I was duly authorized to administer an oath; 10

 That the foregoing transcript is a 11 true and correct transcript of my stenographic notes in said matter, 12 transcribed under my direction and control; 

13 That the cost of the original has been charged to the party who noticed the 14 deposition and that all parties who ordered copies have been charged at the same rate 15 for such copies; 

16 That the reading and signing of the deposition was not waived; 17

 That I am not related to any of 18 the parties hereto, nor interested in the outcome of the action and have no contract

19 with any parties, attorneys or persons with an interest in the action that has a

20 substantial tendency to affect my impartiality; 21

 WITNESS MY HAND AND SEAL this 20th

22 day of May, 2016. 

23

 

24 _____________________ Kelly A. Herrick 25 Notary Public

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(54) Pages 214 - 217

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 392 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

[

[sic] (1) 174:23

A

Abercrombie (1) 11:24

able (6) 98:9;129:20;

 135:19;185:4;212:25;

 213:8

above (1) 138:17

above-entitled (1) 5:10

absent (1) 110:4

absolutely (4) 96:18;

 149:15;151:8;180:20

acceptable (1) 158:22

accepted (1) 208:19

access (4) 27:10;

 212:22,25;213:9

accessibility (3) 63:13;

 135:8;179:13

accessible (1) 188:11

accommodation (18)

 147:23;149:8,13;

 151:5,25;153:10;

 154:23;155:8;156:12;

 158:9;159:2,4,9,11,18;

 180:10;181:9;204:9

accommodations (1)

 183:12

accomplish (1) 76:3

according (3) 73:25;

 106:10;143:3

accurate (2) 74:15;

 172:17

accurately (2) 74:10;

 191:7

achieve (2) 98:10;

 99:25

acquisition (2) 23:15;

 169:3

act (29) 79:23;89:6;

 148:1;150:11;195:1,2,

 3,5,6,7,8,9,10,11,12,13,

 14,15,16,17,18,19,20,

 21,22,23,24,25;196:2

acting (2) 20:5;117:5

action (1) 5:10

activities (4) 81:10;

 138:11;201:13,15

actual (1) 191:8

actually (19) 16:16;

 28:11;58:9;60:10;

 72:11;82:21;100:18;

 102:11;126:17;146:1;

 147:7;163:12;166:5;

 176:22;178:10;183:21;

 188:11;194:16;205:9

ADA (29) 147:23,25;

 148:3,7,9,21;149:5,8,

 12,25;151:4,11,21,25;

 154:22;155:3,6,8,13,

 15;156:2,6,9,11,13;

 158:9;180:9;181:8;

 204:9

adding (1) 64:2

addition (2) 21:12;

 32:15

additional (2) 114:25;

 122:11

address (1) 115:5

addressed (1) 144:12

Adjustment (1) 195:13

administrator (1) 17:7

administrators (1)

 212:16

advice (5) 153:6;160:7;

 161:21;207:22,23

affect (1) 187:5

afternoon (2) 101:3;

 177:10

again (33) 31:5;36:1;

 44:11;46:14;47:13;

 48:9;49:20;52:25;64:5,

 12;70:14;77:15;82:5;

 91:11;93:20;95:18;

 96:25;100:7;101:21;

 102:19;111:18;114:12;

 126:25;138:16;143:2;

 144:14;149:24;157:6;

 163:6;173:4;184:14;

 200:7;207:21

against (5) 97:21;

 98:14;104:2,3;127:15

Age (1) 195:4

ago (2) 128:1;151:10

agree (7) 87:7;88:11;

 93:11,14;94:2;111:6;

 187:2

agreed (2) 66:16,25

Agreement (5) 192:19;

 193:2,17;194:2,8

agreements (2) 107:9;

 196:9

ahead (5) 136:25;

 180:11,14;201:9;

 215:17

ahold (1) 52:23

airplane (1) 107:16

al (1) 4:12

allegations (1) 7:5

alleviate (1) 114:21

allotted (1) 211:25

alone (3) 96:3;192:2;

 204:7

along (2) 159:10;186:9

although (2) 109:13;

 190:13

always (2) 31:10;

 115:21

amended (1) 195:5

America (1) 11:20

American (1) 195:22

Americans (2) 147:25;

 195:16

among (1) 25:1

amount (5) 60:2;61:12,

 13;69:21;146:24

Angeles (6) 33:6;84:19,

 20;108:12;175:5;206:4

Angie (5) 84:21,22;

 85:3,8;131:11

Angie's (1) 85:11

angry (1) 149:12

annoy (1) 149:7

annual (1) 62:5

answered (8) 31:22;

 70:20;71:3;98:12;99:8;

 161:15;162:4;178:2

anymore (9) 17:21;

 61:16;73:16;126:10,

 15;183:17;184:12;

 199:24;210:22

apart (2) 136:2;178:23

apologize (3) 65:12;

 77:10;123:4

appear (2) 90:19;

 104:20

appearing (1) 99:4

appears (10) 75:3;

 77:19;113:16;165:5,7;

 166:21;189:9;198:25;

 199:3;207:7

applied (1) 200:8

appointment (9)

 158:18;159:13,15,17;

 160:2;161:5,8,13;

 162:2

appointments (5) 146:7,

 11;158:16;159:1,7

approach (1) 25:7

approached (2) 25:10;

 55:24

appropriate (3) 69:18;

 162:6;181:13

Approximately (3)

 10:22;188:15;190:25

April (7) 10:13;41:23;

 42:5;127:9;167:4,6;

 168:8

area (2) 110:23;176:20

argumentative (3)

 151:7;157:17;161:15

arise (1) 194:25

Arizona (2) 4:14;14:17

around (8) 54:19;

 75:15,17;83:11,18;

 135:18;136:1;176:16

art (1) 172:16

Asbestos (1) 195:24

assesses (1) 86:7

assigned (4) 23:11;

 62:8;80:17;82:10

assistance (3) 150:23;

 152:4;153:1

associated (2) 106:25;

 139:19

assume (5) 9:3;66:9;

 128:9;168:13;202:10

assuming (1) 95:6

attached (2) 39:15;

 77:11

attend (1) 159:7

attention (6) 46:23;

 74:18;112:3;122:11;

 173:17;215:1

attorney (1) 48:25

attorney/client (10)

 42:17;43:13;44:13;

 46:14;47:14,23;48:10,

 17;49:22;196:16

atypical (1) 214:21

Aubin (1) 131:23

audio (5) 173:11,23;

 174:9;179:22;180:3

August (8) 58:19;59:2;

 143:20;164:9,11;

 189:11;215:5,9

aunt (1) 154:4

aunt/cancelled (1)

 153:25

average (1) 34:5

awarded (1) 8:13

aware (19) 71:14,15;

 107:24;127:7,14;

 144:19,24;146:4,6,9,

 22;169:15,25;171:10,

 13;187:21;203:17,25;

 204:1

away (7) 30:17;125:22;

 126:1,8;144:22;187:3;

 199:9

B

babysitter (1) 153:24

baby-sitter (1) 154:4

Bachelor's (1) 12:14

back (42) 12:24;15:1;

 21:2;42:3;44:4;51:16;

 62:25;63:6;64:8,14;

 74:16;76:13;77:8;

 81:14;100:25;101:7,8,

 11,19;102:17;120:9;

 126:6;127:9;138:15;

 141:6;142:2,13,14,20;

 151:19;162:12;163:2;

 169:9;171:2;174:7;

 179:8;186:19;188:12,

 18;200:17;210:7;215:1

background (1) 73:16

bad (2) 26:9;37:8

balancing (1) 89:6

base (6) 93:2,15;95:9,

 16;97:12,14

based (23) 16:14,21;

 47:18;75:22;81:10;

 86:22;94:12,21;95:1;

 96:1;98:6,8,24;103:20;

 106:19;118:9;140:23,

 23;143:11;209:14,15;

 212:5,14

basement (1) 126:14

basically (2) 29:9;86:7

basis (6) 34:15;48:23;

 79:25;81:4;82:12;

 184:22

Bates (16) 112:5;

 113:14;123:15;124:13;

 133:13;138:16;139:14;

 144:8;189:1,5,8,9;

 190:9;192:17;194:14;

 198:24

Bayer (1) 131:15

became (6) 15:5;28:22;

 32:10;36:5;56:8,17

become (4) 10:21;

 28:21;37:1;127:14

becomes (1) 164:7

begin (3) 139:25;

 140:1;163:24

beginning (18) 13:22;

 15:12;19:11,12,16;

 76:8;89:15;94:22;

 95:11;125:2;173:18;

 174:18;183:8;186:4,5;

 189:2;194:20;199:6

begins (5) 4:9;58:16;

 167:10;183:9;194:17

belong (1) 119:16

below (3) 85:18,23;

 99:4

benefit (2) 107:21;

 195:6

benefits (1) 62:4

best (13) 15:19;43:9;

 54:8;56:23;59:21;

 60:20;65:8;68:25;69:2;

 105:2;145:15;150:24;

 215:23

better (4) 70:2;128:17;

 162:17;172:20

beyond (1) 170:8

big (1) 186:10

biggest (3) 135:15,17,

 18

bike (1) 154:6

birth (4) 144:20;145:6,

 23;146:16

bit (2) 69:23;123:4

blob (1) 92:16

block (3) 85:25;86:5;

 163:16

Bob (2) 4:24;73:15

body (1) 144:17

Bonacua (2) 19:22;

 77:20

bored (10) 69:14;

 113:25;114:11,16;

 116:1,2;117:18,20;

 162:10,16

boredom (2) 114:21;

 162:23

both (3) 25:9;67:24;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(1) [sic] - both

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 393 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 87:3

bottom (1) 164:3

box (1) 102:21

branch (12) 20:16;

 21:13;25:12,23,24;

 26:24;29:17;32:7;

 110:20;111:14;135:6;

 205:12

Branches (13) 20:14,

 18,19,21;21:9;65:7;

 107:1;108:12;110:7,

 12,22;111:3;212:7

Brandy (185) 4:11;5:1;

 19:21;26:21;27:20,23;

 29:5,9;31:1;32:1,2,10,

 14;34:9,17,19;35:15;

 36:5,14,20,25;38:2,20,

 24;39:17;41:20;42:12;

 45:4,6,10,12,15,20;

 46:4;48:6;50:23;51:3;

 52:23;53:24;54:13;

 55:2,13,19;56:5,8,13;

 57:2;58:2,10;62:18,23;

 64:7;70:25;71:7,17;

 72:10;73:6;74:2;76:11,

 15,24,24;79:5,8;81:15;

 82:12,20;83:9,16;

 84:24;85:22;86:18;

 88:24;91:7;97:9,15;

 98:22;101:5;102:6,10;

 103:6,17;105:4,11,20;

 106:11;108:14;109:25;

 110:3,9,25;111:8;

 117:17,21;118:12;

 123:5,18;124:4,23;

 125:4;127:15;129:7,

 17;133:19;134:8,21;

 136:21;137:13,23;

 138:25;139:24;140:2,

 8;142:6,10;143:11;

 144:11,24;145:7;

 146:23;147:17,22;

 149:7;150:4;151:4;

 153:15;156:14;158:14;

 159:4,21;161:3,11;

 162:1,9;163:6,22;

 164:12;169:16;170:1,

 11;171:7;173:16;

 176:4,14,21;177:13,19;

 179:25;180:6;181:19,

 23;182:7;183:10;

 184:10,13;185:22;

 189:10,17,23;190:7,21;

 191:13,19;192:11,23;

 196:20;197:12,21;

 198:2,12,13,17;199:1;

 201:25;202:7;203:10,

 17;205:3;206:10;

 207:15;208:11,21;

 209:6,22;215:13

Brandy's (31) 28:21;

 33:22;35:19;63:13;

 72:4;77:10;87:9,17;

 88:9;89:25;98:25;

 100:4;101:14;108:18;

 149:24;151:25;155:6;

 163:11;179:13;181:5;

 186:5,20;187:10;

 192:8;201:22;202:15;

 203:13;204:9,21;

 205:15,21

break (3) 9:6,10;51:24

briefly (1) 8:21

bringing (2) 78:4,25

Briscoe (13) 52:16;

 55:12;56:9,12,24;

 62:17;63:4;64:25;

 84:11;129:9,16;

 131:14;176:11

Briscoe's (2) 56:3;

 63:12

broaden (1) 12:6

broke (1) 101:4

brought (5) 7:1;46:22;

 59:22;66:17;122:10

bucket (3) 85:1;99:19,

 21

buckets (1) 61:15

budgeting (1) 60:1

Building (3) 11:10;

 39:15;84:4

business (60) 10:3;

 12:14;17:5;20:10;25:7,

 9;55:20,20;59:24;

 64:14;65:10;68:7;

 82:25;87:4;89:12,14,

 19,21;90:10,23,24;

 96:17;104:10;105:2;

 107:6,10,11;112:19,23;

 115:1,3;118:5;132:18;

 136:7,8;137:2,24;

 138:4;144:22;160:25;

 175:19,20;178:21;

 179:4;180:18;181:11,

 25;184:20;186:10;

 199:10,13,14,17,18,19,

 23;200:5,6,10,16

businesses (1) 107:8

business's (1) 104:7

C

calculated (1) 95:22

calendar (4) 154:8,10;

 180:24;181:1

California (17) 14:17;

 33:8,10,14;106:23,25;

 107:20,22,25,25;108:3,

 5,7,11;110:9,23;206:2

call (11) 27:6,6;108:2;

 112:3;133:20;145:19;

 147:8;182:4,8;189:21;

 196:15

called (5) 11:1;54:14;

 74:6;77:9;189:19

calls (16) 27:3,5;39:4;

 42:15;43:12;44:20;

 45:25;46:14;47:13,16;

 49:21;51:7;63:14;

 96:13;97:1;113:7

came (9) 15:17;48:20;

 60:3;69:7;84:6;104:12;

 161:25;196:13;206:21

can (74) 6:6;9:1;43:9,

 9;47:21;49:2,9,23;

 50:9;54:8;61:18;66:9;

 69:1;73:19;80:18;85:9;

 86:12;88:24;89:23;

 92:9,11,13,13;94:3,16;

 99:12;100:9;101:22;

 103:10,13;108:1;

 115:20,20;119:3,18;

 121:16,25;122:20;

 123:11;124:7;126:6;

 128:19;131:18;132:1,

 2,14;133:15;136:15;

 139:14,16;140:3;

 145:15,15;149:20;

 151:18;156:16;163:3,

 11;164:21;166:1;

 170:7,20;184:4,16;

 185:15;186:8,11;

 194:4;197:2,8;200:9;

 201:14;204:2;207:2

Canada (3) 22:14,15;

 213:12

cancelled (1) 154:4

candid (1) 115:18

capacity (3) 32:2,19;

 36:15

capturing (1) 123:21

career (1) 12:6

carefully (2) 158:2,5

Carrie (1) 5:5

case (7) 6:7,8,13;7:10,

 11;8:17;183:22

categories (1) 104:10

categorize (1) 60:20

category (4) 85:15;

 98:6;104:5;145:24

causing (1) 134:22

cc (1) 189:10

cell (2) 61:24;175:9

centers (1) 16:22

certain (3) 24:1;64:6;

 139:12

Certainly (7) 48:22;

 64:15;71:23;73:12;

 80:8;180:21;181:16

certified (1) 4:17

cetera (1) 154:5

challenging (1) 184:2

chance (4) 102:9;

 169:13,23;172:12

change (8) 5:22;15:22;

 51:10;100:19;141:22;

 179:1;199:5,8

changed (7) 19:14,14;

 29:22;105:16;116:2;

 155:11;212:23

changes (2) 16:13;

 199:9

changing (1) 27:9

characterization (2)

 54:2;64:11

charge (7) 14:11;

 41:19;42:11;46:21;

 49:25;50:3;128:2

Charles (1) 131:5

chart (1) 74:6

Chastang (9) 19:1;

 59:20;65:23,24,25;

 66:13;67:1,17;191:9

checking (1) 102:21

checkmark (1) 89:1

choice (1) 45:22

chose (2) 152:12;208:7

chronological (2)

 121:20;124:16

circumstance (1) 97:2

circumstances (1)

 154:25

Cities (1) 107:14

Civil (2) 195:1,20

claim (1) 141:12

claims (3) 156:6;

 194:24;196:5

clarify (1) 201:14

clarity (4) 60:19;61:4;

 130:10;178:4

classroom (1) 75:20

cleaned (2) 126:2,13

clear (3) 98:20;99:9;

 100:17

Clearly (3) 92:21;

 155:11;190:4

client (1) 10:6

close (1) 48:9

closed (1) 181:18

closely (14) 150:23;

 151:3,25;152:3,7,17;

 153:5,7,12;155:7;

 157:1,8;201:7;215:22

Cloud (3) 18:20;

 107:14;131:17

coach (5) 75:15,21;

 83:12,14,18

coaching (2) 103:2;

 132:23

coach-to-win (1) 83:22

Coash (2) 4:18,18

COEs (2) 16:22;23:14

collective (1) 211:6

collectively (1) 107:4

college (5) 12:1,7,9,20;

 15:3

combination (1) 211:13

combined (1) 110:22

comfortable (2) 179:3;

 209:11

coming (15) 53:24;

 84:8;134:19,22,25;

 150:14;153:15,22;

 175:21,24;176:1,5;

 177:15,21;178:23

commencing (1) 4:5

comment (1) 199:24

comments (6) 102:11,

 16;105:5,8,12;186:5

common (1) 89:9

communicating (1)

 190:2

communication (2)

 27:15;47:15

communications (6)

 44:14;46:15;47:23;

 48:11;49:23;51:6

company (14) 11:1,3;

 15:20;16:8;64:3;95:4,

 14,20,24;168:21;

 185:12,23;193:11,16

compare (1) 172:12

comparison (1) 39:13

complaining (1) 200:25

Complaint (3) 45:20;

 53:8;201:4

complaints (4) 30:3;

 177:12,17;179:11

complete (3) 102:12;

 104:4;194:23

completed (2) 69:22;

 164:12

completely (3) 69:24;

 117:2;212:21

compound (5) 24:7;

 38:15;39:3;57:5;

 132:10

computer-based (1)

 11:18

concern (21) 26:12;

 52:22;53:8;54:19,25;

 57:2,12;58:2;62:18;

 63:12;83:16;115:14;

 118:19;120:1;129:22;

 135:10,17,18;181:6;

 200:25;201:3

concerned (5) 26:2;

 52:2;182:11,25;212:20

concerns (21) 25:11,

 16;26:14,16,19;30:4,8;

 53:3,21;54:4,9,12;

 55:18;58:10;135:14;

 141:7;145:23;177:12,

 20;179:11;182:17

conclusions (1) 84:9

condition (7) 123:7;

 153:24;169:17;170:2,

 12;181:7,12

conditions (1) 145:17

conducting (1) 62:12

conference (1) 192:16

confidence (1) 183:16

confidential (3) 120:19;

 122:24;192:19

confirm (1) 80:18

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(2) bottom - confirm

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 394 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

confusing (1) 74:6

confusion (1) 25:1

conjunctively (2)

 110:13,14

connect (1) 136:7

connected (1) 51:9

connection (5) 49:13;

 86:18;92:25;114:1;

 133:16

considerations (1)

 215:10

considered (2) 89:8,13

consist (2) 14:14;27:7

consisted (1) 16:2

consistent (1) 135:3

consistently (3) 150:14;

 153:21;174:20

consists (1) 14:15

constitute (1) 125:14

consultant (1) 211:16

consultation (1) 204:5

consulted (1) 203:15

consultive (1) 153:6

Consumer (2) 195:9,22

consumers (1) 11:10

contact (4) 42:10;51:3,

 6;52:3

contain (1) 122:23

containing (1) 119:4

contains (2) 120:18;

 122:16

content (3) 48:10,13;

 50:12

contest (1) 9:7

context (4) 183:25;

 185:17;199:21;200:14

continuation (1) 194:16

continue (2) 114:24;

 182:20

continued (1) 208:16

contributing (1) 118:5

Control (2) 195:19;

 213:3

conversation (40)

 42:19,22;43:2,10,16;

 48:5;50:10;85:12;

 123:17,19;129:15;

 130:21;131:1,5;

 136:17;139:23;140:2;

 141:16;145:13;147:6;

 158:13;171:7,10;

 172:4,23;173:5,15;

 176:13;177:1;178:8,

 11;179:23,25;180:4;

 181:20;184:10;192:14;

 198:5,12;204:20

conversations (24)

 27:11;42:17;43:7;

 49:18,24;50:5,11,25;

 55:11,14,15,16;83:6;

 127:8;130:13;131:8,

 11;133:11;150:4;

 176:8;204:25;205:2;

 206:7,13

conveying (2) 152:17,

 20

copy (8) 90:7;92:3,5;

 95:7;104:12,22;121:3;

 165:24

corner (2) 187:17,18

corporate (4) 10:5;

 16:6;45:2;92:19

corrected (1) 172:6

correctly (11) 47:8;

 52:6,7;58:22;71:5;

 75:24;138:22;158:23;

 178:12;184:14;199:15

corrupted (1) 172:5

Counsel (7) 4:22;45:2;

 49:12,13;51:1;125:11;

 204:5

counsel's (1) 43:23

country (1) 108:2

couple (8) 8:21;65:1;

 92:1;127:19;128:1;

 145:10;207:25;210:1

course (5) 68:7;81:11;

 112:19,23;149:10

Court (8) 4:13,16;5:7;

 7:16,17,18;101:6;

 151:19

covered (1) 11:25

covering (1) 33:20

created (3) 115:7;

 163:17;164:3

creation (1) 166:19

Credit (2) 195:10,22

criteria (7) 100:3;

 101:14;103:5;105:19;

 108:15,16,20

criterion (2) 102:5;

 106:15

criticism (1) 83:16

criticize (1) 84:3

cross (1) 75:23

cross-over (1) 80:23

crystal (2) 98:20;99:9

culture (1) 132:24

curious (1) 199:7

currently (1) 9:14

curriculum (1) 82:24

Customer (2) 92:25;

 199:18

customers (1) 20:20

D

Dakota (2) 14:16,16

date (33) 4:15;121:18;

 122:4;124:11,19;

 126:2;127:9;133:15,

 17,21;139:13;140:7;

 143:8,12,14,16;144:14;

 147:1,5;149:24;165:9;

 166:24;167:4;190:21;

 191:5,10,11;207:17,24;

 208:3;214:17;215:6,11

dated (9) 41:23;44:24;

 113:21;144:12;189:11;

 190:10,10;199:1;207:8

dating (1) 127:9

Dave's (1) 11:20

day (13) 4:2;39:11;

 112:25;113:1;121:15;

 135:6;176:17;186:22;

 191:1,15;192:8;

 201:11,12

days (2) 69:22;201:12

day-to-day (1) 34:15

de (1) 131:23

dealing (1) 122:7

debated (1) 12:24

December (1) 12:22

decide (1) 12:23

decided (11) 15:17;

 59:7,12;70:25;71:8;

 139:4,6;143:17;

 186:14;207:17,24

decision (29) 68:14;

 69:3,8;70:11,17;71:16;

 72:3,8,9;74:1;143:22;

 190:20;191:8;197:24;

 201:21;208:20,25;

 210:14,18;211:2,5,9,

 17,19,22;214:11,12,23,

 23

defeat (2) 159:2,17

define (2) 103:10;

 116:24

defined (3) 111:12;

 132:10;141:10

degree (1) 12:13

Deinard (1) 6:23

delay (2) 208:10;

 214:14

deliver (1) 20:19

delivery (1) 144:21

denied (1) 215:25

department (9) 11:17;

 15:8;16:15,20;18:12;

 29:20,25;39:2;154:19

depended (2) 34:6;

 39:21

depending (1) 62:10

depends (1) 46:8

DEPOSITION (8) 4:1,

 10,19;6:1,11;8:22;

 121:6,10

depth (1) 145:13

describe (1) 16:1

description (21) 6:6;

 13:25;23:20,24;75:10;

 76:9;77:24;81:21;

 85:16;87:8,10;92:17;

 98:25;99:5;100:15;

 102:2;165:6;166:22;

 167:17;168:7,17

descriptions (6) 97:16,

 20;167:25;168:21,24;

 169:5

design (3) 14:5;23:13;

 132:21

designed (1) 156:23

detail (1) 88:9

detailed (3) 87:18;

 88:12;145:11

determination (9)

 58:25;59:3,17,22;

 60:5;68:9;106:9,16;

 191:5

determine (5) 15:19;

 105:20;108:18;172:12;

 215:22

determined (4) 13:2;

 58:19;143:4,9

determining (2) 150:24;

 203:12

detrimental (1) 212:24

develop (3) 83:1;89:11;

 103:3

developed (1) 78:16

developing (2) 75:19,

 20

development (22) 14:5;

 23:13,14;75:10,19;

 76:9;77:25;79:18;81:7,

 16,22;82:15,21;85:6;

 87:8,11;98:7,21;99:5,

 20;103:2;132:23

Diego (2) 33:4;205:20

differ (1) 28:9

difference (2) 20:15;

 110:19

different (27) 12:5;13:2;

 17:22,25;25:8;27:10;

 31:14;66:7;69:25;

 72:11;87:10,14;94:3;

 117:3,4,5,6;160:3;

 164:15;165:14,16;

 172:22;184:8;194:7;

 200:11;212:22;213:6

differently (10) 25:10;

 37:9;102:25;140:19,

 23;141:2,8,8,13,19

difficult (1) 88:13

dilemma (1) 186:25

direct (10) 28:1,3,21,

 25;30:5,16;34:20;56:9;

 74:18;215:1

direction (1) 49:13

directly (7) 22:25;28:4;

 29:19;67:8,17,25;

 137:7

director (16) 10:20,21;

 13:23;14:19;15:6;

 18:21;19:3;20:6;22:18;

 47:3;129:1,2;155:1;

 170:15;189:22;209:2

directors (2) 28:15;

 211:15

dis- (1) 186:10

Disabilities (2) 147:25;

 195:16

disconnect (1) 186:11

discrepancies (1)

 172:13

discrimination (3)

 41:20;42:11;195:4

discuss (2) 177:19;

 181:4

discussed (4) 69:11;

 122:13;199:10;211:7

discussion (9) 85:21;

 120:8,13;123:6;124:4;

 127:1;174:6;188:16;

 214:1

discussions (4) 48:18;

 49:11;73:2;133:1

disjunctively (1) 110:13

displeasure (1) 62:18

distributed (1) 62:25

distributes (1) 20:18

District (2) 4:13,13

divide (1) 108:10

doctor's (2) 159:13,15

document (57) 40:22;

 41:5,9,18;44:6;46:19;

 48:1,21;53:3,9;58:14;

 71:23;74:17,22;77:8,

 11,16,23;81:1;83:6;

 85:11;90:8,14,17,19;

 95:5,7;97:17;100:11;

 101:10,24;104:15,20;

 112:1,4;118:25;119:3,

 7;122:10;144:9;

 149:18;154:1;163:8,9,

 16;164:22;165:3,5;

 166:16,19;167:21;

 179:19;189:1,5;

 192:18;193:7;207:6

documentation (2)

 71:15;123:17

documented (4) 55:7;

 204:24;205:24;206:12

documenting (1)

 138:24

Dodd-Frank (1) 195:8

done (10) 35:24;36:18;

 38:24;84:24;109:10;

 160:24;163:21;169:15;

 171:23;214:3

door (2) 181:17;182:21

double (1) 144:1

doubt (1) 145:25

down (16) 76:9;85:15;

 88:14;93:22;94:22;

 96:11,19,23,23;103:7,

 17;133:24;145:12;

 163:4;167:9;194:20

downhill (1) 186:14

draft (2) 44:5,8

drafted (2) 44:18;

 105:11

draw (1) 173:17

drive (1) 75:18

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(3) confusing - drive

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 395 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

driving (1) 132:23

Dubiel (1) 8:5

D-U-B-I-E-L (1) 8:7

due (1) 109:11

duly (1) 5:11

during (34) 19:2;22:23;

 28:24;29:12;32:1;

 33:12,16,18,22;34:8,

 17,19;38:1;39:24;56:5;

 70:7;110:9,24;111:6;

 112:16,22;134:8,10;

 146:5;168:1,19,22;

 170:14;181:19;182:7;

 184:9;192:10;197:12;

 202:25

duties (8) 10:4;13:25;

 23:5;24:2,13,18;25:2;

 213:2

duty (1) 200:3

E

earlier (6) 80:25;

 121:18;151:18;162:16;

 204:16;214:9

earliest (1) 124:19

early (13) 53:25;127:9;

 134:19,22;135:1;

 175:13,22,24;176:2,5;

 177:9,15,22

education (1) 15:3

EEOC (5) 48:2,22;49:3,

 4;128:2

effect (1) 212:24

effective (4) 15:11;

 165:8;166:24;210:12

effectiveness (1) 79:19

egregious (1) 109:14

eight (16) 14:21,22;

 19:15,18;20:7,8;159:1,

 16;160:1,11,15;161:3,

 7,12;162:1;212:15

eight-hour (3) 159:20,

 23;160:22

either (12) 67:1,8;

 90:15;92:18;115:5;

 129:21;156:19;158:16;

 161:5,8;202:4;205:17

elevating (1) 138:11

elicit (1) 172:22

eliminate (18) 59:12;

 68:9;69:4;70:12,18,25;

 71:8,17;72:4;139:4,7;

 143:4,10,18;197:25;

 201:22;214:11,12

eliminated (12) 68:18;

 105:22;106:12,17;

 108:19;193:19,22;

 196:4;198:7,9;203:14;

 208:14

eliminating (1) 209:17

elimination (6) 143:9;

 207:14;214:16,18;

 215:7,11

Ellison (3) 19:22;39:8;

 113:19

else (35) 14:7;24:16;

 27:14,18;35:18,23;

 40:7,10;50:19,23;

 63:19;65:11,13;68:13;

 70:15;84:15;94:25;

 97:24,25;98:17;

 100:12;101:25;108:17;

 131:18,22;132:1;

 145:20;154:2;181:14;

 192:10;198:11,15;

 200:18;203:14;204:14

email (9) 54:15;92:19;

 149:20;150:19;189:9,

 17;199:1;207:8,11

emails (2) 51:7;119:12

Emergency (1) 195:24

employed (2) 9:14;

 10:18

employee (35) 7:1,2;

 14:6;16:23;43:5;62:8;

 76:10;78:3,24;86:22,

 23;87:6;88:11,14;93:4,

 12,16;94:12;95:10;

 96:10,18;109:11;

 113:7,11;115:17;

 123:24;148:15,17,20;

 151:16;155:9;159:21;

 195:3,25;207:22

employees (40) 15:20;

 16:7;18:6;21:1;22:22;

 35:13;62:6,7;70:9;

 79:16;86:6;92:20;94:3;

 113:5;114:1;115:17;

 148:3,6,23,24;151:23;

 156:11;158:7;159:19;

 160:3,10,21,21,23;

 188:6;193:10,15,21;

 194:1;196:3,22;

 198:19;212:25;213:4,8

employee's (9) 93:2;

 94:10,19;95:9,17;96:2;

 123:6,8,10

employment (15) 6:8;

 86:19;108:1,5,7;

 191:13,16,20;192:12,

 24;195:2,5;196:1;

 197:13;209:6

empty (2) 128:23,24

encouraged (2) 115:17;

 208:23

end (18) 19:11,17,24;

 52:5;72:24;73:12;

 74:17;77:9,13;81:16,

 19;91:25;144:23;

 163:7;198:25;210:24;

 215:5,9

ending (1) 99:1

endurance (1) 9:7

engage (2) 114:25;

 115:2

enhance (1) 13:3

enough (12) 60:8,13,

 15;65:17;66:2,14,18,

 23;67:4;69:13;162:13;

 178:17

enrollment (2) 62:4,5

ensuring (1) 169:5

entire (4) 19:2;116:21;

 140:1;168:22

entitled (4) 73:17,19;

 77:15;192:18

entity (1) 158:4

Equal (1) 195:7

Eric (23) 19:5;59:20;

 68:11;70:14;131:9;

 191:9,21;192:4;

 197:11;198:12;201:7,

 21,25;202:4,5,6,14,19,

 22;203:15;204:8;

 211:19,19

escorted (2) 198:17,19

essential (6) 10:4;

 167:10,14;169:10;

 170:3,13

essentially (1) 201:5

estimate (1) 21:6

et (2) 4:12;154:5

etc (2) 153:25;199:11

evaluate (4) 15:18;

 97:8;100:4;101:14

evaluated (2) 37:18;

 38:13

evaluating (1) 37:10

evaluation (9) 75:9;

 76:14;77:19;87:9,12;

 89:25;93:3;96:4;

 105:14

evaluations (2) 74:25;

 86:21

even (11) 31:5;45:9;

 73:25,25;152:24;

 163:24;172:6;200:7;

 205:9,12;206:20

everyone (2) 183:14;

 186:22

exact (4) 20:24;128:10;

 133:17;139:13

exactly (8) 28:16;

 91:12;99:18;127:13;

 139:8;159:25;186:3;

 196:10

EXAMINATION (2)

 5:13;214:6

example (1) 98:6

examples (2) 61:18;

 132:14

exceed (1) 96:16

exceeded (1) 96:17

exceeds (2) 81:5;96:21

excellence (1) 16:22

except (1) 100:1

excerpts (1) 184:3

Exempt (6) 159:19,21;

 160:3,10,21,22

exhaustive (1) 93:21

Exhibit (60) 40:20,23;

 44:6,10;46:12;49:19;

 51:20;58:14;74:4,5;

 77:9,11;81:2,2;91:25;

 111:24;112:2;113:14;

 118:23;119:1,11;

 120:15,25;125:15;

 126:12;133:14;138:15;

 144:5,8;149:16,19,25;

 163:4,8;164:18,21;

 165:13,21,23,25;166:3,

 4,6,15;169:11;171:1,

 20,25;172:3;173:13;

 179:17,20;183:21;

 188:17,23,23;207:4,7;

 215:2,16

exist (1) 154:15

existing (1) 115:6

expect (5) 46:5;89:10;

 103:1;133:20;202:24

expectation (3) 96:16;

 136:3;138:10

expectations (16) 81:6;

 82:1,13;83:10,17;

 85:23;89:3;93:25;

 96:17,21;98:24;

 102:23;108:24;137:21,

 22;138:3

expected (3) 91:9;

 137:24;160:23

expenses (1) 60:2

experience (1) 75:22

experienced (1) 158:17

experiences (2) 12:6;

 67:3

experiencing (6)

 144:19,25;145:4;

 146:1,24;147:19

explain (6) 15:14;

 19:13;26:25;28:24;

 42:10;63:12

explaining (1) 145:7

explore (1) 72:14

exposure (2) 47:14;

 75:22

express (10) 62:17;

 63:21;64:1,5;67:2;

 116:17;117:8;118:8;

 129:21;140:17

expressed (14) 25:11,

 16,18;26:14,15;30:4;

 53:4,8;54:9;57:1;58:1,

 10;65:15;118:19

expressing (9) 26:11,

 18;52:22;54:12;61:5;

 83:15;118:2;200:25;

 201:3

expressions (2) 54:24;

 57:12

extended (1) 175:5

extent (9) 42:15;43:12;

 44:12;47:13,22,24;

 49:21;121:7;196:15

extremely (1) 109:14

F

facilitator (1) 136:4

facilities (1) 32:14

facility (4) 32:5;176:16;

 187:24;205:8

fact (8) 70:4;71:11;

 98:23;104:3;127:1;

 159:8;175:23;177:7

factors (1) 214:22

fair (10) 9:13;34:8;

 63:8;66:8,8;179:10;

 193:14;195:10,14,15

familiar (2) 41:11;108:5

Family (3) 150:10,10;

 195:11

Famous (1) 11:20

far (6) 80:22;86:12;

 87:17;92:11;156:16;

 158:10

fault (1) 55:25

favorably (2) 138:14;

 181:7

favored (1) 63:2

February (13) 19:16;

 23:4,6,19;24:25;28:7;

 39:7,24;70:7;155:18,

 21;201:17;210:12

Federal (1) 7:16

feedback (24) 16:5;

 47:5;48:6;52:1;59:23,

 24,25;60:4;69:11;84:1;

 85:4;116:8,14;129:8,

 16,23;130:2,9;132:6,

 12,17;137:1,4;189:18

feel (9) 114:1;116:9;

 118:4;147:3;153:11;

 173:3;179:3;183:11,14

feeling (1) 184:16

feelings (1) 212:6

fell (1) 154:6

felt (17) 55:23;116:7;

 117:8;118:3,13;129:8;

 135:24;140:14,22;

 181:3,24;184:23;

 185:1,1,11;186:24;

 211:24

few (5) 7:8;65:2;112:8;

 151:10;214:4

field (2) 16:6;211:15

Fifth (3) 4:3;74:19;

 81:18

figure (1) 210:23

file (3) 154:2;172:5,6

filed (5) 42:12;48:1,22;

 127:15;128:7

filling (1) 69:22

final (3) 143:12;187:25;

 190:25

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(4) driving - final

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 396 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

find (12) 48:20;55:25;

 84:23;89:23;104:11;

 134:17;174:10;184:16;

 186:6,23;215:14,17

finding (1) 136:9

fine (3) 9:7;91:19;92:2

finished (1) 24:8

Firm (1) 4:20

first (33) 5:11;8:23;

 10:14;14:23;40:25;

 41:8,24;44:9;45:21;

 46:12;59:16;65:20;

 76:14;90:3;105:5;

 112:3,8;120:3;122:23;

 123:10;144:17;147:11;

 150:2;153:13;155:12,

 15,19,23,25;156:13;

 158:18;172:8;189:5

fiscal (8) 77:5;93:5;

 94:4,11;95:11;96:12;

 99:1;103:19

fit (8) 72:15;182:15,22;

 183:1,16;184:11,18,21

Fitch (1) 11:24

five (4) 11:6;22:14;

 34:7;213:12

fix (1) 115:21

flat (2) 153:25;154:5

flight (2) 153:25;154:4

fly (1) 191:25

FMLA (2) 150:8,10

focus (5) 75:18;89:25;

 92:25;112:8;199:18

focused (3) 87:22;

 91:24;188:9

folks (1) 177:13

follow (3) 43:23;186:9;

 215:3

following (5) 19:16;

 60:7;155:14,17;156:5

follows (3) 5:12;101:12,

 20

forcing (1) 160:1

forgot (1) 163:5

form (104) 17:16;24:6;

 26:4;30:10,19;32:16;

 37:13;39:4;45:24;46:7;

 53:10,16;54:1,10,21;

 55:3,8;57:4,14,18;

 58:3;59:13;60:17;61:1,

 8;62:21;63:7;64:10,20;

 69:5;71:19,24;72:7,25;

 73:8,14;74:24;75:2;

 80:9;81:8;82:16;83:20;

 84:12;85:7;86:1;87:13,

 19,24;88:3,16;89:15;

 91:3;93:7,18;94:7,14;

 95:19;96:5;97:18;

 98:11;99:2;100:6,8;

 101:16,21;103:9;

 109:20;110:11;111:1,

 10,19;117:14;118:15;

 130:6,17,22;132:9,16;

 133:4;134:24;135:12;

 136:22;140:20;141:3;

 144:1;146:13;149:9;

 151:6,13;152:22;

 156:21;157:2,9,16,21;

 160:5,13;162:20;

 169:20;180:12;183:3,

 20;193:1,2

formal (1) 15:3

former (1) 7:2

formerly (1) 5:20

forms (1) 194:7

forward (6) 39:8;78:4,

 25;208:3;211:3,10

found (11) 121:12;

 126:14,20,21;127:4,20,

 21,23,25;128:8;186:7

foundation (25) 30:20;

 36:8;37:4,14,21;38:8;

 56:15;67:11,20;68:20;

 76:21;78:11;79:2;

 86:12;148:13;169:20;

 170:18;196:7,15,25;

 197:8;200:21;203:4;

 209:24;213:18

four (9) 20:25;22:14;

 34:6;41:8;44:9;46:12;

 106:21;112:4;213:12

fourth (2) 81:18;133:25

FOX (1) 174:12

Frank (1) 190:1

free (1) 147:3

frequently (8) 34:3;

 39:16,19;64:24;

 114:18;137:9,11;

 202:19

friction (1) 134:23

front (7) 171:20;

 173:13;184:15;186:16,

 16;188:10,22

full (2) 72:13;152:24

function (1) 30:24

functional (1) 75:23

functions (9) 27:16;

 63:23;64:6;167:11,15;

 169:10;170:4,13;

 211:14

future (1) 27:10

G

gain (1) 75:16

gave (9) 80:24;82:4;

 100:10;101:23;102:15,

 18;127:11;137:1;

 165:13

general (50) 6:6;10:5;

 13:25;14:9;21:22,23,

 25;22:2,19,24;28:12,

 14;29:4,5,14,16;30:4,

 17;35:25;36:1,10,11,

 19;37:12;38:3,6,20,23;

 54:25;56:4;57:1;113:7;

 114:8,8;116:14;

 177:16;182:3,4;

 187:17;188:7;192:20;

 193:3,17;194:2,8;

 196:20,23;198:5;

 199:16;213:2

generalist (68) 18:1;

 23:2,5,19,24;25:14;

 26:13;27:1;28:10,22;

 31:2;32:10,20;33:15,

 17,19;34:10,20,24;

 35:16,20;36:2,6,15;

 37:1;40:12;55:21;56:6,

 8,18;58:21;61:23;

 63:22;68:10,18;70:3,

 12;71:18;72:5;81:12;

 102:24;105:22;106:20,

 22;108:22;110:10;

 111:7;116:3,10,16,19;

 117:11;118:14;129:17;

 130:5;133:7;140:10;

 142:13,15,20;165:9;

 166:25;167:18,22;

 168:4,7;170:14;182:13

generalists (66) 16:24;

 18:2;20:2;24:5,12,18;

 25:2,25;26:5,10;27:17;

 29:24;35:1;40:1,7;

 59:8,18,23;60:3,4,6,12,

 12,23;61:11,20,25;

 62:14;64:2,13;65:14,

 16;66:1,3,4,5,14,18,23;

 67:3,9,18;68:1;69:12;

 70:8;74:7,11,12;75:1;

 76:19;77:4;78:15;

 89:10;130:16;132:8;

 133:2;138:1;200:4,17;

 201:1,4;210:14;211:2,

 9;212:12;213:15

generalist's (2) 136:12,

 14

generalizing (1) 66:4

generally (10) 16:1;

 30:8;49:25;64:4;79:25;

 117:13;132:2;139:16;

 145:18;187:7

Genetic (1) 195:17

geographically (1)

 107:17

geography (1) 143:11

George (2) 206:17,20

Gibson (1) 131:19

given (3) 6:1;92:18;

 94:10

giving (1) 129:16

GK (8) 74:22;77:16;

 89:17,21;90:2;92:10,

 14;199:8

goal (4) 75:18;76:2;

 99:21;210:23

goals (4) 80:13;96:19;

 199:16;200:13

goes (2) 76:1;147:22

Gomez (1) 190:1

Good (11) 5:15,16;

 20:23;72:15;101:3;

 104:23;174:15;178:20;

 183:16;184:11;212:6

goodness (1) 7:6

GP (2) 97:17;102:12

grab (1) 40:17

Graczyk (2) 84:21;

 131:11

graduate (2) 12:11,21

granted (1) 159:8

granting (1) 159:10

granular (1) 48:15

great (3) 108:2;122:21;

 190:2

Greg (1) 131:19

grid (1) 86:6

ground (1) 8:21

group (11) 79:15;85:1;

 92:17;138:1;148:15,

 17,20,22,24;188:11;

 211:6

groups (1) 10:6

guess (6) 53:17;

 111:23;128:17;168:11;

 178:3;189:3

guessing (1) 107:24

guide (1) 136:8

guys (2) 143:17;183:15

H

half (1) 121:15

hallway (1) 187:19

Hammond (4) 189:11,

 13,14;209:4

hand (1) 40:22

handed (6) 112:1;

 144:7;149:18;164:20;

 165:15;207:6

handing (3) 118:25;

 119:7;179:19

handle (1) 149:5

handled (2) 148:9,20

handling (1) 151:20

hands (1) 75:21

handwriting (1) 112:9

handwritten (2) 119:4;

 121:3

happen (3) 13:21;

 126:11;143:13

happened (6) 28:17;

 31:9;38:6,9;125:20;

 209:14

happening (2) 73:3;

 197:17

happy (4) 63:5;64:6;

 118:6;189:24

hard (2) 123:4;212:5

harsh (1) 100:2

hate (1) 114:3

hated (4) 115:10,15,24;

 117:22

Hazard (1) 195:24

head (1) 206:21

heading (6) 76:8;

 77:24;85:19;99:5;

 169:6;192:21

headings (2) 92:11;

 104:25

headway (1) 182:19

health (16) 144:20,25;

 145:3,9,17,19,24;

 146:1;147:14,19;

 180:8;182:17;183:12;

 185:2,3;195:21

hear (4) 30:3;52:8;

 60:11;174:2

heard (7) 60:10;84:10;

 116:8,11,13;135:10;

 179:12

hearing (8) 60:16,22;

 118:10;133:3;135:21;

 174:21;175:1,12

Heavens (1) 201:6

heavy (1) 70:2

held (5) 29:8,12;

 159:20,23;160:22

help (10) 40:8;76:2;

 89:19;99:15;136:6,7,8;

 153:4;179:2;190:4

helpful (2) 91:18;178:9

helping (2) 132:22;

 185:16

Herrick (1) 4:16

herself (13) 82:25;

 86:24;93:4,17;94:22;

 96:24;98:3;100:5;

 101:15;102:7,18;

 103:6,17

hey (3) 73:6;136:10,15

Hi (1) 189:17

higher (2) 23:8;132:18

high-potential (1) 79:17

hire (1) 209:20

hired (2) 10:15;29:7

history (1) 108:6

hold (2) 10:17;174:23

Honestly (13) 24:14;

 50:20;121:22;129:24;

 137:19;147:20;163:23;

 164:13,16;179:6;

 182:5;186:13;207:1

hope (1) 75:16

hopeful (1) 215:12

hosting (1) 139:22

hour (1) 159:12

hours (13) 69:20;

 158:15;159:1,16;

 160:1,11,15,24;161:1,

 3,7,12;162:1

house (1) 126:2

housed (1) 38:16

HR (185) 10:5,20,20;

 11:18;12:6,25;13:3,17;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(5) find - HR

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 397 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 14:3,9;15:8,16,22,24;

 16:4,11,12,15,20,24;

 17:3,6,6,9,13,21;18:1,

 2,11;20:2;22:21;23:2,

 5,8,17,19,24;24:5,12,

 18;25:2,9,14,25;26:5,

 10,13,25;27:3,8,17;

 28:8,9,10,13,15,22;

 29:3,10,20,24,25;30:6,

 16,22,23,24;31:2,2,6;

 32:10,19;33:15,16,19;

 34:10,20,24;35:1,16,

 20;36:2,5,15;37:1,19;

 38:2,25;39:1;40:1,7,

 12;47:3;56:6,8,18;

 58:21;59:8,18;60:7,23;

 61:10,11,19,23,25;

 62:1,2,20;63:22;64:2;

 66:14;67:9,18;68:10,

 18;70:3,8,12;71:18;

 72:5;75:1;77:4;81:11;

 105:17;107:22;110:10;

 111:7;116:4,10,18,22;

 117:10;118:14;129:17;

 130:4,16;132:8,19;

 133:2,7;136:12,14;

 140:10;142:13,15,20;

 155:1,1,12,14;165:9;

 166:25;167:18,22;

 168:4,7,25;170:14;

 182:13;199:16;200:4,

 8,14,17;201:1,4,24;

 210:14,15,21,24;211:2,

 9,13;212:6,6,12,15,15,

 19,22,25;213:9,15

HRR (2) 188:2;213:1

human (9) 9:21;10:3,

 16,19;12:15;13:23;

 14:19;15:6;18:22

HUND (2) 5:5,6

hundred (1) 213:5

hypothetically (2)

 96:18,19

I

idea (11) 35:23;52:9;

 125:21;154:14;161:11,

 19,25;164:16;194:12;

 196:18;202:12

identified (2) 78:15;

 83:3

identify (8) 4:22;79:16,

 17;82:23;119:3;

 149:20;164:22,23

immediate (1) 21:20

Immigration (1) 195:19

impact (2) 114:2;190:4

implying (1) 157:11

important (3) 108:8;

 178:17;185:2

Improvement (6) 109:1,

 6,8,15,19;110:1

inaccessibility (1) 178:1

inaccessible (3) 57:3;

 58:2,11

inaccurate (2) 173:2,8

include (3) 108:12;

 199:8;200:16

included (1) 85:1

includes (4) 58:18;

 88:12;194:23;198:5

including (4) 14:3;47:5;

 116:1;137:23

income (3) 90:10,25;

 195:3

incomplete (1) 90:8

Incorporated (2) 11:8,

 12

increased (1) 189:25

indicated (2) 41:13;

 101:9

indicating (7) 81:5;

 85:2;91:13;167:1;

 171:18;203:20;204:1

individual (5) 94:19;

 120:18;123:23;196:9;

 204:15

industrial (1) 12:15

ineffective (1) 52:5

inform (1) 191:22

information (20) 42:13,

 15,16;43:12;45:19,23;

 47:10;48:16,20;

 120:19;122:17,23,24;

 123:15;129:20;145:11;

 180:17;181:16;195:18;

 198:6

informed (4) 191:19;

 197:13;198:13,20

Infrequently (1) 137:10

initially (1) 214:18

input (2) 24:2;193:6

inquires (1) 44:12

inquiry (2) 49:22;

 196:16

insert (1) 82:25

insight (1) 163:20

instance (2) 99:22;

 129:19

instances (1) 122:12

instead (5) 16:24;56:2;

 63:19;84:8;212:1

instruct (2) 43:15;48:14

instructing (2) 43:19;

 48:12

instructions (1) 43:24

intent (1) 155:6

interact (1) 138:5

interacting (1) 186:21

intern (2) 11:14,16

internal (1) 78:13

into (19) 47:22;49:22;

 70:1;82:25;135:20;

 138:2;141:12;142:7,

 11;143:20;171:24;

 174:18;188:12;196:16;

 206:21;210:19;214:22;

 215:10,15

introduced (3) 23:3,6,

 19

introduction (1) 27:6

investigate (1) 141:20

investigation (2) 49:6;

 141:12

involve (1) 6:9

involved (28) 6:22,24;

 59:16;68:8,11,11,12;

 70:11,15;151:11,17,20;

 152:21;156:2,6,8;

 191:4;201:21;204:8,

 12,17;208:24;210:17;

 211:1,8,17,19,21

involvement (2) 208:20;

 210:13

irrelevant (1) 13:18

issue (4) 46:22;136:11;

 174:23;186:19

issues (9) 108:7;

 134:12;140:24;141:9,

 14;147:19;180:9,19;

 183:12

items (1) 20:17

J

Jacob (10) 52:16;

 55:12;56:3,9,12,24;

 62:17;63:4;64:24;

 84:10

Jake (14) 55:18;129:9,

 16;131:13,14;137:1,

 11;176:10,14;177:2;

 181:4;186:14;187:22;

 202:22

James (1) 8:5

Janelle (19) 19:22,24;

 39:17;77:19;78:21;

 79:10,11,13,20,24;

 80:11;81:5;106:23;

 107:19,21;108:10;

 110:8,24;129:21

Janelle's (4) 87:12;

 88:2,7,23

Jenny (1) 121:13

job (50) 9:25;10:4,14;

 23:5,6,20,24;24:2,12,

 18;28:6;34:14;72:5;

 73:7,23;105:16,17;

 114:3;115:10,15,24;

 116:2,3,4;117:18,22;

 136:5,6,12,14;165:5;

 166:21;167:11,14,17,

 25;168:6,17,20,24,25;

 169:1,5,10;170:3,13;

 185:8;190:2;200:3;

 208:2

jobs (2) 12:1;168:1

Joe (1) 4:17

Jude (8) 9:17,22;10:7,

 10,15;12:4;72:12,19

Julie (1) 129:6

July (17) 72:24;140:6;

 143:20;144:13,15,21;

 146:5,23;149:21,24;

 155:22;156:8;162:16;

 164:4;180:1;199:2;

 204:10

jumping (2) 84:9;

 178:25

June (24) 47:2;59:4,5,

 7,11;68:15;70:21,24;

 71:7,16;72:3;99:1;

 106:10;113:21;133:19,

 22;139:3,7,10;143:18;

 171:8;173:16;178:8;

 214:13

jurisdictions (1) 13:13

jury (2) 8:8,12

K

Kaela (22) 19:21,25;

 26:18,20;39:8;107:5,

 18;108:14;113:16,19;

 114:6,10,15;115:8;

 116:17;117:8;118:19;

 120:18;129:21;162:9,

 15,19

keep (2) 126:4,4

Kelly (1) 4:16

Kietzer (2) 149:3;

 156:20

kind (36) 17:1;27:5;

 69:20;82:25;107:3;

 114:8;116:22,23;

 117:3,4;122:3,5;126:4;

 128:1;130:8,11;135:4,

 19;136:1,6;137:24;

 141:17;144:1;145:22,

 24;178:14,22;182:18,

 21;185:16;188:8;

 199:15;200:9,12;

 209:13;210:21

kinda (1) 183:11

kitty (2) 187:17,18

knew (3) 107:10;

 181:12;186:22

knowing (3) 56:19;

 168:9;210:20

knowledge (8) 45:7,10;

 59:21;75:17;105:11;

 110:3;165:2;166:18

known (2) 5:20;80:7

knows (2) 49:10;

 186:17

Kristin (2) 5:2;121:13

K's (3) 32:5;41:18;

 109:17

L

LA (2) 107:3;139:21

labor (4) 62:9;107:9;

 194:25;195:14

lack (1) 130:10

laid (2) 18:12;106:20

language (2) 196:11,13

lapse (1) 13:19

larger (1) 16:10

last (19) 8:6;65:22;

 74:18,19;122:16,18;

 123:8;137:5;147:10;

 158:13;163:15,17;

 164:1,8;172:5;183:24;

 191:15;192:8;206:19

lasted (1) 43:7

late (20) 53:25;55:22;

 134:19,22,25;150:15;

 153:15,22;175:12,21,

 24;176:1,5;177:14,15,

 22;178:15,16;208:4;

 210:12

lately (1) 150:4

later (2) 126:1;147:6

Law (13) 4:20;12:17,

 19,20,23;13:1,4,5,7,16;

 15:2;108:1,6

lawsuit (5) 6:15;7:1,5;

 127:15;128:7

lawyers (1) 6:19

layoffs (1) 18:6

lead (2) 73:18,19

leaders (12) 15:21;

 25:17;75:15,16;83:11,

 18;84:5;85:24;89:11;

 136:8;175:4;212:24

leadership (26) 16:4;

 75:10,19;76:9;77:25;

 79:15;81:6,16,22;

 82:14,21;85:6;87:8,11;

 98:7,19,21;99:5,20;

 103:2;132:23;136:16;

 201:8,24;211:13;

 212:18

leading (2) 73:15;138:1

learn (2) 25:6;127:18

learned (2) 128:6;

 204:4

least (4) 111:3;149:1;

 158:15,25

leave (7) 12:3;125:23;

 128:19;150:11;177:9;

 195:12;204:7

leaves (1) 175:12

leaving (10) 53:25;

 134:19,22;135:1;

 175:21,24;176:2,5;

 177:15,22

led (3) 60:5;67:3;

 187:20

Ledbetter (1) 195:15

left (13) 39:25;42:25;

 50:22;51:4;125:25;

 128:11,12,14,18,22;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(6) HRR - left

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 398 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 167:19,23;200:15

lengthy (1) 146:19

Leonard (5) 4:3,20;5:3;

 6:21,23

Less (2) 137:11;181:6

letter (8) 144:11,18;

 146:23;147:9,10,18,22;

 149:25

level (2) 23:8;132:19

liaison (4) 78:3,23;

 79:24;88:7

license (1) 13:19

licensed (3) 13:5,7,15

light (1) 158:13

likely (4) 139:10;

 143:11;205:25;206:12

Lily (1) 195:14

limit (1) 213:8

limitation (1) 194:24

limited (1) 66:10

line (11) 45:3;122:16,

 18;164:7;173:18,18;

 174:19;183:8,9;186:5,

 7

line-by-line (1) 174:13

lines (3) 30:23;122:23;

 194:20

Linked (1) 51:9

list (7) 76:5;88:24;

 93:21,23;99:24;100:1;

 167:14

listed (6) 82:14;85:5;

 89:14;100:12;101:25;

 115:25

listen (1) 136:3

listened (2) 171:15;

 180:3

listening (3) 84:9;

 172:21;179:2

lists (1) 76:1

literally (1) 122:17

little (5) 8:20;65:9;

 69:23;108:1;123:4

located (6) 21:23;22:6;

 32:3;33:23;39:13;

 45:17

location (15) 16:25;

 17:4,7;18:16;33:25;

 52:12;62:10,25;175:4;

 176:15;187:14,25;

 188:1,10;205:19

locations (15) 14:15;

 17:23;18:3;20:10;

 23:10,16;32:22;33:14,

 20;34:23;55:1;61:22;

 62:8;111:9,11

location's (1) 92:18

logical (1) 107:17

long (9) 9:22;11:5;

 31:19;43:6,6;108:6;

 121:14;194:15;199:25

longer (6) 13:15;30:5;

 63:23;64:18;72:15;

 208:15

look (37) 40:24;41:8;

 51:21;74:4,9,16;76:13;

 77:22;82:23;85:15;

 89:6;101:9;104:9;

 105:5;112:6;119:2;

 121:20,23;126:6,18;

 133:24;138:15;147:1;

 154:17;158:14;162:12;

 163:3;166:14;169:9;

 183:7;186:4;192:17;

 194:14;196:8;198:24;

 210:2;211:7

looked (6) 16:9,13;

 84:3;103:16;108:9;

 114:12

looking (19) 12:5;

 15:21;42:3;45:19;46:9;

 51:20,22;60:1;73:7,23;

 80:22;81:15;90:1;

 114:24;121:16;126:16;

 164:17;165:16;172:8

looks (3) 121:4;139:21;

 192:25

Loren (1) 131:15

Los (6) 33:6;84:19,20;

 108:12;175:5;206:4

losing (1) 185:8

lot (7) 46:5;73:15;80:3;

 132:2;178:13;183:24;

 185:15

Lots (3) 14:8;41:6;

 200:11

Lotus (2) 154:8,10

lunch (1) 106:7

M

ma'am (5) 9:14;112:1;

 123:15;149:18;171:6

Macy's (2) 11:12,13

main (2) 76:2;199:15

major (1) 12:15

making (10) 114:6,9;

 140:14;149:25;182:10;

 191:4,8;209:11;

 210:17;211:1

manage (19) 150:22;

 151:2,25;152:2,6,16;

 153:7,11;154:22;

 155:6,7;156:25;157:4,

 7,12;158:2,5,8;215:22

managed (4) 61:23,25;

 155:3;203:1

Management (4) 75:17;

 76:3;85:16;175:3

manager (46) 10:20;

 21:7,10,25;22:2;28:12;

 29:4,5,14,16;35:25;

 36:1,10,11;38:4,20,23,

 23;43:5;53:8;54:25;

 55:1;56:4;58:1;64:9;

 78:3,24;80:14;81:25;

 83:15;86:21;92:19;

 113:6;136:10,13;

 151:16,16,22;181:14;

 187:19;188:7,8;

 189:16;205:5,16;

 207:22

managers (90) 21:12,

 13,14,15,19,21,22,23;

 22:20,20,24,25;25:12,

 13,19,20,22,23,24;

 26:2,12,24;27:15;

 28:14;30:4,18;36:19,

 19;47:6;48:7;52:2,4,9,

 11,18,21,25;53:23;

 54:12;55:24;56:25;

 57:1,8,13;61:5;63:1,6;

 65:6;76:2;84:2,18,19;

 85:4;114:2;115:2;

 116:5,8,12,14;117:9;

 118:13,20;129:23;

 130:14,20;132:7;

 133:3;134:12,23;

 135:11,22;136:20;

 137:1;176:3,17;

 177:20;179:12;181:5;

 187:4;188:12;200:19,

 24;201:5;202:23;

 204:21;205:3,14,21;

 206:8,16

manager's (3) 128:24;

 187:11,17

managing (4) 62:11;

 153:4;156:6,10

many (34) 6:4;10:7;

 14:18;18:9;19:7;20:4,

 21;21:1,4;22:13;34:5;

 35:1,4;42:7;50:5;

 52:15;70:5;110:7,7,22;

 125:13,13;137:16;

 148:24;151:23;155:3;

 175:25;193:13,24;

 211:9;213:10,13,14,15

Marie (32) 43:3,4;

 45:12,14,17;48:5;

 50:14,17,24;127:8,25;

 149:3,21;150:13;

 152:18,25;153:4;

 156:19;157:20,23,25;

 158:10;160:7;161:6,

 10,20;204:15,17;207:8,

 12,13;209:15

Marie's (3) 152:3;

 153:6;161:11

mark (3) 44:1;111:22;

 179:15

marked (19) 40:20,23;

 111:24;112:2;118:23;

 119:1;144:5,7;149:16,

 19;164:18,20;165:23;

 171:1;179:17,20;

 188:17;207:4,7

master (1) 17:1

Master's (1) 12:24

matched (1) 196:10

materials (8) 11:10;

 24:5,11,17,22;82:24;

 83:1;103:3

matrix (1) 31:10

matter (2) 4:11;178:17

max (1) 213:4

May (31) 4:2,15;18:8;

 24:1;28:11,18,20;

 35:25;46:21;48:16,16;

 50:10;53:5,18,18;55:9;

 79:22;85:13;116:13;

 124:21,25;125:2,5,25;

 155:23;165:9;166:24;

 172:22;205:1,10;

 206:14

maybe (13) 8:7;38:18;

 65:1;91:1;106:2,3;

 119:5;149:1;166:4;

 185:2;205:11;209:4;

 213:3

McNaul (13) 19:5;

 59:20;66:22;67:1,25;

 131:9;191:9,21;

 197:11;201:7,21;

 204:8;211:20

mean (27) 14:8;39:22;

 40:9;41:9;51:6;61:4;

 73:18;78:23;88:10;

 90:15;92:6,13;110:13,

 14;121:17,21;125:9;

 130:8;141:18;152:14;

 164:17;175:16;186:1,

 13;199:19,22;201:14

Meaning (2) 28:4;

 147:25

means (6) 92:23;

 158:19;161:1;185:18;

 199:12;200:11

meant (5) 79:5,14,20;

 141:17;200:14

measures (1) 90:11

Medical (27) 9:17,23;

 10:8,10,15;12:4;72:12,

 19;122:17,23;123:7;

 140:24;141:9,14;

 145:23;146:7,10;

 150:10,11;153:24;

 169:16;170:1,12;

 180:19;181:7,12;

 195:12

meet (5) 26:23;89:3;

 93:23;115:1;121:14

Meeting (17) 81:25;

 82:12;83:10,17;85:24;

 88:13;93:25;98:23;

 108:24;113:5,10,12;

 138:8;180:25;192:11,

 23;197:12

meetings (4) 55:22;

 177:14,22;180:24

member (1) 189:14

memorandum (2)

 190:10,15

memorized (1) 121:8

Menard's (1) 11:8

mental (3) 146:25;

 147:13,19

mentally (1) 147:12

mentioned (2) 102:19;

 204:16

mentor (1) 75:21

met (5) 16:3;45:9;

 86:22;103:21;121:13

mic (1) 173:21

Michael (4) 189:10,13,

 14;209:3

microphone (1) 173:25

middle (6) 46:19;58:15;

 77:23;167:9;169:10;

 207:18

midyear (1) 105:12

Mid-year (1) 105:8

might (12) 35:24;77:12;

 80:4;81:4;95:24;

 102:24;129:20;136:17;

 142:16;183:13,15;

 187:4

Mildenberger (1) 4:17

MILLS (223) 4:24,24,

 25;5:14;8:3,11,16;

 17:18,24;24:8,10;26:7;

 30:14,25;31:25;32:18;

 36:12;37:7,17,22;

 38:11,19;39:6;40:18,

 21;41:16;42:21;43:22;

 44:1,3,17,25;46:3,10,

 17;47:17,25;48:19;

 49:2,8,15;50:4,18;

 51:10,19;53:13,20;

 54:6,18,23;55:6,10;

 56:16;57:10,16,22;

 58:7;59:15;60:21;61:2,

 17;63:3,10,20;64:16,

 23;67:12,22;68:5,24;

 69:6;70:6,23;71:6,22;

 72:2,18;73:4,11,17,24;

 75:4;77:1;78:17;79:7;

 80:10;81:13;82:18;

 83:24;84:14;85:10;

 86:4,16;87:16,21,25;

 88:6,18;91:19,22;

 93:10;94:1,9,18;95:2,

 23;96:9,15;97:6,23;

 98:16;99:3,11;100:13,

 18;101:3;102:3;

 103:12;104:8;105:25;

 106:5;109:24;110:14,

 16;111:5,13,20,22,25;

 117:16;118:18,24;

 119:8,13,17;120:21,24;

 121:1;122:2,14,19;

 123:1,11,14;124:6,12;

 127:5;130:12,19,24;

 132:13,25;133:5,10;

 135:9,16;136:24;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(7) lengthy - MILLS

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 399 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 140:25;141:11,21;

 142:5,24;144:2,6;

 146:15,21;148:18;

 149:11,17;151:9,14;

 153:2,3;156:24;157:5,

 13,19,24;160:9,16;

 161:18;162:7,22;

 164:19;165:15,21;

 166:1,5,8,11,13;

 169:22;170:10,20;

 171:5;172:24;173:12,

 21;174:14,17;177:25;

 178:6;179:15,18;

 180:13;183:6;184:7;

 188:21;194:6,13;

 196:12,19;197:5,10;

 200:23;203:6;204:3;

 207:5;210:1,10;

 213:21;214:2;215:17

mind (1) 165:17

mind-set (1) 117:3

mine (1) 165:10

Minneapolis (6) 4:4,21;

 9:18;131:21,25;192:4

Minnesota (15) 4:4,21;

 6:14;12:10,25;13:9,16;

 14:15;18:20;22:7;

 33:23;39:9;45:18;

 106:21,22

minor (1) 93:24

minute (1) 112:6

minutes (5) 92:1;

 178:15,15,16;210:2

mischaracterizes (7)

 94:15;96:6;99:8;

 103:24;105:24;151:7;

 152:23

mischaracterizing (1)

 141:4

miss (3) 113:25;

 146:10;173:9

missed (1) 154:3

misses (1) 99:22

missing (11) 46:24;

 54:19;90:16;92:5,8,9;

 95:4;150:14;153:15,

 22;177:22

misstating (1) 99:13

Mitch (6) 137:3,7,13;

 138:12;176:12;177:4

Mitchell (1) 12:20

Mitch's (1) 137:5

model (8) 15:18;16:21;

 75:15;83:12,19,22;

 211:7;212:22

models (1) 132:22

modified (1) 164:8

moment (1) 214:24

moments (1) 151:10

money (1) 8:12

monitor (15) 4:7;51:13,

 18;100:22;101:1;

 120:6,10;141:24;

 142:4;170:23;171:3;

 174:4;188:19;210:4,8

month (1) 65:2

monthly (1) 85:24

months (3) 11:6;42:7;

 127:19

more (49) 16:21;30:21;

 39:16,19;46:5;55:25;

 61:9;63:17;65:9;68:7,

 22;69:18,23;76:3;

 87:17,22;88:1,9,10,12,

 13;91:15;102:20;

 108:21;111:4,9,16;

 129:18,20;132:19;

 135:1,20;137:18;

 149:1;155:7;163:20;

 172:16;178:4;179:1,3;

 180:17;183:24;188:11;

 211:6,24;212:7,7;

 213:5,22

morning (4) 5:15,16;

 110:18;213:11

morning' (1) 158:19

most (2) 14:21;201:12

move (6) 111:21;

 120:24;132:20;186:14;

 187:22;208:3

moved (3) 176:15,24;

 187:22

moving (1) 176:19

much (12) 8:12;39:19;

 46:24;54:19;62:11;

 107:13;114:19;133:12;

 162:16;197:22;213:2;

 214:3

multiple (10) 17:14,23;

 18:3;25:17;102:14;

 118:2;131:8;148:23;

 155:5;176:7

must (1) 199:17

Myself (6) 59:20;70:13;

 130:1;157:4,11;191:8

N

name (19) 4:16;5:17,

 22;7:25;8:4,6;35:7;

 57:25;65:20,22;123:8,

 8,10;129:6;137:5;

 139:19;206:19,24,25

named (1) 52:16

names (10) 52:15,15,

 20;56:25;57:7,9;58:6;

 149:2;163:23;206:15

National (1) 194:25

near (2) 188:6,7

necessarily (13) 17:9;

 25:22;63:1;88:10;

 102:21;108:24;115:16;

 135:23;141:15;143:15;

 159:3,19;184:19

necessary (1) 78:5

need (13) 9:6;51:10;

 63:22;73:7;91:14;

 100:18;115:22;126:5,

 10;138:19;153:11;

 159:12;165:24

needed (10) 62:10;

 70:5;73:22;101:9;

 107:15;132:18;159:14;

 160:24;177:11;211:10

needing (1) 69:21

needle (1) 132:20

needs (5) 16:7;79:18;

 115:3,5;178:22

negative (1) 144:1

negotiations (1) 14:4

neighbor (1) 107:25

new (15) 15:16,24;

 25:5;55:21;62:6,7;

 75:16;77:25;78:14;

 82:23;118:20;125:2;

 138:2;158:10;212:21

next (9) 85:15;150:17,

 21;158:12;164:7;

 167:3;187:19;190:9;

 192:17

nice (1) 70:2

night (2) 172:5;183:24

Nikki (4) 149:3;156:20;

 204:16,17

Nondiscrimination (1)

 195:18

none (1) 180:20

noon (1) 158:20

North (1) 14:16

Northern (5) 106:23,24;

 107:20;110:8,23

Northwest (31) 14:12,

 14;15:7;18:14;20:5,22;

 21:4;22:11,16;35:2;

 40:12;58:20,25;59:9,

 19;66:6,11;67:13,18;

 68:1,22;74:13,14;

 111:8;170:15;189:19,

 20;212:8,12,18;213:20

Note (2) 114:13;123:5

notebook (8) 121:11;

 125:1,3,17;127:12,20,

 21,24

notebooks (4) 125:14,

 20;126:9;128:12

noted (1) 50:2

notes (43) 42:3;53:5;

 85:13;112:13,15,18,20,

 22;113:1,3,4,6;119:4;

 121:3,12,16,18;123:20;

 124:16,20,21;125:4,13,

 14;126:3,4;127:4,10;

 129:13;130:1;133:16;

 134:20;139:17,21,22;

 147:2;154:1,8,10;

 172:11;178:11;179:9;

 210:2

notice (2) 153:16,23

Notification (1) 195:13

notified (2) 127:3,7

notify (1) 127:6

NPS (1) 90:25

nuances (1) 145:14

Number (16) 4:10;

 20:24;50:11;107:22;

 114:13;124:13;133:13;

 138:16;144:8;153:14;

 160:23;189:8,9;

 192:17;193:14;194:14

numbered (10) 112:5;

 113:14,24;120:17;

 123:16;139:14;189:1,

 6;190:9;198:24

numbers (1) 123:3

O

object (15) 43:11;

 44:12;46:7,13;47:12,

 15;48:9;49:21;93:6;

 94:6;97:1;103:23;

 135:12;143:25;183:19

Objection (140) 8:1,10,

 14;17:16;24:6;26:4;

 30:10,19;31:21;32:16;

 36:7;37:3,13,20;38:7,

 15;39:3;41:12;42:14;

 44:20;45:24;53:10,16;

 54:1,10,21;55:3,8;

 56:14;57:4,14,18;58:3;

 59:13;60:17;61:1,8;

 62:21;63:7,14;64:10,

 20;67:10,19;68:3,19;

 69:5,9;70:19;71:2,19,

 24;72:7,25;73:8,14;

 75:2;76:20;78:10;79:1;

 80:9;81:8;82:16;83:20;

 84:12;85:7;86:1,11;

 87:13,19,24;88:3,16;

 93:18;94:14,24;95:18;

 96:5,13;97:18;99:2;

 100:7;101:21;103:9;

 105:23;109:20;110:11;

 111:1,10,18;117:14;

 118:15;130:6,17,22;

 132:9,16;133:4,8;

 134:24;136:22;140:20;

 141:3;142:22;146:13,

 18;148:12;149:9,14;

 151:6,13;152:22;

 156:21;157:2,9,16,21;

 160:5,13;161:14;

 162:3,20;169:19,20;

 170:17;172:1;177:24;

 180:12;183:3;194:3,

 10;196:6,14,24;197:7;

 200:20;203:3,24;

 209:23;213:17

objections (4) 73:20;

 87:17;170:5;183:20

objective (15) 81:6;

 88:12,13,15,21,23;

 93:12,17,20;96:3;

 98:14,15,18;103:5,11

objectives (52) 76:17,

 18;77:5;82:13;86:23;

 87:4,5,9,11;89:7,12,14,

 17,22;90:3,6,9,18,22;

 92:14;93:4,16;94:4,13,

 21;95:4,11,13,14,17,

 21,24;96:2,11,22;

 97:16,21;98:2,9,10,25;

 100:5;101:15;102:6,

 17;103:6,16,21;104:2,

 6,10;105:3

observing (1) 34:14

obviously (2) 107:20;

 182:16

occasions (4) 102:14;

 114:15;118:3;145:10

Occupational (1)

 195:21

occur (3) 190:24;191:6;

 214:16

occurred (5) 42:23;

 172:23;187:1;204:25;

 210:12

October (1) 9:24

off (19) 18:12;51:12;

 100:21;102:21;119:20;

 120:5,8;141:23;154:6;

 156:19;159:6;170:20,

 22;174:3,6;188:14,16;

 210:3;214:1

offensive (1) 84:7

offer (6) 207:21;208:2,

 21,23;209:6,12

offered (2) 208:11,17

offhand (2) 6:20;24:23

office (27) 39:13;54:13;

 128:16,20;139:21;

 158:15;171:23;176:15,

 19,20,23;186:12,15,17;

 187:3,10,18,18,22,25;

 188:1,3,6,10;198:17,

 20;201:10

offices (1) 187:11

official (1) 31:9

offsite (1) 180:25

off-the-record (1)

 120:13

old (1) 173:5

Older (1) 195:6

onboarding (2) 61:25;

 62:6

Once (1) 6:5

one (57) 8:18,23;9:5;

 15:1;18:14;20:25;35:5;

 50:14;58:20;61:22;

 66:17;68:9;69:2;80:19;

 89:2,20;90:1;91:4;

 93:23;99:23;100:1;

 103:25;107:19;108:19;

 112:3;113:10;117:1;

 124:10;125:16;126:12;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(8) mind - one

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 400 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 133:24;135:13,15;

 137:18;138:17;139:18;

 147:6;149:4;155:23,

 25;156:25;161:22,25;

 165:14,19;168:15,16;

 175:20;179:16;186:15,

 16,17;197:16;200:1;

 205:7,11;213:23

one-on-one (10) 113:9,

 10,12,17;115:16;

 123:5;124:22;133:18;

 134:8,10

one-on-ones (1) 113:4

onerous (3) 88:1,5,10

ones (1) 88:1

ongoing (6) 60:18;

 61:3;79:25;145:22;

 153:10;184:22

only (9) 9:5,8;28:21;

 33:14;40:1,4;103:25;

 124:10;193:18

onsite (2) 34:14,21

Ontario (3) 33:8;206:1,

 16

open (1) 181:17

opened (1) 182:21

open-ended (2) 143:14,

 15

operating (2) 90:10,25

operations (1) 189:22

opinion (5) 79:4;161:6,

 10;211:22,23

opportunities (1)

 114:25

opportunity (4) 72:10,

 13;100:20;121:5

opposed (2) 210:14;

 212:8

option (1) 210:25

order (6) 102:8;121:20,

 24;124:10,17;179:7

org (1) 132:21

organization (11)

 11:18;15:22;16:4,7,

 14;27:8;158:4;189:15;

 199:16;201:24;213:9

organizational (3) 14:5;

 23:12;79:19

organizations (2)

 16:10;30:22

original (1) 208:3

originally (1) 91:6

others (9) 35:22;76:4;

 105:19;106:15;108:21;

 141:7;155:24;182:25;

 209:4

Otherwise (1) 9:3

out (34) 7:19;32:5,8;

 34:3;48:20;56:1;69:22;

 84:7;99:15;106:20;

 115:1;122:20;123:19;

 124:7;125:15;126:12;

 127:23;135:25;136:3;

 150:8;179:3;181:20,

 24;185:11,23;186:15,

 24;191:25;198:17,19;

 202:19;207:12,25;

 210:23

outlier (1) 108:13

out-of-office (1) 135:5

outside (3) 57:13;58:1,

 9

over (8) 8:21;30:6;

 121:11;127:22;128:21;

 142:12;169:13,23

overall (6) 60:1;69:16;

 87:1;95:14,21;102:15

overestimated (1) 70:4

overly (1) 100:2

oversaw (2) 201:13,14

overseen (1) 201:1

overstaffed (5) 58:20;

 59:1,8,18;60:6

overtures (1) 182:10

own (6) 16:13;77:5;

 94:13;98:8,10;212:17

P

packet (1) 91:20

page (45) 41:24;46:18,

 19;51:21;58:13,15;

 74:19,19,21;75:8;

 76:14;77:15,22,23;

 81:14,18,21;90:3;

 105:6;113:13;120:14;

 122:15,18,21;123:1,15;

 124:13;133:13;138:16;

 139:14;163:15;164:1;

 167:9;169:11;173:18;

 183:7;186:4;189:8,8;

 190:9;192:17;194:14,

 16,18;198:24

pages (11) 41:6,8;44:7,

 9;46:12;77:13;112:4,8;

 122:4;172:4;189:5

paper (1) 117:2

paragraph (21) 51:23;

 58:15;113:23;115:25;

 120:17;122:16,22,25;

 123:16,24;133:25;

 138:17;147:11;150:2,

 17,21;153:13;164:2;

 177:18;194:15,17

Pardon (2) 11:15;41:3

PARKER (202) 5:2,2;

 8:1,10,14;17:16;24:6;

 26:4;30:10,19;31:21;

 32:16;36:7;37:3,13,20;

 38:7,15;39:3;40:16;

 41:12;42:14;43:11,19;

 44:11,20;45:24;46:7,

 13;47:12,21;48:8,25;

 49:5,9,20;50:9;53:10,

 16;54:1,10,21;55:3,8;

 56:14;57:4,14,18;58:3;

 59:13;60:17;61:1,8;

 62:21;63:7,14;64:10,

 20;67:10,19;68:3,19;

 69:5,9;70:19;71:2,19,

 24;72:7,25;73:8,14;

 75:2;76:20;78:10;79:1;

 80:9;81:8;82:16;83:20;

 84:12;85:7;86:1,11;

 87:13,19,24;88:3,16;

 91:14;93:6,18;94:6,14,

 24;95:18;96:5,13,25;

 97:18;98:11;99:2,7;

 100:7;101:17,21;

 103:9,23;105:23;

 106:3;109:20;110:11;

 111:1,10,18;117:14;

 118:15;119:5,10,15,20;

 120:1,12,23;121:25;

 122:9,15,21;123:3,13;

 124:8;126:25;130:6,

 17,22;132:9,16;133:4,

 8;134:24;135:12;

 136:22;140:20;141:3;

 142:22;143:25;146:13,

 18;148:12;149:9,14;

 151:6,13;152:22;

 156:21;157:2,9,16,21;

 160:5,13;161:14;

 162:3,20;165:14,19,24;

 166:3,7,10;169:19;

 170:5,17;171:24;

 173:4,9,19,22;174:10,

 16;177:24;178:2;

 180:12;183:3,19;

 194:3,10;196:6,14,24;

 197:2,7;200:20;203:3,

 20,23;209:23;213:17,

 25;214:4,7;215:19

part (21) 23:15,25;

 27:3;31:12;50:2;65:15;

 77:11;90:23;91:1;

 95:14,21;103:25;

 163:8;168:20;169:7;

 182:12;201:8,23;

 202:12;203:12;207:13

participate (1) 138:4

particular (7) 105:21;

 114:14;129:10;176:8;

 191:10,11;200:13

partner (4) 10:3;

 132:19;138:8;178:20

partnering (5) 23:9,13;

 56:2;132:21;178:20

partners (4) 16:5;134:1,

 5;212:19

partners/ (1) 134:1

partnership (1) 135:19

party (1) 6:15

pass (1) 156:19

past (5) 23:9;117:7;

 127:19;130:9;175:8

Paul (9) 9:19;22:7,9;

 39:15;65:10;107:5,18;

 131:8;192:5

Pay (2) 195:7,15

payroll (1) 62:3

Pelham (12) 19:1;

 59:20;65:19,22;68:11;

 70:13;191:9;201:19;

 202:2;203:9,15;204:12

pelvic (2) 145:19,24

penalize (1) 99:24

pending (2) 6:13;9:9

people (19) 10:7;

 14:18;19:7;40:1,4;

 69:17;84:6;109:7;

 118:3,10;132:2;

 140:16,18,22;174:22;

 176:23;185:15;186:11;

 211:16

per (3) 45:2;134:20;

 211:22

perceive (3) 134:2,5;

 186:18

perceived (5) 52:4;

 134:15;180:8;181:6;

 183:14

perceiving (1) 141:8

percent (2) 50:15;

 124:11

perception (5) 134:14,

 15,18;178:16;187:5

perceptions (5) 174:20;

 175:19,20;178:13,13

perfect (1) 100:19

perform (8) 62:3;74:22;

 77:16;92:10,14;97:17;

 102:12;199:8

performance (59)

 34:14;35:12,15,17,19;

 36:6,14,17;37:2,11,18;

 40:11,13;46:22;47:5;

 55:13;56:12;74:22,25;

 75:17;77:16;86:7,10;

 90:2,22;91:3,6,24;93:3,

 11;94:5,10,20;97:9,14,

 21;100:4;101:14;

 102:7,8,20;104:7;

 105:6;108:22,23,25;

 109:6,8,12,15,18,22;

 110:1;150:3;200:19;

 202:15;204:22;205:15,

 22

performed (1) 208:7

performing (6) 63:23;

 64:7;109:7;169:18;

 170:3,13

perhaps (1) 65:9

perilously (1) 48:9

period (11) 19:2;21:18;

 29:12;36:22;38:1;

 39:24;146:19;147:14;

 160:15;202:25;214:14

periods (1) 28:25

permanent (8) 207:21;

 208:2,11,18,21;209:6,

 12,20

permanently (1) 142:16

person (12) 7:24;

 16:25;18:16;23:10;

 57:20;96:20;102:23;

 137:3;186:21;187:6;

 212:17,19

personally (3) 98:4;

 201:25;212:11

personnel (2) 120:19;

 154:2

person's (2) 136:13;

 187:3

perspective (3) 16:11;

 22:21;23:17

pertaining (1) 167:22

Perusing (5) 92:3;

 112:7;122:8;166:9;

 169:21

Phoenix (43) 32:3,5,15;

 33:25;34:21;36:19;

 52:11;53:1,24;57:8,13;

 58:1,9;84:18;85:3,8;

 107:2;108:13,14;

 110:25;129:9;134:23;

 135:7,11,22;137:2;

 175:4;176:4,16;

 177:13,20;179:12;

 180:8,18;181:5;

 182:19;187:14;191:24,

 25;192:3,16;202:20,23

phone (8) 51:7;61:24;

 65:3;134:13,16;175:9,

 10;182:7

photocopy (1) 104:23

physical (1) 205:8

physically (3) 34:13;

 38:10;176:22

pick (5) 108:11,14;

 136:2;173:20,25

picked (1) 173:24

picking (2) 84:7;178:22

picture (1) 23:16

pieces (1) 48:16

place (7) 4:20;83:2;

 84:6;86:6;115:6;

 187:23;192:15

placed (2) 109:8;

 188:22

Plaintiff (3) 4:25;7:25;

 8:4

Plan (3) 109:9;110:1;

 151:24

Pland (1) 131:1

plant (25) 17:7,10;

 20:15,17,25;21:7,13,

 19,21,25;22:24;25:12,

 19,20,22;29:17;32:7,9;

 107:3,3;110:19;

 111:14;187:20;188:7;

 192:16

plants (20) 17:14;20:4,

 8,11;21:24;22:20;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(9) one-on-one - plants

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 401 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 26:24;65:6;69:17;

 106:21,24;107:14,14,

 20;110:7,12,22;111:2;

 212:7,16

play (5) 23:23;165:1;

 166:18;168:18,20

played (1) 174:9

playing (1) 55:19

please (5) 4:22;5:8,17;

 100:14;102:1

plenty (1) 70:2

pm (13) 101:2;120:7,

 11;141:25;142:4;

 170:24;171:4;174:5,8;

 188:15,20;210:5,9

point (28) 14:22;15:5;

 17:12,17;22:23;28:12,

 14;29:8,22;36:2;54:5;

 55:25;56:11;66:8,8,17;

 127:14;129:10;156:1;

 168:14;187:21;190:19,

 20;201:16,19;202:10;

 209:12,13

policy (1) 109:18

Polygraph (1) 195:25

poor (1) 109:22

portion (7) 44:6,9,19;

 52:1;64:13;79:8;

 194:20

posed (1) 161:22

position (51) 23:2,18,

 21;29:9,13;41:19;

 59:12;69:4;70:12,18;

 71:1,9,17;72:4,14,21,

 21,23;105:21;106:11,

 17;108:18;128:21,24;

 129:3;139:5,7;142:12;

 143:5,9,18;167:18;

 197:25;198:6,6,13,22;

 201:22;203:13,18;

 207:14;208:12,14,18,

 21;209:18,21;214:11,

 13,19;215:6

positions (6) 10:17;

 68:10,18;193:18,21;

 196:4

positive (1) 190:4

possession (2) 125:9,

 18

possibility (1) 142:16

possible (20) 24:20,24;

 28:18,20;30:12;35:21;

 44:18;53:12;57:15;

 82:6,8;119:22;128:11,

 13;129:13;168:6,10,

 11;202:17,18

post-implementation (1)

 116:23

posting (1) 169:5

potential (1) 86:8

potentially (8) 7:7;

 15:21;20:25;69:20;

 72:15;92:12;96:21;

 209:14

practice (4) 13:5,7,16,

 17

precisely (1) 49:11

preferable (1) 172:17

pre-HR (1) 169:1

preparation (6) 49:14,

 19;133:18;165:2;

 168:20;193:6

prepare (4) 56:12;

 121:9;190:15;193:5

prepared (4) 91:7;

 167:2;172:18;208:1

preparing (2) 23:23;

 134:9

Prescott (2) 32:25;

 205:13

present (5) 5:5;176:22;

 192:10;193:9,20

presented (2) 192:22,

 25

president (5) 15:16,24;

 19:6;22:4,5

presidents (1) 22:8

Presumably (1) 208:19

pretty (6) 62:11;107:13;

 114:19;196:11,11;

 214:8

prevented (3) 169:17;

 170:2,12

previous (1) 194:17

previously (3) 65:12;

 156:6;158:17

primary (1) 108:20

principal (1) 179:10

Prior (29) 17:2;27:20,

 24,24;28:7;36:5,25;

 56:17;59:2;64:11;

 94:15;96:6;99:9,10;

 105:24;121:6;125:4;

 139:10;141:4;147:17;

 152:23;155:1,11;

 167:18,22;168:7;

 188:2;190:25;203:2

privilege (3) 43:14,14;

 196:17

privileged (9) 42:17;

 44:13;46:15;47:15,23;

 48:11,17;49:7,22

Probably (18) 13:22;

 14:9;45:21;65:9;70:4;

 121:15;125:21;126:1;

 135:14;168:15;173:7;

 179:6;193:14,25;

 199:24;207:16;209:1,3

problem (1) 40:18

problems (5) 136:6;

 144:20,25;145:4;146:2

process (13) 27:4;60:1;

 62:5;65:15;69:7;76:23;

 109:16;155:11;156:23;

 158:10;203:12;204:1;

 207:14

processes (2) 20:17;

 62:12

processing (1) 62:3

produce (1) 90:13

product (4) 43:14;49:1,

 3,6

products (1) 20:19

program (5) 61:23,24;

 109:1,6,19

programs (3) 62:12;

 75:20;82:23

progress (1) 140:14

project (6) 14:6;15:12,

 19;16:3;23:25;210:20

projects (2) 23:12;

 67:24

prompt (1) 113:2

proper (1) 49:11

proposing (1) 161:2

protect (7) 199:17,18,

 19,22;200:5,6,10

protected (1) 43:13

protecting (4) 199:10,

 13,14;200:16

Protection (4) 195:6,9,

 22,25

Provide (6) 10:5;24:4,

 11;78:5;105:4;178:4

provided (2) 24:2,17

provider (1) 147:14

providing (1) 47:5

public (1) 119:24

published (1) 119:25

purportedly (1) 175:1

purpose (4) 159:2,18;

 191:25;192:2

purposes (1) 23:11

push (1) 212:11

pushed (4) 181:24;

 185:11,22;212:5

put (11) 63:5;64:8;

 94:3;96:11;109:17,18,

 25;171:20,25;173:13;

 180:23

puts (2) 88:14;93:21

putting (2) 84:6;88:24

Q

quality (3) 92:5;104:23;

 174:1

quick (2) 119:2,19

quite (1) 7:8

quote (20) 51:25;52:5;

 58:18;75:14;76:1;78:2;

 113:25;138:18;144:18,

 23;147:11;150:3,21;

 151:24;152:5;158:13;

 183:10;186:9;194:22;

 199:7

quote-unquote (3)

 157:14;199:22;200:5

R

RACHAEL (8) 4:1,10;

 5:9,19,20;47:3;91:14;

 164:8

raised (1) 66:20

Randy (4) 15:25;211:4,

 4,15

RASKOVICH (6) 4:1,

 11;5:4,9,19;214:9

rate (7) 96:10;97:19,

 25;98:1,1;102:8,10

rated (6) 97:20;98:14,

 22;99:18;103:20;104:1

Rating (24) 76:10;

 80:11,14,20;81:25;

 82:4,7;86:21;87:1;

 90:24;92:17;93:12,15;

 94:11,20;95:9,15,22;

 97:9,15;98:5,23;

 102:15;103:8

ratings (8) 80:17,24,24;

 82:10;86:10,20;

 100:10;101:23

rationale (1) 30:15

RDO (3) 189:19,20,21

reaching (1) 207:12

reacted (1) 197:21

reaction (1) 197:23

read (34) 47:8;52:6,7;

 58:22;75:24;78:7;

 91:15;92:1;100:14,16;

 101:7,11,19;102:1;

 114:4;123:4;134:3;

 138:22;150:25;151:19;

 158:23;169:12,13,23;

 174:18;175:14;179:6;

 182:23;183:4,18;

 185:24;186:8;194:19;

 199:5

reading (7) 137:3;

 152:24;174:16;175:15;

 181:21;182:1;208:8

reads (5) 51:25;74:21;

 75:14;113:24;194:22

real (1) 190:3

realignment (12)

 116:22;155:2,12,14,

 16,17,18,21;156:5,7,

 13;169:1

reality (1) 178:14

realize (1) 126:13

realized (1) 70:3

really (25) 17:21;34:6;

 39:22;51:2;61:6;82:24;

 90:16;91:23;97:7;

 99:23;107:11;108:8;

 116:24;126:14;132:18;

 135:18;136:11;141:19;

 145:12;174:22;191:12;

 197:22;199:25;205:12;

 213:13

realm (1) 186:24

reapplying (1) 203:18

re-ask (1) 102:4

reason (5) 139:17;

 145:25;151:2;180:18,

 22

reasons (4) 153:17,19,

 23;181:3

recall (207) 6:19,20,25;

 7:12,19,25;8:12;21:1;

 23:22;24:14,21,25;

 25:4,5,11,24;26:17,18;

 27:2,11;28:6;30:7,8,11,

 13,15;31:8,19;36:17,

 23,24;39:19,23;40:15;

 41:14;42:18,19,22;

 43:6;46:11;48:4;49:17;

 50:1;52:14,16,21;53:5,

 21,23;54:3,8,11;55:4,

 11,16,18,23;56:20,25;

 57:11,17,19,25;58:12,

 24,24;59:3;62:22,24;

 63:4,25;64:21;65:1,19,

 25;66:13,20;67:6;

 68:12,21;69:1;70:16;

 71:4,25;73:1,5,10,21;

 77:3;78:19;79:22;81:4;

 82:5,11,19,20;83:8,13,

 15,25;84:1;85:9,14,20,

 21;86:3;90:20,22;

 108:25;111:4;113:1;

 115:9,13,23;116:11;

 117:19,21;118:1,2,11,

 12;127:11;129:7,12,15,

 24;130:20;131:18;

 132:1,2;137:16,19,20;

 138:12;140:8,12;

 142:6,14;145:7,16;

 147:17;148:19;156:1;

 158:11;166:20;167:20,

 24;168:3,5;171:6;

 176:3,6,10,14,18,19,

 21;178:12;179:24;

 180:6;181:19,21,23;

 184:9,13,23;185:6,9,

 10,13;189:7;191:11,

 18;192:1,7,9;197:15,

 20,21,22;198:1,2,8,10,

 11,15,18;200:24;

 201:3;202:16;203:11,

 16;204:13,23;205:2,16,

 23;206:6,15,19;

 211:23;214:17,20,22;

 215:4,20,25

recalling (1) 28:16

receive (2) 54:24;60:5

received (7) 41:18;

 84:1;155:13;156:14;

 172:5,7;183:23

receiving (1) 57:12

recently (1) 140:19

recess (5) 51:15;

 100:24;142:1;170:25;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(10) play - recess

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 402 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 210:6

recognize (2) 112:9;

 166:15

recollect (1) 190:13

recollection (8) 7:4;

 56:23;65:8;69:2;105:2;

 172:22;182:3,4

recommended (2)

 212:2,3

record (28) 4:7;5:18;

 51:13,17;82:9;98:20;

 100:22;101:1;119:20;

 120:6,8,10,22;141:24;

 142:3;170:21,23;

 171:3;172:1;174:4,6,

 18;188:15,16,19;210:4,

 8;214:1

recorded (3) 133:20;

 140:4;171:11

recording (16) 134:7;

 171:15,17,22;172:10,

 11,18,21;173:11,20,24;

 174:11,13;179:22;

 180:3;184:2

recover (1) 185:4

recovering (1) 185:3

Recovery (1) 195:23

recruited (1) 168:14

Recruiting (21) 11:4;

 16:23;62:7;72:21;

 132:21;142:7,11,17,19;

 169:2;189:15,16,25;

 207:19;208:1,11,17,22;

 209:3,21;215:12

redact (2) 120:16;123:9

redacted (3) 104:14,19;

 123:9

redaction (2) 120:2;

 122:12

redesign (1) 139:22

Reemployment (1)

 196:2

refer (4) 147:3;150:2;

 169:9;179:8

reference (1) 172:25

referenced (1) 123:23

referred (3) 80:1,5;

 178:11

referring (17) 36:22;

 50:6;52:10;66:5;74:13;

 78:9,21;79:24;86:25;

 87:1,3;105:13;113:19;

 157:15,25;158:1;163:6

refers (2) 92:21;166:25

reflected (1) 69:15

reflecting (1) 95:7

reflects (2) 74:10;

 124:22

Reform (2) 195:9,19

refresh (1) 130:1

refuse (1) 197:6

regard (1) 85:12

regarding (22) 27:16;

 36:20;42:16;47:4,14;

 48:6,18;49:18;50:23;

 55:12;58:2;63:12;

 83:11,17;85:5;91:7;

 101:5;120:17;125:4;

 162:8;204:21;205:3

regardless (1) 96:22

region (34) 14:2,12,14;

 15:7;18:15;20:5,22;

 21:5;22:11,15,16;35:2;

 40:12;58:20;59:1,9,19;

 66:6,11;67:13,18;68:2;

 106:19;108:10;111:8;

 116:14;155:14;170:16;

 190:1;212:8,12,18;

 213:16,22

region! (1) 190:5

regional (27) 10:20,21;

 13:23;14:19;15:6;

 18:21;19:3,5;20:6;

 21:12,14,14,15;22:4,5,

 8,18;47:3;128:24;

 129:1,2;155:1;170:15;

 189:22;201:8,23,24

regions (7) 22:13;

 68:17,23,25;212:4,9;

 213:10

Rehabilitation (2)

 195:11,17

Reinvestment (1)

 195:23

relate (1) 90:9

related (6) 104:6;

 107:9;145:6,18,23;

 177:17

relation (1) 187:11

relations (9) 12:16;

 14:6;43:5;62:9;148:15,

 17,20;195:1;207:22

relationship (3) 22:19;

 27:23;31:11

relationships (2) 84:5;

 182:20

relatively (1) 146:19

Release (9) 192:20;

 193:3,17;194:2,9,23;

 196:5,20,23

Relevance (9) 8:1,10,

 14;194:4,11;196:7,14,

 24;197:7

relevant (3) 105:17;

 113:8;126:5

reliant (2) 27:4;60:7

relied (1) 107:11

remember (54) 7:7;

 23:25;29:4;44:16;

 50:15,16,19,21,22;

 52:18,19;54:17;55:14;

 57:7,9;58:5,6,8;65:18;

 69:24;80:4;81:1;83:21;

 114:14;115:22;116:3,

 20;117:15;118:16;

 126:7;128:8,9;129:14,

 18,25;140:11;145:10,

 18;147:20;149:2;

 156:16;182:6;184:14;

 185:19,21,24;191:7;

 197:19;199:14;200:13,

 22;206:24,25;213:13

remotely (1) 34:11

renew (1) 183:20

repeat (2) 43:17;94:16

rephrase (7) 9:1;16:17;

 24:9;26:8;38:21;

 162:25;199:20

report (4) 21:19;22:3;

 28:1,3

reported (10) 19:4;

 21:21;22:25;28:4,11,

 13,15;29:3,5;172:4

reporter (4) 4:16;5:8;

 101:7;151:19

reporting (7) 29:13,19,

 24;30:23;36:11;

 195:10;200:17

reports (1) 113:11

represent (5) 4:23,25;

 41:17;171:21;179:21

representation (1)

 74:15

representative (22)

 10:16,19;17:3,4,6,9,

 13,21;28:8,9;29:3,10;

 31:3,6;38:2,25;62:20;

 64:8;105:18;116:4;

 168:25;210:22

representatives (11)

 28:13;30:6,17;37:19;

 61:10,19;62:1,2;63:24;

 210:15;212:15

represented (1) 173:14

representing (2) 4:18;

 5:3

request (30) 72:12;

 149:5,25;150:22;

 151:3,5;152:1,6,17,21;

 153:5,7,9,9,12;155:4,7,

 8,13,15,22;156:14;

 157:8;158:2,5;159:9;

 181:8;204:9,18;215:22

requested (7) 101:11,

 19;128:4,6;149:8,12;

 156:11

requesting (1) 120:16

requests (12) 147:23;

 148:4,7,9,21;151:12,

 21;154:23;156:3,9;

 158:10;180:9

require (1) 161:2

required (2) 160:11,14

requirement (1) 160:20

resign (2) 182:8,9

resolution (1) 136:9

resource (1) 135:24

resources (9) 9:21;

 10:3,16,19;12:15;

 13:24;14:20;15:6;

 18:22

respect (13) 43:15;

 48:13,15;49:24;60:22;

 65:5;82:13;85:24;93:9;

 120:13;146:14;164:23;

 200:12

respond (3) 49:23;

 50:9;180:16

responded (4) 138:12,

 14;185:15;209:15

responding (1) 42:11

response (8) 41:19;

 47:2;58:16,18;101:8;

 114:10;115:9;195:24

responses (1) 62:9

responsibilities (2)

 14:1;63:5

responsibility (1) 200:4

responsible (4) 17:14;

 18:2;169:2;209:2

responsive (2) 54:15;

 134:17

restructure (1) 210:24

restructured (1) 16:16

restructuring (16) 15:8,

 14;16:2,20;17:2,8,19;

 18:5,13;19:19;21:18;

 31:13;39:7;203:2,7;

 210:11

result (4) 16:19;18:12;

 19:19;72:16

resulted (1) 18:6

resume (1) 14:9

Retirement (2) 195:2,3

Retraining (1) 195:13

revenue (2) 90:10,25

review (34) 35:15,17,

 19;36:14;38:3,6,20,24;

 39:1;40:8,9;41:7;

 46:12;77:10;80:2,14;

 85:25;91:3,6;94:5;

 100:11;101:5,24;

 102:7,9;104:4;105:6;

 121:5;163:7,11,21;

 164:12,14;172:10

reviewed (2) 40:4;

 79:13

reviewing (1) 122:10

reviews (13) 35:12;

 36:6,18;37:2,11,18;

 40:6,11,13,14;56:13;

 90:21;91:24

Rich (1) 131:1

ride (1) 138:7

ride-alongs (3) 55:24;

 84:2;115:2

rides (1) 135:25

right (99) 29:17,20;

 32:3,15,20;36:3;39:9;

 45:23;46:6,19;56:10;

 58:11;65:9,20;71:23;

 72:24;74:16,22;76:6,

 11,15,19;77:23,25;

 78:7;79:9;85:9;87:12,

 18,22;88:2,5,8;91:3,23;

 92:14;94:5,13,23;95:5;

 96:4,24;99:17;103:22;

 104:21;106:6,12;

 110:20;113:17;114:4;

 120:12;124:9;132:5;

 133:22;134:3;139:1,

 11;142:21;145:1;

 146:25;150:5,8,15,18,

 25;151:21;152:10,12,

 21;155:9,18,22;

 156:20;157:1,20;

 159:9,13,24;161:3,19,

 23;162:2,14;166:14,

 25;168:11;173:24;

 178:13;179:15;182:15,

 22;183:1,18;184:17,

 21;200:10;206:17;

 207:3;215:16

Rights (3) 195:1,20;

 196:2

Robert (1) 131:23

role (63) 14:23;17:22,

 25;18:1;22:18;23:8,23;

 25:5,13;26:3,13,25;

 27:16;29:7;33:15;

 55:19,21;60:19;61:4,7;

 69:25;72:11;77:25;

 108:22;116:10,16,18;

 117:10;118:14,21;

 129:17;130:4,10;

 132:3,4,19;133:7;

 135:20;137:24;138:3;

 139:22;140:9,15;

 142:7,11,17,19;151:22;

 165:1;166:18;169:4,8;

 182:13;184:18,20;

 200:9;207:19;208:6,6;

 209:17;210:22;212:21;

 215:13

roles (6) 25:10;27:9,10;

 31:2;116:25;168:13

roll (2) 30:23;158:19

roll-up (2) 27:3,6

room (4) 188:4,4,13;

 192:16

Ross (2) 15:25;211:5

route (4) 135:25;138:7;

 205:7,11

Rubinoff (2) 137:3,6

rules (1) 8:22

Ruth (8) 45:1,2,4,6,9,

 21;46:6;48:4

S

Sacramento (1) 131:3

Safety (1) 195:21

sales (1) 11:10

same (20) 29:9;51:22;

 65:5;68:3;69:9;85:1;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(11) recognize - same

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 403 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 90:24;92:24;94:24;

 102:23;110:9,24;

 123:6;133:8,12;

 146:18;162:9;170:5;

 201:10;213:11

San (2) 33:4;205:20

Sarbanes-Oxley (1)

 195:8

sat (5) 107:5,12;

 145:12;188:5;201:10

saw (2) 39:17;119:22

saying (18) 48:23;

 53:24;61:19;66:13;

 73:6;82:12;129:12;

 158:3;176:18;178:25;

 182:21,24;184:10;

 185:9,10,13,19,21

schedule (6) 39:21,22;

 135:4;159:20,24;

 160:22

scheduled (1) 208:4

Schneider (1) 209:2

school (6) 12:17,19,23;

 13:1,4;15:2

science (1) 12:14

scope (1) 17:23

se (1) 211:22

Search (2) 11:2;174:12

second (13) 15:1;

 40:16;44:4;46:18;

 51:21,25;58:17;75:8;

 77:22;113:13;170:21;

 199:6;213:25

Secondary (1) 108:20

Section (6) 92:10;

 105:8,10;167:10,13;

 195:7

sections (1) 87:2

Security (1) 195:3

seeing (6) 24:21;36:17,

 23;41:14;81:1;168:3

seeking (3) 42:16,16;

 116:24

selected (2) 191:10,12

sending (1) 164:14

Senior (2) 10:19;45:2

sense (5) 15:18;69:16;

 107:18;108:9;209:16

sent (2) 39:1;149:21

sentence (8) 51:25;

 58:17;144:17;147:11;

 152:24;158:12;183:8;

 199:6

separate (1) 119:6

Separation (5) 192:19;

 193:2,16;194:2,8

September (11) 71:12;

 72:6;73:12;190:11;

 191:2,17;192:7;

 203:19;207:9,18;208:4

Serve (3) 78:2,23;88:7

server (1) 11:22

service (4) 188:4,5,9,13

service-excellence (1)

 132:24

Services (9) 4:12;5:4;

 10:11;14:3;16:23;

 72:20;170:9;196:1;

 212:23

servicing (3) 18:17;

 110:24,25

serving (1) 18:21

set (18) 12:5;13:3;

 86:23;93:4,16;94:12;

 95:10;97:22;98:2;

 120:4;137:21,22;

 143:8,12;213:2;

 214:18,23;215:11

sets (1) 87:6

setting (1) 138:2

Several (4) 34:4;76:6;

 81:3;213:5

share (3) 181:14,17;

 189:18

shared (1) 181:15

sharing (3) 123:21,22;

 145:11

sharpening (1) 76:4

shift (1) 117:3

shoe (1) 61:23

short (2) 198:16;214:8

shortly (1) 200:14

showing (1) 117:4

sick (2) 153:24;154:4

side (1) 161:5

SIGGERUD (6) 4:1;5:9,

 20;47:3;122:9;164:8

sign (5) 44:22;193:16;

 194:1;196:20,22

signal (1) 203:24

signature (1) 45:3

significant (3) 60:2;

 144:20;146:24

similar (4) 117:24;

 118:19;122:12;205:18

simply (1) 69:10

single (3) 99:25;

 186:21,22

singularly (1) 188:9

sit (6) 65:1;100:14,16;

 102:1;105:3;147:20

sitting (2) 107:19;

 156:16

situations (2) 153:14;

 158:18

Six (1) 42:8

size (1) 16:10

skill (1) 13:3

skills (2) 76:5;136:16

slightly (1) 13:2

small (4) 61:12,12;

 64:13;205:19

smaller (1) 213:3

Smith (16) 43:3,4;

 45:12,14,17;48:5;

 50:14,17,24;127:9,25;

 149:3,21;156:19;

 207:8,13

solely (9) 93:3,15;

 94:12;95:10,13,16;

 96:2;98:8,24

solicited (1) 16:5

solve (2) 69:20;136:5

somebody (7) 93:21;

 99:22,25;108:4;

 109:13;132:20;148:22

somehow (1) 53:9

someone (9) 29:19,25;

 39:1;45:22;52:16;

 63:19;109:18,21;

 113:11

someplace (1) 187:23

sometimes (1) 55:25

somewhere (1) 133:21

son (4) 144:21;145:6,

 24;146:16

sorry (23) 6:20;37:16,

 24;38:17;41:15;50:20;

 52:8;57:6;58:4;65:20;

 72:20;79:10;123:1;

 129:2;134:1;136:23;

 141:21;165:24;166:17;

 184:5;201:9;207:1;

 215:2

sort (4) 177:16;196:16;

 210:19,23

sorts (1) 211:16

sound (4) 133:22;

 173:20,23;174:1

Sounds (1) 9:13

South (2) 4:3;14:16

space (3) 14:3;138:2;

 213:5

span (1) 213:3

speak (5) 27:18;47:4;

 88:24;137:9;211:25

speaking (6) 48:4;

 50:16,19;64:4;183:10;

 187:7

special (1) 23:12

specific (20) 27:9;

 55:11,14;57:20;76:6;

 83:22;99:24;117:23;

 129:19;130:3;136:20;

 139:9;141:6,20;145:5;

 168:4;173:8;178:4;

 184:15;207:17

specifically (51) 24:14;

 27:2,12;30:7,12;39:23;

 41:15;42:19;43:10;

 50:2;52:21;54:4;57:17;

 60:14;62:23;66:20;

 73:2;79:23;80:4,7;

 83:13;86:2;97:8;107:9;

 114:13;116:11;117:12;

 118:17;135:21;136:18;

 144:12;145:8,16;

 148:19;176:3,7,18;

 181:10;185:13;186:3;

 190:1,14,18;192:1,14;

 197:15,20;198:1,4;

 204:23;214:20

specifics (3) 43:16;

 181:3;182:6

speculate (2) 47:19;

 155:10

speculating (1) 78:22

speculation (7) 39:4;

 44:21;45:25;47:16;

 63:15;96:14;97:1

Spell (1) 8:6

spending (1) 179:4

Spent (1) 167:11

spirit (2) 88:20,22

split (1) 107:4

spoke (3) 50:13;

 126:23;186:2

spying (1) 201:5

St (21) 9:17,19,22;10:7,

 10,15;12:4;18:20;22:7,

 9;39:15;65:10;72:12,

 19;107:5,14,18;131:8,

 17,23;192:5

staff (1) 138:8

staffing (2) 23:15;

 132:22

stamp (2) 149:23;

 163:13

standard (2) 74:24;

 196:11

Standards (1) 195:14

standing (1) 138:21

start (8) 10:12;19:12;

 73:7,22;117:4;121:17;

 124:25;202:5

started (9) 14:23;15:12;

 19:4;29:2;73:2;102:15;

 107:7;162:15;182:10

state (9) 4:23;5:17;

 7:16,18;76:25;150:13;

 174:19;175:11;189:17

stated (3) 97:16;98:10;

 141:9

statement (9) 41:19;

 46:20;49:14;58:18;

 63:9;98:8;115:9;164:3;

 215:21

statements (4) 94:3;

 114:6,9;185:17

States (4) 4:13;13:11;

 147:10;153:13

stating (1) 46:23

stationed (1) 192:4

status (2) 128:2;164:15

statutes (1) 196:5

stay (4) 107:18;142:16,

 19;209:16

step (1) 135:19

stick (1) 21:17

still (11) 143:21,21;

 154:11,15;166:17;

 176:19;182:11;201:23;

 208:3,12;215:5

Stinson (4) 4:3,20;5:3;

 6:21

stipulate (3) 120:21;

 122:19;124:6

stipulation (1) 120:20

stood (1) 177:7

straight (1) 178:25

strategic (3) 23:16;

 132:19;135:20

strategically (1) 23:9

Street (6) 4:3,4,20;5:3;

 6:23;195:9

strengthen (1) 136:16

stress (4) 140:17;

 146:25;185:1,5

stressed (6) 140:9,11,

 13;181:20;185:1,7

strike (24) 7:10;16:17;

 28:19;32:13;33:17;

 34:18;53:22;57:23;

 71:14;80:11;95:25;

 97:13;108:15;110:17;

 112:20;140:16;151:23;

 168:18;185:20;190:19;

 193:1;202:4;213:14;

 215:2

strikes (1) 173:2

strong (1) 150:3

structure (4) 17:12;

 30:22;69:15;74:10

structured (2) 15:23;

 16:12

struggled (3) 82:20;

 84:4;108:21

struggles (1) 182:18

struggling (2) 136:11;

 175:7

studied (1) 30:23

stuff (1) 92:7

submitted (1) 158:9

subtleties (1) 173:10

succeeding (1) 78:6

success (1) 215:14

successful (1) 138:19

sudden (1) 178:23

suggesting (1) 117:13

suggestions (1) 115:4

Suite (1) 4:4

summer (1) 142:8

Sun (4) 33:10;206:6,8,

 16

super (1) 119:19

Superior (1) 11:1

supervise (7) 10:7;

 14:18;19:7;31:1;45:4,

 12;201:15

supervised (1) 31:6

supervising (7) 33:19;

 34:9,10;35:9;40:2;

 60:24;70:8

supervision (2) 30:6,16

supervisor (10) 18:23;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(12) San - supervisor

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 404 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 28:21;29:1;32:2;33:13,

 23;34:21;36:3;46:4;

 56:9

supervisors (1) 21:20

support (16) 10:5;

 14:22;15:20;25:7;70:3;

 75:14,16;76:2;78:4,24;

 83:11,17;103:3;136:7;

 147:14;189:25

supported (9) 14:2,21;

 22:21;32:13,14,22;

 47:7;55:20;107:6

supporting (7) 34:24;

 35:2;55:2;69:17;110:8;

 111:9,16

supposed (5) 50:8;

 61:14;84:25;119:6,12

Sure (29) 14:2;17:17;

 19:15;31:5;37:5,15;

 39:18;40:18;61:22;

 87:15;96:8;98:20;

 103:18;110:12;123:13;

 132:15;135:5;163:12;

 172:6;173:23;175:5;

 182:15;184:16,17;

 185:14;186:1;200:2,7;

 213:7

surprise (1) 118:17

surprised (1) 138:6

swear (1) 5:8

sworn (1) 5:11

system (5) 38:17;82:9;

 96:20;163:13,25

T

talent (9) 23:14,14;

 76:3;78:4,25;79:17;

 85:16;132:22;169:2

talk (16) 64:24;83:4,9;

 134:10,11,21;136:15,

 17;137:7,13;138:20,

 25;177:2,11;205:14,20

talked (14) 66:21;

 83:13;102:13;110:18;

 130:8;132:3;145:22;

 175:7;176:25;178:12,

 19;179:8;180:23;

 202:22

Talking (8) 27:8;50:22;

 51:23;85:2;138:18;

 175:18;184:13;207:19

talks (1) 182:17

tape (3) 51:11;100:19;

 141:22

tardy (1) 110:4

tasks (2) 76:6;169:18

team (15) 16:4,23,24;

 24:1;25:9;76:4;82:22;

 103:4;182:12,19;

 188:5,9;201:8;202:12;

 211:14

teams (1) 16:12

telephone (4) 171:6;

 173:15;179:23,24

telling (25) 26:1;73:22;

 85:22;114:10;117:21;

 118:12;129:7;136:20;

 138:13;140:8,12;

 147:17;162:10,15;

 173:7;176:4,14,21;

 180:7;181:19,23;

 182:24;184:23;185:6;

 198:2

template (1) 164:4

temporary (7) 142:7,12;

 199:5,7;208:6,6;

 209:17

tenure (6) 22:23;

 112:16;168:1,19,22;

 170:14

term (1) 72:15

terminate (1) 72:17

terminated (16) 71:11;

 72:6;109:11,22;

 143:23;190:22;191:14,

 20;192:12,24;193:10,

 15;197:14;198:14,22;

 208:12

terminating (2) 86:18;

 109:19

termination (5) 7:8;

 143:14,15;191:6;

 193:21

terms (3) 133:6;162:23;

 172:13

testified (7) 8:17;106:6;

 143:17;151:10,18;

 214:10,13

testifies (1) 5:12

testify (1) 7:14

testifying (1) 215:4

testimony (17) 64:11;

 70:24;74:1;94:15;96:6;

 99:9,10;101:19;

 103:15,24,25;105:24;

 106:10;141:4;143:3,

 22;152:23

texts (1) 75:13

Therefore (1) 87:22

Theresa (1) 209:1

thinking (1) 70:1

third (3) 58:13;120:14;

 164:1

thoroughly (1) 91:16

though (8) 41:7;86:25;

 89:9;121:8;139:11;

 168:12;176:8,20

thought (5) 69:19;

 113:8;132:7;138:3;

 203:21

thoughts (1) 126:5

thousand (1) 213:6

three (23) 19:16,19,21;

 20:2;24:23;26:15,17;

 34:6;35:9;50:16;58:5;

 60:10,23;69:17;107:4,

 13;111:9,16;112:4;

 133:25;212:1,5,11

three-year (1) 173:5

threw (1) 126:1

throughout (1) 81:10

thrown (2) 125:21;

 126:8

tie (1) 102:17

timeframe (5) 70:22;

 122:6;139:8;146:5;

 178:5

timeline (1) 162:12

times (12) 6:4;34:4;

 55:22;65:2,2;137:16;

 155:3,5;175:25;176:1;

 193:13,24

timing (4) 72:9;128:10;

 214:10;215:10

Timm (8) 45:1,2,4,6,9,

 21;46:6;48:4

tire (2) 153:25;154:5

title (5) 9:25;10:14;

 28:6;56:3;195:1

today (10) 65:1;70:16;

 85:14;129:25;130:9;

 147:21;156:17;172:19;

 189:19;214:9

Today's (1) 4:15

together (1) 119:16

told (16) 60:9;95:3;

 99:19;114:15;115:23;

 134:8;136:18,19;

 142:18;143:2;145:16;

 153:20;160:19;180:20;

 192:23;197:16

toll (1) 147:12

tone (1) 173:10

Tony (1) 189:24

took (2) 126:1;128:21

tools (10) 78:5,9,13,15,

 20;83:1;89:8,9;115:6,7

top (11) 41:24;74:21;

 75:9;81:21;140:7;

 163:16;164:2,2;165:8;

 194:15,21

topic (2) 124:3;176:9

total (3) 21:1;110:22;

 194:22

totality (1) 102:20

totally (1) 206:21

toward (2) 77:8;198:25

towards (4) 74:17;

 81:16;164:2;165:8

trades (1) 17:1

traditional (1) 210:21

training (7) 11:18;

 62:13;75:20,21,22,23;

 103:3

transcribed (1) 172:14

transcript (17) 140:5;

 171:17,18,22;172:3,8;

 174:8;179:6,22;

 181:22;182:1,16,23;

 183:5,22,23;185:25

transcription (3) 172:2,

 15;173:14

transition (4) 28:17;

 31:9,12;215:15

transpire (1) 137:25

travel (2) 39:21,22

treated (3) 141:13,18;

 146:4

treating (5) 140:18,22;

 141:2,7;160:2

trial (3) 7:11,14;8:8

tricky (1) 108:1

tried (2) 141:15,16

true (10) 92:24;139:5;

 151:5,12;153:8;156:9;

 160:4;162:11;168:10;

 206:1

try (5) 8:25;72:11;

 136:1;163:24;209:16

trying (7) 25:6;48:19;

 90:16;99:16,17;

 137:22;178:20

Tucson (3) 32:22;

 204:21;206:23

turn (13) 46:18;58:13;

 75:8;81:14;113:13;

 133:13;136:1;138:5;

 139:14;163:15;164:1;

 189:8;190:9

turned (4) 7:19;121:11;

 127:22,23

Twin (1) 107:14

Two (20) 10:9;19:9,17;

 69:2,18;106:24;

 107:19;111:2,3;112:3;

 122:11,23;133:24;

 149:1;190:25;205:11;

 212:2,3,4,21

type (3) 62:8,9;82:20

types (2) 40:14;113:2

typical (3) 30:21;76:23;

 135:10

typically (28) 36:10;

 53:7,11,14,14,17,18;

 65:3,4;77:4;109:10,13,

 22;112:20,22;113:11;

 143:13;148:9;149:5;

 151:11,17,20;156:18;

 160:25;198:4,19,21,23

U

ultimately (2) 13:1;

 215:15

umbrella (1) 200:6

Um-hmm (4) 25:21;

 59:6;160:17;177:5

unable (1) 181:2

unclear (2) 79:4;97:5

under (17) 49:12;

 80:13;81:15;82:14;

 85:6;87:8,11;89:17;

 92:10,13,24;98:6,19,

 21;154:25;194:25;

 196:5

underlined (2) 46:20;

 58:16

underlying (2) 49:5,6

underneath (1) 92:15

understood (2) 9:3;

 116:9

undertook (2) 15:19;

 16:3

unfold (1) 137:25

unfortunate (1) 70:5

unfortunately (6) 20:24;

 31:24;35:7;52:19;54:5;

 80:3

unhappiness (1) 118:9

unhappy (2) 117:9;

 151:4

Uniformed (1) 196:1

union (1) 14:4

unions (1) 107:10

unique (1) 107:8

United (1) 4:12

University (2) 12:10,25

unless (2) 129:25;

 180:20

unquote (4) 78:6;

 138:21;147:15;150:4

unrelated (3) 153:16,

 18,23

unsure (1) 128:2

up (26) 15:1;39:25;

 44:4;66:17;72:23;77:8;

 108:10,11,14;110:4;

 115:4;117:4;135:20;

 141:6;156:1,7;161:25;

 163:2;164:1;173:20,

 24,25;186:16,16;

 196:13;215:4

Update (4) 75:14;

 83:11,18;85:25

updated (3) 163:17;

 168:24;169:6

updating (1) 164:15

upon (1) 86:22

upwards (1) 193:14

USC (1) 195:7

use (5) 86:9;105:20;

 106:15;172:17;173:21

used (13) 61:13,20;

 62:2,4,19;74:25;86:15,

 17;102:8;103:7;

 108:17;193:3;194:7

using (8) 83:1;100:3,9;

 101:13,22;117:19;

 172:1;173:25

V

vague (1) 88:14

Valley (6) 32:25;33:10;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(13) supervisors - Valley

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 405 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

 205:13;206:6,8,16

value (2) 64:3;84:23

valued (1) 212:18

varied (1) 14:21

variety (3) 52:14;78:13;

 132:11

various (2) 80:13;94:2

vastly (1) 87:10

version (1) 171:19

versus (4) 4:12;61:14;

 80:24;136:2

vice (6) 15:16,24;19:5;

 22:4,5,8

video (28) 4:7,9,19;

 51:13,13,17,17;100:21,

 22;101:1,1;120:6,10;

 141:23,24;142:3,3;

 170:23;171:3,3;174:4,

 4,8;188:14,19,19;

 210:4,8

VIDEOGRAPHER (19)

 4:6,17;5:7;51:12,16;

 100:21,25;120:5,9;

 141:23;142:2;170:22;

 171:2;174:3,7;188:14,

 18;210:3,7

VII (1) 195:1

visibility (1) 181:1

visit (1) 33:25

Vocational (1) 195:11

Volume (1) 4:9

W

wait (2) 208:5,9

waiver (1) 194:23

Wall (1) 195:8

wants (2) 138:7,8

water (1) 40:17

way (29) 13:3;15:20,

 22;25:8;55:23;56:19;

 60:20;67:23;68:6;86:6;

 96:20;106:19;109:17;

 117:5,5,6;121:9;

 138:21;150:24;156:22;

 168:9;172:14;173:7;

 181:3;184:24;189:3;

 204:8;212:22;215:23

ways (2) 15:22;82:24

week (1) 161:1

weekly (1) 114:19

weeks (2) 190:25;

 207:25

weren't (10) 29:19;

 34:13;61:14,15;84:8;

 109:7;129:22;135:5;

 152:18;210:20

what's (18) 7:4;11:3;

 12:13;20:15;50:5,6;

 65:22;80:1;86:5;90:16,

 20;113:9;121:17;

 124:13,19;144:7;

 164:20;166:5

whereby (2) 17:13;69:7

whole (3) 127:1;179:6;

 183:25

whomever (1) 158:5

whose (4) 70:17;

 193:18,21;196:3

wider (1) 188:11

William (1) 12:20

Williams (55) 4:11;5:1;

 19:21;27:21,24;31:1;

 34:9;36:20;38:21,24;

 41:21;42:12;45:4,6,10,

 12,15,20;47:4,6;48:6;

 50:24;51:4;52:3;57:2;

 71:7;76:11,15;81:15;

 91:7;97:9,15;98:5,22;

 101:6;109:25;110:3;

 111:8;117:17,21;

 123:18;127:15;137:14;

 142:6;144:11;149:7;

 156:15;163:7;171:7;

 173:16;179:25;186:9;

 189:10;205:4;215:6

Williams' (14) 32:2;

 35:15;46:4,23;55:13;

 70:25;71:17;86:18;

 105:20;106:11;169:16;

 170:1,11;214:12

Williams-000088 (1)

 189:2

Wilson (1) 131:6

win (7) 7:22,23,24;

 75:15;83:12,14,18

Wisconsin (1) 14:16

withdrawn (1) 166:12

within (15) 16:4,13;

 27:24;29:20,25;37:2;

 57:1;72:11;127:19;

 175:4;176:15;187:23;

 200:18;213:10,16

without (8) 82:9;

 107:15;125:1;153:16,

 22;178:22;188:12;

 194:24

witness (151) 5:8,10;

 8:2,15;17:20;26:5;

 30:11,21;31:23;32:17;

 36:9;37:5,15;38:9,16;

 39:5;41:14;42:18;

 43:17,21;44:15,22;

 46:1,8,16;47:20;50:1,

 13;53:11,17;54:3,11,

 22;55:4,9;57:6,15,19;

 58:4;59:14;60:18;61:9;

 62:22;63:8,16;64:12,

 21;67:21;68:4,21;

 69:10;70:21;71:4,20,

 25;72:8;73:1,9,18,21;

 75:3;76:22;78:12;79:3;

 81:9;82:17;83:21;

 84:13;85:8;86:2,14;

 87:14,20;88:4,17;

 91:17,20;93:8,19;94:8,

 16,25;95:20;96:7;97:4,

 19;98:13;100:9;

 101:22;103:10;104:1;

 109:21;111:2,11;

 117:15;118:16;119:18,

 21;120:3;123:11;

 124:9;126:23;127:3;

 130:7,18,23;132:11,17;

 133:9;134:25;135:13;

 136:23;140:21;141:5;

 142:23;148:14;149:10,

 15;151:8;156:22;

 157:3,10,18,22;160:6,

 14;161:16;162:5,21;

 165:18;166:9;169:21;

 170:6,19;173:6;178:3;

 183:4;184:5;194:5,12;

 196:8,18;197:1,4,9;

 200:22;203:5,21,25;

 209:25;213:19

wonder (1) 119:11

Woods (1) 4:25

word (2) 88:5;117:19

words (12) 29:8;34:13;

 117:23,24;118:7;

 152:8,10,12,14;157:7,

 10;184:15

work (70) 9:21;10:10,

 23,25;11:5;13:17;14:6,

 10;15:12;16:14;22:15;

 27:20;35:19;43:14;

 44:23;45:6;46:24;49:1,

 3,6;54:20;60:8,13,15;

 61:15;62:24;65:17;

 66:2,15,18,23;67:5,8,

 17,25;69:13,21,21;

 84:23,24;85:2;89:5,10;

 103:1;115:20;146:10;

 150:14;153:16,22;

 154:3;156:23;158:15,

 25;159:16;160:1,11,15,

 23,24;161:3,4,7,12;

 162:1,13;175:8,9;

 201:7,9,11

worked (13) 9:22;11:1,

 8,12,20,24;32:5,7;

 45:14;75:5;107:22;

 170:8;209:19

Workers (2) 195:6,12

working (10) 10:12;

 18:11;23:11;39:8;

 49:12;79:15;108:6;

 117:6;147:13;208:16

works (4) 89:4;96:20;

 163:13,25

worried (1) 185:7

write (10) 77:2,5;78:18;

 79:8;85:18;102:10,24;

 133:25;138:18;150:21

writes (1) 144:18

writing (2) 113:16;

 150:18

written (18) 23:20,23;

 24:4,11,17,21;36:17;

 38:3;76:10,18;96:19;

 99:18;109:8;110:4;

 152:9;163:4;167:17;

 168:6

wrong (10) 56:1;93:2,8;

 103:14;113:25;136:2;

 165:13;178:24;205:17;

 206:22

wrongful (1) 7:8

wrote (14) 76:24;79:5;

 94:22;96:23,23;99:23;

 100:5;101:16;102:6;

 103:7,17;104:3;

 150:19;190:7

X

XYZ (1) 136:11

Y

year (16) 13:22;19:8;

 34:4,6;77:6;80:23,25;

 93:5;94:4,11,20,23;

 95:12;96:12;99:1;

 103:19

year-end (1) 105:13

years (7) 7:9;24:23;

 50:16;58:5;81:3;

 107:23;128:1

yep (3) 13:20,20;164:6

Yuma (6) 33:2;205:3,5,

 6,8,18

0

000310 (1) 122:15

000437 (1) 144:8

000450 (1) 120:14

1

1 (23) 4:9,10;40:19,20,

 23;41:23;42:5;44:6,10;

 46:12;49:19;51:20;

 58:14;74:5;81:2,25;

 113:24;114:13;122:22,

 25;123:16,24;163:4

1,800 (1) 21:6

1:01 (1) 120:7

1:04 (1) 120:11

1:39 (1) 141:25

1:52 (1) 142:4

10 (6) 46:21;93:23;

 102:22;188:17,23;

 194:20

10:20 (1) 51:14

10:37 (1) 51:18

100 (3) 50:15;124:11;

 190:9

101 (1) 192:18

103 (1) 194:14

11 (4) 4:15;144:21;

 207:4,7

11:37 (1) 100:23

11th (1) 4:2

12 (1) 77:13

12:37 (1) 101:2

126 (1) 198:24

128 (1) 189:2

13 (3) 113:21;183:7;

 207:9

14 (1) 189:11

15 (2) 77:13;178:15

150 (2) 4:3;193:14

17 (4) 140:6;165:9;

 166:24;180:1

1964 (1) 195:2

1967 (1) 195:5

1973 (1) 195:17

1974 (1) 195:4

1981 (1) 195:7

1986 (1) 195:19

1991 (1) 195:20

1st (1) 124:21

2

2 (7) 92:10;111:22,24;

 112:2;119:11;120:15,

 17

2,000 (1) 21:6

2:29 (1) 170:24

2:51 (1) 171:4

2:55 (1) 174:5

2:56 (1) 174:8

20 (2) 178:15;193:25

2004 (1) 12:12

2005 (1) 10:13

2009 (2) 195:15,23

2010 (4) 5:23,24;6:12;

 12:22

2011 (2) 10:22;14:24

2012 (3) 15:13;144:21;

 210:12

2013 (60) 9:24;15:12;

 19:8,11,17,17,24;21:2;

 23:4,7,20;24:25;27:20,

 25;28:7;35:17;39:7,25;

 46:21;47:2;58:19;59:7,

 11;68:15;70:7,21,24;

 71:7,16;72:3,6;74:11;

 99:1;113:21;124:21,

 25;125:5;140:6;142:8;

 144:13,15;146:5,23;

 149:22;155:18;156:8;

 164:4,9;171:8;173:16;

 180:1;189:11;190:11;

 191:2;199:2;201:17;

 203:19;204:10;207:9;

 210:13

2014 (7) 41:23;42:5;

 165:9;166:24;167:4,7;

 168:8

2016 (2) 4:2,15

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(14) value - 2016

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 406 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Rachael Siggerud Raskovich

May 11, 2016

21 (2) 186:5,7

2300 (1) 4:4

23rd (1) 191:17

24 (1) 190:11

24th (1) 191:17

26 (3) 164:4;171:8;

 173:16

26th (4) 133:22;139:3,

 10;178:8

28 (2) 164:9;172:4

28th (1) 164:11

29 (4) 167:4,6;168:8;

 199:2

29th (1) 192:7

3

3 (8) 118:23;119:1;

 120:25;123:2;125:15;

 126:12;133:14;138:15

3:16 (1) 188:15

3:27 (1) 188:20

30 (3) 99:1;186:4;

 193:25

300 (1) 213:3

313 (2) 124:14,15

314 (2) 133:13;138:16

319 (3) 122:22;123:3,

 16

322 (1) 139:14

37-page (1) 183:23

38-page (1) 183:22

4

4 (3) 144:5,8;149:25

4:01 (1) 210:5

4:17 (1) 210:9

400 (1) 213:4

42 (1) 195:7

448 (1) 112:5

449 (1) 113:14

451 (2) 112:5,7

5

5 (6) 149:16,19;

 173:18;178:15;215:2,

 16

50 (1) 44:7

50-page (1) 91:20

55 (1) 161:1

6

6 (5) 164:18,21;166:7,

 11;183:8

6/26 (1) 147:5

7

7 (10) 122:16;165:22,

 23,25;166:4,6,10,11,

 15;169:11

7,800 (1) 21:3

7/17 (1) 147:7

7/2/13 (1) 123:5

8

8 (13) 144:13,15;

 146:23;149:21;158:15;

 171:1,20,25;172:3;

 173:13,18;174:19;

 183:21

88 (1) 189:6

8th (2) 149:24;162:16

9

9 (4) 85:25;86:5;

 179:17,20

9:22 (2) 4:5,8

93 (1) 189:6

99 (2) 189:8,9

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(15) 21 - 99

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 407 of 505
EXHIBIT I

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 408 of 505
Title 

Base Pay Rate 

Annualized Base Pay 

Pay Change % 

Grade 

Brandy =tams 

Compensation Summary Statement 

Pay Rate change 

Effectlye 5/412013 

current CQrnreristion New compensation 

HR Generalist HR Generalist 

$871.00 per week $968.66 per week 

$45,306 $50,365 

11.2% 

Corporate K Corporate K 

Benefits Level 

This Is or o summary IV 811010 of tho bonefits 411/51Mbla to you Meese reference your spetifie benefits sum Mary for your ?WV &ono& Wel For the 

Wells el your teripiefe bananas package. (Lotus Notee .HR Martell fieneiNS aunefirta Bonoff to Summeries) 

Contribution Level Contr Level 1 Conti Level 1 

Vacation Standard Schedule Standard Schedule 

Non-Compete Agreement 18 Months - Nationwide 18 Months - Nationwide 

Signatures: 

Recheal SIggeted - Regional FIR Dir 01 Data 

Manager 

Pothorn Chaste Sr birector Human Resources Dale 

HR Approval 

Brandy Williams Oata 

Employee Acceptance 

Wiflfams Compensation Summary • 4125/2013 Pogo 1 of 

This offer supersedes elf other mitten or veibal offers. Your employment at 06e, witi ba for an Indefinite terra tiothIng in thrs statement modifies Ihe 

relatJonshlp betveann yourself and MK. All program eligibility Is SUNOCt la charWO and Is subjnot to the lormo end oonditiona of the programs In 

place at the lime of /sward 

WILLIAMS-000096 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 409 of 505
EXHIBIT J

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 410 of 505
VI o) 4- /V 

FT9111 Brandy L Williams/9KB 

ThRechaqt M Slog eruci/GKSOgks 

Unto 06J1412013 Oa 57 PM 

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Hi there, 

I Just wanted to let you know that I'm In the office today, I'm doing ok, I do have restrictions of no lifting, 

pulling, pushing over 10 pounds, no prolonged standing, no climbing stairs for 2 weeks, t will follow up 

with my surgeon and Doc for the next two weeks. Hope your having a great Friday! 

Brandy L Williams 

Human Resources Generalist 

Arizona and Southern California 

G&K Services 

4804 W. Roosevelt 

Phoenix, AZ 85043 

Phone: 607-353-3100 Cell 602-768-3952 

Fax: 602-278-7074 

rn 

WILLIAMS-000119 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 411 of 505
EXHIBIT K

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 412 of 505
Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

Eric McNaul - May 12, 2016 1

 UNITED STATES DISTRICT COURT

 FOR THE DISTRICT OF ARIZONA

 Court File No. 2:15-cv-01744-DJH

 - - - - - - - - - - - - - - - - - - - - - -

 Brandy Williams,

 Plaintiff,

 vs.

 G & K Services, Inc., a Minnesota

 corporation, Jane and John Does 1-100,

 Black Corporations 1-100, White

 Partnerships 1-100,

 Defendant.

 - - - - - - - - - - - - - - - - - - - - - -

 - - - - - - - - - - - - - - - - - - - - - - -

 VIDEOTAPED DEPOSITION OF

 ERIC McNAUL

 May 12, 2016

 - - - - - - - - - - - - - - - - - - - - - -

 Prepared by:

 By Kelly A. Herrick

 Notary Public

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 413 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

Page 2

 1 APPEARANCES: 

 2

 MILLS + WOODS LAW PLLC

 3 5055 N. 12th Street Suite 101

 4 Phoenix, Arizona 85014 Phone: 80.999.4556

 5 Email: Rmills@millsandwoods.com 

 6 By: Robert T. Mills For the Plaintiff

 7

 

 8 STINSON, LEONARD, STREET 150 South Fifth Street

 9 Suite 2300 Minneapolis, Minnesota 55402 10 Phone: 612.335.1770 Email: Kristin.parker@stinson.com 11

 By: Kristin Parker 12 For the Defendant 

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 1 I N D E X 

 2 Examination by Mr. Mills 5 Examination by Ms. Parker 93 3

 

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 INDEX OF EXHIBITS

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 NUMBER DESCRIPTION

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 (None marked.)

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 8 PREVIOUSLY MARKED EXHIBITS REFERENCED: 

 9 Siggerud 1, Siggerud 7 

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 CERTIFIED QUESTION: Page 62 11

 

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01:04-01:06 Page 4

 1 THE DEPOSITION OF ERIC McNAUL is taken on

 2 this 12th day of May, 2016, at Stinson,

 3 Leonard, Street, 150 South Fifth Street,

 4 Suite 2300, Minneapolis, Minnesota,

 5 commencing at 1:04 p.m.

 6 THE VIDEOGRAPHER: We are on the

 7 record. The time on the video monitor is

 8 1:04 p.m. Here begins Volume 1, Video

 9 Number 1, in the deposition of Eric McNaul

10 in the matter of Brandy Williams versus

11 G & K Services, Inc., et al., filed in the

12 United States District Court for the

13 District of Arizona, Case Number

14 2:15-cv-01744-DJH.

15 Today's date is May 12, 2016. Our

16 court reporter is Kelly Herrick. My name is

17 Bob Buchman, certified videographer

18 representing Coash & Coash. This video

19 deposition is taking place in Minneapolis,

20 Minnesota.

21 Counsel, please identify yourself

22 and state whom you represent.

23 MR. MILLS: Bob Mills of Mills +

24 Woods on behalf of Plaintiff, Brandy

25 Williams.

01:06 Page 5

 1 MS. PARKER: Kristin Parker of

 2 Stinson, Leonard, Street on behalf of G & K,

 3 Inc.

 4 THE VIDEOGRAPHER: Would the court

 5 reporter please swear in the witness.

 6 ERIC McNAUL,

 7 A witness in the above-entitled action,

 8 after having been first duly sworn,

 9 testifies and says as follows:

10 EXAMINATION

11 BY MR. MILLS: 

12 Q. Good afternoon.

13 Could you go ahead and state your

14 name for the record?

15 A. Yeah, Eric McNaul.

16 Q. Have you ever given a deposition before,

17 Mr. McNaul?

18 A. Yes.

19 Q. How many times?

20 A. Twice.

21 Q. And could you -- or have you ever been a

22 party to a lawsuit before?

23 A. No.

24 Q. Okay. And could you tell me a little bit

25 about the cases that you've given

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(1) Pages 2 - 5

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 414 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:07 Page 6

 1 depositions in.

 2 A. Both of them were customer-related incidents

 3 with regard to early termination of

 4 services.

 5 Q. Okay. And these related to G & K Services?

 6 A. Yes.

 7 Q. And were those cases in Minnesota?

 8 A. Yes.

 9 Q. Do you know if they were in State or Federal

10 Court?

11 A. State.

12 Q. And how long ago was that?

13 A. Nine years ago.

14 Q. They are both nine years ago?

15 A. Yeah, approximate timeframe, yeah.

16 Q. These were, basically, breach of contract

17 cases?

18 A. Yes.

19 Q. And who was representing G & K in those

20 cases?

21 A. I don't recall. I don't remember who the

22 specific --

23 Q. Are you currently employed by G & K

24 Services?

25 A. Yes, sir.

01:07-01:09 Page 7

 1 Q. And what's your job title?

 2 A. Regional vice president.

 3 Q. And how long have you been a regional vice

 4 president?

 5 A. Seven and a half years.

 6 Q. And what region do you cover?

 7 A. US-1.

 8 Q. And what does that mean? What does that

 9 encompass?

10 A. Geographically?

11 Q. Yes.

12 A. It covers all of Minnesota, Western

13 Wisconsin, the Dakotas, Montana, all of

14 California, Reno, all of Arizona.

15 Q. Okay. How long have you been with G & K

16 Services?

17 A. I'm in my 12th year.

18 Q. And what other positions have you held at

19 G & K?

20 A. General manager.

21 Q. What's a general manager do?

22 A. Responsible for geographic business,

23 ownership of a specific business comprised

24 of a production company that does our

25 processing of our garments and facility

01:09-01:10 Page 8

 1 service products, mats, bulk products,

 2 towels, and it encompasses a geographic

 3 region that would have -- geographic area

 4 that would have, not only the processing

 5 area, but also branch responsibility.

 6 Q. Where were you located when you were general

 7 manager?

 8 A. St. Paul, Minnesota.

 9 Q. Where are you located as a regional vice

10 president?

11 A. St. Paul, Minnesota.

12 Q. Have you ever been located anywhere else in

13 connection with any work you've done for

14 G & K?

15 A. No.

16 Q. What other positions have you held at G & K?

17 A. Only those two.

18 Q. And where did you work before you went to

19 work for G & K?

20 A. I worked for a company called Brady

21 Corporation out of Milwaukee, Wisconsin.

22 Q. What did Brady Corporation do?

23 A. They were an industrial identification

24 barcoding systems, software, die cut pieces

25 and facility identification.

01:10-01:11 Page 9

 1 Q. What did you do for Brady Corp.?

 2 A. Last position was managing director of Latin

 3 America.

 4 Q. Where were you located in that job?

 5 A. Well, Milwaukee, Wisconsin, San Paulo,

 6 Brazil in two separate occasions, Manaus,

 7 Brazil on another occasion, Buenos Aires,

 8 Argentina on another occasion, and Mexico

 9 City.

10 Q. Did you go to college?

11 A. Yes.

12 Q. Okay. Where did you go?

13 A. Miami University.

14 Q. When did you graduate?

15 A. '83.

16 Q. Did you get a degree?

17 A. Yes.

18 Q. What in?

19 A. Marketing with an emphasis in international

20 marketing, supported by a management degree

21 with an English language focus.

22 Q. Any postgraduate studies?

23 A. None.

24 Q. Any formal education beyond Miami

25 University?

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(2) Pages 6 - 9

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 415 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:11-01:12 Page 10

 1 A. No.

 2 Q. Could you just briefly walk me through what

 3 jobs you've held since you graduated from

 4 college up until you started Brady Corp.?

 5 A. Yeah, sure. Started my career working for

 6 the HJ Heinz Company as a sales

 7 representative based in Cincinnati, Ohio,

 8 where I had 120 retail stores and several

 9 headquarter stores, most notably Kroeger

10 Corporation.

11 Left that, went to work for Avery

12 in a division out of New Brunswick,

13 New Jersey called Permacel. They do

14 industrial tape, electronic tape, electrical

15 tape, aeronautical tape.

16 I served in that capacity as a

17 market specialist in Marietta, Georgia

18 covering 17 states.

19 From there I took on the

20 responsibility of national accounts manager

21 for Permacel, at which point in 1988 I left

22 and went to work for the Brady Corporation,

23 which at that point was the WH Brady

24 Company.

25 Q. Do you have an immediate supervisor at

01:12-01:14 Page 11

 1 G & K?

 2 A. I do.

 3 Q. Who is that?

 4 A. His name is Ian Davis.

 5 Q. And what's his job title?

 6 A. He is senior vice president, US operations.

 7 Q. And how long has Mr. Davis been your

 8 immediate supervisor?

 9 A. 15 months.

10 Q. And prior to that, who was your immediate

11 supervisor?

12 A. Timm Curran.

13 Q. Can you spell the last name, please.

14 A. C-U-R-R-A-N.

15 Q. Thank you.

16 How long was he your supervisor?

17 A. Six and a half years.

18 Q. In your capacity as regional vice president,

19 how many people do you supervise directly?

20 A. Well, let's see, seven, eight, nine -- nine

21 people directly reporting to me.

22 Q. And what are their titles?

23 A. I have one senior general manager, I have

24 one director of sales, I have one

25 administrative assistant, and the rest hold

01:14-01:15 Page 12

 1 the position of general manager.

 2 Q. And are the general managers located at

 3 various locations?

 4 A. Yes.

 5 Q. Are any of them in Arizona?

 6 A. Yes.

 7 Q. Okay. Who is in Arizona right now?

 8 A. A gentleman by the name of Mike Malloy.

 9 Q. Is he the only individual in Arizona that

10 reports directly to you now?

11 A. Yes.

12 Q. Is he located in Phoenix?

13 A. Yes.

14 Q. And do you have general managers reporting

15 directly to you from California?

16 A. Yes.

17 Q. How many?

18 A. Two.

19 Q. And who are they?

20 A. A gentleman by the name of Richard Pland,

21 P-L-A-N-D, and Angie Grazyk, G-R-A-Z-Y-K.

22 Q. Where are they located?

23 A. Richard is in Sacramento. Angie is in

24 Santa Fe springs.

25 Q. What department of G & K are you with?

01:16-01:17 Page 13

 1 A. US operations.

 2 Q. That's separate from the human resources

 3 department, right?

 4 A. Yes.

 5 Q. Have you ever been in the human resources

 6 department?

 7 A. No.

 8 Q. Was there ever a time when people in the

 9 human resources department reported directly

10 to you?

11 A. Not directly to me -- well, yes. I had a

12 regional human resources director that

13 reported to me.

14 Q. When was that?

15 A. Up until mid 2012.

16 Q. Do you recall that there was a restructuring

17 of the human resources department in 2012?

18 A. There was a restructuring of the HR

19 department, yes, but the official

20 restructure was not in 2012.

21 The preliminary work was done in

22 2012. The execution of the plan to

23 restructure actually occurred in February of

24 2013.

25 Q. Were any of the other departments or

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 416 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:17-01:18 Page 14

 1 divisions of G & K restructured at that

 2 time?

 3 A. No.

 4 Q. Did you play any role in the restructuring

 5 of the human resources department in

 6 February 2013?

 7 A. I was a field representative to the HR

 8 organization to provide insight in a field

 9 perspective to help provide guidance to what

10 the new structure would look like.

11 Q. What guidance did you provide them?

12 A. The guidance that I provided them was that

13 we needed to have people in the field that

14 would be able to provide support to the

15 local business managers as opposed to a

16 completely centralized approach, and that

17 was the guidance I provided them.

18 Q. Had there been a centralized approach prior

19 to February 2013?

20 A. No.

21 Q. What had it been before that?

22 A. Decentralized.

23 Q. How did the HR department differ after the

24 restructuring than before?

25 A. The HR department was structured in such a

01:18-01:20 Page 15

 1 fashion that the day-to-day tactical,

 2 mundane things that an HR generalist in a

 3 business was assigned to do was centralized

 4 with regard to payroll function, time and

 5 attendance function, employee relations

 6 functions, more the mundane administrative

 7 tasks that were assigned to our generalists

 8 were centralized here in Minnetonka in our

 9 corporate headquarters.

10 The generalists were designed to be

11 field partners, HR business partners, to

12 support the local general managers in regard

13 to the people side of the equation, people

14 development, more actions that would be more

15 strategic in their design.

16 Q. These administrative tasks that you were

17 just talking about, these are tasks that had

18 formerly been performed by HR

19 representatives?

20 A. Yes.

21 Q. And after the restructuring, who was

22 performing those tasks?

23 MS. PARKER: Objection:

24 Foundation. You can answer as far as you

25 know.

01:20-01:21 Page 16

 1 THE WITNESS: It was a centralized

 2 function at our corporate office.

 3 BY MR. MILLS: 

 4 Q. Did those tasks fall on the local managers?

 5 A. Some aspect of it did, such as the time and

 6 attendance reporting fell into the

 7 individual functional managers in their

 8 respective locations, of which that would be

 9 transmitted to a corporate centralized

10 function.

11 Q. Did you ever hear any complaints or concerns

12 from the managers that you were supervising

13 about having to take on tasks that were

14 formerly being performed by HR

15 representatives?

16 MS. PARKER: Objection: Form.

17 THE WITNESS: Yes.

18 BY MR. MILLS: 

19 Q. And what were the nature of those complaints

20 or concerns that you heard?

21 A. That this was a task that was formerly taken

22 on by the HR generalist, that there were

23 certain functions that, because of the

24 organization change, that they would be

25 required to do their job differently and,

01:21-01:22 Page 17

 1 just in general, anytime there's change,

 2 you're never going to get 100 percent

 3 buy-in.

 4 I had some managers that absolutely

 5 loved the change. They felt that it

 6 provided them a greater degree of intimacy

 7 with regard to how they were able to work

 8 with and manage their team members. I had

 9 others that, for lack of a better word,

10 resisted change.

11 Q. How many managers were you supervising back

12 in 2013 after the restructuring?

13 MS. PARKER: Objection to form.

14 THE WITNESS: The same number that

15 I manage right now.

16 BY MR. MILLS: 

17 Q. And how many of those --

18 A. Excuse me, let me take that back. I had one

19 additional general manager.

20 Q. Okay. Where was that?

21 A. It was in our Pittsburgh, California

22 operation. We subsequently consolidated the

23 businesses.

24 Q. And how many of the managers that you were

25 supervising back in 2013 were resistant to

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 417 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:22-01:23 Page 18

 1 the change brought about by the

 2 restructuring?

 3 MS. PARKER: Objection to form.

 4 THE WITNESS: Specific to the ones

 5 I manage, none were resistant to the change.

 6 I mean, resistance is a very

 7 subjective word. There were discussions

 8 with regard to how we were to do our job

 9 differently.

10 BY MR. MILLS: 

11 Q. Were you -- in 2013 after the restructuring,

12 did you supervise a gentleman named Jake

13 Briscoe in Phoenix?

14 A. I did, yes.

15 Q. Did he ever express to you any concerns or

16 complaints about the restructuring?

17 MS. PARKER: Objection to form.

18 THE WITNESS: Nothing specific

19 relative to the restructuring itself.

20 BY MR. MILLS: 

21 Q. Did he ever express to you that he was

22 unhappy about having to take on tasks that

23 had formerly been performed by HR

24 representatives?

25 A. No.

01:23-01:24 Page 19

 1 Q. How frequently did you talk to Jake Briscoe?

 2 A. Frequently. Minimum of once a week, if not

 3 more.

 4 Q. And did you ever go out to Phoenix to visit

 5 the G & K facilities there?

 6 A. Yes.

 7 Q. How frequently did you do that?

 8 A. Minimum of once a quarter.

 9 Q. What was the purpose of traveling to Phoenix

10 or any other location? Was it --

11 MS. PARKER: Object to form. What

12 timeframe are we talking about?

13 BY MR. MILLS: 

14 Q. Let's focus -- yeah, let me restate that.

15 Focusing on the 2013 timeframe

16 after the restructuring, what would have

17 been the purpose for traveling to Phoenix?

18 A. As my role as regional vice president, I

19 perform quarterly business reviews with each

20 of our general managers and their teams.

21 Q. Does that encompass traveling to the

22 locations of the managers that you're

23 supervising?

24 A. Yes.

25 Q. Once a quarter?

01:24-01:26 Page 20

 1 A. Yes. I also travel specifically to meet

 2 with key prospects that we're trying to win

 3 business, meet with current customers that

 4 we have business relationships with.

 5 Q. Are you familiar with the Northwest Region

 6 of the human resources department?

 7 A. I'm familiar with the Northwest Region

 8 because US-1 is also known as Northwest

 9 Region from a geographic --

10 Q. Okay. What I'm getting at is: Are the HR

11 department structured than US-1 in terms of

12 the geographic areas that are covered?

13 MS. PARKER: Objection to form.

14 THE WITNESS: No. Is it covered

15 different than any other region? In theory,

16 no. Are you talking specifically about

17 2013?

18 BY MR. MILLS: 

19 Q. Yeah, let's talk about 2013.

20 A. Before or after?

21 Q. After the restructuring.

22 A. We were different.

23 Q. And in what way?

24 MS. PARKER: Objection to form.

25 THE WITNESS: We had, to support

01:26-01:27 Page 21

 1 our region, three HR generalists. The

 2 design was to have two HR generalists.

 3 BY MR. MILLS: 

 4 Q. Okay. And why were there three if the

 5 design was to have two?

 6 A. I was very concerned about being

 7 underrepresented from our HR organization

 8 relative to what the design of the role

 9 would to be -- or to be, and selfishly I

10 wanted to have, in my opinion, some degree

11 of overrepresentation.

12 And I asked for that and they

13 acquiesced and they gave me the opportunity

14 to have three generalists.

15 Q. Are you the one who proposed having three

16 generalists in the Northwest Region?

17 A. Yes.

18 Q. Did you believe, at the time you proposed

19 that, that you needed three generalists in

20 that region?

21 A. Yes.

22 Q. When was the -- when was the position of

23 HR generalist introduced at G & K?

24 MS. PARKER: Object to foundation.

25 THE WITNESS: Post-restructure --

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 418 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:27-01:29 Page 22

 1 actually, it was part of the restructuring

 2 organizational design.

 3 BY MR. MILLS: 

 4 Q. And prior to that, what did you have, rather

 5 than HR generalists?

 6 A. Well, we had the same term. It was an HR

 7 generalist role -- actually, it was an HR

 8 representative, HRR is what we called it,

 9 the acronym for it, and we had one HRR

10 assigned to each respective business, with

11 the exception of, here in the Twin Cities,

12 we only had one HRR for three businesses.

13 Q. But typically you would have one HRR at each

14 location where G & K was doing business?

15 A. Yes.

16 Q. And, then, after the restructuring -- after

17 the restructuring, G & K had HR generalists

18 who would service a number of locations; is

19 that right?

20 A. Yes.

21 Q. Did you supervise any of the HR generalists

22 after the restructuring?

23 A. No.

24 Q. Did you decide who any of the HR generalists

25 were going to be serving the Northwest

01:29-01:30 Page 23

 1 Region?

 2 A. Can you -- I didn't hear that.

 3 Q. Let me rephrase that.

 4 Did you decide who the

 5 HR generalists were going to be to serve the

 6 Northwest Region after the restructuring?

 7 A. Not specifically.

 8 Q. Did you have any input in that at all?

 9 A. Yes.

10 Q. What was your input?

11 A. Knowing the design of the HR generalist

12 position, we felt that -- I felt that there

13 were certain individuals that were going to

14 be better suited for a generalist role

15 versus roles in recruiting, which was the

16 other assigned task, and there were also

17 roles that were eliminated at that time,

18 positions that were eliminated.

19 Q. When -- when the HR generalists, again,

20 working after the restructuring in 2013 --

21 let me withdraw that question and rephrase

22 it. It was very bad.

23 Right after the restructuring in

24 2013, the three HR generalists that you had

25 working in the Northwest Region were Brandy

01:30-01:31 Page 24

 1 Williams, right?

 2 A. Um-hmm.

 3 Q. Is that a yes?

 4 A. Yes.

 5 Q. Okay.

 6 A. Brandy Williams was a generalist, yes.

 7 Q. And Kaela Ellison?

 8 A. Yes.

 9 Q. And who else?

10 A. Janelle Bonacua.

11 Q. Okay. And did you play any role in hiring

12 any of those three for their position?

13 A. I did not specifically interview Kaela. She

14 came over because she was a human resources

15 representative with our St. Paul, a very

16 highly competent HR representative.

17 Janelle, I interviewed at the onset

18 of her career, and I can't recall whether I

19 actually interviewed Brandy or not.

20 Q. Did you know Brandy Williams prior to the

21 restructuring?

22 A. Yes.

23 Q. How did you know her?

24 A. She was the HR representative in our Phoenix

25 operation.

01:31-01:32 Page 25

 1 Q. Prior to restructuring, who did the HR

 2 representatives report to?

 3 A. The local general manager.

 4 Q. And, in Phoenix in 2013, that would have

 5 been Jake Briscoe?

 6 A. Yes.

 7 Q. So, prior to the restructuring, Brandy

 8 Williams would have been reporting directly

 9 to him?

10 A. Yes.

11 Q. Then, after the restructuring, who did she

12 report to?

13 A. Rachael Siggerud.

14 Q. What was Rachael's title?

15 A. Human resources director.

16 Q. Was there -- strike that.

17 At the time of the restructuring in

18 2013, was there a written job description

19 for an HR generalist at G & K?

20 MS. PARKER: Objection to form.

21 THE WITNESS: Can you repeat that,

22 please.

23 BY MR. MILLS: 

24 Q. Yeah. At the time of the restructuring in

25 2013, was there a written job description

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 419 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:32-01:33 Page 26

 1 for an HR generalist?

 2 A. No.

 3 Q. Has there ever been a written job

 4 description for an HR generalist?

 5 A. Yes.

 6 Q. And when was that job description issued?

 7 MS. PARKER: Objection:

 8 Foundation.

 9 THE WITNESS: I don't know.

10 BY MR. MILLS: 

11 Q. Was it sometime after the restructuring?

12 A. Yes.

13 Q. Do you know how long after the

14 restructuring?

15 A. I don't know.

16 Q. Have you ever seen it?

17 A. Yeah, I have seen work in process. I don't

18 know if I've actually seen the finalized

19 document.

20 Q. Do you remember when you saw the work in

21 process?

22 A. After the restructuring.

23 Q. Did you play any role in developing the job

24 description for an HR generalist?

25 A. Other than providing feedback to the

01:33-01:35 Page 27

 1 directors -- yes.

 2 Q. Okay. And can you tell me what that is.

 3 A. I felt that the HR generalist role was

 4 designed -- needed to be aligned with

 5 business partnership with the local managers

 6 in the field to focus on developmental

 7 plans, culture change, training support,

 8 people development, succession planning, and

 9 to a lesser extent, some degree of

10 performance evaluation of our management --

11 of our team members in our field, and not

12 specifically exempt, but also non-exempt

13 personnel.

14 Q. I'll show you a document that we marked

15 yesterday as Exhibit 7.

16 A. Would you like me to read it?

17 Q. Could you -- I'm going to first ask if

18 you've seen that before. You can -- yeah,

19 you can look at it.

20 A. (Perusing.) I don't recall specifically

21 seeing this document in this form, no.

22 Q. Okay. The document at the top purports to

23 be a G & K job description, right?

24 A. Yes.

25 Q. And it's for an HR generalist; is that

01:35-01:36 Page 28

 1 right?

 2 A. I don't necessarily see where it says

 3 HR generalist, what --

 4 Q. Go down --

 5 A. Sure, sure.

 6 Q. The effective date is May 17, 2014?

 7 A. Yes.

 8 Q. And, then, if you look down to the right of

 9 that, there's -- there's a date that says

10 April 29, 2014.

11 A. Can you show me?

12 Q. (Indicating.) Yeah, right here.

13 A. April -- yeah, okay, good, all right.

14 Q. Do you know who prepared this?

15 A. I do not.

16 Q. Is it possible that G & K didn't have a

17 written job description for an HR generalist

18 prior to April 2014?

19 MS. PARKER: Objection:

20 Foundation; calls for speculation.

21 THE WITNESS: I don't know.

22 BY MR. MILLS: 

23 Q. It's possible?

24 A. I don't know.

25 MS. PARKER: Objection: Calls for

01:36-01:37 Page 29

 1 speculation.

 2 BY MR. MILLS: 

 3 Q. You can't testify that you saw a written job

 4 description for an HR generalist prior to

 5 April 2014?

 6 A. No, I did not.

 7 Q. All right. Did you ever have any -- any

 8 discussions with the plant managers that you

 9 were supervising about the role of

10 HR generalist after the restructuring?

11 A. Sure, yes.

12 Q. What were the nature of those discussions?

13 A. Ways that we could potentially bring the

14 HR generalist in to align with our goals of

15 performance enhancement and people

16 development.

17 Q. Did you get any feedback from the managers

18 as to what they -- what they expected of

19 HR generalists?

20 A. Yes.

21 Q. What kind of feedback did you get?

22 A. Can you be more specific, when you say

23 "managers"?

24 Q. The managers that you were supervising.

25 A. Oh, my managers?

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 420 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:37-01:39 Page 30

 1 Q. Yes.

 2 A. Okay. Yeah, I think the feedback is very,

 3 very important in that they were looking to

 4 have a business partner that could help them

 5 with regard to the people development side

 6 of their business, how to create individual

 7 development plans, how to enhance the career

 8 opportunities of our employees, how to

 9 better prepare them and educate them, and

10 train them, to take on more additional tasks

11 in their career progression.

12 We have a goal of trying to promote

13 as many people from within, and we recognize

14 that, in order to do that, we needed to

15 improve the overall competency of the people

16 within our organization and team members at

17 every level of the organization.

18 Q. Did you ever hear any concerns from any of

19 the managers that you were supervising after

20 the restructuring that they didn't

21 understand what the HR generalists were

22 doing?

23 MS. PARKER: Object to form.

24 THE WITNESS: Only one.

25 BY MR. MILLS: 

01:39-01:40 Page 31

 1 Q. What was that?

 2 A. Excuse me?

 3 Q. And who was that?

 4 A. It was from Angie Grazyk, general manager in

 5 Santa Fe Springs, Los Angeles.

 6 Q. What specifically did Angie say?

 7 A. Angie shared with me her frustration with

 8 the position after Brandy Williams had

 9 visited her.

10 Q. What do you mean by that, "after Brandy

11 Williams had visited her"?

12 A. Specifically, she felt that Brandy had no

13 clue as to what she was going to do, she

14 didn't understand her role, she was not

15 interested, really, in supporting the

16 direction we had been providing to her, and

17 that Brandy was incapable of providing any

18 value whatsoever to her team.

19 Q. Did you talk to Angie about what Brandy's

20 role was supposed to be?

21 A. Yes.

22 Q. And what did you say?

23 A. Told her specifically what I previously

24 addressed, Brandy is there to design

25 individual development plans for your team

01:40-01:41 Page 32

 1 members, to identify needs of -- areas of

 2 opportunities for further development,

 3 opportunities or strengths that an

 4 individual have that we could leverage in a

 5 greater extent, and to be a strategic

 6 business partner working with the general

 7 manager and department managers to further

 8 develop and enhance the people within their

 9 teams.

10 Q. Did -- did you document anywhere Angie's --

11 what Angie told you about Brandy?

12 A. No.

13 Q. Would you typically document those types of

14 complaints?

15 A. No.

16 Q. Why not?

17 A. I have weekly one-on-one discussions with my

18 general managers and they are more verbal

19 conversation feedback. Nothing -- we do not

20 memorialize every conversation we have.

21 Q. Any of the managers that you supervised

22 other than Angie express to you that they

23 didn't understand the role of an HR

24 generalist?

25 A. No.

01:41-01:43 Page 33

 1 Q. Did you ever have any discussions with

 2 Brandy Williams about her performance as an

 3 HR generalist?

 4 A. No.

 5 Q. Did you ever observe Brandy Williams working

 6 as an HR generalist?

 7 A. Not directly.

 8 Q. Did you ever do a performance review of

 9 Brandy Williams?

10 A. No.

11 Q. How long had you known Brandy Williams?

12 A. Probably -- maybe two years. I can't

13 specifically recall when she came on to our

14 team, but approximately two years.

15 Q. Prior to the restructuring, had you ever

16 heard any complaints about Brandy's

17 performance in the HR department?

18 A. Nothing specific, no.

19 Q. And prior to the restructuring, who would

20 have been -- who would have been doing

21 Brandy's performance review?

22 MS. PARKER: Object to foundation.

23 THE WITNESS: Jacob Briscoe.

24 BY MR. MILLS: 

25 Q. Anybody else?

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 421 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:43-01:45 Page 34

 1 MS. PARKER: Same objection.

 2 THE WITNESS: Jacob would have

 3 worked with the director of human resources

 4 to provide feedback and observational

 5 feedback with regard to her performance.

 6 BY MR. MILLS: 

 7 Q. Do you have any personal knowledge of Brandy

 8 Williams' performance as an HR generalist,

 9 anything other than what's been told to you

10 by others?

11 A. Nothing personal that I had direct

12 interaction with Brandy of, no.

13 Q. So, whatever understanding you have about

14 Brandy Williams' performance as an HR

15 generalist is based on what others have told

16 you?

17 MS. PARKER: Objection.

18 BY MR. MILLS: 

19 Q. Is that fair to say?

20 A. Yes.

21 Q. How closely did you work with Rachael

22 Siggerud back in the 2013 timeframe?

23 A. We had an office in the same regional

24 office.

25 Q. Did you see her every day?

01:45-01:46 Page 35

 1 A. When we were in the office, yes.

 2 Q. How frequently were you traveling back then?

 3 How frequently were you traveling back then?

 4 A. 60, 70 percent of the time, typically out of

 5 the office Tuesday through Thursday.

 6 Q. Did Rachael ever have conversations with you

 7 regarding Brandy Williams?

 8 A. Yes.

 9 Q. And what were the nature of those

10 conversations?

11 MS. PARKER: Object to form.

12 BY MR. MILLS: 

13 Q. What did she tell you?

14 A. Well, the conversations started during the

15 restructuring process when we were going

16 through the process of looking at our HR

17 representatives and determining those that

18 would potentially be suited to be a

19 generalist, those that would go into

20 recruiting, those that would potentially

21 be -- positions would be eliminated, so

22 those were discussions that we had relative

23 to Brandy, post-discussion,

24 post-transformation, conversations primarily

25 surrounding Brandy were centered on Brandy's

01:46-01:47 Page 36

 1 lack of performance.

 2 Q. At least initially, though, you had

 3 determined that Brandy would be a good fit

 4 for an HR generalist?

 5 MS. PARKER: Objection:

 6 Mischaracterizes prior testimony.

 7 THE WITNESS: I'd say a fit. I

 8 don't know if it would be considered a good

 9 fit, but it was a fit.

10 BY MR. MILLS: 

11 Q. Well, you wouldn't have recommended someone

12 for that position unless you thought it

13 would be a good fit, would you?

14 MS. PARKER: Objection: Form.

15 THE WITNESS: I wouldn't recommend

16 it if they weren't -- if they would be a bad

17 fit.

18 You know, ultimately, when you say

19 a good fit, that bodes, you know, something

20 that would happen in the future. I would

21 think that she would be adequately -- she

22 could fulfill the responsibilities of the

23 position in an adequate manner.

24 BY MR. MILLS: 

25 Q. Yeah, did you recommend Brandy Williams for

01:47-01:49 Page 37

 1 the position of HR generalist?

 2 A. I did not recommend Brandy for that role.

 3 Q. Do you know who did?

 4 A. I do not.

 5 Q. Was HR generalist considered to be a

 6 promotion from HR representative?

 7 MS. PARKER: Object to foundation.

 8 THE WITNESS: No.

 9 BY MR. MILLS: 

10 Q. Okay. And, then, when you had indicated you

11 had discussions with Rachael Siggerud after

12 the restructuring regarding Brandy's

13 performance, what specifically did Rachael

14 say to you?

15 MS. PARKER: Object to form.

16 THE WITNESS: Well, I'm going back

17 almost three years. The feedback -- the

18 feedback from Rachael was that she was

19 hearing complaints from the local business

20 team there with regard to Brandy's

21 unresponsiveness to the business needs of

22 the people within that business in that

23 there were times when they would reach out

24 specifically to Brandy for help from a

25 business partnership role, and they would

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 422 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:49-01:50 Page 38

 1 either not get a response or, if she did

 2 respond, it would be days later.

 3 Her general lack of responsiveness

 4 was very frustrating to the local business

 5 team there in the management staff in

 6 Arizona.

 7 BY MR. MILLS: 

 8 Q. When we're talking about the people there,

 9 "there" means the Phoenix location?

10 A. Yes, or Phoenix business, yes.

11 Q. Do you know who in particular Rachael said

12 was complaining?

13 A. Jacob Briscoe in particular, because he was

14 the general manager, and that's who she

15 primarily interfaced with, but there would

16 be other managers within that organization,

17 from a department head standpoint, that

18 Rachael would interface with, and there was

19 a high degree of dissatisfaction with regard

20 to Brandy's performance and responsiveness

21 to the business needs.

22 Q. And a high degree of dissatisfaction from

23 whom?

24 A. General manager in particular, director of

25 sales -- excuse me, the district sales

01:50-01:51 Page 39

 1 manager.

 2 Q. Who was that?

 3 A. Gary Lehrer.

 4 Q. Do you know anything particular that

 5 Mr. Lehrer had to say about Brandy?

 6 MS. PARKER: Object, no foundation.

 7 THE WITNESS: Sure, I know one

 8 incident in particular in that we had a

 9 sales team, brand new, 7 of the 10 sellers

10 were brand new, under six months, and they

11 were struggling.

12 And there was a meeting that was

13 specifically called to address this, and it

14 was with Brandy, the general manager, and

15 the district sales manager, and she

16 confirmed her attendance at that meeting and

17 she actually did not show up. She didn't

18 come in for the meeting.

19 And that was specifically part of

20 her job function, and that's just one

21 example in that there was a general lack of

22 responsiveness to the business needs.

23 BY MR. MILLS: 

24 Q. Any other comments from Mr. Lehrer other

25 than that she missed the meeting?

01:51-01:52 Page 40

 1 MS. PARKER: Objection to form.

 2 THE WITNESS: I'm not privy to any

 3 specifics because he did not share them with

 4 me, but the general lack -- the general

 5 overall frustration that was expressed to

 6 Jake from his management team with regard to

 7 her availability, whether it be in the sales

 8 department, service department, office.

 9 BY MR. MILLS: 

10 Q. Was Jake expressing that to you or to

11 Rachael?

12 A. Both.

13 Q. What exactly did Jake tell you about Brandy

14 Williams?

15 A. As I previously noted, she was unresponsive,

16 difficult to reach out to and get feedback

17 from, she was missing meetings, she was

18 unaccounted for during specific times of the

19 week.

20 We had -- and have -- a shared

21 calendar where people are to identify, you

22 know, their blocks of time when they are

23 unavailable and when they are available, and

24 the team specifically would reach out to

25 Brandy in areas of time when she was

01:52-01:53 Page 41

 1 available, and yet there was no Brandy to be

 2 found, nor would she call back, nor would

 3 she literally inform anybody of her lack of

 4 availability.

 5 Q. Can you give me very specific examples of

 6 that.

 7 MS. PARKER: Objection: Form.

 8 THE WITNESS: I can't give specific

 9 examples.

10 BY MR. MILLS: 

11 Q. Can you give me a specific example of Brandy

12 being unresponsive?

13 MS. PARKER: Objection:

14 Foundation.

15 THE WITNESS: I can't give you a

16 specific example, other than what Jake

17 shared with me, a general pattern of

18 unresponsiveness.

19 BY MR. MILLS: 

20 Q. Can you describe for me a specific example

21 of Brandy being unavailable to get ahold of?

22 MS. PARKER: Objection: Foundation

23 and asked and answered.

24 THE WITNESS: I cannot.

25 BY MR. MILLS: 

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 423 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:53-01:54 Page 42

 1 Q. Can you describe for me a specific example

 2 of Brandy being difficult to get ahold of.

 3 MS. PARKER: Same objections.

 4 THE WITNESS: Not for me directly,

 5 only through the feedback that I received

 6 through my general manager.

 7 BY MR. MILLS: 

 8 Q. You never personally experienced Brandy

 9 being unresponsive?

10 A. I did not.

11 Q. And you never personally experienced her

12 being difficult to get ahold of, right?

13 A. I did not, but I would never really have a

14 need to reach out to Brandy directly.

15 Q. Any other individuals at Phoenix who were

16 expressing any complaints or concerns about

17 Brandy Williams?

18 MS. PARKER: Objection to form.

19 THE WITNESS: I don't know

20 specifically.

21 BY MR. MILLS: 

22 Q. Do you know the names of anybody else at

23 Phoenix who was expressing a complaint or a

24 concern about --

25 A. Nobody voiced a concern directly to me.

01:54-01:55 Page 43

 1 Q. Did Rachael tell you that there was anybody

 2 else --

 3 A. I don't recall.

 4 Q. -- other than Jacob and Gary?

 5 A. I don't recall.

 6 Q. And, then, we talked about -- Angie?

 7 A. Yes.

 8 Q. Did Angie ever say anything to you other

 9 than what we've already discussed about

10 Brandy?

11 A. No, no. She only went out there one time.

12 Q. When was that?

13 A. Post-restructuring.

14 Q. Do you know how far after?

15 A. No.

16 Q. Were there any other specific complaints or

17 expressions of concern about Brandy from any

18 of the other managers of any of the other

19 locations that she was supporting?

20 MS. PARKER: Objection to form.

21 THE WITNESS: She only had two

22 locations.

23 BY MR. MILLS: 

24 Q. What do you mean, "she only had two

25 locations"?

01:55-01:56 Page 44

 1 A. Well, Phoenix, and then we attempted to get

 2 her involved in Southern California.

 3 Q. What do you mean you attempted to get her

 4 involved in Southern California?

 5 A. We provided her the opportunity to take

 6 responsibility of the generalist role in

 7 Southern California.

 8 Q. She was assigned to locations in Southern

 9 California, right?

10 A. She was.

11 Q. And those included Los Angeles, right?

12 A. Yes.

13 Q. And San Diego?

14 A. Yes.

15 Q. And Ontario?

16 A. Yes.

17 Q. And Sun Valley?

18 A. Yes.

19 Q. And she also was assigned to multiple

20 locations in Arizona, right?

21 A. Yes.

22 Q. Phoenix, right?

23 A. Yes.

24 Q. And Tucson?

25 A. Yes.

01:56-01:57 Page 45

 1 Q. And Prescott Valley?

 2 A. Yes.

 3 Q. And Yuma, right?

 4 A. Yes.

 5 Q. And were there managers at each of those

 6 locations?

 7 A. Yes.

 8 Q. And other than Jake and Gary and Angie, did

 9 you ever hear a complaint or a criticism

10 about Brandy from any of the other

11 locations?

12 A. I don't think the other locations ever met

13 Brandy.

14 Q. What basis do you have to say that?

15 A. I've never heard any feedback one way or

16 another. I'm unaware of her visiting any of

17 the Ontario locations or Sun Valley

18 locations. I'm not --

19 Q. How about Los Angeles?

20 A. Santa Fe Springs?

21 Q. Um-hmm.

22 A. I believe she went there, yes.

23 Q. San Diego?

24 A. She may have gone there.

25 Q. She went to Tucson, didn't she?

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 424 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

01:57-01:58 Page 46

 1 A. Yeah, but Tucson is an hour away from

 2 Phoenix so -- I don't even really consider

 3 it as a geographic -- it's so close to the

 4 business.

 5 Q. So, when you just testified that she didn't

 6 go to any other locations, that was not

 7 true, was it?

 8 MS. PARKER: Objection: Form;

 9 argumentative; mischaracterizes prior

10 testimony.

11 MR. MILLS: No, let's find it. I

12 want to find it because it's important.

13 Back up a little bit.

14 (Question and answer read back by

15 Mr. Mills as follows:

16 "Q. And other than Jake and Gary and

17 Angie, did you ever hear a complaint or a

18 criticism about Brandy from any of the other

19 locations?

20 "A. I don't think the other locations

21 ever met Brandy.")

22 MS. PARKER: Objection to form.

23 THE WITNESS: Okay, Bob, let's get

24 this straight. I don't know whether or not

25 they actually met Brandy.

01:58-01:59 Page 47

 1 BY MR. MILLS: 

 2 Q. You said: I don't think they ever met

 3 Brandy.

 4 A. I don't think --

 5 Q. You don't have a basis for saying that, do

 6 you?

 7 MS. PARKER: Objection to form.

 8 THE WITNESS: So, let me make sure

 9 I can be very clear.

10 BY MR. MILLS: 

11 Q. Please.

12 A. I am unsure as to whether or not they met

13 Brandy or not.

14 Q. Okay. Okay.

15 A. Clear? Did I make myself clear?

16 Q. Yes.

17 A. Okay.

18 Q. But when you said "I don't think the other

19 locations ever met her," you didn't have a

20 basis for saying that, did you?

21 MS. PARKER: Objection to form;

22 argumentative.

23 THE WITNESS: Okay, let's figure

24 out, do we want to go into literal context

25 of our conversation now?

01:59-02:00 Page 48

 1 BY MR. MILLS: 

 2 Q. I just want to be clear.

 3 A. Fine, fine. I just want to know the degree

 4 of literacy or literal interpretation of the

 5 word that we need to get into, and if you

 6 want to go to the far end of the extreme, I

 7 can do that.

 8 Q. Have you ever talked to any of the managers

 9 at the other locations as to whether they

10 met Brandy?

11 A. No.

12 Q. You have no idea whether they have or not,

13 do you?

14 MS. PARKER: Object to form;

15 mischaracterizes prior testimony.

16 THE WITNESS: I am unsure as to

17 whether they met Brandy or not.

18 BY MR. MILLS: 

19 Q. Okay. That's fine.

20 I'm going to hand you an exhibit

21 that was marked yesterday, Exhibit 1.

22 I'd ask you to take a look at the

23 first one, two, three, four pages of the

24 exhibit. I'm going to ask if you've ever

25 seen this before.

02:00-02:04 Page 49

 1 And you can take your time and read

 2 it if you want.

 3 A. (Perusing.)

 4 MS. PARKER: Do we have a Bates

 5 numbered copy of this?

 6 MR. MILLS: I think the one we

 7 marked was not Bates numbered.

 8 THE WITNESS: (Perusing.) Okay.

 9 BY MR. MILLS: 

10 Q. Have you ever seen this before?

11 A. I have seen the document, but this is really

12 the first time I've read the document.

13 Q. Did you -- did you draft any portion of this

14 document?

15 A. No.

16 Q. Did you provide any input into the

17 information that's in there?

18 MS. PARKER: Objection. I'll

19 instruct you not to answer with respect to

20 the content of any attorney/client

21 privileged communications that you may have

22 had with Ruth Timm, who is senior corporate

23 counsel with G & K, with respect to the

24 investigation of this or any other

25 investigation done at her direction.

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 425 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:04-02:05 Page 50

 1 THE WITNESS: So, I don't know

 2 what -- do I answer now, or what? I mean --

 3 MS. PARKER: You can answer to the

 4 extent whether you had a conversation but

 5 not any of the content of the conversation.

 6 THE WITNESS: Yes, I had a

 7 conversation.

 8 BY MR. MILLS: 

 9 Q. With whom?

10 A. Ruth Timm.

11 Q. And who is Ruth Timm?

12 A. Actually, not Ruth Timm. Sarah Murdock.

13 Q. Who is Sarah Murdock?

14 A. She works in our human resources department

15 at G & K.

16 Q. Is she an attorney?

17 A. No.

18 Q. And when was that conversation?

19 A. I don't recall specifically.

20 Q. Was it sometime after Brandy Williams had

21 been terminated?

22 A. Yes.

23 Q. Was it sometime after Rachael Siggerud had

24 left the company?

25 A. Yes.

02:05-02:06 Page 51

 1 Q. Do you recall how long after?

 2 A. I do not recall.

 3 Q. Was it your understanding that the

 4 conversation was in connection with an

 5 investigation being conducted by the

 6 company?

 7 A. No.

 8 Q. And what was the conversation?

 9 MS. PARKER: And, again, I'm going

10 to object to the extent that my

11 understanding is this conversation would

12 have been in connection with investigation

13 of this charge, and that Mr. McNaul may not

14 fully understand the bounds of the privilege

15 but that privilege can only be waived by the

16 company.

17 MR. MILLS: Okay. Well, I think he

18 just testified that the conversation was

19 with someone in the HR department and was

20 not a lawyer?

21 MS. PARKER: And that that

22 conversation could have, and most likely was

23 in connection with gathering information for

24 this response, which would have been

25 directed by Ruth Timm, and that that person

02:06-02:07 Page 52

 1 in the HR department, considering we know it

 2 was after Ms. Williams' termination and

 3 after Ms. Siggerud was gone, that -- I

 4 believe that would have been in connection

 5 with this investigation for purposes of

 6 responding to the EEOC charge and would fall

 7 within the attorney/client privilege or work

 8 product privileges.

 9 MR. MILLS: I don't see the basis

10 for the privilege attaching under the

11 circumstances but --

12 MS. PARKER: I am having a hard

13 time imagining where that conversation

14 wouldn't have been privileged. A discussion

15 had with somebody in the organization at the

16 direction of counsel, whether this

17 information was gathered by an attorney or

18 non-attorney is still going --

19 MR. MILLS: G & K has in-house

20 counsel, and they could have conducted it

21 with an in-house attorney, right?

22 MS. PARKER: But attorneys are also

23 entitled to use agents that have these

24 discussions. I --

25 MR. MILLS: I don't even know

02:07-02:21 Page 53

 1 whether this person was an agent of the

 2 attorney. I don't know enough

 3 information --

 4 MS. PARKER: Why don't we go off

 5 the record and Mr. McNaul and I can have a

 6 conversation so that I can make a more

 7 informed objection.

 8 MR. MILLS: If you want to do that,

 9 that's fine.

10 THE VIDEOGRAPHER: We are off the

11 record. The time on the video monitor is

12 2:07 p.m. This ends Tape Number 1.

13 (A recess was taken.)

14 THE VIDEOGRAPHER: We are on the

15 record. The time on the video monitor is

16 2:20 p.m. This begins Tape Number 2.

17 BY MR. MILLS: 

18 Q. Okay. Mr. McNaul, before the break, we were

19 talking about Exhibit Number 1, and you had

20 mentioned that you had had a conversation

21 with -- what was her name again, Sarah --

22 MS. PARKER: You can answer this

23 part, that it's with Sarah.

24 THE WITNESS: Murdock.

25 BY MR. MILLS: 

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(13) Pages 50 - 53

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 426 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:21-02:22 Page 54

 1 Q. Murdock? And that Sarah was in the HR

 2 department?

 3 A. Yes.

 4 Q. And Sarah is not an attorney?

 5 A. She is not -- I don't believe she is an

 6 attorney.

 7 Q. Do you believe that the conversation you had

 8 with her has something to do with the

 9 document that you looked at,

10 Exhibit Number 1?

11 MS. PARKER: I'm going to object to

12 this line of inquiry. As you know, we went

13 out to determine whether this conversation

14 was, in fact, within the privilege, and

15 based on conversations we had with G & K's

16 corporate counsel, I believe that my

17 objection was proper, that this is

18 attorney/client and work product privilege

19 and I'm instructing Mr. McNaul not to

20 answer.

21 MR. MILLS: You're instructing him

22 not to answer that question? Because

23 one thing I think -- just, as you know, one

24 thing I think I need to do is lay a little

25 bit of foundation so I will have some basis

02:22-02:23 Page 55

 1 for challenging the privilege.

 2 MS. PARKER: That's -- that's fair.

 3 MR. MILLS: -- privilege, rather.

 4 MS. PARKER: So, if --

 5 MR. MILLS: It doesn't violate the

 6 privilege for me to ask him whether he

 7 thinks that the conversation had something

 8 to do with this document.

 9 MS. PARKER: Fair enough, as long

10 as it's a yes-or-no question.

11 BY MR. MILLS: 

12 Q. Do you believe that your conversation with

13 Sarah had something to do with the document

14 that's Exhibit Number 1?

15 A. No.

16 Q. Okay. And do you have an understanding of

17 what the conversation had to do with?

18 MS. PARKER: Object to the extent

19 that it goes into the nature of the

20 conversation. You can answer as to whether

21 you had an understanding of what your

22 conversation was about.

23 THE WITNESS: Can you repeat that,

24 please.

25 MS. PARKER: The question was a

02:23-02:24 Page 56

 1 little convoluted, but it was whether you

 2 understood what your conversation with

 3 Ms. Murdock was about. Did I get that

 4 right?

 5 THE WITNESS: I understand what she

 6 was asking me, yes.

 7 BY MR. MILLS: 

 8 Q. Did you understand why you were having this

 9 conversation with Ms. Murdock?

10 MS. PARKER: Objection to form.

11 THE WITNESS: I -- I'm not sure --

12 I don't understand the question.

13 BY MR. MILLS: 

14 Q. Did you initiate the conversation or did

15 Ms. Murdock initiate it?

16 A. Ms. Murdock initiated the conversation.

17 Q. And it was a conversation regarding Brandy

18 Williams?

19 A. Yes.

20 Q. Do you know why she initiated that

21 conversation with you?

22 MS. PARKER: Objection.

23 THE WITNESS: I do now.

24 BY MR. MILLS: 

25 Q. And what's your understanding as to why she

02:24 Page 57

 1 did it?

 2 MS. PARKER: Objection. This

 3 inquiry is going too far into what the

 4 purpose of the conversation from an

 5 attorney/client privilege and work product

 6 standpoint was.

 7 MR. MILLS: I don't think it was

 8 asking -- I hadn't gotten into the content

 9 of it. It's, like, does the witness have an

10 understanding as to what -- as to why they

11 were having this conversation.

12 MS. PARKER: You can answer that

13 yes or no.

14 BY MR. MILLS: 

15 Q. Let me ask it that way.

16 Do you have an understanding as to

17 why you were having this conversation?

18 A. Yes.

19 Q. What's that understanding?

20 MS. PARKER: I'm going to object to

21 this.

22 MR. MILLS: As to his understanding

23 as to why they are having the conversation?

24 MS. PARKER: Well, I think it gets

25 dangerously close to what the content of the

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(14) Pages 54 - 57

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 427 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:24-02:25 Page 58

 1 conversation was, whether it gets into

 2 strategy with respect to the litigation.

 3 MR. MILLS: I think I'm entitled to

 4 ask what his understanding was as to why the

 5 conversation was occurring.

 6 MS. PARKER: I'm going to object to

 7 form. You know that we're objecting, that

 8 this is getting into attorney/client

 9 privileged conversation. Your question is

10 open-answered and improperly eliciting a

11 response from a non-attorney who doesn't

12 fully understand the contours of the

13 attorney/client privilege. You can ask --

14 MR. MILLS: I know, but --

15 MS. PARKER: -- manner.

16 MR. MILLS: Even if there was a

17 conversation with an attorney, though, I'm

18 entitled to ask: Was the conversation in

19 connection with the litigation?

20 MS. PARKER: And you didn't ask

21 that question. You just asked him what the

22 open-ended and eliciting a response --

23 MR. MILLS: I can ask the witness:

24 What was the conversation about? And they

25 can say it was about this lawsuit, and then

02:25-02:26 Page 59

 1 I can say, okay, fine, let's stop, it was

 2 attorney/client privilege.

 3 MS. PARKER: My point is that the

 4 form of the question eliciting a response

 5 that's more broad. You can ask whether it

 6 was about this litigation and I'll permit

 7 him to answer yes or no.

 8 BY MR. MILLS: 

 9 Q. Was your conversation with Ms. Murdock about

10 the current litigation?

11 A. Yes.

12 Q. Was it about Brandy Williams' lawsuit

13 against G & K?

14 A. Yes.

15 Q. You're aware -- were you aware that Brandy

16 Williams had filed a complaint with the

17 Equal Employment Opportunity Commission

18 prior to filing the lawsuit?

19 MS. PARKER: Objection: This goes

20 to the content of the conversation and it

21 goes into the discussion of what

22 specifically was discussed.

23 Mr. McNaul has already testified

24 that it was about this litigation and it's

25 an attorney/client or work product

02:26-02:27 Page 60

 1 privileged conversation and I'm instructing

 2 him not to answer any further.

 3 MR. MILLS: The EEOC Complaint is a

 4 public document.

 5 BY MR. MILLS: 

 6 Q. Were you aware that she had filed an EEOC

 7 complaint against G & K?

 8 MS. PARKER: You can answer with

 9 respect to your knowledge preceding the

10 conversation but nothing you would have

11 learned in the conversation.

12 THE WITNESS: No, I was unaware.

13 BY MR. MILLS: 

14 Q. Did Ms. Murdock tell you that --

15 MS. PARKER: Objection.

16 BY MR. MILLS: 

17 Q. -- your conversation was in connection with

18 Brandy Williams' lawsuit against G & K?

19 A. Can you repeat the question?

20 Q. Did Ms. Williams [sic] tell you or indicate

21 to you in any way that her conversation with

22 you was in connection with Brandy Williams'

23 lawsuit?

24 (Discussion off the record.)

25 BY MR. MILLS: 

02:27-02:28 Page 61

 1 Q. Strike that.

 2 Did Ms. Murdock tell you or

 3 indicate to you in any way that her

 4 conversation with you was in connection with

 5 Brandy Williams' lawsuit against G & K?

 6 MS. PARKER: Object to form; object

 7 because --

 8 MR. MILLS: He can answer that.

 9 MS. PARKER: Well, I'm objecting

10 that this was an attorney/client or work

11 product privileged conversation.

12 MR. MILLS: Clearly, it wasn't

13 attorney/client, we know that.

14 MS. PARKER: You can absolutely

15 have an attorney/client privileged

16 conversation that's done with an agent of

17 the attorney.

18 I'm not waiving that objection.

19 I'm asserting that objection. Mr. McNaul is

20 a non-attorney. I -- the privilege belongs

21 to G & K, and I'm not allowing any more

22 discussion into what the conversation or the

23 content of the conversation was.

24 I'll terminate the deposition if

25 you continue down this road.

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(15) Pages 58 - 61

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 428 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:28-02:29 Page 62

 1 MR. MILLS: Okay. Can you read

 2 back -- just read back the last question.

 3 One thing -- my last question to the

 4 witness.

 5 (Question read back as requested as

 6 follows:

 7 "Q. Did Ms. Murdock tell you or

 8 indicate to you in any way that her

 9 conversation with you was in connection with

10 Brandy Williams' lawsuit against G & K?")

11 MR. MILLS: Are you going to

12 instruct the witness not to answer that

13 question?

14 MS. PARKER: To the extent that the

15 question doesn't go into the content of the

16 conversation any more than permitted, it's

17 been asked and answered, so I'm going to

18 instruct him not to answer it any further.

19 He's already indicated that his

20 understanding was that this was with respect

21 to the litigation.

22 MR. MILLS: Let's certify that

23 question.

24 BY MR. MILLS: 

25 Q. Do you know whether any of the information

02:29-02:30 Page 63

 1 that's contained in Exhibit 1 is information

 2 that you provided?

 3 MS. PARKER: I'll object to the

 4 extent that this goes into any

 5 attorney/client privileged communications.

 6 THE WITNESS: Do you want me to

 7 answer? I haven't read it thoroughly so

 8 I'll probably need a good 30 minutes to go

 9 through it and read it.

10 MS. PARKER: And give me a second

11 because I don't see how we can talk about

12 what specific pieces that he provided

13 without talking about what his

14 attorney/client privileged conversations

15 were, and we also haven't even established

16 that he had a conversation prior to the

17 preparation of this. So, you can ask him

18 what he knows.

19 BY MR. MILLS: 

20 Q. Let me ask you this: Do you know -- strike

21 that.

22 Did your conversation with

23 Ms. Murdock happen prior to April 1, 2014?

24 A. No.

25 Q. Do you recall when the first time you saw

02:30-02:32 Page 64

 1 this document, Exhibit 1, was?

 2 A. Last -- well, last week -- a week ago

 3 Friday.

 4 Q. Had you ever seen drafts of it?

 5 A. No.

 6 Q. Do you know whether you had any -- strike

 7 that.

 8 Do you remember whether you had any

 9 input into the preparation of this document,

10 Exhibit 1?

11 A. I did not.

12 Q. Were you involved in the decision to

13 eliminate an HR generalist position in 2013?

14 A. Yes.

15 Q. In the Northwest Region?

16 A. Yes.

17 Q. Who else was involved in that decision?

18 A. Rachael Siggerud, and I believe her manager

19 was informed as well.

20 Q. And that was Pelham?

21 A. Yes.

22 Q. What's his last name?

23 A. Chastang, C-H-A-S-T-A-N-G.

24 Q. And when was the decision made to eliminate

25 an HR generalist position in the Northwest

02:32-02:33 Page 65

 1 Region?

 2 MS. PARKER: Object to form.

 3 THE WITNESS: It would have been

 4 mid -- probably mid June timeframe.

 5 BY MR. MILLS: 

 6 Q. And how -- how did that decision come about?

 7 What was the process?

 8 A. Well, we started down the path of having

 9 three generalists, and it was probably three

10 months into it -- I'm trying to remember,

11 February March April -- April/May timeframe,

12 probably in Mayish, May timeframe -- that

13 Rachael first came to me and stated that she

14 felt that we may have been -- we may be

15 overstaffed in the generalist role.

16 I inquired why because I previously

17 thought, okay, we need three. She explained

18 to me that we had overcapacity with regard

19 to the generalist role and the execution of

20 the job as it had been designed, and that we

21 had more generalists than what the work was

22 demanding.

23 And she broached the subject with

24 me because she knew I was very sensitive

25 about, you know, having adequate

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(16) Pages 62 - 65

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 429 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:33-02:34 Page 66

 1 representation, and that it was my region

 2 that, you know, she was managing from an HR

 3 perspective.

 4 I said, okay, you know, let's give

 5 it a little bit more time. Let me try to

 6 figure this out. Let me get a sense.

 7 And during the next four, five, six

 8 weeks, you know, she continued to provide

 9 feedback to me with regard to the fact that,

10 you know, we've got more generalist capacity

11 than what we originally thought, and that

12 the concept of having a reduction in force

13 was something that we felt, and I agreed to

14 in June, that, yes, this is something that

15 feels like we need to do.

16 It would be a good, prudent

17 business decision based on the capacity and

18 the overcapacity in the generalist role, and

19 we needed to right-size it relative to the

20 rest of the regions.

21 Q. So, it was Rachael who initially proposed

22 doing away with an HR generalist position?

23 A. Yes.

24 Q. And were you relying on what she was telling

25 you in connection with making your decision

02:34-02:35 Page 67

 1 as to whether to get rid of an HR

 2 generalist?

 3 MS. PARKER: Objection to form.

 4 THE WITNESS: Yes, for the most

 5 part.

 6 BY MR. MILLS: 

 7 Q. In other words, you weren't doing an

 8 independent investigation of your own as to

 9 whether you were overstaffed in that way?

10 A. No.

11 Q. And once the decision was made to -- or

12 strike that.

13 Were you also involved in the

14 decision to do away with Brandy Williams'

15 position in particular?

16 MS. PARKER: Objection to form.

17 THE WITNESS: Yes.

18 BY MR. MILLS: 

19 Q. Okay. In other words, you were involved in

20 the decision of which one of the three

21 HR generalists would go?

22 A. Yes.

23 Q. And what was your involvement in that

24 process?

25 MS. PARKER: Objection to form.

02:35-02:36 Page 68

 1 THE WITNESS: My concern was that

 2 we aligned the most competent, capable

 3 generalists with the businesses in such a

 4 fashion so as to provide adequate

 5 representation of the generalist role in the

 6 application of their duties.

 7 BY MR. MILLS: 

 8 Q. And how was that concern of yours brought to

 9 bear on the decision as to which one would

10 be eliminated?

11 MS. PARKER: Objection to form.

12 THE WITNESS: There were several

13 factors that went into the decision that

14 Rachael shared with me and we had

15 discussions about.

16 First and foremost was we need to

17 clearly establish the fact that we had

18 overcapacity and that a reduction in force

19 and/or position elimination is going to be

20 required.

21 Once we clearly established that

22 fact, we knew that we then needed to reduce

23 one person.

24 Second came in to the question with

25 regard to geographic coverage, and we were

02:37-02:38 Page 69

 1 able to ascertain that the best structure

 2 for that was to have one person that would

 3 be able to handle the Minnesota market and

 4 our Phoenix operations, and another person

 5 to handle our California operations.

 6 Third, the next element came to the

 7 selection of the individuals. We had Kaela

 8 Ellison here in Minnesota, and we had

 9 Janelle Bonacua, who was residing in

10 California.

11 Fourth, I then looked at the

12 overall competencies of the people and

13 ascertained that Kaela had very high

14 performance ratings, very positive feedback

15 from the team members that she was

16 supporting, and demonstrated a capacity to

17 embrace the role and really succeed in it.

18 Janelle, having previous California

19 experience, situated in California, and was

20 performing very well in the role as well.

21 Lastly, Brandy Williams in Phoenix,

22 underperforming in the role, struggling in

23 the role, expressing a desire that she did

24 not like the role and she did not want to

25 get into the role.

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(17) Pages 66 - 69

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 430 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:38-02:39 Page 70

 1 We, basically, made the decision

 2 based on those four factors that Brandy

 3 would be the person that we would eliminate.

 4 BY MR. MILLS: 

 5 Q. How do you know that Brandy Williams didn't

 6 want the role of HR generalist?

 7 A. Rachael has expressed to me in our

 8 conversations that Brandy had expressed

 9 frustration, not knowing what to do with the

10 role, was not taking feedback that Rachael

11 was providing to her, not executing in the

12 role, coupled with the feedback that I was

13 getting concurrently from the general

14 manager about her lack of involvement in the

15 business and responsiveness to the business,

16 and the business needs, and that Brandy had,

17 basically, said, you know, she wasn't happy

18 in the position that it was -- as it was

19 structured.

20 Q. How do you know that she was struggling in

21 that position?

22 A. Twofold: From feedback that her direct

23 manager provided to me.

24 Q. That's Jake Briscoe?

25 A. No, her direct manager was Rachael Siggerud.

02:39-02:40 Page 71

 1 Q. Okay.

 2 A. She had provided that information to me, and

 3 the fact that she was unresponsive to the

 4 business needs clearly demonstrated a lack

 5 of performance expectations or meeting

 6 performance expectations to service the

 7 business. She was unresponsive to the

 8 business needs.

 9 Q. How did you know that she was unresponsive

10 to the business needs?

11 A. Jacob Briscoe shared that with me, Rachael

12 shared that with me. I know that Jacob and

13 Rachael had had conversations as well with

14 regard to Brandy's performance.

15 Q. Did you look at Brandy's performance reviews

16 in connection with whether to --

17 A. I did not specifically look at her reviews.

18 Q. Did you look at the reviews of any -- of

19 Kaela or Janelle?

20 A. I did not.

21 Q. To what extent were you relying on Rachael

22 for evaluating which one would be

23 eliminated?

24 MS. PARKER: Objection to form.

25 THE WITNESS: Yes, Rachael had

02:40-02:41 Page 72

 1 shared with me during our discussion what

 2 her performance reviews were.

 3 BY MR. MILLS: 

 4 Q. What did she tell you?

 5 A. That, as I previously just shared, and want

 6 to go back, that Kaela was performing well

 7 in the job, exceeding expectations, doing an

 8 exceptional job, demonstrated a capacity and

 9 a bandwidth to be able to take on more

10 responsibility. She was a rock star.

11 Janelle had performed well in the

12 organization design as well, and she too was

13 doing exceedingly well, taking the position

14 and running with it.

15 And that Brandy, for a multitude of

16 reasons, which I think I've previously

17 articulated, was failing miserably in her

18 job.

19 Q. Rachael told you that she was failing

20 miserably?

21 A. Not only Rachael did, but Jacob did as well.

22 Q. Did anybody else tell you that?

23 A. Not specifically, that I can recall. There

24 may have been others, but I don't recall the

25 specifics -- you know, it gets to a point

02:41-02:42 Page 73

 1 where you hear so much negative feedback

 2 about someone's performance where you go,

 3 okay.

 4 Q. Were you aware that Brandy had health

 5 problems?

 6 A. I was not aware of that.

 7 Q. Have you ever become aware of the fact that

 8 she had health problems?

 9 A. I became aware of that in reading the

10 documents. That was the first time --

11 Q. In connection with this lawsuit, right?

12 A. Yes, that's the first time I actually became

13 aware of it.

14 Q. And Rachael had never said anything to you

15 about --

16 A. No.

17 Q. -- having health problems?

18 A. Absolutely not. You know, one of the things

19 that we pride ourselves in at G & K is the

20 confidentiality of any of our team members

21 as it pertains any related -- health-related

22 issues.

23 There's things that, by law, that

24 you can and cannot share, and they abide by

25 the law like you wouldn't believe in every

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(18) Pages 70 - 73

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 431 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:42-02:43 Page 74

 1 instance.

 2 Q. When was the decision made to terminate

 3 Brandy's employment?

 4 MS. PARKER: Objection to form.

 5 THE WITNESS: I believe it was late

 6 September is when the actual decision was

 7 made.

 8 BY MR. MILLS: 

 9 Q. So, if I understand your testimony

10 correctly, there was a period in June, I

11 believe, in which the decision was made that

12 a position has to be eliminated?

13 A. Yes.

14 Q. And, then, it was not until September that

15 you decided it was going to be Brandy

16 Williams?

17 MS. PARKER: Objection to form and

18 mischaracterizes prior testimony.

19 THE WITNESS: That is incorrect.

20 BY MR. MILLS: 

21 Q. Correct me, then.

22 A. We made a decision in June that a position

23 needed to be eliminated. We made a decision

24 in June that that person would be Brandy

25 Williams. Based on the fact that she had

02:43-02:44 Page 75

 1 expressed a desire to not be in the

 2 position, she had expressed frustration with

 3 the job, and that we had overcapacity in the

 4 position.

 5 She was the least qualified to

 6 handle the position in comparison with her

 7 peers, and she was not geographically

 8 situated to be able to perform the role as

 9 we designed with two HR generalists.

10 Q. She wasn't actually terminated until late

11 September, correct?

12 A. I believe that was the timeframe, yes.

13 Q. So, why -- why was it that there was this

14 delay from June until September?

15 A. Well, we actually left it in limbo and,

16 actually, I want to explain that. We had

17 budgeted for the position for the entire

18 year, knowing that Janelle Bonacua was

19 pregnant and she was going to be going on

20 maternity leave sometime in the late fall

21 quarter sometime, and we felt that,

22 dependent on her timeframe when she would go

23 out on maternity leave, we believed that,

24 you know, perhaps Brandy, with some further

25 guidance and direction, would be able to

02:44-02:46 Page 76

 1 fulfill the role of the generalist in

 2 Janelle's absence.

 3 So, we knew that we were going to

 4 do a riss [ph] in June, we just didn't know

 5 the specific timeframe.

 6 And as it turned out, concurrent to

 7 that timeframe, a couple of things happened,

 8 and that goes into the fact that a position

 9 in our recruiting area came about.

10 And she had expressed a desire and

11 an interest to Rachael that she wanted to go

12 and go into recruiting, and so we

13 facilitated that opportunity for Brandy to

14 go into recruiting on a temporary basis.

15 Q. She did go into recruiting for some period

16 of time, right?

17 A. She did.

18 Q. If recruiting had offered Brandy a permanent

19 position, would she have been allowed to

20 stay at G & K?

21 MS. PARKER: Objection: Calls for

22 speculation.

23 THE WITNESS: I can't answer that.

24 BY MR. MILLS: 

25 Q. Did you ever talk --

02:46-02:47 Page 77

 1 A. I don't know the answer.

 2 Q. Did you ever talk to anybody in the

 3 recruiting department about Brandy?

 4 A. I did not specifically.

 5 Q. Do you know who she was working with over

 6 there?

 7 A. I believe Michael Hammond was her direct

 8 supervisor and Theresa Schneider was head of

 9 the recruiting, but I believe her interface

10 was with those individuals.

11 Q. And at what point did you tell Brandy that

12 her job at G & K was terminated?

13 A. Late September timeframe, I don't remember

14 the specific date, and I did not tell her

15 that.

16 Q. Were you present when she was told that?

17 A. I was present.

18 Q. And who told her that?

19 A. Rachael Siggerud.

20 Q. Did you say anything to Brandy at that

21 meeting?

22 A. I don't recall. If I did, it was very

23 minimal, nothing relative to the position

24 elimination.

25 Q. Do you remember what Rachael said to her?

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(19) Pages 74 - 77

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 432 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:47-02:49 Page 78

 1 A. I don't remember word-for-word, but I know

 2 the -- what transpired was Rachael explained

 3 to her that we were going to eliminate a

 4 position and that, unfortunately, the

 5 position was going to be her's.

 6 During that timeframe, Brandy

 7 expressed what I perceived as being a little

 8 bit of relief, she stated that this would be

 9 good, that it would afford her the

10 opportunity to spend more time with her

11 family.

12 Brandy conducted herself in a very

13 professional manner. You know, terminations

14 and position eliminations are never a

15 pleasant environment, and Brandy, in my

16 opinion, handled herself exceedingly

17 professionally, as did Rachael Siggerud.

18 It was a short meeting, all of 10

19 minutes at that, and there was no further

20 discussion beyond that. There were no

21 questions from Brandy as to why or reasons

22 for.

23 Q. What was Pelham Chastang's input in

24 connection with the determination to

25 eliminate Brandy's position?

02:49-02:50 Page 79

 1 A. I do not know.

 2 Q. Did you ever talk to him about it?

 3 A. Not specifically, no.

 4 Q. Did you ever -- did you ever talk to him

 5 about eliminating a general -- or an HR

 6 generalist position at G & K?

 7 A. Yes.

 8 Q. What was that discussion -- or was there

 9 more than one discussion?

10 A. It probably went something along the lines

11 of, Pelham, you were right, I was wrong, I

12 know I wanted three but we've got one too

13 many.

14 And Pelham probably said, I knew

15 you would come around to the correct way of

16 thinking.

17 Q. Was Pelham, from the very beginning,

18 resistant to having three HR generalists?

19 A. Yes.

20 Q. Did he tell you why?

21 A. He felt we would be overstaffed and have

22 overcapacity, and as much as I hate to admit

23 it, he was right.

24 Q. How long had Pelham been at G & K, do you

25 know?

02:50-02:51 Page 80

 1 A. 28 years, maybe. He's a long-time employee

 2 of G & K.

 3 Q. Did he ever say anything to you about Brandy

 4 Williams or her performance?

 5 A. No.

 6 Q. So, do you know whether he had any input

 7 into the decision whether to terminate her

 8 job at G & K?

 9 A. I do not know.

10 Q. Was there anybody, to your knowledge, other

11 than you and Rachael, that had any input

12 into that decision?

13 A. I don't know.

14 Q. If Rachael had told you, "I think we should

15 keep Brandy," would you have gone along with

16 that?

17 MS. PARKER: Objection: Calls for

18 speculation.

19 THE WITNESS: Wow, I don't know.

20 If Rachael had told me that we should keep

21 Brandy, would I have gone along with that?

22 Ultimately, I probably would have,

23 other than the fact that, you know, for the

24 primary reason that I trust all of my team

25 members emphatically, and we have a very

02:51-02:52 Page 81

 1 strong belief in empowering our decisions --

 2 our managers to make decisions, and it was

 3 her team member.

 4 And I would have felt that it would

 5 have been out of place for me to juxtapose

 6 my belief one way or the other.

 7 BY MR. MILLS: 

 8 Q. Were you aware that Brandy Williams had made

 9 a request for accommodation under the

10 Americans With Disabilities Act?

11 MS. PARKER: Objection: Asked and

12 answered. You can answer.

13 THE WITNESS: I was unaware.

14 BY MR. MILLS: 

15 Q. Unaware during the time period that she --

16 that Brandy Williams was an HR generalist --

17 let me rephrase the question so it's a

18 little more clear.

19 Were you aware at any time frame

20 during Brandy Williams' tenure at G & K that

21 she had made a request for accommodation

22 under the Americans With Disabilities Act?

23 A. I was unaware of any request whatsoever.

24 MR. MILLS: Can we take like a

25 five-minute break.

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(20) Pages 78 - 81

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 433 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

02:52-03:11 Page 82

 1 THE VIDEOGRAPHER: We are going off

 2 record. The time now is 2:52 p.m.

 3 (A recess was taken.)

 4 THE VIDEOGRAPHER: We are going

 5 back on the record. The time now is

 6 3:10 p.m.

 7 BY MR. MILLS: 

 8 Q. Is Janelle Bonacua still with G & K?

 9 A. She is not.

10 Q. When did she leave the company?

11 A. I don't remember.

12 Q. Did she --

13 A. Sorry. I don't recall.

14 Q. Did she leave voluntarily?

15 MS. PARKER: Objection:

16 Foundation.

17 THE WITNESS: We had another

18 reduction in force and we eliminated a

19 second generalist position.

20 BY MR. MILLS: 

21 Q. In the Northwest Region?

22 A. Yes.

23 Q. And that was her position?

24 MS. PARKER: Objection:

25 Foundation.

03:11-03:12 Page 83

 1 THE WITNESS: Yes.

 2 BY MR. MILLS: 

 3 Q. And do you recall when that happened?

 4 A. I do not recall.

 5 Q. Was it sometime after Brandy Williams had

 6 left?

 7 A. Yes.

 8 Q. Is Kaela Ellison still with G & K?

 9 A. She is no longer with G & K.

10 Q. When did she leave?

11 MS. PARKER: Objection:

12 Foundation.

13 THE WITNESS: Probably a year and a

14 half ago, year ago, yeah, it's been a while.

15 BY MR. MILLS: 

16 Q. Did she leave voluntarily?

17 A. She did, yeah, she actually got a really

18 nice job promotion with an external company.

19 Q. Just to be clear, Janelle was laid off due

20 to a reduction in force?

21 MS. PARKER: Objection:

22 Foundation.

23 THE WITNESS: Yes.

24 BY MR. MILLS: 

25 Q. How many HR generalists are there currently

03:12 Page 84

 1 servicing the Northwest Region?

 2 A. One. Let me -- no, no, no, no, I've got to

 3 go back on this one. Can we strike that,

 4 strike that, strike that.

 5 I believe Janelle was laid off for

 6 performance-related issues, not a reduction

 7 in force.

 8 Q. Okay.

 9 A. Because I remember at the time we had

10 considered backfilling her role.

11 Q. Do you know what the performance-related

12 issues were?

13 MS. PARKER: Objection:

14 Foundation.

15 THE WITNESS: I don't know the

16 specifics.

17 BY MR. MILLS: 

18 Q. Were you involved in the decision to

19 terminate her?

20 A. Minimally, more from an advisory standpoint

21 and, you know, feedback that I had received.

22 Q. Do you recall anything that anybody said to

23 you about Janelle's performance in

24 connection with that?

25 MS. PARKER: Objection: Form.

03:12-03:14 Page 85

 1 THE WITNESS: I do.

 2 BY MR. MILLS: 

 3 Q. What do you recall?

 4 A. She would not travel. She had travel

 5 restrictions was the only thing that I can

 6 recall, but I'm sure there were a multitude

 7 of other performance-related issues that I'm

 8 not privy to.

 9 Q. Who did you hear that -- strike that.

10 Who told you that she would not

11 travel?

12 A. The general manager, Richard Pland, and the

13 human resources director, Julie Pfieffer,

14 P-F-I-E-F-F-E-R.

15 Q. And did you actually provide any advice with

16 respect to the termination of Janelle?

17 A. No.

18 Q. Do you recall who it was that actually told

19 her that she was being terminated from the

20 company?

21 MS. PARKER: Objection:

22 Foundation.

23 THE WITNESS: I believe it was

24 Julie Pfieffer.

25 BY MR. MILLS: 

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(21) Pages 82 - 85

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 434 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

03:14-03:15 Page 86

 1 Q. What is Julie Pfieffer's title?

 2 A. Director of human resources, or to be more

 3 accurate, human resources director.

 4 Q. Had Julie taken over the role that Rachael

 5 Siggerud had previously had?

 6 A. Yes.

 7 Q. Okay. Anything else you can recall about

 8 any complaints or concerns about Janelle's

 9 performance other than that she would not

10 travel?

11 MS. PARKER: Object to form.

12 THE WITNESS: I don't remember any

13 of the specific details.

14 BY MR. MILLS: 

15 Q. Did you personally ever observe Janelle's

16 performance?

17 MS. PARKER: Object to form.

18 THE WITNESS: No, nor would I have

19 any real opportunity to.

20 BY MR. MILLS: 

21 Q. Did Rachael Siggerud ever say anything to

22 you -- or strike that.

23 Did Rachael Siggerud ever relate to

24 you any complaints or concerns about

25 Janelle's performance?

03:15-03:16 Page 87

 1 MS. PARKER: Object to form.

 2 THE WITNESS: Not that I can

 3 recall.

 4 BY MR. MILLS: 

 5 Q. And who is currently the HR generalist for

 6 the Northwest Region?

 7 A. A gentleman by the name of Chris Iverson.

 8 Q. And how long has he been the sole

 9 HR generalist?

10 A. Probably 18 months, maybe -- maybe a little

11 bit longer. He was hired to backfill for

12 Kaela Ellison when she left.

13 Q. How many regions does G & K have?

14 A. Five in the United States.

15 Q. Is there any of those regions that have more

16 than one HR generalist?

17 A. I don't believe so.

18 Q. Were there in the past?

19 MS. PARKER: Objection: Relevance.

20 THE WITNESS: Were there -- can you

21 be more specific?

22 BY MR. MILLS: 

23 Q. Let me just really briefly back up and do

24 this -- at the time of the restructuring

25 back in 2013 --

03:16-03:18 Page 88

 1 A. Yes.

 2 Q. -- I know that you testified there were

 3 three HR generalists in the Northwest

 4 Region.

 5 A. Yes.

 6 Q. Were there more than one generalist in any

 7 of the other regions?

 8 MS. PARKER: Objection: Relevance.

 9 THE WITNESS: I don't know

10 specifically -- I don't know the specifics

11 of the other regions.

12 BY MR. MILLS: 

13 Q. Did your responsibilities' job duties extend

14 to any of the regions other than the

15 Northwest Region?

16 A. No, no.

17 Q. Did any of the managers that you were

18 supervising express to you any -- any

19 complaints or concerns about Janelle's

20 performance other than the travel

21 restrictions?

22 A. Not that I can recall.

23 Q. What did you do to prepare for this

24 deposition?

25 A. I went and met with our general counsel. He

03:18-03:19 Page 89

 1 shared with me some correspondence, and we

 2 had an hour-and-a-half, two-hour meeting,

 3 and, basically, talked to me primarily about

 4 the deposition and what would take place,

 5 and that was pretty much it.

 6 Other than that, I left the next

 7 day to go to Washington, D.C. on vacation

 8 for eight days and a lovely wedding with

 9 Newt Gingrich.

10 Q. Did you look at any documents in preparation

11 for the deposition?

12 A. I did.

13 Q. What did you look at?

14 A. I looked at two documents, relatively

15 innocuous, that I was copied on, that I

16 couldn't make heads nor tails as to why they

17 were even presented.

18 Q. Could you be a little bit more descriptive

19 as to what they were. Were they emails?

20 A. They were emails, and so -- that was it,

21 couple of emails, one that I looked at, and

22 I went, like, this doesn't even make sense.

23 I couldn't even figure out -- my first

24 question was: Why is this document in here?

25 Q. Do you remember who the emails were from?

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(22) Pages 86 - 89

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 435 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

03:19-03:20 Page 90

 1 A. Oh, I do remember one email in particular

 2 because it did -- because in my particularly

 3 very curt way of answering questions was one

 4 that was from Rachael Siggerud that had

 5 expressed a desire --

 6 MS. PARKER: You know, I'll

 7 interject here. Why do we need to get into

 8 the specific documents?

 9 MR. MILLS: What do you mean, why

10 do we need to get into them?

11 MS. PARKER: I mean, the fact that

12 he met with the GC and looked at documents,

13 I mean, to the extent that there are

14 specific documents that you haven't asked

15 him about or discussed in this deposition --

16 MR. MILLS: I can ask him what

17 documents he looked at in preparation for

18 the deposition. That's always asked that

19 question in a deposition.

20 THE WITNESS: The only document

21 that I can recall is one that Rachael had

22 sent to me, her game plan, with regard to

23 how we could potentially keep Brandy as an

24 employee of the company.

25 Please understand, Bob, we all

03:20-03:21 Page 91

 1 cared for Brandy very much. We liked her,

 2 she was a nice person, and for me as a -- as

 3 a vice president, I have a profound interest

 4 in providing employment -- long-term career

 5 opportunity for our team members, and

 6 Rachael had shared with me that there was a

 7 temporary position that was available in

 8 recruiting, and that, during her

 9 conversation with Brandy, Brandy had

10 expressed an interest to go into recruiting.

11 And she sent a document saying,

12 here's an opportunity where we might be able

13 to find a home for Brandy that would fit

14 better within her skill sets with regard to

15 her desire as to what she wanted to do, and

16 that if she performed well in that role, she

17 could potentially fill a need in our

18 recruiting department.

19 And my response to her was, I think

20 it's a neat idea, it's a good idea.

21 And I thought that was a great way,

22 because, keep in mind, the last thing I

23 really want to do is reduce our force. It's

24 painful enough when you have to say good-bye

25 to people, but if I can find another

03:21-03:22 Page 92

 1 opportunity and provide somebody the

 2 opportunity to succeed, so be it, great,

 3 win-win for the company.

 4 We had a need and she was going to

 5 get the opportunity to do something that she

 6 really expressed an interest in.

 7 BY MR. MILLS: 

 8 Q. Have you had any communications with Brandy

 9 Williams since the time she left?

10 A. No, no.

11 Q. Okay. Have you had any communications with

12 Janelle since she left?

13 A. No.

14 Q. Or any communications with Kaela since she

15 left?

16 A. Yes.

17 Q. Just, in general, what was those?

18 MS. PARKER: Objection: Relevance.

19 THE WITNESS: Kaela got a brand new

20 puppy, and she knows I'm a dog lover, and so

21 she sent me a picture of her puppy.

22 And so I called her and

23 congratulated her on the adoption of her new

24 puppy, and we had a nice conversation. And

25 to the extent of it, I guess Kaela and puppy

03:22-03:23 Page 93

 1 are doing fine, yes, other than the fact she

 2 had a puppy birthday party and I wasn't

 3 invited so I feel a little remiss from that.

 4 MR. MILLS: Okay. I think that's

 5 all I have. Thank you.

 6 MS. PARKER: I'll ask two questions

 7 just to clear up something that I think

 8 there's some confusion on.

 9 EXAMINATION

10 BY MS. PARKER: 

11 Q. You testified earlier today that you

12 received a call from Ms. Murdock at some

13 point, and that she left you a voicemail.

14 At that point when she left you a

15 voicemail, were you aware that her call was

16 about litigation?

17 A. I was unaware of that.

18 Q. When you later had a conversation with her,

19 did you become aware that the call was about

20 litigation?

21 A. I then became aware of the litigation

22 aspect -- the purpose of her call.

23 MS. PARKER: No further questions.

24 MR. MILLS: Thank you.

25 THE VIDEOGRAPHER: We are off the

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(23) Pages 90 - 93

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 436 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

03:23 Page 94

 1 record. The time on the monitor is 

 2 5:23 p.m. [sic]. This ends Video Number 2 

 3 and the deposition of Eric McNaul. 

 4 (At 3:23 p.m. the deposition was 

 5 recessed.) 

 6

 

 7

 

 8

 

 9

 

10

 

11

 

12

 

13

 

14

 

15

 

16

 

17

 

18 _______________________ Eric McNaul

19

 

20

 

21

 

22

 

23

 

24

 

25

Page 95

 1 STATE OF MINNESOTA 

 2 CERTIFICATE COUNTY OF WASHINGTON

 3

 I, Kelly A. Herrick, hereby 4 certify that I reported the deposition of ERIC McNAUL on the 12th day of May, 2016 in

 5 Minneapolis, Minnesota, and that the witness was by me first duly sworn to tell the truth 6 and nothing but the truth concerning the matter in controversy aforesaid;

 7

 That I was then and there a notary 8 public in and for the County of Washington, State of Minnesota; that by virtue thereof I 9 was duly authorized to administer an oath; 

10 That the foregoing transcript is a true and correct transcript of my 11 stenographic notes in said matter, transcribed under my direction and control; 12

 That the cost of the original has 13 been charged to the party who noticed the deposition and that all parties who ordered 14 copies have been charged at the same rate for such copies; 15

 That the reading and signing of 16 the deposition was not waived; 

17 That I am not related to any of the parties hereto, nor interested in the 18 outcome of the action and have no contract with any parties, attorneys or persons with 19 an interest in the action that has a substantial tendency to affect my 20 impartiality; 

21 WITNESS MY HAND AND SEAL this 21st day of May, 2016. 22

 

23

 _____________________ 24 Kelly A. Herrick Notary Public 25

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(24) Pages 94 - 95

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 437 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

[

[ph] (1) 76:4

[sic] (1) 60:20

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able (8) 14:14;17:7;

 69:1,3;72:9;75:8,25;

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absence (1) 76:2

absolutely (3) 17:4;

 61:14;73:18

accommodation (2)

 81:9,21

accounts (1) 10:20

accurate (1) 86:3

acquiesced (1) 21:13

acronym (1) 22:9

Act (2) 81:10,22

action (1) 5:7

actions (1) 15:14

actual (1) 74:6

actually (15) 13:23;

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additional (2) 17:19;

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address (1) 39:13

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adequately (1) 36:21

administrative (3)

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admit (1) 79:22

adoption (1) 92:23

advice (1) 85:15

advisory (1) 84:20

aeronautical (1) 10:15

afford (1) 78:9

afternoon (1) 5:12

again (3) 23:19;51:9;

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against (5) 59:13;60:7,

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agent (2) 53:1;61:16

agents (1) 52:23

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ahead (1) 5:13

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align (1) 29:14

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allowed (1) 76:19

allowing (1) 61:21

almost (1) 37:17

along (3) 79:10;80:15,

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always (1) 90:18

America (1) 9:3

Americans (2) 81:10,22

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Angie's (1) 32:10

answered (3) 41:23;

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application (1) 68:6

approach (2) 14:16,18

approximate (1) 6:15

approximately (1) 33:14

April (6) 28:10,13,18;

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April/May (1) 65:11

area (3) 8:3,5;76:9

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argumentative (2) 46:9;

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Arizona (7) 4:13;7:14;

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around (1) 79:15

articulated (1) 72:17

ascertain (1) 69:1

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aspect (2) 16:5;93:22

asserting (1) 61:19

assigned (6) 15:3,7;

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assistant (1) 11:25

attaching (1) 52:10

attempted (2) 44:1,3

attendance (3) 15:5;

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attorney (8) 50:16;

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attorney/client (13)

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aware (13) 59:15,15;

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away (3) 46:1;66:22;

 67:14

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backfill (1) 87:11

backfilling (1) 84:10

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bandwidth (1) 72:9

barcoding (1) 8:24

based (6) 10:7;34:15;

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basically (4) 6:16;70:1,

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basis (6) 45:14;47:5,

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Bates (2) 49:4,7

bear (1) 68:9

became (3) 73:9,12;

 93:21

become (2) 73:7;93:19

beginning (1) 79:17

begins (2) 4:8;53:16

behalf (2) 4:24;5:2

belief (2) 81:1,6

belongs (1) 61:20

best (1) 69:1

better (4) 17:9;23:14;

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beyond (2) 9:24;78:20

birthday (1) 93:2

bit (7) 5:24;46:13;

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Bob (4) 4:17,23;46:23;

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bodes (1) 36:19

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bounds (1) 51:14

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brand (3) 39:9,10;

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breach (1) 6:16

break (2) 53:18;81:25

briefly (2) 10:2;87:23

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broached (1) 65:23

broad (1) 59:5

brought (2) 18:1;68:8

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Buchman (1) 4:17

budgeted (1) 75:17

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bulk (1) 8:1

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calls (4) 28:20,25;

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cases (4) 5:25;6:7,17,

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certify (1) 62:22

challenging (1) 55:1

change (7) 16:24;17:1,

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charge (2) 51:13;52:6

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C-H-A-S-T-A-N-G (1)

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Chastang's (1) 78:23

Chris (1) 87:7

Cincinnati (1) 10:7

circumstances (1)

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Cities (1) 22:11

City (1) 9:9

clear (7) 47:9,15,15;

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close (2) 46:3;57:25

closely (1) 34:21

clue (1) 31:13

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college (2) 9:10;10:4

commencing (1) 4:5

comments (1) 39:24

Commission (1) 59:17

communications (5)

 49:21;63:5;92:8,11,14

company (12) 7:24;

 8:20;10:6,24;50:24;

 51:6,16;82:10;83:18;

 85:20;90:24;92:3

comparison (1) 75:6

competencies (1) 69:12

competency (1) 30:15

competent (2) 24:16;

 68:2

complaining (1) 38:12

complaint (6) 42:23;

 45:9;46:17;59:16;60:3,

 7

complaints (11) 16:11,

 19;18:16;32:14;33:16;

 37:19;42:16;43:16;

 86:8,24;88:19

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(1) [ph] - complaints

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 438 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

completely (1) 14:16

comprised (1) 7:23

concept (1) 66:12

concern (5) 42:24,25;

 43:17;68:1,8

concerned (1) 21:6

concerns (8) 16:11,20;

 18:15;30:18;42:16;

 86:8,24;88:19

concurrent (1) 76:6

concurrently (1) 70:13

conducted (3) 51:5;

 52:20;78:12

confidentiality (1) 73:20

confirmed (1) 39:16

confusion (1) 93:8

congratulated (1) 92:23

connection (15) 8:13;

 51:4,12,23;52:4;58:19;

 60:17,22;61:4;62:9;

 66:25;71:16;73:11;

 78:24;84:24

consider (1) 46:2

considered (3) 36:8;

 37:5;84:10

considering (1) 52:1

consolidated (1) 17:22

contained (1) 63:1

content (7) 49:20;50:5;

 57:8,25;59:20;61:23;

 62:15

context (1) 47:24

continue (1) 61:25

continued (1) 66:8

contours (1) 58:12

contract (1) 6:16

conversation (57)

 32:19,20;47:25;50:4,5,

 7,18;51:4,8,11,18,22;

 52:13;53:6,20;54:7,13;

 55:7,12,17,20,22;56:2,

 9,14,16,17,21;57:4,11,

 17,23;58:1,5,9,17,18,

 24;59:9,20;60:1,10,11,

 17,21;61:4,11,16,22,

 23;62:9,16;63:16,22;

 91:9;92:24;93:18

conversations (8) 35:6,

 10,14,24;54:15;63:14;

 70:8;71:13

convoluted (1) 56:1

copied (1) 89:15

copy (1) 49:5

Corp (2) 9:1;10:4

corporate (5) 15:9;16:2,

 9;49:22;54:16

Corporation (4) 8:21,

 22;10:10,22

correctly (1) 74:10

correspondence (1)

 89:1

Counsel (6) 4:21;

 49:23;52:16,20;54:16;

 88:25

couple (2) 76:7;89:21

coupled (1) 70:12

Court (4) 4:12,16;5:4;

 6:10

cover (1) 7:6

coverage (1) 68:25

covered (2) 20:12,14

covering (1) 10:18

covers (1) 7:12

create (1) 30:6

criticism (2) 45:9;46:18

culture (1) 27:7

Curran (1) 11:12

C-U-R-R-A-N (1) 11:14

current (2) 20:3;59:10

currently (3) 6:23;

 83:25;87:5

curt (1) 90:3

customer-related (1)

 6:2

customers (1) 20:3

cut (1) 8:24

D

Dakotas (1) 7:13

dangerously (1) 57:25

date (4) 4:15;28:6,9;

 77:14

Davis (2) 11:4,7

day (3) 4:2;34:25;89:7

days (2) 38:2;89:8

day-to-day (1) 15:1

DC (1) 89:7

Decentralized (1) 14:22

decide (2) 22:24;23:4

decided (1) 74:15

decision (20) 64:12,17,

 24;65:6;66:17,25;

 67:11,14,20;68:9,13;

 70:1;74:2,6,11,22,23;

 80:7,12;84:18

decisions (2) 81:1,2

degree (8) 9:16,20;

 17:6;21:10;27:9;38:19,

 22;48:3

delay (1) 75:14

demanding (1) 65:22

demonstrated (3)

 69:16;71:4;72:8

department (22) 12:25;

 13:3,6,9,17,19;14:5,23,

 25;20:6,11;32:7;33:17;

 38:17;40:8,8;50:14;

 51:19;52:1;54:2;77:3;

 91:18

departments (1) 13:25

dependent (1) 75:22

DEPOSITION (11) 4:1,

 9,19;5:16;61:24;88:24;

 89:4,11;90:15,18,19

depositions (1) 6:1

describe (2) 41:20;42:1

description (8) 25:18,

 25;26:4,6,24;27:23;

 28:17;29:4

descriptive (1) 89:18

design (8) 15:15;21:2,

 5,8;22:2;23:11;31:24;

 72:12

designed (4) 15:10;

 27:4;65:20;75:9

desire (5) 69:23;75:1;

 76:10;90:5;91:15

details (1) 86:13

determination (1) 78:24

determine (1) 54:13

determined (1) 36:3

determining (1) 35:17

develop (1) 32:8

developing (1) 26:23

development (7) 15:14;

 27:8;29:16;30:5,7;

 31:25;32:2

developmental (1) 27:6

die (1) 8:24

Diego (2) 44:13;45:23

differ (1) 14:23

different (2) 20:15,22

differently (2) 16:25;

 18:9

difficult (3) 40:16;42:2,

 12

direct (4) 34:11;70:22,

 25;77:7

directed (1) 51:25

direction (4) 31:16;

 49:25;52:16;75:25

directly (11) 11:19,21;

 12:10,15;13:9,11;25:8;

 33:7;42:4,14,25

director (9) 9:2;11:24;

 13:12;25:15;34:3;

 38:24;85:13;86:2,3

directors (1) 27:1

Disabilities (2) 81:10,22

discussed (3) 43:9;

 59:22;90:15

discussion (8) 52:14;

 59:21;60:24;61:22;

 72:1;78:20;79:8,9

discussions (9) 18:7;

 29:8,12;32:17;33:1;

 35:22;37:11;52:24;

 68:15

dissatisfaction (2)

 38:19,22

District (4) 4:12,13;

 38:25;39:15

division (1) 10:12

divisions (1) 14:1

document (18) 26:19;

 27:14,21,22;32:10,13;

 49:11,12,14;54:9;55:8,

 13;60:4;64:1,9;89:24;

 90:20;91:11

documents (7) 73:10;

 89:10,14;90:8,12,14,17

dog (1) 92:20

done (4) 8:13;13:21;

 49:25;61:16

down (4) 28:4,8;61:25;

 65:8

draft (1) 49:13

drafts (1) 64:4

due (1) 83:19

duly (1) 5:8

during (8) 35:14;40:18;

 66:7;72:1;78:6;81:15,

 20;91:8

duties (2) 68:6;88:13

E

earlier (1) 93:11

early (1) 6:3

educate (1) 30:9

education (1) 9:24

EEOC (3) 52:6;60:3,6

effective (1) 28:6

eight (2) 11:20;89:8

either (1) 38:1

electrical (1) 10:14

electronic (1) 10:14

element (1) 69:6

eliciting (3) 58:10,22;

 59:4

eliminate (5) 64:13,24;

 70:3;78:3,25

eliminated (8) 23:17,

 18;35:21;68:10;71:23;

 74:12,23;82:18

eliminating (1) 79:5

elimination (2) 68:19;

 77:24

eliminations (1) 78:14

Ellison (4) 24:7;69:8;

 83:8;87:12

else (8) 8:12;24:9;

 33:25;42:22;43:2;

 64:17;72:22;86:7

email (1) 90:1

emails (4) 89:19,20,21,

 25

embrace (1) 69:17

emphasis (1) 9:19

emphatically (1) 80:25

employed (1) 6:23

employee (3) 15:5;

 80:1;90:24

employees (1) 30:8

Employment (3) 59:17;

 74:3;91:4

empowering (1) 81:1

encompass (2) 7:9;

 19:21

encompasses (1) 8:2

end (1) 48:6

ends (1) 53:12

English (1) 9:21

enhance (2) 30:7;32:8

enhancement (1) 29:15

enough (3) 53:2;55:9;

 91:24

entire (1) 75:17

entitled (3) 52:23;58:3,

 18

environment (1) 78:15

Equal (1) 59:17

equation (1) 15:13

ERIC (4) 4:1,9;5:6,15

establish (1) 68:17

established (2) 63:15;

 68:21

et (1) 4:11

evaluating (1) 71:22

evaluation (1) 27:10

even (7) 46:2;52:25;

 58:16;63:15;89:17,22,

 23

exactly (1) 40:13

EXAMINATION (2)

 5:10;93:9

example (5) 39:21;

 41:11,16,20;42:1

examples (2) 41:5,9

exceeding (1) 72:7

exceedingly (2) 72:13;

 78:16

exception (1) 22:11

exceptional (1) 72:8

Excuse (3) 17:18;31:2;

 38:25

executing (1) 70:11

execution (2) 13:22;

 65:19

exempt (1) 27:12

Exhibit (10) 27:15;

 48:20,21,24;53:19;

 54:10;55:14;63:1;64:1,

 10

expectations (3) 71:5,6;

 72:7

expected (1) 29:18

experience (1) 69:19

experienced (2) 42:8,

 11

explain (1) 75:16

explained (2) 65:17;

 78:2

express (4) 18:15,21;

 32:22;88:18

expressed (10) 40:5;

 70:7,8;75:1,2;76:10;

 78:7;90:5;91:10;92:6

expressing (4) 40:10;

 42:16,23;69:23

expressions (1) 43:17

extend (1) 88:13

extent (10) 27:9;32:5;

 50:4;51:10;55:18;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(2) completely - extent

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 439 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

 62:14;63:4;71:21;

 90:13;92:25

external (1) 83:18

extreme (1) 48:6

F

facilitated (1) 76:13

facilities (1) 19:5

facility (2) 7:25;8:25

fact (11) 54:14;66:9;

 68:17,22;71:3;73:7;

 74:25;76:8;80:23;

 90:11;93:1

factors (2) 68:13;70:2

failing (2) 72:17,19

fair (3) 34:19;55:2,9

fall (3) 16:4;52:6;75:20

familiar (2) 20:5,7

family (1) 78:11

far (4) 15:24;43:14;

 48:6;57:3

fashion (2) 15:1;68:4

Fe (3) 12:24;31:5;

 45:20

February (4) 13:23;

 14:6,19;65:11

Federal (1) 6:9

feedback (19) 26:25;

 29:17,21;30:2;32:19;

 34:4,5;37:17,18;40:16;

 42:5;45:15;66:9;69:14;

 70:10,12,22;73:1;

 84:21

feel (1) 93:3

feels (1) 66:15

fell (1) 16:6

felt (10) 17:5;23:12,12;

 27:3;31:12;65:14;

 66:13;75:21;79:21;

 81:4

field (6) 14:7,8,13;

 15:11;27:6,11

Fifth (1) 4:3

figure (3) 47:23;66:6;

 89:23

filed (3) 4:11;59:16;

 60:6

filing (1) 59:18

fill (1) 91:17

finalized (1) 26:18

find (4) 46:11,12;91:13,

 25

Fine (6) 48:3,3,19;

 53:9;59:1;93:1

first (10) 5:8;27:17;

 48:23;49:12;63:25;

 65:13;68:16;73:10,12;

 89:23

fit (8) 36:3,7,9,9,13,17,

 19;91:13

five (2) 66:7;87:14

five-minute (1) 81:25

focus (3) 9:21;19:14;

 27:6

Focusing (1) 19:15

follows (3) 5:9;46:15;

 62:6

force (6) 66:12;68:18;

 82:18;83:20;84:7;

 91:23

foremost (1) 68:16

Form (38) 16:16;17:13;

 18:3,17;19:11;20:13,

 24;25:20;27:21;30:23;

 35:11;36:14;37:15;

 40:1;41:7;42:18;43:20;

 46:8,22;47:7,21;48:14;

 56:10;58:7;59:4;61:6;

 65:2;67:3,16,25;68:11;

 71:24;74:4,17;84:25;

 86:11,17;87:1

formal (1) 9:24

formerly (4) 15:18;

 16:14,21;18:23

found (1) 41:2

Foundation (16) 15:24;

 21:24;26:8;28:20;

 33:22;37:7;39:6;41:14,

 22;54:25;82:16,25;

 83:12,22;84:14;85:22

four (3) 48:23;66:7;

 70:2

Fourth (1) 69:11

frame (1) 81:19

frequently (5) 19:1,2,7;

 35:2,3

Friday (1) 64:3

frustrating (1) 38:4

frustration (4) 31:7;

 40:5;70:9;75:2

fulfill (2) 36:22;76:1

fully (2) 51:14;58:12

function (5) 15:4,5;

 16:2,10;39:20

functional (1) 16:7

functions (2) 15:6;

 16:23

further (7) 32:2,7;60:2;

 62:18;75:24;78:19;

 93:23

future (1) 36:20

G

game (1) 90:22

garments (1) 7:25

Gary (4) 39:3;43:4;

 45:8;46:16

gathered (1) 52:17

gathering (1) 51:23

gave (1) 21:13

GC (1) 90:12

General (29) 7:20,21;

 8:6;11:23;12:1,2,14;

 15:12;17:1,19;19:20;

 25:3;31:4;32:6,18;

 38:3,14,24;39:14,21;

 40:4,4;41:17;42:6;

 70:13;79:5;85:12;

 88:25;92:17

generalist (46) 15:2;

 16:22;21:23;22:7;

 23:11,14;24:6;25:19;

 26:1,4,24;27:3,25;28:3,

 17;29:4,10,14;32:24;

 33:3,6;34:8,15;35:19;

 36:4;37:1,5;44:6;

 64:13,25;65:15,19;

 66:10,18,22;67:2;68:5;

 70:6;76:1;79:6;81:16;

 82:19;87:5,9,16;88:6

generalists (24) 15:7,

 10;21:1,2,14,16,19;

 22:5,17,21,24;23:5,19,

 24;29:19;30:21;65:9,

 21;67:21;68:3;75:9;

 79:18;83:25;88:3

gentleman (4) 12:8,20;

 18:12;87:7

geographic (7) 7:22;

 8:2,3;20:9,12;46:3;

 68:25

Geographically (2)

 7:10;75:7

Georgia (1) 10:17

gets (3) 57:24;58:1;

 72:25

Gingrich (1) 89:9

given (2) 5:16,25

goal (1) 30:12

goals (1) 29:14

goes (5) 55:19;59:19,

 21;63:4;76:8

Good (10) 5:12;28:13;

 36:3,8,13,19;63:8;

 66:16;78:9;91:20

good-bye (1) 91:24

graduate (1) 9:14

graduated (1) 10:3

Grazyk (2) 12:21;31:4

G-R-A-Z-Y-K (1) 12:21

great (2) 91:21;92:2

greater (2) 17:6;32:5

guess (1) 92:25

guidance (5) 14:9,11,

 12,17;75:25

H

half (3) 7:5;11:17;

 83:14

Hammond (1) 77:7

hand (1) 48:20

handle (3) 69:3,5;75:6

handled (1) 78:16

happen (2) 36:20;

 63:23

happened (2) 76:7;

 83:3

happy (1) 70:17

hard (1) 52:12

hate (1) 79:22

head (2) 38:17;77:8

headquarter (1) 10:9

headquarters (1) 15:9

heads (1) 89:16

health (3) 73:4,8,17

health-related (1) 73:21

hear (7) 16:11;23:2;

 30:18;45:9;46:17;73:1;

 85:9

heard (3) 16:20;33:16;

 45:15

hearing (1) 37:19

Heinz (1) 10:6

held (3) 7:18;8:16;10:3

help (3) 14:9;30:4;

 37:24

here's (1) 91:12

Herrick (1) 4:16

her's (1) 78:5

herself (2) 78:12,16

high (3) 38:19,22;69:13

highly (1) 24:16

hired (1) 87:11

hiring (1) 24:11

HJ (1) 10:6

hold (1) 11:25

home (1) 91:13

hour (1) 46:1

hour-and-a-half (1)

 89:2

HR (71) 13:18;14:7,23,

 25;15:2,11,18;16:14,

 22;18:23;20:10;21:1,2,

 7,23;22:5,6,7,17,21,24;

 23:5,11,19,24;24:16,

 24;25:1,19;26:1,4,24;

 27:3,25;28:3,17;29:4,

 10,14,19;30:21;32:23;

 33:3,6,17;34:8,14;

 35:16;36:4;37:1,5,6;

 51:19;52:1;54:1;64:13,

 25;66:2,22;67:1,21;

 70:6;75:9;79:5,18;

 81:16;83:25;87:5,9,16;

 88:3

HRR (4) 22:8,9,12,13

human (14) 13:2,5,9,

 12,17;14:5;20:6;24:14;

 25:15;34:3;50:14;

 85:13;86:2,3

I

Ian (1) 11:4

idea (3) 48:12;91:20,20

identification (2) 8:23,

 25

identify (3) 4:21;32:1;

 40:21

imagining (1) 52:13

immediate (3) 10:25;

 11:8,10

important (2) 30:3;

 46:12

improperly (1) 58:10

improve (1) 30:15

Inc (2) 4:11;5:3

incapable (1) 31:17

incident (1) 39:8

incidents (1) 6:2

included (1) 44:11

incorrect (1) 74:19

independent (1) 67:8

indicate (3) 60:20;61:3;

 62:8

indicated (2) 37:10;

 62:19

Indicating (1) 28:12

individual (5) 12:9;

 16:7;30:6;31:25;32:4

individuals (4) 23:13;

 42:15;69:7;77:10

industrial (2) 8:23;

 10:14

inform (1) 41:3

information (7) 49:17;

 51:23;52:17;53:3;

 62:25;63:1;71:2

informed (2) 53:7;64:19

in-house (2) 52:19,21

initially (2) 36:2;66:21

initiate (2) 56:14,15

initiated (2) 56:16,20

innocuous (1) 89:15

input (7) 23:8,10;49:16;

 64:9;78:23;80:6,11

inquired (1) 65:16

inquiry (2) 54:12;57:3

insight (1) 14:8

instance (1) 74:1

instruct (3) 49:19;

 62:12,18

instructing (3) 54:19,21;

 60:1

interaction (1) 34:12

interest (4) 76:11;91:3,

 10;92:6

interested (1) 31:15

interface (2) 38:18;77:9

interfaced (1) 38:15

interject (1) 90:7

international (1) 9:19

interpretation (1) 48:4

interview (1) 24:13

interviewed (2) 24:17,

 19

intimacy (1) 17:6

into (27) 16:6;35:19;

 47:24;48:5;49:16;

 55:19;57:3,8;58:1,8;

 59:21;61:22;62:15;

 63:4;64:9;65:10;68:13;

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(3) external - into

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 440 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

 69:25;76:8,12,14,15;

 80:7,12;90:7,10;91:10

introduced (1) 21:23

investigation (6) 49:24,

 25;51:5,12;52:5;67:8

invited (1) 93:3

involved (7) 44:2,4;

 64:12,17;67:13,19;

 84:18

involvement (2) 67:23;

 70:14

issued (1) 26:6

issues (4) 73:22;84:6,

 12;85:7

Iverson (1) 87:7

J

Jacob (7) 33:23;34:2;

 38:13;43:4;71:11,12;

 72:21

Jake (10) 18:12;19:1;

 25:5;40:6,10,13;41:16;

 45:8;46:16;70:24

Janelle (12) 24:10,17;

 69:9,18;71:19;72:11;

 75:18;82:8;83:19;84:5;

 85:16;92:12

Janelle's (6) 76:2;

 84:23;86:8,15,25;

 88:19

Jersey (1) 10:13

job (23) 7:1;9:4;11:5;

 16:25;18:8;25:18,25;

 26:3,6,23;27:23;28:17;

 29:3;39:20;65:20;72:7,

 8,18;75:3;77:12;80:8;

 83:18;88:13

jobs (1) 10:3

Julie (4) 85:13,24;86:1,

 4

June (7) 65:4;66:14;

 74:10,22,24;75:14;

 76:4

juxtapose (1) 81:5

K

Kaela (11) 24:7,13;

 69:7,13;71:19;72:6;

 83:8;87:12;92:14,19,

 25

keep (4) 80:15,20;

 90:23;91:22

Kelly (1) 4:16

key (1) 20:2

kind (1) 29:21

knew (4) 65:24;68:22;

 76:3;79:14

Knowing (3) 23:11;

 70:9;75:18

knowledge (3) 34:7;

 60:9;80:10

known (2) 20:8;33:11

knows (2) 63:18;92:20

Kristin (1) 5:1

Kroeger (1) 10:9

K's (1) 54:15

L

lack (8) 17:9;36:1;38:3;

 39:21;40:4;41:3;70:14;

 71:4

laid (2) 83:19;84:5

language (1) 9:21

Last (8) 9:2;11:13;62:2,

 3;64:2,2,22;91:22

Lastly (1) 69:21

late (4) 74:5;75:10,20;

 77:13

later (2) 38:2;93:18

Latin (1) 9:2

law (2) 73:23,25

lawsuit (9) 5:22;58:25;

 59:12,18;60:18,23;

 61:5;62:10;73:11

lawyer (1) 51:20

lay (1) 54:24

learned (1) 60:11

least (2) 36:2;75:5

leave (6) 75:20,23;

 82:10,14;83:10,16

Left (12) 10:11,21;

 50:24;75:15;83:6;

 87:12;89:6;92:9,12,15;

 93:13,14

Lehrer (3) 39:3,5,24

Leonard (2) 4:3;5:2

lesser (1) 27:9

level (1) 30:17

leverage (1) 32:4

liked (1) 91:1

likely (1) 51:22

limbo (1) 75:15

line (1) 54:12

lines (1) 79:10

literacy (1) 48:4

literal (2) 47:24;48:4

literally (1) 41:3

litigation (9) 58:2,19;

 59:6,10,24;62:21;

 93:16,20,21

little (10) 5:24;46:13;

 54:24;56:1;66:5;78:7;

 81:18;87:10;89:18;

 93:3

local (7) 14:15;15:12;

 16:4;25:3;27:5;37:19;

 38:4

located (7) 8:6,9,12;

 9:4;12:2,12,22

location (3) 19:10;

 22:14;38:9

locations (19) 12:3;

 16:8;19:22;22:18;

 43:19,22,25;44:8,20;

 45:6,11,12,17,18;46:6,

 19,20;47:19;48:9

long (11) 6:12;7:3,15;

 11:7,16;26:13;33:11;

 51:1;55:9;79:24;87:8

longer (2) 83:9;87:11

long-term (1) 91:4

long-time (1) 80:1

look (9) 14:10;27:19;

 28:8;48:22;71:15,17,

 18;89:10,13

looked (6) 54:9;69:11;

 89:14,21;90:12,17

looking (2) 30:3;35:16

Los (3) 31:5;44:11;

 45:19

loved (1) 17:5

lovely (1) 89:8

lover (1) 92:20

M

making (1) 66:25

Malloy (1) 12:8

manage (3) 17:8,15;

 18:5

management (4) 9:20;

 27:10;38:5;40:6

manager (21) 7:20,21;

 8:7;10:20;11:23;12:1;

 17:19;25:3;31:4;32:7;

 38:14,24;39:1,14,15;

 42:6;64:18;70:14,23,

 25;85:12

managers (28) 12:2,14;

 14:15;15:12;16:4,7,12;

 17:4,11,24;19:20,22;

 27:5;29:8,17,23,24,25;

 30:19;32:7,18,21;

 38:16;43:18;45:5;48:8;

 81:2;88:17

managing (2) 9:2;66:2

Manaus (1) 9:6

manner (3) 36:23;

 58:15;78:13

many (10) 5:19;11:19;

 12:17;17:11,17,24;

 30:13;79:13;83:25;

 87:13

March (1) 65:11

Marietta (1) 10:17

marked (3) 27:14;

 48:21;49:7

market (2) 10:17;69:3

Marketing (2) 9:19,20

maternity (2) 75:20,23

mats (1) 8:1

matter (1) 4:10

May (10) 4:2,15;28:6;

 45:24;49:21;51:13;

 65:12,14,14;72:24

maybe (4) 33:12;80:1;

 87:10,10

Mayish (1) 65:12

McNAUL (11) 4:1,9;5:6,

 15,17;51:13;53:5,18;

 54:19;59:23;61:19

mean (9) 7:8;18:6;

 31:10;43:24;44:3;50:2;

 90:9,11,13

means (1) 38:9

meet (2) 20:1,3

meeting (8) 39:12,16,

 18,25;71:5;77:21;

 78:18;89:2

meetings (1) 40:17

member (1) 81:3

members (8) 17:8;

 27:11;30:16;32:1;

 69:15;73:20;80:25;

 91:5

memorialize (1) 32:20

mentioned (1) 53:20

met (10) 45:12;46:21,

 25;47:2,12,19;48:10,

 17;88:25;90:12

Mexico (1) 9:8

Miami (2) 9:13,24

Michael (1) 77:7

mid (3) 13:15;65:4,4

might (1) 91:12

Mike (1) 12:8

MILLS (107) 4:23,23,

 23;5:11;16:3,18;17:16;

 18:10,20;19:13;20:18;

 21:3;22:3;25:23;26:10;

 28:22;29:2;30:25;

 33:24;34:6,18;35:12;

 36:10,24;37:9;38:7;

 39:23;40:9;41:10,19,

 25;42:7,21;43:23;

 46:11,15;47:1,10;48:1,

 18;49:6,9;50:8;51:17;

 52:9,19,25;53:8,17,25;

 54:21;55:3,5,11;56:7,

 13,24;57:7,14,22;58:3,

 14,16,23;59:8;60:3,5,

 13,16,25;61:8,12;62:1,

 11,22,24;63:19;65:5;

 67:6,18;68:7;70:4;

 72:3;74:8,20;76:24;

 81:7,14,24;82:7,20;

 83:2,15,24;84:17;85:2,

 25;86:14,20;87:4,22;

 88:12;90:9,16;92:7;

 93:4,24

Milwaukee (2) 8:21;9:5

mind (1) 91:22

minimal (1) 77:23

Minimally (1) 84:20

Minimum (2) 19:2,8

Minneapolis (2) 4:4,19

Minnesota (8) 4:4,20;

 6:7;7:12;8:8,11;69:3,8

Minnetonka (1) 15:8

minutes (2) 63:8;78:19

Mischaracterizes (4)

 36:6;46:9;48:15;74:18

miserably (2) 72:17,20

missed (1) 39:25

missing (1) 40:17

monitor (3) 4:7;53:11,

 15

Montana (1) 7:13

months (4) 11:9;39:10;

 65:10;87:10

more (24) 15:6,14,14;

 19:3;29:22;30:10;

 32:18;53:6;59:5;61:21;

 62:16;65:21;66:5,10;

 72:9;78:10;79:9;81:18;

 84:20;86:2;87:15,21;

 88:6;89:18

most (4) 10:9;51:22;

 67:4;68:2

much (4) 73:1;79:22;

 89:5;91:1

multiple (1) 44:19

multitude (2) 72:15;

 85:6

mundane (2) 15:2,6

Murdock (14) 50:12,13;

 53:24;54:1;56:3,9,15,

 16;59:9;60:14;61:2;

 62:7;63:23;93:12

myself (1) 47:15

N

name (9) 4:16;5:14;

 11:4,13;12:8,20;53:21;

 64:22;87:7

named (1) 18:12

names (1) 42:22

national (1) 10:20

nature (4) 16:19;29:12;

 35:9;55:19

neat (1) 91:20

necessarily (1) 28:2

need (11) 42:14;48:5;

 54:24;63:8;65:17;

 66:15;68:16;90:7,10;

 91:17;92:4

needed (7) 14:13;

 21:19;27:4;30:14;

 66:19;68:22;74:23

needs (8) 32:1;37:21;

 38:21;39:22;70:16;

 71:4,8,10

negative (1) 73:1

New (7) 10:12,13;

 14:10;39:9,10;92:19,

 23

Newt (1) 89:9

next (3) 66:7;69:6;89:6

nice (3) 83:18;91:2;

 92:24

Nine (4) 6:13,14;11:20,

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(4) introduced - Nine

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 441 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

 20

Nobody (1) 42:25

non-attorney (3) 52:18;

 58:11;61:20

None (2) 9:23;18:5

non-exempt (1) 27:12

nor (4) 41:2,2;86:18;

 89:16

Northwest (14) 20:5,7,

 8;21:16;22:25;23:6,25;

 64:15,25;82:21;84:1;

 87:6;88:3,15

notably (1) 10:9

noted (1) 40:15

Number (9) 4:9,13;

 17:14;22:18;53:12,16,

 19;54:10;55:14

numbered (2) 49:5,7

O

Object (21) 19:11;

 21:24;30:23;33:22;

 35:11;37:7,15;39:6;

 48:14;51:10;54:11;

 55:18;57:20;58:6;61:6,

 6;63:3;65:2;86:11,17;

 87:1

objecting (2) 58:7;61:9

Objection (55) 15:23;

 16:16;17:13;18:3,17;

 20:13,24;25:20;26:7;

 28:19,25;34:1,17;36:5,

 14;40:1;41:7,13,22;

 42:18;43:20;46:8,22;

 47:7,21;49:18;53:7;

 54:17;56:10,22;57:2;

 59:19;60:15;61:18,19;

 67:3,16,25;68:11;

 71:24;74:4,17;76:21;

 80:17;81:11;82:15,24;

 83:11,21;84:13,25;

 85:21;87:19;88:8;

 92:18

objections (1) 42:3

observational (1) 34:4

observe (2) 33:5;86:15

occasion (2) 9:7,8

occasions (1) 9:6

occurred (1) 13:23

occurring (1) 58:5

off (7) 53:4,10;60:24;

 82:1;83:19;84:5;93:25

offered (1) 76:18

office (6) 16:2;34:23,

 24;35:1,5;40:8

official (1) 13:19

Ohio (1) 10:7

once (5) 19:2,8,25;

 67:11;68:21

one (35) 11:23,24,24;

 17:18;21:15;22:9,12,

 13;30:24;39:7,20;

 43:11;45:15;48:23;

 49:6;54:23,23;62:3;

 67:20;68:9,23;69:2;

 71:22;73:18;79:9,12;

 81:6;84:2,3;87:16;

 88:6;89:21;90:1,3,21

one-on-one (1) 32:17

ones (1) 18:4

only (13) 8:4,17;12:9;

 22:12;30:24;42:5;

 43:11,21,24;51:15;

 72:21;85:5;90:20

onset (1) 24:17

Ontario (2) 44:15;45:17

open-answered (1)

 58:10

open-ended (1) 58:22

operation (2) 17:22;

 24:25

operations (4) 11:6;

 13:1;69:4,5

opinion (2) 21:10;78:16

opportunities (3) 30:8;

 32:2,3

opportunity (11) 21:13;

 44:5;59:17;76:13;

 78:10;86:19;91:5,12;

 92:1,2,5

opposed (1) 14:15

order (1) 30:14

organization (8) 14:8;

 16:24;21:7;30:16,17;

 38:16;52:15;72:12

organizational (1) 22:2

originally (1) 66:11

others (4) 17:9;34:10,

 15;72:24

ourselves (1) 73:19

out (16) 8:21;10:12;

 19:4;35:4;37:23;40:16,

 24;42:14;43:11;47:24;

 54:13;66:6;75:23;76:6;

 81:5;89:23

over (3) 24:14;77:5;

 86:4

overall (3) 30:15;40:5;

 69:12

overcapacity (5) 65:18;

 66:18;68:18;75:3;

 79:22

overrepresentation (1)

 21:11

overstaffed (3) 65:15;

 67:9;79:21

own (1) 67:8

ownership (1) 7:23

P

pages (1) 48:23

painful (1) 91:24

PARKER (100) 5:1,1;

 15:23;16:16;17:13;

 18:3,17;19:11;20:13,

 24;21:24;25:20;26:7;

 28:19,25;30:23;33:22;

 34:1,17;35:11;36:5,14;

 37:7,15;39:6;40:1;

 41:7,13,22;42:3,18;

 43:20;46:8,22;47:7,21;

 48:14;49:4,18;50:3;

 51:9,21;52:12,22;53:4,

 22;54:11;55:2,4,9,18,

 25;56:10,22;57:2,12,

 20,24;58:6,15,20;59:3,

 19;60:8,15;61:6,9,14;

 62:14;63:3,10;65:2;

 67:3,16,25;68:11;

 71:24;74:4,17;76:21;

 80:17;81:11;82:15,24;

 83:11,21;84:13,25;

 85:21;86:11,17;87:1,

 19;88:8;90:6,11;92:18;

 93:6,10,23

part (4) 22:1;39:19;

 53:23;67:5

particular (7) 38:11,13,

 24;39:4,8;67:15;90:1

particularly (1) 90:2

partner (2) 30:4;32:6

partners (2) 15:11,11

partnership (2) 27:5;

 37:25

party (2) 5:22;93:2

past (1) 87:18

path (1) 65:8

pattern (1) 41:17

Paul (3) 8:8,11;24:15

Paulo (1) 9:5

payroll (1) 15:4

peers (1) 75:7

Pelham (6) 64:20;

 78:23;79:11,14,17,24

people (17) 11:19,21;

 13:8;14:13;15:13,13;

 27:8;29:15;30:5,13,15;

 32:8;37:22;38:8;40:21;

 69:12;91:25

perceived (1) 78:7

percent (2) 17:2;35:4

perform (2) 19:19;75:8

performance (25)

 27:10;29:15;33:2,8,17,

 21;34:5,8,14;36:1;

 37:13;38:20;69:14;

 71:5,6,14,15;72:2;

 73:2;80:4;84:23;86:9,

 16,25;88:20

performance-related (3)

 84:6,11;85:7

performed (5) 15:18;

 16:14;18:23;72:11;

 91:16

performing (3) 15:22;

 69:20;72:6

perhaps (1) 75:24

period (3) 74:10;76:15;

 81:15

Permacel (2) 10:13,21

permanent (1) 76:18

permit (1) 59:6

permitted (1) 62:16

person (8) 51:25;53:1;

 68:23;69:2,4;70:3;

 74:24;91:2

personal (2) 34:7,11

personally (3) 42:8,11;

 86:15

personnel (1) 27:13

perspective (2) 14:9;

 66:3

pertains (1) 73:21

Perusing (3) 27:20;

 49:3,8

Pfieffer (2) 85:13,24

P-F-I-E-F-F-E-R (1)

 85:14

Pfieffer's (1) 86:1

Phoenix (16) 12:12;

 18:13;19:4,9,17;24:24;

 25:4;38:9,10;42:15,23;

 44:1,22;46:2;69:4,21

picture (1) 92:21

pieces (2) 8:24;63:12

Pittsburgh (1) 17:21

place (3) 4:19;81:5;

 89:4

Plaintiff (1) 4:24

plan (2) 13:22;90:22

Pland (2) 12:20;85:12

P-L-A-N-D (1) 12:21

planning (1) 27:8

plans (3) 27:7;30:7;

 31:25

plant (1) 29:8

play (3) 14:4;24:11;

 26:23

pleasant (1) 78:15

please (7) 4:21;5:5;

 11:13;25:22;47:11;

 55:24;90:25

pm (6) 4:5,8;53:12,16;

 82:2,6

point (7) 10:21,23;59:3;

 72:25;77:11;93:13,14

portion (1) 49:13

position (34) 9:2;12:1;

 21:22;23:12;24:12;

 31:8;36:12,23;37:1;

 64:13,25;66:22;67:15;

 68:19;70:18,21;72:13;

 74:12,22;75:2,4,6,17;

 76:8,19;77:23;78:4,5,

 14,25;79:6;82:19,23;

 91:7

positions (4) 7:18;8:16;

 23:18;35:21

positive (1) 69:14

possible (2) 28:16,23

post-discussion (1)

 35:23

postgraduate (1) 9:22

Post-restructure (1)

 21:25

Post-restructuring (1)

 43:13

post-transformation (1)

 35:24

potentially (5) 29:13;

 35:18,20;90:23;91:17

preceding (1) 60:9

pregnant (1) 75:19

preliminary (1) 13:21

preparation (4) 63:17;

 64:9;89:10;90:17

prepare (2) 30:9;88:23

prepared (1) 28:14

Prescott (1) 45:1

present (2) 77:16,17

presented (1) 89:17

president (7) 7:2,4;

 8:10;11:6,18;19:18;

 91:3

pretty (1) 89:5

previous (1) 69:18

previously (6) 31:23;

 40:15;65:16;72:5,16;

 86:5

pride (1) 73:19

primarily (3) 35:24;

 38:15;89:3

primary (1) 80:24

prior (17) 11:10;14:18;

 22:4;24:20;25:1,7;

 28:18;29:4;33:15,19;

 36:6;46:9;48:15;59:18;

 63:16,23;74:18

privilege (13) 51:14,15;

 52:7,10;54:14,18;55:1,

 3,6;57:5;58:13;59:2;

 61:20

privileged (8) 49:21;

 52:14;58:9;60:1;61:11,

 15;63:5,14

privileges (1) 52:8

privy (2) 40:2;85:8

Probably (10) 33:12;

 63:8;65:4,9,12;79:10,

 14;80:22;83:13;87:10

problems (3) 73:5,8,17

process (6) 26:17,21;

 35:15,16;65:7;67:24

processing (2) 7:25;8:4

product (5) 52:8;54:18;

 57:5;59:25;61:11

production (1) 7:24

products (2) 8:1,1

professional (1) 78:13

professionally (1) 78:17

profound (1) 91:3

progression (1) 30:11

promote (1) 30:12

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(5) Nobody - promote

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 442 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

promotion (2) 37:6;

 83:18

proper (1) 54:17

proposed (3) 21:15,18;

 66:21

prospects (1) 20:2

provide (10) 14:8,9,11,

 14;34:4;49:16;66:8;

 68:4;85:15;92:1

provided (8) 14:12,17;

 17:6;44:5;63:2,12;

 70:23;71:2

providing (5) 26:25;

 31:16,17;70:11;91:4

prudent (1) 66:16

public (1) 60:4

puppy (5) 92:20,21,24,

 25;93:2

purports (1) 27:22

purpose (4) 19:9,17;

 57:4;93:22

purposes (1) 52:5

Q

qualified (1) 75:5

quarter (3) 19:8,25;

 75:21

quarterly (1) 19:19

R

Rachael (39) 25:13;

 34:21;35:6;37:11,13,

 18;38:11,18;40:11;

 43:1;50:23;64:18;

 65:13;66:21;68:14;

 70:7,10,25;71:11,13,

 21,25;72:19,21;73:14;

 76:11;77:19,25;78:2,

 17;80:11,14,20;86:4,

 21,23;90:4,21;91:6

Rachael's (1) 25:14

rather (2) 22:4;55:3

ratings (1) 69:14

reach (4) 37:23;40:16,

 24;42:14

read (9) 27:16;46:14;

 49:1,12;62:1,2,5;63:7,9

reading (1) 73:9

real (1) 86:19

really (9) 31:15;42:13;

 46:2;49:11;69:17;

 83:17;87:23;91:23;

 92:6

reason (1) 80:24

reasons (2) 72:16;

 78:21

recall (25) 6:21;13:16;

 24:18;27:20;33:13;

 43:3,5;50:19;51:1,2;

 63:25;72:23,24;77:22;

 82:13;83:3,4;84:22;

 85:3,6,18;86:7;87:3;

 88:22;90:21

received (3) 42:5;

 84:21;93:12

recess (2) 53:13;82:3

recognize (1) 30:13

recommend (3) 36:15,

 25;37:2

recommended (1)

 36:11

record (8) 4:7;5:14;

 53:5,11,15;60:24;82:2,

 5

recruiting (12) 23:15;

 35:20;76:9,12,14,15,

 18;77:3,9;91:8,10,18

reduce (2) 68:22;91:23

reduction (5) 66:12;

 68:18;82:18;83:20;

 84:6

regard (16) 6:3;15:4,

 12;17:7;18:8;30:5;

 34:5;37:20;38:19;40:6;

 65:18;66:9;68:25;

 71:14;90:22;91:14

regarding (3) 35:7;

 37:12;56:17

region (20) 7:6;8:3;

 20:5,7,9,15;21:1,16,20;

 23:1,6,25;64:15;65:1;

 66:1;82:21;84:1;87:6;

 88:4,15

Regional (7) 7:2,3;8:9;

 11:18;13:12;19:18;

 34:23

regions (6) 66:20;

 87:13,15;88:7,11,14

relate (1) 86:23

related (2) 6:5;73:21

relations (1) 15:5

relationships (1) 20:4

relative (5) 18:19;21:8;

 35:22;66:19;77:23

relatively (1) 89:14

Relevance (3) 87:19;

 88:8;92:18

relief (1) 78:8

relying (2) 66:24;71:21

remember (12) 6:21;

 26:20;64:8;65:10;

 77:13,25;78:1;82:11;

 84:9;86:12;89:25;90:1

remiss (1) 93:3

Reno (1) 7:14

repeat (3) 25:21;55:23;

 60:19

rephrase (3) 23:3,21;

 81:17

report (2) 25:2,12

reported (2) 13:9,13

reporter (2) 4:16;5:5

reporting (4) 11:21;

 12:14;16:6;25:8

reports (1) 12:10

represent (1) 4:22

representation (2) 66:1;

 68:5

representative (7) 10:7;

 14:7;22:8;24:15,16,24;

 37:6

representatives (5)

 15:19;16:15;18:24;

 25:2;35:17

representing (2) 4:18;

 6:19

request (3) 81:9,21,23

requested (1) 62:5

required (2) 16:25;

 68:20

residing (1) 69:9

resistance (1) 18:6

resistant (3) 17:25;

 18:5;79:18

resisted (1) 17:10

resources (14) 13:2,5,9,

 12,17;14:5;20:6;24:14;

 25:15;34:3;50:14;

 85:13;86:2,3

respect (6) 49:19,23;

 58:2;60:9;62:20;85:16

respective (2) 16:8;

 22:10

respond (1) 38:2

responding (1) 52:6

response (6) 38:1;

 51:24;58:11,22;59:4;

 91:19

responsibilities (1)

 36:22

responsibilities' (1)

 88:13

responsibility (4) 8:5;

 10:20;44:6;72:10

Responsible (1) 7:22

responsiveness (4)

 38:3,20;39:22;70:15

rest (2) 11:25;66:20

restate (1) 19:14

restrictions (2) 85:5;

 88:21

restructure (2) 13:20,23

restructured (1) 14:1

restructuring (35)

 13:16,18;14:4,24;

 15:21;17:12;18:2,11,

 16,19;19:16;20:21;

 22:1,16,17,22;23:6,20,

 23;24:21;25:1,7,11,17,

 24;26:11,14,22;29:10;

 30:20;33:15,19;35:15;

 37:12;87:24

retail (1) 10:8

review (2) 33:8,21

reviews (5) 19:19;

 71:15,17,18;72:2

Richard (3) 12:20,23;

 85:12

rid (1) 67:1

right (24) 12:7;13:3;

 17:15;22:19;23:23;

 24:1;27:23;28:1,8,12,

 13;29:7;42:12;44:9,11,

 20,22;45:3;52:21;56:4;

 73:11;76:16;79:11,23

right-size (1) 66:19

riss (1) 76:4

road (1) 61:25

rock (1) 72:10

role (33) 14:4;19:18;

 21:8;22:7;23:14;24:11;

 26:23;27:3;29:9;31:14,

 20;32:23;37:2,25;44:6;

 65:15,19;66:18;68:5;

 69:17,20,22,23,24,25;

 70:6,10,12;75:8;76:1;

 84:10;86:4;91:16

roles (2) 23:15,17

running (1) 72:14

Ruth (5) 49:22;50:10,

 11,12;51:25

S

Sacramento (1) 12:23

sales (7) 10:6;11:24;

 38:25,25;39:9,15;40:7

same (5) 17:14;22:6;

 34:1,23;42:3

San (3) 9:5;44:13;

 45:23

Santa (3) 12:24;31:5;

 45:20

Sarah (7) 50:12,13;

 53:21,23;54:1,4;55:13

saw (3) 26:20;29:3;

 63:25

saying (3) 47:5,20;

 91:11

Schneider (1) 77:8

second (3) 63:10;

 68:24;82:19

seeing (1) 27:21

selection (1) 69:7

selfishly (1) 21:9

sellers (1) 39:9

senior (3) 11:6,23;

 49:22

sense (2) 66:6;89:22

sensitive (1) 65:24

sent (3) 90:22;91:11;

 92:21

separate (2) 9:6;13:2

September (5) 74:6,14;

 75:11,14;77:13

serve (1) 23:5

served (1) 10:16

service (4) 8:1;22:18;

 40:8;71:6

Services (5) 4:11;6:4,5,

 24;7:16

servicing (1) 84:1

serving (1) 22:25

sets (1) 91:14

Seven (2) 7:5;11:20

several (2) 10:8;68:12

share (2) 40:3;73:24

shared (10) 31:7;

 40:20;41:17;68:14;

 71:11,12;72:1,5;89:1;

 91:6

short (1) 78:18

show (3) 27:14;28:11;

 39:17

side (2) 15:13;30:5

Siggerud (13) 25:13;

 34:22;37:11;50:23;

 52:3;64:18;70:25;

 77:19;78:17;86:5,21,

 23;90:4

situated (2) 69:19;75:8

Six (3) 11:17;39:10;

 66:7

skill (1) 91:14

software (1) 8:24

sole (1) 87:8

somebody (2) 52:15;

 92:1

someone (2) 36:11;

 51:19

someone's (1) 73:2

sometime (6) 26:11;

 50:20,23;75:20,21;

 83:5

Sorry (1) 82:13

South (1) 4:3

Southern (4) 44:2,4,7,8

specialist (1) 10:17

specific (21) 6:22;7:23;

 18:4,18;29:22;33:18;

 40:18;41:5,8,11,16,20;

 42:1;43:16;63:12;76:5;

 77:14;86:13;87:21;

 90:8,14

specifically (23) 20:1,

 16;23:7;24:13;27:12,

 20;31:6,12,23;33:13;

 37:13,24;39:13,19;

 40:24;42:20;50:19;

 59:22;71:17;72:23;

 77:4;79:3;88:10

specifics (4) 40:3;

 72:25;84:16;88:10

speculation (4) 28:20;

 29:1;76:22;80:18

spell (1) 11:13

spend (1) 78:10

springs (3) 12:24;31:5;

 45:20

St (3) 8:8,11;24:15

staff (1) 38:5

standpoint (3) 38:17;

 57:6;84:20

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(6) promotion - standpoint

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 443 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

star (1) 72:10

started (4) 10:4,5;

 35:14;65:8

state (4) 4:22;5:13;6:9,

 11

stated (2) 65:13;78:8

States (3) 4:12;10:18;

 87:14

stay (1) 76:20

still (3) 52:18;82:8;83:8

Stinson (2) 4:2;5:2

stop (1) 59:1

stores (2) 10:8,9

straight (1) 46:24

strategic (2) 15:15;32:5

strategy (1) 58:2

Street (3) 4:3,3;5:2

strengths (1) 32:3

strike (10) 25:16;61:1;

 63:20;64:6;67:12;84:3,

 4,4;85:9;86:22

strong (1) 81:1

structure (2) 14:10;69:1

structured (3) 14:25;

 20:11;70:19

struggling (3) 39:11;

 69:22;70:20

studies (1) 9:22

subject (1) 65:23

subjective (1) 18:7

subsequently (1) 17:22

succeed (2) 69:17;92:2

succession (1) 27:8

Suite (1) 4:4

suited (2) 23:14;35:18

Sun (2) 44:17;45:17

supervise (3) 11:19;

 18:12;22:21

supervised (1) 32:21

supervising (8) 16:12;

 17:11,25;19:23;29:9,

 24;30:19;88:18

supervisor (5) 10:25;

 11:8,11,16;77:8

support (4) 14:14;

 15:12;20:25;27:7

supported (1) 9:20

supporting (3) 31:15;

 43:19;69:16

supposed (1) 31:20

sure (8) 10:5;28:5,5;

 29:11;39:7;47:8;56:11;

 85:6

surrounding (1) 35:25

swear (1) 5:5

sworn (1) 5:8

systems (1) 8:24

T

tactical (1) 15:1

tails (1) 89:16

talk (8) 19:1;20:19;

 31:19;63:11;76:25;

 77:2;79:2,4

talked (3) 43:6;48:8;

 89:3

talking (6) 15:17;19:12;

 20:16;38:8;53:19;

 63:13

tape (6) 10:14,14,15,

 15;53:12,16

task (2) 16:21;23:16

tasks (8) 15:7,16,17,22;

 16:4,13;18:22;30:10

team (16) 17:8;27:11;

 30:16;31:18,25;33:14;

 37:20;38:5;39:9;40:6,

 24;69:15;73:20;80:24;

 81:3;91:5

teams (2) 19:20;32:9

telling (1) 66:24

temporary (2) 76:14;

 91:7

tenure (1) 81:20

term (1) 22:6

terminate (4) 61:24;

 74:2;80:7;84:19

terminated (4) 50:21;

 75:10;77:12;85:19

termination (3) 6:3;

 52:2;85:16

terminations (1) 78:13

terms (1) 20:11

testified (5) 46:5;51:18;

 59:23;88:2;93:11

testifies (1) 5:9

testify (1) 29:3

testimony (5) 36:6;

 46:10;48:15;74:9,18

theory (1) 20:15

Theresa (1) 77:8

thinking (1) 79:16

Third (1) 69:6

thoroughly (1) 63:7

though (2) 36:2;58:17

thought (4) 36:12;

 65:17;66:11;91:21

three (17) 21:1,4,14,15,

 19;22:12;23:24;24:12;

 37:17;48:23;65:9,9,17;

 67:20;79:12,18;88:3

Thursday (1) 35:5

timeframe (13) 6:15;

 19:12,15;34:22;65:4,

 11,12;75:12,22;76:5,7;

 77:13;78:6

times (3) 5:19;37:23;

 40:18

Timm (6) 11:12;49:22;

 50:10,11,12;51:25

title (4) 7:1;11:5;25:14;

 86:1

titles (1) 11:22

today (1) 93:11

Today's (1) 4:15

Told (11) 31:23;32:11;

 34:9,15;72:19;77:16,

 18;80:14,20;85:10,18

took (1) 10:19

top (1) 27:22

towels (1) 8:2

train (1) 30:10

training (1) 27:7

transmitted (1) 16:9

transpired (1) 78:2

travel (6) 20:1;85:4,4,

 11;86:10;88:20

traveling (5) 19:9,17,

 21;35:2,3

true (1) 46:7

trust (1) 80:24

try (1) 66:5

trying (3) 20:2;30:12;

 65:10

Tucson (3) 44:24;

 45:25;46:1

Tuesday (1) 35:5

turned (1) 76:6

Twice (1) 5:20

Twin (1) 22:11

two (13) 8:17;9:6;

 12:18;21:2,5;33:12,14;

 43:21,24;48:23;75:9;

 89:14;93:6

Twofold (1) 70:22

two-hour (1) 89:2

types (1) 32:13

typically (3) 22:13;

 32:13;35:4

U

ultimately (2) 36:18;

 80:22

Um-hmm (2) 24:2;

 45:21

unaccounted (1) 40:18

unavailable (2) 40:23;

 41:21

unaware (6) 45:16;

 60:12;81:13,15,23;

 93:17

under (4) 39:10;52:10;

 81:9,22

underperforming (1)

 69:22

underrepresented (1)

 21:7

understood (1) 56:2

unfortunately (1) 78:4

unhappy (1) 18:22

United (2) 4:12;87:14

University (2) 9:13,25

unless (1) 36:12

unresponsive (6)

 40:15;41:12;42:9;

 71:3,7,9

unresponsiveness (2)

 37:21;41:18

unsure (2) 47:12;48:16

up (6) 10:4;13:15;

 39:17;46:13;87:23;

 93:7

US-1 (3) 7:7;20:8,11

use (1) 52:23

V

vacation (1) 89:7

Valley (3) 44:17;45:1,

 17

value (1) 31:18

various (1) 12:3

verbal (1) 32:18

versus (2) 4:10;23:15

vice (7) 7:2,3;8:9;11:6,

 18;19:18;91:3

video (5) 4:7,8,18;

 53:11,15

VIDEOGRAPHER (8)

 4:6,17;5:4;53:10,14;

 82:1,4;93:25

violate (1) 55:5

visit (1) 19:4

visited (2) 31:9,11

visiting (1) 45:16

voiced (1) 42:25

voicemail (2) 93:13,15

Volume (1) 4:8

voluntarily (2) 82:14;

 83:16

W

waived (1) 51:15

waiving (1) 61:18

walk (1) 10:2

Washington (1) 89:7

way (11) 20:23;45:15;

 57:15;60:21;61:3;62:8;

 67:9;79:15;81:6;90:3;

 91:21

Ways (1) 29:13

wedding (1) 89:8

week (4) 19:2;40:19;

 64:2,2

weekly (1) 32:17

weeks (1) 66:8

weren't (2) 36:16;67:7

Western (1) 7:12

WH (1) 10:23

what's (7) 7:1,21;11:5;

 34:9;56:25;57:19;

 64:22

whatsoever (2) 31:18;

 81:23

Williams (29) 4:10,25;

 24:1,6,20;25:8;31:8,

 11;33:2,5,9,11;35:7;

 36:25;40:14;42:17;

 50:20;56:18;59:16;

 60:20;69:21;70:5;

 74:16,25;80:4;81:8,16;

 83:5;92:9

Williams' (10) 34:8,14;

 52:2;59:12;60:18,22;

 61:5;62:10;67:14;

 81:20

win (1) 20:2

win-win (1) 92:3

Wisconsin (3) 7:13;

 8:21;9:5

withdraw (1) 23:21

within (8) 30:13,16;

 32:8;37:22;38:16;52:7;

 54:14;91:14

without (1) 63:13

witness (71) 5:5,7;16:1,

 17;17:14;18:4,18;

 20:14,25;21:25;25:21;

 26:9;28:21;30:24;

 33:23;34:2;36:7,15;

 37:8,16;39:7;40:2;

 41:8,15,24;42:4,19;

 43:21;46:23;47:8,23;

 48:16;49:8;50:1,6;

 53:24;55:23;56:5,11,

 23;57:9;58:23;60:12;

 62:4,12;63:6;65:3;

 67:4,17;68:1,12;71:25;

 74:5,19;76:23;80:19;

 81:13;82:17;83:1,13,

 23;84:15;85:1,23;

 86:12,18;87:2,20;88:9;

 90:20;92:19

Woods (1) 4:24

word (3) 17:9;18:7;

 48:5

word-for-word (1) 78:1

words (2) 67:7,19

work (16) 8:13,18,19;

 10:11,22;13:21;17:7;

 26:17,20;34:21;52:7;

 54:18;57:5;59:25;

 61:10;65:21

worked (2) 8:20;34:3

working (6) 10:5;23:20,

 25;32:6;33:5;77:5

works (1) 50:14

Wow (1) 80:19

written (5) 25:18,25;

 26:3;28:17;29:3

wrong (1) 79:11

Y

year (4) 7:17;75:18;

 83:13,14

years (8) 6:13,14;7:5;

 11:17;33:12,14;37:17;

 80:1

yes-or-no (1) 55:10

yesterday (2) 27:15;

 48:21

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(7) star - yesterday

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 444 of 505
Williams vs. G & K Services, Inc. 

2:15-CV-01744-DJH

Eric McNaul

May 12, 2016

Yuma (1) 45:3

1

1 (11) 4:8,9;48:21;

 53:12,19;54:10;55:14;

 63:1,23;64:1,10

1:04 (2) 4:5,8

10 (2) 39:9;78:18

100 (1) 17:2

12 (1) 4:15

120 (1) 10:8

12th (2) 4:2;7:17

15 (1) 11:9

150 (1) 4:3

17 (2) 10:18;28:6

18 (1) 87:10

1988 (1) 10:21

2

2 (1) 53:16

2:07 (1) 53:12

2:15-cv-01744-DJH (1)

 4:14

2:20 (1) 53:16

2:52 (1) 82:2

2012 (4) 13:15,17,20,

 22

2013 (17) 13:24;14:6,

 19;17:12,25;18:11;

 19:15;20:17,19;23:20,

 24;25:4,18,25;34:22;

 64:13;87:25

2014 (5) 28:6,10,18;

 29:5;63:23

2016 (2) 4:2,15

2300 (1) 4:4

28 (1) 80:1

29 (1) 28:10

3

3:10 (1) 82:6

30 (1) 63:8

6

60 (1) 35:4

7

7 (2) 27:15;39:9

70 (1) 35:4

8

83 (1) 9:15

Min-U-Script® Coash & Coash, Inc.

602-258-1440 www.coashandcoash.com

(8) Yuma - 83

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 445 of 505
EXHIBIT L

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 446 of 505
In The Matter Of:

Brandy Williams vs. G&K Services, Inc.

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Arizona Reporting Service, Inc.

2928 North Evergreen Street

Phoenix, AZ 85014-5508

(602) 274-9944

www.az-reporting.com

Original File 07-17-2013 Conversation Brandy Williams and Rachel Siggerud.txt

Min-U-Script® with Word Index

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 447 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 1

 (1) UNITED STATES DISTRICT COURT 

 (2) DISTRICT OF ARIZONA 

 (3) Brandy Williams, ) )

 (4) Plaintiff, ) )

 (5) vs. ) Case No. 15-cv-01744-PHX-DDD )

 (6) G&K Services, Inc., a ) Minnesota corporation, ) (7) Jane and Johns Doe 1-100; ) Black Corporation 1-100; ) (8) White Partnership 1-100, ) )

 (9) Defendant. ) __________________________) Telephonic Conversation (10)

 

(11)

 TRANSCRIPT OF AUDIO RECORDED PROCEEDINGS

(12)

 Phoenix, Arizona

(13) July 17, 2013 

(14)

 

(15) TELEPHONIC CONVERSATION BETWEEN BRANDY WILLIAMS AND RACHEL SIGGERUD

(16)

 

(17)

 (File name: WILLIAMS-000317 - 130717

(18) Recorded Phone Call (1)) 

(19)

 

(20) ARIZONA REPORTING SERVICE, INC. Audio Transcription Specialists (21) 2928 North Evergreen Street Phoenix, Arizona 85014-5508

(22)

 

(23)

 

(24) Deanna C. Bakurza, RPR Certified Reporter (25) Certification Number 50412

Page 2

 (1) (Commencement of audio file: 00:37:03.01)

 (2)

 (3) MS. WILLIAMS: Uh-huh.

 (4) MS. SIGGERUD: The person who's currently in

 (5) postings is gonna have to move to customer service. Is

 (6) somebody that has good customer service skills or has

 (7) demonstrated that -- has an interest in working with our

 (8) customers. Because if they don't and they, you know,

 (9) would rather just kind of do individual work --

(10) MS. WILLIAMS: Uh-huh.

(11) MS. SIGGERUD: -- we don't want to just shove

(12) somebody into a job that they might not like.

(13) MS. WILLIAMS: Right. Okay.

(14) MS. SIGGERUD: So I think there's -- I think

(15) there's a good opportunity to look at the entire office

(16) and evaluate their skill sets.

(17) MS. WILLIAMS: Okay.

(18) MS. SIGGERUD: If it's a position that somebody

(19) might perceive as better than there's, then I think

(20) there's a good opportunity to post it --

(21) MS. WILLIAMS: Okay.

(22) MS. SIGGERUD: -- and see who falls where. Um,

(23) that being said, if nobody applies for either, then I

(24) think we probably need to talk about -- let's look at,

(25) maybe, moving people.

Page 3

 (1) MS. WILLIAMS: Okay.

 (2) MS. SIGGERUD: And I think the -- one of the

 (3) ways that she could, maybe, get folks to apply for them

 (4) or be interested in them, and I don't think that it's

 (5) necessarily an outside posting, I think it's maybe more

 (6) of an internal.

 (7) MS. WILLIAMS: Right. Yeah, we did talk about

 (8) that. And I did ask her, you know, would you like this

 (9) to be internal, external? I said, it sounds as if, you

(10) know, it maybe just could -- could just be an internal

(11) posting. She goes, no, definitely. I only want to

(12) offer it internally.

(13) MS. SIGGERUD: Yeah.

(14) MS. WILLIAMS: As, you know, she felt that she

(15) would be able to just appropriately move around

(16) everyone. But she did say she was gonna post for the

(17) receptionist position portion. Because that's the one

(18) that she was gonna replace. But she felt the other two,

(19) that she could move individuals around to better benefit

(20) the business.

(21) MS. SIGGERUD: Sure. It's, um -- it's -- if

(22) it's helpful. I mean, because she could do it either

(23) way. I mean, she's entitled to -- you know, in her

(24) position, she's able to go up to each of these people

(25) and say, hey, this is the way, you know, business needs

Page 4

 (1) are changing. I would like you to move into this

 (2) position. You know, ultimately the easiest way to do

 (3) that would be to take the receptionist, put the

 (4) receptionist in the customer service position. Leave

 (5) the poster where she is.

 (6) MS. WILLIAMS: Uh-huh.

 (7) MS. SIGGERUD: Um, she can approach it from a

 (8) trying to round out your skill set, make sure you've

 (9) got, you know, some other things in your toolbox.

(10) There'll be a raise included with it. But then the

(11) other piece of that is the: Do we have other people who

(12) would be also in need of rounding out their skill set?

(13) MS. WILLIAMS: Uh-huh.

(14) MS. SIGGERUD: It's a good time to, maybe, make

(15) more changes. So aside of just these two, do we look at

(16) broadening everybody's skill set, doing more

(17) cross-training, having everybody kind of rotate?

(18) MS. WILLIAMS: She said she does have everyone

(19) cross-trained and that everyone can do all the other

(20) positions.

(21) MS. SIGGERUD: So then why these two?

(22) MS. WILLIAMS: Um, she said she felt that the

(23) one that she wants to move into this open space of this

(24) employee leaving, that she -- her skills best fit this

(25) position. And she said, then, the reason why she wants

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Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 5

 (1) to move the receptionist, is because she feels that she

 (2) still needs some improvement because her English is

 (3) still not all that great, but she feels like if she

 (4) moves her into this customer services role, that she'll

 (5) be able to gain more experience with talking to people

 (6) and working with customers and it'll prepare her to be

 (7) able to be more cross-trained on all the other

 (8) positions.

 (9) MS. SIGGERUD: Is this because she talks in

(10) Spanish to employees in the plant?

(11) MS. WILLIAMS: Um, I think sh- -- yeah, I think

(12) that's a portion of it. I think she said that her

(13) English was a little -- a little rusty. And she said

(14) that she does do pretty well at it, she said, but

(15) sometimes she kind of struggles with some understanding.

(16) And she said she thinks that, um, she could improve.

(17) Because that was part of the discussion when we

(18) had the discussion around their IDPs also. Was that,

(19) you know, she did come from the plant and she did work

(20) her way up, and you know she did learn English and we

(21) did kinda talk about maybe, like, um, having

(22) conversations with her around, you know, improving her

(23) English or going to a learning center or, um, someplace

(24) like that to help, like, improve her knowledge around

(25) it.

Page 6

 (1) MS. SIGGERUD: I think we need to be very, very

 (2) careful.

 (3) MS. WILLIAMS: No. No. Well, I -- I told her --

 (4) just her and I -- I talked about that, we didn't -- we

 (5) didn't -- she didn't have that discussion with her

 (6) but . . .

 (7) MS. SIGGERUD: English is not a bona fide

 (8) occupational qualification for any --

 (9) MS. WILLIAMS: Right.

(10) MS. SIGGERUD: -- position here.

(11) MS. WILLIAMS: Yeah.

(12) MS. SIGGERUD: So the question I would have --

(13) she comes from the plant?

(14) MS. WILLIAMS: Uh-huh.

(15) MS. SIGGERUD: Does -- where are -- where do her

(16) computer skills lie? On a spectrum of doesn't know how

(17) to turn it on to -- office job here because we've done

(18) that before in other locations where we've promoted

(19) people from the plant and we've had some folks that have

(20) struggled significantly with being able to, you know,

(21) write good e-mails, to writing at all, use the

(22) technology.

(23) MS. WILLIAMS: Uh-huh.

(24) MS. SIGGERUD: So that would be something that

(25) she should probably be aware of too.

Page 7

 (1) MS. WILLIAMS: Okay.

 (2) MS. SIGGERUD: If it's somebody who's a

 (3) receptionist and doesn't really need to use much in the

 (4) way of computers right now. Because she'll be needing

 (5) to be able to accurately use multiple different systems

 (6) as a poster.

 (7) MS. WILLIAMS: Okay.

 (8) MS. SIGGERUD: So we should definitely look at

 (9) assessing her, um . . .

(10) MS. WILLIAMS: Computer skills.

(11) MS. SIGGERUD: Computer skills.

(12) MS. WILLIAMS: Okay.

(13) MS. SIGGERUD: So . . . And the first thing I

(14) think to do would be for -- so I -- I think

(15) there's quali- -- or I think there's value in posting

(16) the position.

(17) MS. WILLIAMS: Okay.

(18) MS. SIGGERUD: Um, and then I think there's

(19) value in having Melissa approach both of these

(20) individuals to say, Hey, you know what, here's the

(21) thing. I'd really like you to think about applying for

(22) this role.

(23) Um, I think what we'd want to do is post one

(24) first and then the other. So we've got the customer

(25) service position opening up.

Page 8

 (1) MS. WILLIAMS: Uh-huh.

 (2) MS. SIGGERUD: So I think that we would open

 (3) that one first, see who applies, and it doesn't have

 (4) to -- maybe just a few days even. Reach out to the --

 (5) the person that she's interested -- the poster, say,

 (6) hey, I'd really like you to apply for this. This is why

 (7) I think it's a great fit, and it's gonna be a very

 (8) positive thing. Ultimately, if the employee says

 (9) absolutely not, I don't want to do it, so be it.

(10) MS. WILLIAMS: Okay.

(11) MS. SIGGERUD: You know, if it's a position with

(12) more responsibilities then I think that we should look

(13) about giving them a bump. Not to $17, but maybe it's a

(14) $0.50 raise.

(15) MS. WILLIAMS: Uh-huh.

(16) MS. SIGGERUD: You know, and then from the

(17) receptionist to the poster, same thing. And then if

(18) she's interested, you know, $0.50 raise, whatever. Then

(19) we can backfill the receptionist. But regardless if

(20) either of these folks really say, I really don't want to

(21) do that. What we don't want to do is just move 'em into

(22) it anyway.

(23) MS. WILLIAMS: Okay.

(24) MS. SIGGERUD: So. . . Make sense?

(25) MS. WILLIAMS: Yep.

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Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 9

 (1) MS. SIGGERUD: All righty.

 (2) MS. WILLIAMS: That makes great sense.

 (3) MS. SIGGERUD: Okay. Yeah, let me know how

 (4) it -- how it goes. I think -- I'm trying to think if we

 (5) wanna -- I don't know -- I would work with Marissa. I

 (6) think she does office, doesn't she?

 (7) MS. WILLIAMS: Yep.

 (8) MS. SIGGERUD: I would work with her to see if

 (9) we even need to post it into --

(10) MS. WILLIAMS: Okay.

(11) MS. SIGGERUD: Either way it would be internal

(12) but, um, I would ask her whether she thinks we need to

(13) or not. Since pretty much all of the jobs feel like are

(14) very equivalent. It sort of feels like we're working

(15) with, you know, in the plant if we have a level 2 job

(16) open.

(17) MS. WILLIAMS: Uh-huh.

(18) MS. SIGGERUD: We don't necessarily put it into

(19) [unintelligible], we post it in the plant.

(20) MS. WILLIAMS: Okay.

(21) MS. SIGGERUD: All right. Like on a piece of

(22) paper. So I would work with her to see what she

(23) thinks -- which means she should probably reach out to

(24) Michael Shipman to determine the best way to post it.

(25) MS. WILLIAMS: Okay. All righty. I will do

Page 10

 (1) that.

 (2) MS. SIGGERUD: Okay?

 (3) All righty. And I want to make sure that we do

 (4) one at a time, again.

 (5) MS. WILLIAMS: Okay.

 (6) MS. SIGGERUD: Because the poster hasn't applied

 (7) for the other job yet and so we don't want to post her

 (8) job --

 (9) MS. WILLIAMS: Okay.

(10) MS. SIGGERUD: -- until she's not it anymore.

(11) MS. WILLIAMS: Okay. Right. All righty that

(12) makes sense.

(13) MS. SIGGERUD: Okay. Sounds good.

(14) Jump to -- all right.

(15) Then you had mentioned in your e-mail that you

(16) wanted to touch base on something else?

(17) MS. WILLIAMS: Yeah. Um . . . I just kinda

(18) wanted to have a pretty open conversation, I guess,

(19) around, you know, where -- where things are at. Um, I

(20) guess 'cause I'm just -- I'm just trying to make sure

(21) that I'm doing everything, you know, that I need to be

(22) doing 'cause I -- I mean, as I mentioned before, you

(23) know, I really enjoy being here, and so I just -- you

(24) know, in our last conversation, in our one-on-one the

(25) last week, I kinda felt a little, you know, blind sided,

Page 11

 (1) I guess, by some things. But, um, you know, I just want

 (2) to make sure that I'm very clear of, you know, how

 (3) things are. So I just -- I just, basically -- I guess,

 (4) am looking for a little bit of candidness around, you

 (5) know, my position here. My position and my

 (6) relationship, where it stands with Jake and the Phoenix

 (7) team, and also -- with you also.

 (8) I feel like, you know, I'm doing everything that

 (9) I can do, you know, to be successful. You know,

(10) definitely I take, you know, all constructive criticism

(11) into consideration and, you know, try to make sure I'm

(12) completing everything that's been suggested and then

(13) also making sure that I'm coming up and being creative

(14) with other things too. But also I kinda just, you know,

(15) with the continuing, you know, I guess communication

(16) back and forth between us, I still kinda feel like

(17) there's a little communication lost. So I just wanna

(18) make sure, you know, I'm on the -- the clear

(19) understanding, kinda of, of where things are at.

(20) I mean, because you know, professionally, you

(21) know, I -- being in HR, Rachael, you know, we've had

(22) conversations with employees before and I just want to

(23) be very clear that, you know, I want this to be

(24) beneficial for me as an employee but also beneficial for

(25) the company as well. And I want to be very -- very

Page 12

 (1) professional and I don't want to waste my time or the

 (2) companies time so I just want to make sure of clearly

 (3) where I stand. If -- you know, I've -- I have always

 (4) felt that I have been an asset to the business here

 (5) because I've always done any and everything that, you

 (6) know, has ever been asked of me. I feel like I've gone

 (7) above and beyond. I have supported employees, I've

 (8) always felt that I've had a great relationship with

 (9) everyone, but I just kinda wanted to get a clear picture

(10) of what -- what -- what it really is, I guess, is the

(11) best way to say it.

(12) MS. SIGGERUD: So -- so what is -- when you say

(13) "what it is," what - what is "it" that you're kinda

(14) referring to?

(15) MS. WILLIAMS: I guess -- I mean, 'cause I -- I

(16) feel like, you know, I'm getting kinda mixed signals. I

(17) mean, I -- I feel like the last couple of meetings and

(18) conversations, and the last little bit of information I

(19) received is kinda like, you know, I'm -- I feel like I

(20) kinda being put on, you know, the spot, you know, about

(21) things and, like I said, I felt blind sided because I

(22) didn't really think that the things that were being

(23) brought up were happening.

(24) You know, I -- when I -- like, the

(25) misunderstanding or miscommunication of, you know, me

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 450 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 13

 (1) not being engaged or me not communicating with everyone

 (2) or -- like you said before, everyone's perception. So

 (3) I'm just trying to make sure that if those things are

 (4) changing, are they gonna change for the better or -- you

 (5) know, is this just to the point of where you and Jake

 (6) don't feel that I'm a good fit anymore? Because I kinda

 (7) feel like with, you know, my health issues and the

 (8) accomodation that I've asked for might not be that well

 (9) perceived by everyone. And then I feel, like, with

(10) that, that you guys might not have confidence in me that

(11) I'm a good fit anymore.

(12) MS. SIGGERUD: Well, with respect to your

(13) accom- -- the accommodation, I mean, it's

(14) [unintelligible] that you're gonna use us in a way,

(15) and -- I mean, it's an hour a week, and that's certainly

(16) not anything. And like you and I talked about, I think

(17) it was last week, nobody in that business, in Phoenix,

(18) should really know much of anything about it.

(19) MS. WILLIAMS: Right.

(20) MS. SIGGERUD: And so that -- you know, that's

(21) your private information. And we had talked about just

(22) putting on your calender that you've got an off-site

(23) meeting or appointment or whatever. So Jake doesn't

(24) know anything about it unless you've told him.

(25) MS. WILLIAMS: No.

Page 14

 (1) MS. SIGGERUD: Right. So I certainly haven't

 (2) and I know that Marie hasn't.

 (3) MS. WILLIAMS: Right.

 (4) MS. SIGGERUD: So, with respect to that, that

 (5) certainly has nothing bearing on anything. It's -- it's

 (6) an hour a week and it's -- it's -- you know, it's us, in

 (7) a way, not a big deal.

 (8) And the conversation that you and I had, was,

 (9) you know, before any of that even came forward, so . . .

(10) Um, you know, with respect to the conversation

(11) from last week, are you talking about the one from a

(12) couple of weeks ago or the one from last week? Because

(13) we have our one-on-one from 7/9, our one-on-one from

(14) 7/12 and we talked mostly about -- um, we talked, like,

(15) your letter to Monica, we talked about the

(16) [unintelligible] that you and Mitch were gonna -- you

(17) and Mitch and Jake were gonna have, kinda how to show up

(18) for that.

(19) MS. WILLIAMS: Right. No, I think I'm talking

(20) about the one from 7/9 where we had the conversation

(21) around the lack of engagement and support and . . .

(22) MS. SIGGERUD: Sure.

(23) MS. WILLIAMS: Just the relationship here around

(24) the business with Phoenix.

(25) MS. SIGGERUD: Okay. And -- and -- so is your

Page 15

 (1) question -- you know, is it too late? Or is it, you

 (2) know, what -- you know, as far as where it stands,

 (3) perception is something that -- it -- it takes a while

 (4) to change perception. So if your question is: Has it

 (5) changed since we talked? I don't know. Jake is on

 (6) vacation. I haven't talked to him. I haven't heard

 (7) anything.

 (8) Um, what I can speak to is I know, you know, it

 (9) was -- it was frustrating to me that you weren't at our

(10) one-on-one yesterday and didn't call, didn't cancel. I

(11) certainly understand that things come up. They come up

(12) with me, too, but it's just the, you know -- we had

(13) talked about being on time, having people know where

(14) you're at. Um, I got some feedback about the work comp

(15) sharp shooters meeting, and that you were late for that

(16) one. About 15 minutes.

(17) And I -- I totally understand that -- that

(18) meetings happen and you get caught up, but -- but you

(19) gotta live by your calender because that's -- you know,

(20) it's a commitment.

(21) MS. WILLIAMS: I was late because the code that

(22) I got wasn't correct. So I did call Melissa to let her

(23) know that it -- it wasn't the appropriate . . .

(24) That's what I'm saying. So, you know, like,

(25) I -- I wanna be -- make sure that I'm judged by what I'm

Page 16

 (1) actually doing and not someone's perception. Because in

 (2) all -- in all -- in all reality here, you know, I live

 (3) off of reality and I can't live off of perception. So

 (4) if -- if that's everyone's perception of me and not what

 (5) I'm actually doing, then I think that everyone needs to

 (6) decide whether this is a good fit for me or not.

 (7) Because, honestly, all these things, I feel, like, they

 (8) didn't come up until I started having health issues and

 (9) then I needed -- um, I needed assistance with that. So,

(10) you know, that's why I did put that letter in writing

(11) because it's not like it has been unknown that I have

(12) needed assistance with that. I've had numerous

(13) conversations around that I did need -- need assistance

(14) with that, but to me at this point I feel like I'm

(15) starting to get, um, a little micromanaged around the

(16) fact of "do a calender" and then I am doing a calender

(17) but then I get an email of, well, you know it's not

(18) reasonable to ask people to look and see if you're gonna

(19) be doing something on your calendar.

(20) So I'm a little lost between what I should be

(21) doing and what I shouldn't. Because I'm really trying

(22) my best here, but I'm just asking for some clear

(23) guidelines around what it is that needs to be done and,

(24) you know, I don't -- I -- I do have health issues and

(25) health concerns and the business is very important to

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Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 17

 (1) me. But in all reality, on top of that, my own health

 (2) is very important as well. And dealing with the stress

 (3) of these, to me, minor things that can be worked out, is

 (4) not worth me taking on the stresses of dealing with

 (5) this. Because to me, these minor things are dropping my

 (6) morale with the company, with the business, and it's

 (7) also putting undue stress on me which, in further, is

 (8) not gonna help to support my health and my wellbeing

 (9) here in order for me to improve.

(10) So I kinda feel like I'm set up for failure. So

(11) I'm trying to just make sure if that's the case, then we

(12) can just come to a, um, compromise on things, um, or,

(13) you know, they can continue to improve and I can move

(14) forward. I'm just really trying to get a candid answer

(15) of, yes, we -- we would love to have you here and, you

(16) know, time will tell that things are gonna get better

(17) or, no, with the things that have occurred, we don't

(18) feel like you're a good fit.

(19) MS. SIGGERUD: So -- so -- I'd love to have you

(20) engaged and work -- work -- you know, let's work to

(21) en- -- kinda get things back on track. So that's my

(22) goal. And in these -- you know, I think what you're

(23) perceiving as micromanaging, that's me trying to stay

(24) real close to the situation to make sure that I know

(25) what's going on; that I can help keep you on track so we

Page 18

 (1) can start changing the perception with your partners.

 (2) So Jake doesn't know about the conversation that

 (3) you and I had, Angie doesn't know about the conversation

 (4) that you and I had. So that's -- I'm staying close to

 (5) you, because I want to make sure that I can help you be

 (6) successful. So . . .

 (7) MS. WILLIAMS: In turn I would need for you to

 (8) be supportive of me though and respond. And it's

 (9) like -- I feel like it's a double-edged sword here

(10) because it's like I'm held to these things, but then,

(11) like, when I ask -- reach out to you, like, I don't hear

(12) back from you for, like, you know, a couple days or, you

(13) know, I'm still waiting on an answer from someone, or

(14) I'm still working on things, but I don't get anything

(15) back from you.

(16) MS. SIGGERUD: Did you mean your e-mail from

(17) today? Because I'm not quite sure what --

(18) MS. WILLIAMS: Just the past couple. And then

(19) it's, like, you know, then I'm logged for the Phoenix

(20) group. I mean, I've been waiting on that for --

(21) MS. SIGGERUD: So what are you waiting on?

(22) MS. WILLIAMS: -- like, two months now. To find

(23) out, like, you know, where you and Jake decided to place

(24) everyone. I mean --

(25) MS. SIGGERUD: But it's not -- you mean, the

Page 19

 (1) leaders?

 (2) MS. WILLIAMS: Yeah.

 (3) MS. SIGGERUD: It's --

 (4) MS. WILLIAMS: I mean, I don't know who to work

 (5) on an IDP with, and I don't know whether to have

 (6) continuing further conversations --

 (7) MS. SIGGERUD: That's sort of the --

 (8) MS. WILLIAMS: -- around --

 (9) MS. SIGGERUD: And I've talked to the whole

(10) team -- our regional team about that. I work with Jake

(11) on his people leaders.

(12) MS. WILLIAMS: Okay.

(13) MS. SIGGERUD: And then your -- you are working

(14) with them on their direct reports.

(15) MS. WILLIAMS: Well, that's what I'm saying. So

(16) I sent you an e-mail asking if you're gonna work on the

(17) ones with Angie or if I should reach out to her and work

(18) with her on them. But I never got a response to, okay,

(19) no, you're gonna do those with her, and I shouldn't

(20) worry about them . . .

(21) MS. SIGGERUD: But these are things -- so,

(22) Brandy, that's -- part of where I get frustrated is that

(23) these are things that we've talked about. So if I say

(24) I'm working with the GM's on their people leaders, and

(25) you guys are working with their leaders on everything

Page 20

 (1) below, that's the -- so where -- I guess I don't

 (2) understand where the question comes in on that?

 (3) MS. WILLIAMS: Okay. I've reached out to

 (4) Janelle and Kayla and they didn't seem to know either.

 (5) So I guess I'm not the only one that didn't hear that.

 (6) MS. SIGGERUD: None of the others have -- Yeah.

 (7) It's not been a question from anyone else.

 (8) So, you know, that aside, you know, with respect

 (9) to the calendars, the -- your Phoenix drive is one that

(10) nobody has access to except people from Phoenix.

(11) MS. WILLIAMS: And that was maybe a mistake on

(12) my part that I didn't know about. So I apologize for

(13) that portion.

(14) MS. SIGGERUD: So -- but -- but regardless it's

(15) the -- you know, it's you put on there that you're

(16) gonna, you know, attend, you know -- who knows. Like,

(17) the payroll call for Los Angeles that you received an

(18) invite for.

(19) MS. WILLIAMS: Uh-huh.

(20) MS. SIGGERUD: If you accept the Lotus invite

(21) and then don't attend the meeting, it's not reasonable

(22) to expect that whoever organized that meeting goes out

(23) to -- you know, a random, you know, hard drive and check

(24) their calender to see if you were or weren't going to be

(25) there. What is an appropriate and reasonable outcome is

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 452 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 21

 (1) that you say okay, I've got XYZ conflict, I can't attend

 (2) it, period, so I'm not gonna accept the invite I'll

 (3) decline it. Or if something comes up unexpectedly, that

 (4) you go back in and you decline it and let the -- the

 (5) organizer know why. And just let 'em know that you're

 (6) not gonna be there.

 (7) MS. WILLIAMS: Okay. So my question is --

 (8) MS. SIGGERUD: The client --

 (9) MS. WILLIAMS: -- I'm not aware that that has

(10) happened, because I don't think that's been a conflict,

(11) because I just put that calender up --

(12) MS. SIGGERUD: Well, it happened yesterday.

(13) MS. WILLIAMS: -- a week ago.

(14) MS. SIGGERUD: No, it happened -- it happened

(15) yesterday for our one-on-one.

(16) MS. WILLIAMS: Yeah, but I didn't have on the

(17) Phoenix calendar that I was attending the one-on-one,

(18) that was in the Lotus notes. So I think that was just a

(19) miscommunication between you and I, because I think that

(20) there's too many different calendars going on here now.

(21) MS. SIGGERUD: On your Lotus calenders do you

(22) not have the one-on-one on there.

(23) MS. WILLIAMS: I do. And that's a recurring

(24) thing that is always on there. And it's -- I mean, it's

(25) not anything new. It's a recurring thing that is done

Page 22

 (1) every single week. And sometimes we have them and

 (2) sometimes we don't, so I -- you know, honestly, I'm --

 (3) to be honest, I didn't think there was that much

 (4) emphasis around it because sometimes if we have them

 (5) great or if you're traveling and we don't then we

 (6) reschedule, so I mean --

 (7) MS. SIGGERUD: But if I'm traveling I'll let you

 (8) know. If I get hung up at the airport or something,

 (9) I'll let you know that I won't be there and that's

(10) the -- it's the letting someone know that you can't make

(11) it. So if you had said, hey, I'm in Tucson today, can

(12) we reschedule our one-on-one? Or, Hey, just realized

(13) our one-on-one is scheduled for 1:00 o'clock. I'm in

(14) Tucson, I'm in a meeting, can we reschedule it for

(15) tomorrow. That's not a big deal.

(16) MS. WILLIAMS: Well, I had my cell phone, so,

(17) honestly, I didn't think that I was gonna miss it

(18) because I thought that you would call me on my cell and

(19) not just my desk phone. So I was waiting for the call

(20) at 11:00 and I was just thinking that when I didn't get

(21) the call that -- at 11:00 that maybe you just had a

(22) meeting or you had something come up. So I was, like,

(23) okay, well, you know -- that's when I e-mailed you to,

(24) you know, kinda let you know where I was at. That

(25) way -- you know, I was just touching base. Because,

Page 23

 (1) honestly, it was an honest mistake. And that's what I

 (2) kinda feel like it is at this point. That these things

 (3) are taken a little to the extreme instead of just, like,

 (4) an understanding that it was, like, an honest mistake.

 (5) MS. SIGGERUD: So . . .

 (6) MS. WILLIAMS: So that's where I get to the --

 (7) to the point of feeling, like, I'm not wanted or needed

 (8) here anymore because of the minor things that are coming

 (9) up.

(10) MS. SIGGERUD: So you're certainly wanted. And

(11) I, you know, I want you as a part of my team. But what

(12) I'm -- I'm hearing is that I don't know if you want it.

(13) And if you don't, it's not -- your passion's not here,

(14) your heart's not in it, I get that.

(15) This job had changed an awful lot and it's not

(16) what everybody wants. Not everybody says, gosh, this

(17) is -- you know, when I started working in HR this is the

(18) type of job I really aspired to have, or this is what I

(19) imagined it would be and -- and that's okay. And if

(20) that's where you're at, I'd like you to kinda think

(21) about it for the next couple of days. Because the

(22) staying close to you, holding you to the -- we gotta be

(23) on the calls, things like that, that's me trying to make

(24) sure that I'm close to you, so I can help make sure that

(25) you're on track. If that's not kinda what you're

Page 24

 (1) looking for, I can assure you it has absolutely nothing

 (2) to do with any medical condition, you know, and I think

 (3) it's a -- a little unfair to say that because we had the

 (4) conversation about expectations before anything came up

 (5) and --

 (6) MS. WILLIAMS: What do you mean before anything

 (7) came up? I've been dealing with these issues since the

 (8) birth of my son. Since I came back.

 (9) MS. SIGGERUD: And it's never been any kind of

(10) an issue.

(11) MS. WILLIAMS: None of the things with -- None

(12) of the things or the issues with me came up until about

(13) two months ago.

(14) MS. SIGGERUD: So the -- your medical concerns

(15) have been ongoing and it's not changed.

(16) MS. WILLIAMS: Right.

(17) MS. SIGGERUD: And so what came up about a month

(18) ago is a performance conversation. It had nothing to do

(19) with anything related to your medical condition. It has

(20) everything to do with performance and expectations.

(21) MS. WILLIAMS: But the performance was around

(22) you getting the feedback of the perception that I wasn't

(23) here.

(24) MS. SIGGERUD: That's not the only thing that

(25) was part of that conversation. That was one small piece

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Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 25

 (1) of it. And so that's kinda the --

 (2) MS. WILLIAMS: I do want to be here, Rachael, I

 (3) do. I'll be honest about that. And I definitely had

 (4) high expectations up- -- upon coming to G & K, and I

 (5) never planned on leaving the company, but I'm -- I -- I

 (6) feel, like, you know, I shouldn't continue to stress

 (7) myself considering the health situation that I'm in, um,

 (8) if, um, it's not gonna be beneficial to me.

 (9) If I'm -- if I feel that my morale has dropped

(10) due to the situation, and I feel that, um, I'm not

(11) wanted, then I don't feel like I should continue to make

(12) an effort. But if I am wanted here then by all means I

(13) am gonna be the utmost professional. I do enjoy my job.

(14) This is something that I've done for years and, um, I

(15) would love to stay with the company because I'm not an

(16) individual that's gonna quit or give up. But like I

(17) said, I -- I'm not gonna continue to be stressed or to

(18) deal with minor, you know, issues if it's not gonna be

(19) beneficial to G & K or to myself.

(20) MS. SIGGERUD: Well, as far as being beneficial

(21) to G & K, these are things that are important. The

(22) things that we have talked about, those are important.

(23) Being a good partner, being on time, meeting

(24) commitments, those are extremely important. And if

(25) that's kinda not where your head's at and you say, gosh,

Page 26

 (1) I would rather have a different type of, you know, work

 (2) environment. I'd rather have a different kinda

 (3) schedule, you know, I understand that. You know, I'd

 (4) love to have you here, but if you say, gosh, this isn't

 (5) the right thing for me, let me know.

 (6) MS. WILLIAMS: No, I don't want this to be put

 (7) back off on me because I haven't expressed that I didn't

 (8) want to be here. I've never expressed an issue with

 (9) being here. An issue, you know, with not wanting to be

(10) in HR. I feel like this issue has come up and was

(11) brought to me, so that's why I'm trying to make sure

(12) that I'm addressing it. So I think the question is: Am

(13) I wanted here? And if so, are things going to continue

(14) to improve?

(15) MS. SIGGERUD: Brandy, I just told you that

(16) you're wanted here, and whether they improve or not is

(17) up to you.

(18) MS. WILLIAMS: Not necessarily. It takes two.

(19) MS. SIGGERUD: So --

(20) MS. WILLIAMS: It's a 50-50 relationship. So I

(21) can do as much as I want to do, but if I'm not wanted

(22) here by Jake or other individuals on this group or this

(23) team here, or yourself, then I'm not gonna be

(24) successful.

(25) MS. SIGGERUD: So, again, I've told you that I

Page 27

 (1) want you on my team. But the performance piece is --

 (2) it's -- it's up to you. And I'm hear to help ya and I'm

 (3) here to work with ya, but ultimately it sounds to me

 (4) what you're saying, like, you're not quite sure that

 (5) this is what you want.

 (6) MS. WILLIAMS: No. Because if I felt that way,

 (7) Rachael, I would tell you.

 (8) MS. SIGGERUD: Well, you just -- you did just

 (9) say it. You said if the -- if my morale is gonna

(10) continue to be low and if I'm gonna feel like I'm not

(11) wanted, then I don't want -- then let's make -- let's

(12) come to an agreement. And so if what you're asking for

(13) is for transition support --

(14) MS. WILLIAMS: Yes. Because I'm telling you at

(15) this point I feel like I'm being pushed out of the

(16) business. I'm feeling pushed to quit, because of the

(17) things that are being brought to you that I feel are not

(18) true. And here I am trying to work harder to make sure

(19) that I'm changing everyone's perception, even though I

(20) guess we should go back to Jody's term of, it's really

(21) not the reality, you know.

(22) MS. SIGGERUD: Perceptions have to do with

(23) reality.

(24) MS. WILLIAMS: I'm working hard to change

(25) everyone --

Page 28

 (1) Okay. Well, your answer to me always was,

 (2) again, Brandy, we're talking about people's perceptions.

 (3) We're talking about people's perceptions here and how

 (4) they perceive you, so. . . Then, again, is it

 (5) perception or reality then?

 (6) MS. SIGGERUD: But, Brandy, perception is

 (7) reality.

 (8) MS. WILLIAMS: Okay. But -- no, you never said

 (9) that. Because I asked you before. Okay. So these are

(10) things that people are saying, but I'm not actually

(11) doing these things, and you said, again, we're talking

(12) about people's perceptions and how they view you and

(13) what they think.

(14) MS. SIGGERUD: People's perceptions are their

(15) reality.

(16) MS. WILLIAMS: Okay. And so -- so that's what I

(17) was asking for you to make clear then. So -- so now,

(18) that that's put out there, that people's receptions

(19) [sic] are reality because that's not --

(20) MS. SIGGERUD: Brandy, I think your mis- --

(21) maybe --

(22) MS. WILLIAMS: -- our conversation.

(23) MS. SIGGERUD: So it's the -- have you -- have

(24) you -- have you heard that phrase in the past? So it's

(25) a phrase that basically is, if I perceive that the sky

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Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 29

 (1) is blue, then to me the sky is blue. So --

 (2) MS. WILLIAMS: Oh, yes, I have heard that.

 (3) MS. SIGGERUD: Well, perceptions -- I'm not

 (4) saying that what people are perceiving is what you are

 (5) actually doing. It is not literal.

 (6) MS. WILLIAMS: Okay. Thanks for making that

 (7) clear. Because that's what -- that's the point I was

 (8) getting to. Is that that's how you're coming across to

 (9) me. Is that people's perception is reality, and that's

(10) what I am doing.

(11) MS. SIGGERUD: But the issue is that their

(12) perception will guide their relationship with you. It

(13) will govern the relationship with you. And so these

(14) perceptions come from somewhere. And I don't believe

(15) that everybody has conspired to have -- you know, a

(16) perception of this or that or the other thing.

(17) MS. WILLIAMS: So, you're basically coming out

(18) and telling me that you believe everything they're

(19) telling you is absolutely true.

(20) MS. SIGGERUD: That is not what I said, Brandy.

(21) MS. WILLIAMS: No, I'm asking you.

(22) MS. SIGGERUD: I don't know if it's true or not

(23) I'm not there, I didn't experience it. But what I am --

(24) what I am experiencing is the perceptions and that

(25) people's -- if someone says I don't perceive that

Page 30

 (1) somebody is a good partner. I don't perceive that that

 (2) there's value.

 (3) MS. WILLIAMS: That's -- that's --

 (4) MS. SIGGERUD: That --

 (5) MS. WILLIAMS: -- the point I'm trying to bring

 (6) across to you though, Rachael, is that I kinda feel

 (7) attacked because you came at me like this is what

 (8) they're telling me, and you kinda came out and told me

 (9) that you believe Jake, and I kinda feel that I didn't

(10) get the fair understanding and I didn't get the fair

(11) opportunity to give you my feedback of how I felt. And

(12) it was, like, you're doing this, this is what's

(13) happening, you need to change it. If that makes sense?

(14) MS. SIGGERUD: But you did give me your

(15) feedback. And your feedback was that you don't believe

(16) that it's true.

(17) MS. WILLIAMS: No, I know for a fact that it's

(18) not true.

(19) MS. SIGGERUD: So then the issue is a very big

(20) disconnect.

(21) MS. WILLIAMS: Yes. It's a very big dis- -- a

(22) very big disconnect. Because how can people not know

(23) I'm here if they never come to this office.

(24) I mean, you know, honestly, this all went

(25) downhill when Jake decided to move me out of this office

Page 31

 (1) because no one comes up front. And if no one comes up

 (2) front, no one knows that I'm here in this office and

 (3) they perceive that I'm not here. But when I was in the

 (4) back it was never an issue of whether Brandy's here

 (5) because I was there, I was interacting with every single

 (6) person, every single day. Everyone knew where to find

 (7) me. And it's like since I've been taken out of the

 (8) realm of things, I felt like that's where this dilemma

 (9) has occurred.

(10) MS. SIGGERUD: I'll say again, that piece about

(11) being in the office is a very small piece. That's just

(12) one -- one tiny little piece of the bigger picture.

(13) MS. WILLIAMS: And that's where I talk about I

(14) get back to the micromanaging piece. You know, because

(15) it's, like, what am I supposed to do then? Copy you on

(16) every single interaction I have with everybody just to

(17) prove that I'm doing the same thing that I've always

(18) done in this business? Or is everyone gonna -- gonna

(19) continue to give their perception.

(20) MS. SIGGERUD: So it's been, what, two weeks

(21) since you and I had that conversation?

(22) MS. WILLIAMS: Uh-huh.

(23) MS. SIGGERUD: And I haven't heard anything from

(24) anybody about not -- you know, not being able to work

(25) with you, not being able to find you or anything like

Page 32

 (1) that. So . . .

 (2) MS. WILLIAMS: Because I made an, extra effort

 (3) to go above and beyond and go walk back there and say hi

 (4) to them when I got here. I got out of my office to go

 (5) back there and say hi to them during the midday. I got

 (6) out of my office to go back there to say hi to them

 (7) during the afternoon. Even though I was here.

 (8) And so it's like, I think that proved the point

 (9) of their perception that -- because I actually made it a

(10) point the go walk around and peep in and say, Hey, how

(11) are you? Hey, how are you? Like, consistently

(12) throughout the day, all day long, then it wasn't an

(13) issue that I'm -- I'm not here. Even though I was.

(14) That's what I'm saying. That's -- that's the

(15) point that I'm trying to prove to you. That that's why

(16) I don't feel that it is true. Because before I was, but

(17) by me changing their way of thinking by actually going

(18) around to them consistently throughout the day, and

(19) me -- I'm feeling like I'm micromanaged because I have

(20) to walk around to every single one of them and say, hey,

(21) how are you? How's it going? I'm here. They don't do

(22) that to me. And I don't feel like I should have to be

(23) to the point to where I do that to them. If they leave

(24) they don't come and say, Hey, HR I'm leaving. Or, you

(25) know, if Mitch misses his meeting with me that I had

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Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 33

 (1) scheduled with him about IDP's and I go in there looking

 (2) for him and he says, oh, yeah, I don't have time to do

 (3) that, because I have customer issues to handle so, um,

 (4) I'll get with you when I can. But, you know, I'm not

 (5) coming back and saying those things to you because I'm

 (6) really trying to work through things with them. I'm

 (7) like, okay, you know, I'm trying to be easy going and

 (8) say, well, just let me know when you're available. But

 (9) yet, if I do anything like that, that come to you

(10) immediately and say, hey, Brandy didn't do this. Or

(11) Brandy didn't do that. So that's where I get to the

(12) point of I'm feeling like I'm being micromanaged, and

(13) they're not gonna be held to the same standard. But I'm

(14) going to be held to a higher standard and I'm gonna have

(15) to make sure I'm doing -- going above and beyond and

(16) doing everything I'm doing. But yet they're not gonna,

(17) you know, participate. And it's, like, as long as

(18) they're happy, then that's okay.

(19) MS. SIGGERUD: So, you know, as it pertains to,

(20) I just want to handle it, I don't wanna say anything.

(21) I've -- I -- every time we have a conversation about, so

(22) and so's not doing this. So and so says no biggy. So

(23) and so's, you know, they don't have time. Copy me.

(24) Work with me on it. Let me know if you need me to reach

(25) out.

Page 34

 (1) MS. WILLIAMS: But that's what I'm just saying

 (2) though. You know, two years before that I never had to

 (3) do that.

 (4) MS. SIGGERUD: But the job wasn't the same,

 (5) Brandy. So the activities that we're trying to do now,

 (6) of -- we're not getting them done, because people

 (7) aren't -- they're not making it to meetings, they're too

 (8) busy, they're whatever, that's what your job is now.

 (9) Before your job was different. It was, we're doing

(10) payroll, we're doing benefits, we're hiring people,

(11) we're recruiting. It wasn't the same types of

(12) activities. And so it's -- it wasn't so based on other

(13) people.

(14) MS. WILLIAMS: Okay.

(15) MS. SIGGERUD: But here it is. So kinda -- I'll

(16) leave you with this. You know, I want you on my team.

(17) I wanna help change the perception. And I think we're

(18) on the right track, but I want you to think over the

(19) next few days if this is what you want. And if it's not

(20) what you want, I'm not gonna hold it against ya, we will

(21) come up with a transition plan. I'll support ya. We

(22) can either look for something else within G & K, I can

(23) help you with a transition plan to find something else

(24) outside of G & K, but I'll work with ya to figure it

(25) out.

Page 35

 (1) MS. WILLIAMS: Okay.

 (2) MS. SIGGERUD: So, I want you on my team. And

 (3) I'll continue working with you to make sure that we're

 (4) successful. But if that's not what you want -- I'm not

 (5) gonna change your mind, so . . .

 (6) MS. WILLIAMS: No, I appreciate that. You know,

 (7) and the whole point of this conversation was to be

 (8) professional and to have just a very candid conversation

 (9) and just lay it out on the table of, you know, the facts

(10) and the reality of the situation. If that makes sense?

(11) You know, I mean, no -- no getting emotional or

(12) getting, you know, upset about it but, honestly, just to

(13) be very professional and just have a very open

(14) conversation with you about it. You know, that --

(15) that's all I really wanted to accomplish, honestly,

(16) today, so I -- I appreciate you, you know, talking to me

(17) and listening to me about it. And I -- I, honestly,

(18) really appreciate that so . . .

(19) MS. SIGGERUD: Absolutely. Any time. And I

(20) still look forward to being there next week and sitting

(21) down with Jake and putting together a plan.

(22) MS. WILLIAMS: Okay.

(23) MS. SIGGERUD: So. All righty?

(24) MS. WILLIAMS: All right. Well, thanks I

(25) appreciate your time.

Page 36

 (1) MS. SIGGERUD: Have a good night.

 (2) MS. WILLIAMS: Okay. Bye-bye.

 (3) MS. SIGGERUD: Bye-bye.

 (4)

 (5) (End of audio recorded conversation with Rachael

 (6) Siggerud.)

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 456 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

Page 37

 (1) C E R T I F I C A T E 

 (2)

 

 (3) I, Deanna C. Bakurza, RPR, a Certified Reporter 

 (4) in the State of Arizona, do hereby certify that the 

 (5) foregoing pages 1 - 36 constitute a full, true, and 

 (6) accurate transcript of the audio recording produced in 

 (7) the foregoing matter, all done to the best of my skill 

 (8) and ability. 

 (9) SIGNED and dated this 5th day of May, 2016. 

(10)

 

(11)

 

(12)

 

(13) __________________________ Deanna C. Bakurza, RPR

(14) Certified Reporter Certification Number 50412 (15)

 

(16)

 

(17)

 

(18)

 

(19)

 

(20)

 

(21)

 

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Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

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biggy (1)

 33:22

birth (1)

 24:8

bit (2)

 11:4;12:18

blind (2)

 10:25;12:21

blue (2)

 29:1,1

bona (1)

 6:7

both (1)

 7:19

Brandy (9)

 19:22;26:15;28:2,6,20;

 29:20;33:10,11;34:5

Brandy's (1)

 31:4

bring (1)

 30:5

broadening (1)

 4:16

brought (3)

 12:23;26:11;27:17

bump (1)

 8:13

business (9)

 3:20,25;12:4;13:17;14:24;

 16:25;17:6;27:16;31:18

busy (1)

 34:8

Bye-bye (2)

 36:2,3

C

calendar (2)

 16:19;21:17

calendars (2)

 20:9;21:20

calender (6)

 13:22;15:19;16:16,16;

 20:24;21:11

calenders (1)

 21:21

call (6)

 15:10,22;20:17;22:18,19,

 21

calls (1)

 23:23

came (8)

 14:9;24:4,7,8,12,17;30:7,8

can (21)

 4:7,19;8:19;11:9;15:8;

 17:3,12,13,13,25;18:1,5;

 22:11,14;23:24;24:1;26:21;

 30:22;33:4;34:22,22

cancel (1)

 15:10

candid (2)

 17:14;35:8

candidness (1)

 11:4

careful (1)

 6:2

case (1)

 17:11

caught (1)

 15:18

cause (3)

 10:20,22;12:15

cell (2)

 22:16,18

center (1)

 5:23

certainly (5)

 13:15;14:1,5;15:11;23:10

change (6)

 13:4;15:4;27:24;30:13;

 34:17;35:5

changed (3)

 15:5;23:15;24:15

changes (1)

 4:15

changing (5)

 4:1;13:4;18:1;27:19;32:17

check (1)

 20:23

clear (7)

 11:2,18,23;12:9;16:22;

 28:17;29:7

clearly (1)

 12:2

client (1)

 21:8

close (4)

 17:24;18:4;23:22,24

code (1)

 15:21

coming (6)

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 458 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

 11:13;23:8;25:4;29:8,17;

 33:5

Commencement (1)

 2:1

commitment (1)

 15:20

commitments (1)

 25:24

communicating (1)

 13:1

communication (2)

 11:15,17

comp (1)

 15:14

companies (1)

 12:2

company (4)

 11:25;17:6;25:5,15

completing (1)

 11:12

compromise (1)

 17:12

computer (3)

 6:16;7:10,11

computers (1)

 7:4

concerns (2)

 16:25;24:14

condition (2)

 24:2,19

confidence (1)

 13:10

conflict (2)

 21:1,10

consideration (1)

 11:11

considering (1)

 25:7

consistently (2)

 32:11,18

conspired (1)

 29:15

constructive (1)

 11:10

continue (8)

 17:13;25:6,11,17;26:13;

 27:10;31:19;35:3

continuing (2)

 11:15;19:6

conversation (17)

 10:18,24;14:8,10,20;18:2,

 3;24:4,18,25;28:22;31:21;

 33:21;35:7,8,14;36:5

conversations (5)

 5:22;11:22;12:18;16:13;

 19:6

Copy (2)

 31:15;33:23

couple (5)

 12:17;14:12;18:12,18;

 23:21

creative (1)

 11:13

criticism (1)

 11:10

cross-trained (2)

 4:19;5:7

cross-training (1)

 4:17

currently (1)

 2:4

customer (6)

 2:5,6;4:4;5:4;7:24;33:3

customers (2)

 2:8;5:6

D

day (4)

 31:6;32:12,12,18

days (4)

 8:4;18:12;23:21;34:19

deal (3)

 14:7;22:15;25:18

dealing (3)

 17:2,4;24:7

decide (1)

 16:6

decided (2)

 18:23;30:25

decline (2)

 21:3,4

definitely (4)

 3:11;7:8;11:10;25:3

demonstrated (1)

 2:7

desk (1)

 22:19

determine (1)

 9:24

different (5)

 7:5;21:20;26:1,2;34:9

dilemma (1)

 31:8

direct (1)

 19:14

dis- (1)

 30:21

disconnect (2)

 30:20,22

discussion (3)

 5:17,18;6:5

done (7)

 6:17;12:5;16:23;21:25;

 25:14;31:18;34:6

double-edged (1)

 18:9

down (1)

 35:21

downhill (1)

 30:25

drive (2)

 20:9,23

dropped (1)

 25:9

dropping (1)

 17:5

due (1)

 25:10

during (2)

 32:5,7

E

easiest (1)

 4:2

easy (1)

 33:7

effort (2)

 25:12;32:2

either (6)

 2:23;3:22;8:20;9:11;20:4;

 34:22

else (4)

 10:16;20:7;34:22,23

em (2)

 8:21;21:5

email (1)

 16:17

e-mail (3)

 10:15;18:16;19:16

e-mailed (1)

 22:23

e-mails (1)

 6:21

emotional (1)

 35:11

emphasis (1)

 22:4

employee (3)

 4:24;8:8;11:24

employees (3)

 5:10;11:22;12:7

en- (1)

 17:21

End (1)

 36:5

engaged (2)

 13:1;17:20

engagement (1)

 14:21

English (5)

 5:2,13,20,23;6:7

enjoy (2)

 10:23;25:13

entire (1)

 2:15

entitled (1)

 3:23

environment (1)

 26:2

equivalent (1)

 9:14

evaluate (1)

 2:16

even (6)

 8:4;9:9;14:9;27:19;32:7,13

everybody (5)

 4:17;23:16,16;29:15;31:16

everybody's (1)

 4:16

everyone (11)

 3:16;4:18,19;12:9;13:1,9;

 16:5;18:24;27:25;31:6,18

everyone's (3)

 13:2;16:4;27:19

except (1)

 20:10

expect (1)

 20:22

expectations (3)

 24:4,20;25:4

experience (2)

 5:5;29:23

experiencing (1)

 29:24

expressed (2)

 26:7,8

external (1)

 3:9

extra (1)

 32:2

extreme (1)

 23:3

extremely (1)

 25:24

F

fact (2)

 16:16;30:17

facts (1)

 35:9

failure (1)

 17:10

fair (2)

 30:10,10

falls (1)

 2:22

far (2)

 15:2;25:20

feedback (5)

 15:14;24:22;30:11,15,15

feel (28)

 9:13;11:8,16;12:6,16,17,

 19;13:6,7,9;16:7,14;17:10,

 18;18:9;23:2;25:6,9,10,11;

 26:10;27:10,15,17;30:6,9;

 32:16,22

feeling (4)

 23:7;27:16;32:19;33:12

feels (3)

 5:1,3;9:14

felt (10)

 3:14,18;4:22;10:25;12:4,8,

 21;27:6;30:11;31:8

few (2)

 8:4;34:19

fide (1)

 6:7

figure (1)

 34:24

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 459 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

file (1)

 2:1

find (4)

 18:22;31:6,25;34:23

first (3)

 7:13,24;8:3

fit (6)

 4:24;8:7;13:6,11;16:6;

 17:18

folks (3)

 3:3;6:19;8:20

forth (1)

 11:16

forward (3)

 14:9;17:14;35:20

front (2)

 31:1,2

frustrated (1)

 19:22

frustrating (1)

 15:9

further (2)

 17:7;19:6

G

gain (1)

 5:5

giving (1)

 8:13

GM's (1)

 19:24

goal (1)

 17:22

goes (3)

 3:11;9:4;20:22

gonna (32)

 2:5;3:16,18;8:7;13:4,14;

 14:16,17;16:18;17:8,16;

 19:16,19;20:16;21:2,6;22:17;

 25:8,13,16,17,18;26:23;27:9,

 10;31:18,18;33:13,14,16;

 34:20;35:5

good (13)

 2:6,15,20;4:14;6:21;10:13;

 13:6,11;16:6;17:18;25:23;

 30:1;36:1

gosh (3)

 23:16;25:25;26:4

gotta (2)

 15:19;23:22

govern (1)

 29:13

great (5)

 5:3;8:7;9:2;12:8;22:5

group (2)

 18:20;26:22

guess (10)

 10:18,20;11:1,3,15;12:10,

 15;20:1,5;27:20

guide (1)

 29:12

guidelines (1)

 16:23

guys (2)

 13:10;19:25

H

handle (2)

 33:3,20

happen (1)

 15:18

happened (4)

 21:10,12,14,14

happening (2)

 12:23;30:13

happy (1)

 33:18

hard (2)

 20:23;27:24

harder (1)

 27:18

head's (1)

 25:25

health (7)

 13:7;16:8,24,25;17:1,8;

 25:7

hear (3)

 18:11;20:5;27:2

heard (4)

 15:6;28:24;29:2;31:23

hearing (1)

 23:12

heart's (1)

 23:14

held (3)

 18:10;33:13,14

help (8)

 5:24;17:8,25;18:5;23:24;

 27:2;34:17,23

helpful (1)

 3:22

here's (1)

 7:20

hey (10)

 3:25;7:20;8:6;22:11,12;

 32:10,11,20,24;33:10

hi (3)

 32:3,5,6

high (1)

 25:4

higher (1)

 33:14

hiring (1)

 34:10

hold (1)

 34:20

holding (1)

 23:22

honest (4)

 22:3;23:1,4;25:3

honestly (8)

 16:7;22:2,17;23:1;30:24;

 35:12,15,17

hour (2)

 13:15;14:6

How's (1)

 32:21

HR (4)

 11:21;23:17;26:10;32:24

hung (1)

 22:8

I

IDP (1)

 19:5

IDPs (1)

 5:18

IDP's (1)

 33:1

imagined (1)

 23:19

immediately (1)

 33:10

important (5)

 16:25;17:2;25:21,22,24

improve (6)

 5:16,24;17:9,13;26:14,16

improvement (1)

 5:2

improving (1)

 5:22

included (1)

 4:10

individual (2)

 2:9;25:16

individuals (3)

 3:19;7:20;26:22

information (2)

 12:18;13:21

instead (1)

 23:3

interacting (1)

 31:5

interaction (1)

 31:16

interest (1)

 2:7

interested (3)

 3:4;8:5,18

internal (4)

 3:6,9,10;9:11

internally (1)

 3:12

into (8)

 2:12;4:1,23;5:4;8:21;9:9,

 18;11:11

invite (3)

 20:18,20;21:2

issue (8)

 24:10;26:8,9,10;29:11;

 30:19;31:4;32:13

issues (7)

 13:7;16:8,24;24:7,12;

 25:18;33:3

J

Jake (12)

 11:6;13:5,23;14:17;15:5;

 18:2,23;19:10;26:22;30:9,25;

 35:21

Janelle (1)

 20:4

job (11)

 2:12;6:17;9:15;10:7,8;

 23:15,18;25:13;34:4,8,9

jobs (1)

 9:13

Jody's (1)

 27:20

judged (1)

 15:25

Jump (1)

 10:14

K

Kayla (1)

 20:4

keep (1)

 17:25

kind (4)

 2:9;4:17;5:15;24:9

kinda (26)

 5:21;10:17,25;11:14,16,19;

 12:9,13,16,19,20;13:6;14:17;

 17:10,21;22:24;23:2,20,25;

 25:1,25;26:2;30:6,8,9;34:15

knew (1)

 31:6

knowledge (1)

 5:24

knows (2)

 20:16;31:2

L

lack (1)

 14:21

last (7)

 10:24,25;12:17,18;13:17;

 14:11,12

late (3)

 15:1,15,21

lay (1)

 35:9

leaders (4)

 19:1,11,24,25

learn (1)

 5:20

learning (1)

 5:23

Leave (3)

 4:4;32:23;34:16

leaving (3)

 4:24;25:5;32:24

letter (2)

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(3) file - letter

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 460 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

 14:15;16:10

letting (1)

 22:10

level (1)

 9:15

lie (1)

 6:16

listening (1)

 35:17

literal (1)

 29:5

little (11)

 5:13,13;10:25;11:4,17;

 12:18;16:15,20;23:3;24:3;

 31:12

live (3)

 15:19;16:2,3

locations (1)

 6:18

logged (1)

 18:19

long (2)

 32:12;33:17

look (8)

 2:15,24;4:15;7:8;8:12;

 16:18;34:22;35:20

looking (3)

 11:4;24:1;33:1

Los (1)

 20:17

lost (2)

 11:17;16:20

lot (1)

 23:15

Lotus (3)

 20:20;21:18,21

love (4)

 17:15,19;25:15;26:4

low (1)

 27:10

M

makes (4)

 9:2;10:12;30:13;35:10

making (3)

 11:13;29:6;34:7

many (1)

 21:20

Marie (1)

 14:2

Marissa (1)

 9:5

maybe (11)

 2:25;3:3,5,10;4:14;5:21;

 8:4,13;20:11;22:21;28:21

mean (18)

 3:22,23;10:22;11:20;12:15,

 17;13:13,15;18:16,20,24,25;

 19:4;21:24;22:6;24:6;30:24;

 35:11

means (2)

 9:23;25:12

medical (3)

 24:2,14,19

meeting (8)

 13:23;15:15;20:21,22;

 22:14,22;25:23;32:25

meetings (3)

 12:17;15:18;34:7

Melissa (2)

 7:19;15:22

mentioned (2)

 10:15,22

Michael (1)

 9:24

micromanaged (3)

 16:15;32:19;33:12

micromanaging (2)

 17:23;31:14

midday (1)

 32:5

might (4)

 2:12,19;13:8,10

mind (1)

 35:5

minor (4)

 17:3,5;23:8;25:18

minutes (1)

 15:16

mis- (1)

 28:20

miscommunication (2)

 12:25;21:19

miss (1)

 22:17

misses (1)

 32:25

mistake (3)

 20:11;23:1,4

misunderstanding (1)

 12:25

Mitch (3)

 14:16,17;32:25

mixed (1)

 12:16

Monica (1)

 14:15

month (1)

 24:17

months (2)

 18:22;24:13

morale (3)

 17:6;25:9;27:9

more (6)

 3:5;4:15,16;5:5,7;8:12

mostly (1)

 14:14

move (9)

 2:5;3:15,19;4:1,23;5:1;

 8:21;17:13;30:25

moves (1)

 5:4

moving (1)

 2:25

much (5)

 7:3;9:13;13:18;22:3;26:21

multiple (1)

 7:5

myself (2)

 25:7,19

N

necessarily (3)

 3:5;9:18;26:18

need (12)

 2:24;4:12;6:1;7:3;9:9,12;

 10:21;16:13,13;18:7;30:13;

 33:24

needed (4)

 16:9,9,12;23:7

needing (1)

 7:4

needs (4)

 3:25;5:2;16:5,23

new (1)

 21:25

next (3)

 23:21;34:19;35:20

night (1)

 36:1

nobody (3)

 2:23;13:17;20:10

None (3)

 20:6;24:11,11

notes (1)

 21:18

numerous (1)

 16:12

O

occupational (1)

 6:8

occurred (2)

 17:17;31:9

o'clock (1)

 22:13

off (3)

 16:3,3;26:7

offer (1)

 3:12

office (9)

 2:15;6:17;9:6;30:23,25;

 31:2,11;32:4,6

off-site (1)

 13:22

one (19)

 3:2,17;4:23;7:23;8:3;10:4;

 14:11,12,20;15:16;20:5,9;

 24:25;31:1,1,2,12,12;32:20

one-on-one (9)

 10:24;14:13,13;15:10;

 21:15,17,22;22:12,13

ones (1)

 19:17

ongoing (1)

 24:15

only (3)

 3:11;20:5;24:24

open (5)

 4:23;8:2;9:16;10:18;35:13

opening (1)

 7:25

opportunity (3)

 2:15,20;30:11

order (1)

 17:9

organized (1)

 20:22

organizer (1)

 21:5

others (1)

 20:6

out (21)

 4:8,12;8:4;9:23;17:3;

 18:11,23;19:17;20:3,22;

 27:15;28:18;29:17;30:8,25;

 31:7;32:4,6;33:25;34:25;35:9

outcome (1)

 20:25

outside (2)

 3:5;34:24

over (1)

 34:18

own (1)

 17:1

P

paper (1)

 9:22

part (5)

 5:17;19:22;20:12;23:11;

 24:25

participate (1)

 33:17

partner (2)

 25:23;30:1

partners (1)

 18:1

passion's (1)

 23:13

past (2)

 18:18;28:24

payroll (2)

 20:17;34:10

peep (1)

 32:10

people (16)

 2:25;3:24;4:11;5:5;6:19;

 15:13;16:18;19:11,24;20:10;

 28:10;29:4;30:22;34:6,10,13

people's (7)

 28:2,3,12,14,18;29:9,25

perceive (6)

 2:19;28:4,25;29:25;30:1;

 31:3

perceived (1)

 13:9

perceiving (2)

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Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 461 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

 17:23;29:4

perception (17)

 13:2;15:3,4;16:1,3,4;18:1;

 24:22;27:19;28:5,6;29:9,12,

 16;31:19;32:9;34:17

Perceptions (8)

 27:22;28:2,3,12,14;29:3,

 14,24

performance (4)

 24:18,20,21;27:1

period (1)

 21:2

person (3)

 2:4;8:5;31:6

pertains (1)

 33:19

Phoenix (7)

 11:6;13:17;14:24;18:19;

 20:9,10;21:17

phone (2)

 22:16,19

phrase (2)

 28:24,25

picture (2)

 12:9;31:12

piece (8)

 4:11;9:21;24:25;27:1;

 31:10,11,12,14

place (1)

 18:23

plan (3)

 34:21,23;35:21

planned (1)

 25:5

plant (6)

 5:10,19;6:13,19;9:15,19

point (13)

 13:5;16:14;23:2,7;27:15;

 29:7;30:5;32:8,10,15,23;

 33:12;35:7

portion (3)

 3:17;5:12;20:13

position (12)

 2:18;3:17,24;4:2,4,25;6:10;

 7:16,25;8:11;11:5,5

positions (2)

 4:20;5:8

positive (1)

 8:8

post (7)

 2:20;3:16;7:23;9:9,19,24;

 10:7

poster (5)

 4:5;7:6;8:5,17;10:6

posting (3)

 3:5,11;7:15

postings (1)

 2:5

prepare (1)

 5:6

pretty (3)

 5:14;9:13;10:18

private (1)

 13:21

probably (3)

 2:24;6:25;9:23

professional (4)

 12:1;25:13;35:8,13

professionally (1)

 11:20

promoted (1)

 6:18

prove (2)

 31:17;32:15

proved (1)

 32:8

pushed (2)

 27:15,16

put (8)

 4:3;9:18;12:20;16:10;

 20:15;21:11;26:6;28:18

putting (3)

 13:22;17:7;35:21

Q

quali- (1)

 7:15

qualification (1)

 6:8

quit (2)

 25:16;27:16

quite (2)

 18:17;27:4

R

Rachael (5)

 11:21;25:2;27:7;30:6;36:5

raise (3)

 4:10;8:14,18

random (1)

 20:23

rather (3)

 2:9;26:1,2

Reach (5)

 8:4;9:23;18:11;19:17;

 33:24

reached (1)

 20:3

real (1)

 17:24

reality (11)

 16:2,3;17:1;27:21,23;28:5,

 7,15,19;29:9;35:10

realized (1)

 22:12

really (16)

 7:3,21;8:6,20,20;10:23;

 12:10,22;13:18;16:21;17:14;

 23:18;27:20;33:6;35:15,18

realm (1)

 31:8

reason (1)

 4:25

reasonable (3)

 16:18;20:21,25

received (2)

 12:19;20:17

receptionist (7)

 3:17;4:3,4;5:1;7:3;8:17,19

receptions (1)

 28:18

recorded (1)

 36:5

recruiting (1)

 34:11

recurring (2)

 21:23,25

referring (1)

 12:14

regardless (2)

 8:19;20:14

regional (1)

 19:10

related (1)

 24:19

relationship (6)

 11:6;12:8;14:23;26:20;

 29:12,13

replace (1)

 3:18

reports (1)

 19:14

reschedule (3)

 22:6,12,14

respect (4)

 13:12;14:4,10;20:8

respond (1)

 18:8

response (1)

 19:18

responsibilities (1)

 8:12

Right (15)

 2:13;3:7;6:9;7:4;9:21;

 10:11,14;13:19;14:1,3,19;

 24:16;26:5;34:18;35:24

righty (5)

 9:1,25;10:3,11;35:23

role (2)

 5:4;7:22

rotate (1)

 4:17

round (1)

 4:8

rounding (1)

 4:12

rusty (1)

 5:13

S

same (5)

 8:17;31:17;33:13;34:4,11

saying (8)

 15:24;19:15;27:4;28:10;

 29:4;32:14;33:5;34:1

schedule (1)

 26:3

scheduled (2)

 22:13;33:1

seem (1)

 20:4

sense (5)

 8:24;9:2;10:12;30:13;

 35:10

sent (1)

 19:16

service (4)

 2:5,6;4:4;7:25

services (1)

 5:4

set (4)

 4:8,12,16;17:10

sets (1)

 2:16

sh- (1)

 5:11

sharp (1)

 15:15

Shipman (1)

 9:24

shooters (1)

 15:15

shove (1)

 2:11

show (1)

 14:17

sided (2)

 10:25;12:21

SIGGERUD (96)

 2:4,11,14,18,22;3:2,13,21;

 4:7,14,21;5:9;6:1,7,10,12,15,

 24;7:2,8,11,13,18;8:2,11,16,

 24;9:1,3,8,11,18,21;10:2,6,

 10,13;12:12;13:12,20;14:1,4,

 22,25;17:19;18:16,21,25;

 19:3,7,9,13,21;20:6,14,20;

 21:8,12,14,21;22:7;23:5,10;

 24:9,14,17,24;25:20;26:15,

 19,25;27:8,22;28:6,14,20,23;

 29:3,11,20,22;30:4,14,19;

 31:10,20,23;33:19;34:4,15;

 35:2,19,23;36:1,3,6

signals (1)

 12:16

significantly (1)

 6:20

single (5)

 22:1;31:5,6,16;32:20

sitting (1)

 35:20

situation (4)

 17:24;25:7,10;35:10

skill (4)

 2:16;4:8,12,16

skills (5)

 2:6;4:24;6:16;7:10,11

sky (2)

 28:25;29:1

small (2)

Min-U-Script® ARIZONA REPORTING SERVICE, INC.

(602) 274-9944 www.az-reporting.com

(5) perception - small

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 462 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

 24:25;31:11

somebody (5)

 2:6,12,18;7:2;30:1

someone (3)

 18:13;22:10;29:25

someone's (1)

 16:1

someplace (1)

 5:23

sometimes (4)

 5:15;22:1,2,4

somewhere (1)

 29:14

son (1)

 24:8

sort (2)

 9:14;19:7

so's (2)

 33:22,23

sounds (3)

 3:9;10:13;27:3

space (1)

 4:23

Spanish (1)

 5:10

speak (1)

 15:8

spectrum (1)

 6:16

spot (1)

 12:20

stand (1)

 12:3

standard (2)

 33:13,14

stands (2)

 11:6;15:2

start (1)

 18:1

started (2)

 16:8;23:17

starting (1)

 16:15

stay (2)

 17:23;25:15

staying (2)

 18:4;23:22

still (6)

 5:2,3;11:16;18:13,14;35:20

stress (3)

 17:2,7;25:6

stressed (1)

 25:17

stresses (1)

 17:4

struggled (1)

 6:20

struggles (1)

 5:15

successful (4)

 11:9;18:6;26:24;35:4

suggested (1)

 11:12

support (4)

 14:21;17:8;27:13;34:21

supported (1)

 12:7

supportive (1)

 18:8

supposed (1)

 31:15

Sure (23)

 3:21;4:8;10:3,20;11:2,11,

 13,18;12:2;13:3;14:22;15:25;

 17:11,24;18:5,17;23:24,24;

 26:11;27:4,18;33:15;35:3

sword (1)

 18:9

systems (1)

 7:5

T

table (1)

 35:9

talk (4)

 2:24;3:7;5:21;31:13

talked (12)

 6:4;13:16,21;14:14,14,15;

 15:5,6,13;19:9,23;25:22

talking (7)

 5:5;14:11,19;28:2,3,11;

 35:16

talks (1)

 5:9

team (8)

 11:7;19:10,10;23:11;

 26:23;27:1;34:16;35:2

technology (1)

 6:22

telling (4)

 27:14;29:18,19;30:8

term (1)

 27:20

Thanks (2)

 29:6;35:24

There'll (1)

 4:10

thinking (2)

 22:20;32:17

though (6)

 18:8;27:19;30:6;32:7,13;

 34:2

thought (1)

 22:18

throughout (2)

 32:12,18

tiny (1)

 31:12

today (3)

 18:17;22:11;35:16

together (1)

 35:21

told (5)

 6:3;13:24;26:15,25;30:8

tomorrow (1)

 22:15

toolbox (1)

 4:9

top (1)

 17:1

totally (1)

 15:17

touch (1)

 10:16

touching (1)

 22:25

track (4)

 17:21,25;23:25;34:18

transition (3)

 27:13;34:21,23

traveling (2)

 22:5,7

true (6)

 27:18;29:19,22;30:16,18;

 32:16

try (1)

 11:11

trying (16)

 4:8;9:4;10:20;13:3;16:21;

 17:11,14,23;23:23;26:11;

 27:18;30:5;32:15;33:6,7;34:5

Tucson (2)

 22:11,14

turn (2)

 6:17;18:7

two (8)

 3:18;4:15,21;18:22;24:13;

 26:18;31:20;34:2

type (2)

 23:18;26:1

types (1)

 34:11

U

ultimately (3)

 4:2;8:8;27:3

Um (28)

 2:22;3:21;4:7,22;5:11,16,

 21,23;7:9,18,23;9:12;10:17,

 19;11:1;14:10,14;15:8,14;

 16:9,15;17:12,12;25:7,8,10,

 14;33:3

undue (1)

 17:7

unexpectedly (1)

 21:3

unfair (1)

 24:3

unknown (1)

 16:11

unless (1)

 13:24

up (27)

 3:24;5:20;7:25;11:13;

 12:23;14:17;15:11,11,18;

 16:8;17:10;21:3,11;22:8,22;

 23:9;24:4,7,12,17;25:16;

 26:10,17;27:2;31:1,1;34:21

up- (1)

 25:4

upon (1)

 25:4

upset (1)

 35:12

use (4)

 6:21;7:3,5;13:14

utmost (1)

 25:13

V

vacation (1)

 15:6

value (3)

 7:15,19;30:2

view (1)

 28:12

W

waiting (4)

 18:13,20,21;22:19

walk (3)

 32:3,10,20

wanna (5)

 9:5;11:17;15:25;33:20;

 34:17

wants (3)

 4:23,25;23:16

waste (1)

 12:1

way (13)

 3:23,25;4:2;5:20;7:4;9:11,

 24;12:11;13:14;14:7;22:25;

 27:6;32:17

ways (1)

 3:3

week (9)

 10:25;13:15,17;14:6,11,12;

 21:13;22:1;35:20

weeks (2)

 14:12;31:20

wellbeing (1)

 17:8

weren't (2)

 15:9;20:24

what's (2)

 17:25;30:12

whole (2)

 19:9;35:7

who's (2)

 2:4;7:2

WILLIAMS (95)

 2:3,10,13,17,21;3:1,7,14;

 4:6,13,18,22;5:11;6:3,9,11,

 14,23;7:1,7,10,12,17;8:1,10,

 15,23,25;9:2,7,10,17,20,25;

 10:5,9,11,17;12:15;13:19,25;

 14:3,19,23;15:21;18:7,18,22;

 19:2,4,8,12,15;20:3,11,19;

Min-U-Script® ARIZONA REPORTING SERVICE, INC.

(602) 274-9944 www.az-reporting.com

(6) somebody - WILLIAMS

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 463 of 505
Brandy Williams vs. G&K Services, Inc. 

Case No. 15-cv-01744-PHX-DDD

Conversation / Brandy Williams and Rachael Siggerud

July 17, 2013

 21:7,9,13,16,23;22:16;23:6;

 24:6,11,16,21;25:2;26:6,18,

 20;27:6,14,24;28:8,16,22;

 29:2,6,17,21;30:3,5,17,21;

 31:13,22;32:2;34:1,14;35:1,

 6,22,24;36:2

within (1)

 34:22

work (20)

 2:9;5:19;9:5,8,22;15:14;

 17:20,20,20;19:4,10,16,17;

 26:1;27:3,18;31:24;33:6,24;

 34:24

worked (1)

 17:3

working (10)

 2:7;5:6;9:14;18:14;19:13,

 24,25;23:17;27:24;35:3

worry (1)

 19:20

worth (1)

 17:4

write (1)

 6:21

writing (2)

 6:21;16:10

X

XYZ (1)

 21:1

Y

ya (5)

 27:2,3;34:20,21,24

years (2)

 25:14;34:2

Yep (2)

 8:25;9:7

yesterday (3)

 15:10;21:12,15

0

00:37:03.01 (1)

 2:1

1

1:00 (1)

 22:13

11:00 (2)

 22:20,21

15 (1)

 15:16

2

2 (1)

 9:15

5

50-50 (1)

 26:20

7

7/12 (1)

 14:14

7/9 (2)

 14:13,20

Min-U-Script® ARIZONA REPORTING SERVICE, INC.

(602) 274-9944 www.az-reporting.com

(7) within - 7/9

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 464 of 505
EXHIBIT N

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 465 of 505
Fwd: Request 

Racheel M Siggerud to: Marie A Smith 

History: This message has been replied to. 

07/08/2013 06:58 PM 

2 attachments 

,1 

1887_001,pdf 0.3 2,jpg 

Hi Marie, 

I know she copied Nikki but I think you mentioned she is out this week. Can we talk through 

this? I've had some strong performance conversations with Brandy lately as she is not meeting 

my expectations. I also believe that she is out of MLA time, although that's obviously not a bar 

to an accommodation, but she has been consistently missing work or coining in late without 

notice and for reasons -unrelated to her medical condition. (No babysitter, sick aunt/cancelled 

flight, flat tire, etc) and I let her know that she must be more consistent and present in the office 

because she is damaging her relationships with the Phoenix business team by being unreliable 

and uncommunicative. 

I would like to manage this request very closely and would like your assistance in determining 

the best way of doing so. In light of my last conversation with Brandy, I would like to look at 

having her work at least 8 hours in the office either before or after her appointments because I 

have previously experienced situations where an appointment ."first thing in the morning" means 

she d.oesn't roll in until noon. Think that is acceptable? 

R. 

Sent from my iPhone 

Begin forwarded message: 

From: "Brandy L Williams" <Brandy.WilliamsResservices.com > 

Date: July 8, 2013,6:43:04 PM CDT 

To: "Rachael M Siggerud". <RSiggerud(i4gksgsvices.com>,"Nildd L Kietzer" < 

NKietzer ci kservices.com> 

Subject: Request 

Brandy L Williams 

Human Resources Generalist 

Arizona and Southern California 

G&K Services 

4804 W. Roosevelt 

Phoenix, AZ 85043 

G&K000261 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 466 of 505
EXHIBIT O

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 467 of 505
G 0 1 2014 

July 29, 2014 

Mr, Raul Menchaca 

Equal Employment Opportunity Commission 

Phoenix District Office 

3300 North Central Avenue, Suite 690 

Phoenix, AZ 85012 

RE: Brandy Williams vs. 0 & K Services 

Charge Number; 540-2014-01051 

Dear Mr, Menchaca; 

This letter constitutes the rebuttal statement of Brandy Williams in response to the position statement of 

0 & K Services, Inc. ("G&K"). I, Brandy Williams, have carefully reviewed G&K's position statement 

and find there are discrepancies and untrue responses, I, Brandy Williams, do believe that I was 

terminated due to requesting an ADA accommodation and utilizing Intermittent FLMA, 

Factual Background Rebuttal 

I, Brandy Williams, informed Ms. Rachael Siggerud and Mr. Jacob Briscoe on December 11, 2012 that I 

was continuing to deal with ongoing health problems from the complications of the birth and delivery of 

my infant son on July 11, 2012, At the time of informing Ms. Siggerud and Mr. Briscoe of my ongoing 

health issues it was recommended by Ms. Siggerud that request a non-FMLA leave due to I had utilized 

my FMLA leave from July 11, 2012 to October 3, 2012. I was informed at the time that there would be 

an HR Realignment call on Thursday, December 13, 2012 at 10:30 AM CST (See Exhibit A). On 

December 13, 2012 1 attended the HR Realignment call at which time I was made aware that may role with 

the company would be changing from a Human Resource Representative to a Human Resource 

Generalist. I myself along with other HR Employees were made aware that the company had reviewed 

the needs of the RR Department and had made layoffs as necessary and that at that time everyone on the 

call was part of the new HR organization and our titles and roles would officially change in February of 

2013 when the transition began. On December 13, 2012 I also received a phone call from Ms. Siggerud 

informing me that I was being offered a position of an HR Generalist with G&K that was to begin in 

February 2013 and I was asked to review the job offer and sign and return it to her via email and we 

would further discuss upon my return in January. While on leave I continued to support the Phoenix 

office locations via telephone and company email and answered calls and provided assistance and 

guidance on issues surrounding the Phoenix business. 

The responding Party's position statement 

WILLIAMS-000088 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 468 of 505
Response: Ms. Williams requested and was granted various medical leaves during her tenure with G&K, 

From July 10, 2012 to October 3,2012, Ms. Williams was on FMLA leave. Additionally, from 

December 12, 2102 to January II, 2013, Ms. Williams was on non-FMLA medical leave. Finally, 

beginning on August 5, 2013 Ms, Williams was granted intermittent FLMA leave, 

Rebuttal: 1, Brandy Williams, requested FMLA leave on July 11, 2012 due to the complicated birth and 

delivery of my infant son, On December 11, 2012 I informed Ms. Rachael Siggerud and Mr, Jacob 

Briscoe that I was continuing to deal with challenging health and mental problems and needed assistance 

to attend medical and counseling sessions. At that time it was instructed by Ms. Siggcrud that I request a 

non-FMLA medical leave to meet my requested needs. Upon returning from the 30 day non-FMLA 

medical leave on January 11, 2013 I made Ms. Siggerud aware that all of my health concerns had not 

been resolved but that Iliad been cleared by my doctor to return and that I was continuing to attend doctor 

appointments and counseling sessions and I was told by Ms. Siggerud that she would continue to work 

with me and to just let her know dates and times of my scheduled appointments. On July 8, 2013 I 

requested in writing an ADA accommodation due to new continued alarming allegations beginning in 

May 2013 that I was not engaged or perceiveel to not be engaged in the business due to my time away 

from work due to medical appointments, testing, and procedures. Although, G&K is stating that there 

were performance issues I was given an increase to come to the standard salary of an 11.2% increase from 

$45,305 to $50,365 on May 4,2013 (see exhibit B) On July 9, 2013 I received a phone call from Ms. 

Siggerud informing me that she received my written request for an ADA accommodation and forwarded 

it to the employee relations management team and I was instructed by Ms. Siggerud to request a FMLA 

medical leave due to my ADA accommodation request. I was asked to complete and return the medical 

certification portion with my doctor and return so that G&K would know what type and for what period 

of time I needed accommodation. I completed and returned forms to G&K on August 5, 2013. 

Response: In June of 2013, Rachael Siggerud, Regional HR Director, did speak with Ms. Williams 

regarding her performance, including providing Feedback from the managers that Ms. Williams 

supported. A portion of the feedback was that the managers perceived her as being ineffective, Ms. 

Siggerud never told Ms. Williams that she was missing too much work. Instead, Ms. Siggerud advised 

Ms. Williams to keep others notified as to when she would be absent so that those individuals she 

supported would know who to contact for assistance, and so that other I -ER employees would know when 

she required backup. Importantly, this conversation occurred during a time when Ms. Williams was 

actively working (i.e., not on medical leave) prior to Ms. Williams requesting any accommodation. 

Rebuttal: Ms. Siggerud was aware that I was having continued health issues that had been ongoing and 

they were not a concern or addressed as a performance issue. I, Brandy Williams, never was put on 

written Performance Improvement Plan. (See Exhibit C) 

Response: In July 2013, Ms. Williams advised Ms. Siggerud that she wanted to resign because she did 

not want to work as a FIR Generalist and preferred to work on the Talent Acquisition team as a recruiter, 

Ms. Siggerud actually tied to persuade Ms. Williams not to make any rash decisions. Ms. Siggerud 

suggested that Ms. Williams should think about her decision over the weekend. Shortly thereafter, Ms. 

Siggerud learned that the Talent Acquisition team was planning to hire a temporary contract recruiter to 

assist with the team's workload. Rather than hire the temporary contract worker, and to honor Ms. 

Williams' desire to move to the Talent Acquisition team, effective July 29, 2013, Ms. Siggerud placed 

Ms. Williams on the Talent Acquisition team, Ms. Williams' title did not change, as the work in the 

Talent Acquisition area was temporary. The move was unrelated to Ms. Williams' FMLA leave, but was 

done because Ms. Williams herself indicated she desired to work in that area, Ultimately, the Talent 

Acquisition team determined that Ms. Williams' performance during her temporary assignment was 

below that required to consider offering Ms. Williams a permanent position, and because G&K had 

WILLIAMS-000089 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 469 of 505
determined the HR Generalist role was overstaffed, as is more fully discussed below, Ms. Williams was 

terminated, 

Rebuttal., 1, Brandy Williams, had a conversation with Ms. Siggerud on 7/17/2013 to where I expressed 

my concern and stress of feeling forced to quit/resign from the business due to my health concerns, I 

expressed to Ms. Siggerud that this what they were labeling a performance issue was all clue to my time 

away from work to attend doctor's appointments, procedures, testing, surgeries, etc. At no time were any 

performance issues explained specifically other than I was being perceived to not be engaged due to me 

being away from the business. Ms. Siggerud twisted every conversation into a performance issue 

although all we ever discussed was me being away from the business which gave managers a perception 

that I was not engaged or supportive. I made Ms. Siggerud aware that all allegations were completely 

untrue and I knew for a fact that they were due to that I was continuously in the business on a daily basis 

other than attending appointments that she was aware of. Ms. Siggerud suggested that she felt that I 

didn't want to any longer be in the business and that she would give me three days to think about it. Ms. 

Siggerud stated that she would like me to think about whether 1 wanted to continue being in the company 

over the next couple of days to decide whether! wanted to stay in the business. At no time did I ever 

state to Ms. Siggerud that! wanted to resign from the business. (See Voice Recording from 07/17/2013) 

On July 26, 2013 I was granted Intermittent FMLA and I received a phone call from Ms. Siggerud that 

she was placing me in a temporary position on the Talent Acquisition team for 2 to 3 months which was 

to begin effective immediately the following Monday on July 29, 2013. I asked Ms. Siggerud if I should 

continue to perform my role as an FIR Generalist and attend meetings etc and she stated no that I should 

focus on recruiting for Michael Hammond on the Talent Acquisition Team. I asked Ms. Siggerud if I 

would be allowed to return to my role after the temporary role was exhausted and she stated that we 

would discuss that at the time of the end of the temporary role in Talent Acquisition, I was never made 

aware that my performance was below that required due to that I received numerous compliments and 

thank you's for doing such a great job of communicating with managers in real time and making a great 

impact on recruiting for the business (See Exhibit D) Immediately nearing the end of the temporary 

assignment in Talent Acquisition [ received a phone call from Ms. Siggerud on September 23, 2013 

asking mete meet her in the Phoenix business to have a discussion with herself and Mr. Erie MeNaul, 

Regional Vice President, At the time of the meeting with Ms. Siggerud and Mr. MeNaut I was made 

aware that I would not be returning to my regular role with the company and that they had decided that 

the generalist role was overstaffed for that region. I was presented with a Notice of Separation (See 

Exhibit ) and made aware that my last day would be Friday September 27, 2013, 1 was also given a 

Confidential Separation Agreement and General Release which contained a Release of Legal Rights had I 

accepted separation pay in the amount of $3,913,00 equal to four weeks within 7 days of signing the 

agreement, (See Exhibit H) 

Response!Following the Hr realignment in early 2013, G&K's Northwest Region had three HR 

Generalists reporting to Ms, Siggerud-Janellc Bonocua, Kaela Ellison and Brandy Williams, In August 

2013, it was determined that the Northwest Region was overstaffed by one HR Generalist, as HR 

leadership concluded that during the alignment process, HR had overestimated the HR Generalist 

resources necessary for the Northwest Region. Ms. Siggerud and Pelham Chastang, Senior Director 

Human Resources, reviewed the three HR Generalist performance reviews for the most recent fiscal year, 

which ended on June 29, 2013 (see Exhibit I), As a part of the performance review, each G&K employee 

creates up to five objectives at the beginning of each fiscal year, and those objectives are then rated on a 

scale from on through five, with 1 being the lowest rank of "Not Meeting Expectations" and 5 being the 

highest rank of "Outstanding," Any rank below a 3 indicates that an employee is below expectation. 

Along with reviewing past performance, Ms. Siggerud and Mr. Chastang also considered the locations 

each FIR Generalist covered, Ms. Bonacua lived in California, supported seven locations and had 

WILLIAMS-000090 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 470 of 505
knowledge and expertise regarding California's complex employment laws, Ms. Ellision lived in 

Minnesota and supported eleven locations. Ms. Williams lived in Arizona and supported three locations, 

G&K made the decision to retain Ms. Bonucua and Ms. Ellison due to their higher performance ratings 

and higher number of locations they were able to support. Thus, G&K eliminated Ms. Williams' HR 

Generalist position. Notably, Ms. Williams has not been replaced, as Ms. Ellison is now supporting the 

locations previously supported by Ms. Williams. 

On September 24, 2013 Ms, Siggerud, and Eric MeNaul, Regional Vice President, met with Ms. Williams 

to inform her that her position had been eliminated. During the meeting, Ms. Williams did not state that 

she had concerns with the job elimination, and she did not claim that she was target of disability 

discrimination. Rather, Ms. Williams sincerely thanked Ms. Siggcrud for all of the help and support that 

she provided. 

Rebuttal: 1 was not made aware in August of 2013 that it was determined that my position was 

overstaffed. I was not made of aware of the determination of overstaffing until the end of my temporary 

assignment and notice of Separation on September 24, 2013. My objectives were never completed and 

reviewed due to my being on Maternity Leave in July of 2012 at the beginning of the Fiscal year. I asked 

Ms. Siggerud when we would complete these objectives and she stated when I returned we would discuss 

them, also the goals for the fiscal year changed mid-year due to the HR. Realignment in which we were 

place in new roles on February 23, 2013, Ms. Siggerud did not state to complete objectives until June of 

2013 at which time I emailed her requesting advice of what to include in the objectives and goals due to 

the role change. (See Exhibit J). My Fiscal Year Objectives nor my Performance Rating was completed 

until after June 28, 2013. 1 feel that the Performance Rating was subjective due to me taking time away 

from work to attend doctor's appoinments, surgeries, procedures, testing, etc. During the ER Relignment 

notification and placement into new roles I was notified on February 23, 2013 that I would be given 

additional locations in Southern California to support along with my current locations in Arizona, At that 

time I began to support Southern California and began to travel to support all of these locations, 

The structure of the location support is inaccurate as to whom each location was assigned. (Also, please 

see Exhibit K with company email signature stating HR Generalist of Arizona and Southern California) 

Please see corrected chart showing location assignments: 

Northwest Region HR Generalist Coverage Before FIR Generalist Coverage After 

Los Angeles, CA / 4 locations Brandy Williams Janellc Bonacua 

WILLIAMS-000091 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 471 of 505
Sacramento, CA /2 locations JaneIle Bonaeua JaneIle Bonacua 

Pittsburg, CA / 2 Locations JaneIle Bonacua JaneIle Bonaeua, 

Phoenix, AZ / 4 locations Brandy Williams Kaela Ellison 

St, Cloud, MN / 6 locations K.=la Ellison Keela Ellison 

St. Paul, MN / 5 locations Kaela Ellison Kaela Ellison 

1, Brandy Williams, supported all previously assigned locations in Arizona including Phoenix Plant, 

Prescott Valley, Tucson, and Yuma, AZ and also locations in Southern California of Los Angeles Plant, 

Sun Valley, Ontario, and San Diego, CA. I supported a total of 8 locations before being placed into a 

temporary assignment the end of July 2013. These locations were always allocated to myself for support 

from the enactment of the HR Realignment and were not delegated to others until after my termination. 

(Kaela Ellison and Janelle Bonactia can attest to this feet) On September 24, 20131 did meet with Ms. 

Siggerud and Mr. MeNaul in the Phoenix location at which time I was notified of my separation with the 

company effective September 27, 2013. At the time of the notice 1 was very cordial with Ms. Siggerud 

and Mr. McNeill and thanked them for the opportunity of working for G&K as to not present as a 

disgruntled employee and to continue my professional demeanor due to 1 had already expressed on 

numerous occasions to Ms. Siggerud that I was being retaliated against and forced to resign and leave the 

company (See Voice Recording dated July 17, 2013) 1 felt at this time that my concerns were not taken 

seriously and decided I would obtain an attorney and file a charge with the EEOC immediately following 

discharge, at which dine 1 obtained Phillip Dayes Law Group PC on October 8, 2013 to originally to 

represent me in this matter (See Exhibit L) 

Respow:Ms. Williams was not discriminated and retaliated against for requesting ADA aecomodation 

and for taking FMLA leave. G&K granted Ms. Williams leave when it was requested. Ms. Williams' 

termination was unrelated to her medical leave or medical status. Instead, G&K made a business decision 

to eliminate one of it's HR Generalist positions in the Northwest Region. Based on performance, Ms. 

Williams was terminated. Additionally, although G&K granted Ms. Williams' request for intermittent 

FMLA leave, G&K's records indicate that while Ms. Williams did request time off for various reasons, 

she never actually availed herself of FMLA intermittent leave after July 15, 2013, 

Rebuttal:I, Brandy Williams, do feel that I was discriminated and retaliated against for requesting an 

ADA accommodation and taking FMLA leave due to being placed in a temporary role of Talent 

Acquisition arid never being allowed to return to my original position after requesting an ADA 

accommodation and utilizing FMLA Leave, I, Brandy Williams, was never placed on a written 

Performance Improvement Plan or ever given any written warnings, The concern and issues did not arise 

until after me taking time away from work which Ms. Siggerud approved and was fully aware of due to 

my health concerns (See exhibit M) 1 deci ded to document in writing on July 8, 20 13 the need for an 

ADA accommodation due to issues continuing to arise after me expressing a verbal need to Ms. Siggerud 

for support for ongoing health issues at which she had been previously accommodating since December 

of 2012, The I-1R Department and my immediate supervisor were lacking in adequately documenting my 

need for support or any other issues based around my time away from G&K at which time I began to do 

so myself. I, Brandy Williams, was never place on a Performance Improvement Plan or given any written 

warnings, I feel [received a subjective Performance Rating due to my ADA accommodation request and 

FMLA utilization which Ms. Siggerud did not complete until August 28, 2014 well after my ADA 

accommodation request and utilization of Intermittent FLMA (See exhibit N). The findings in the 

previous responses arc untrue where as it is stated I supported less locations and that my performance was 

below that required to obtain a position with G&K due to me receiving positive feedback of managers 

being very happy with the increased recruiting support in the region from myself and specifically stating 

WILLIAMS-000092 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 472 of 505
EXHIBIT P

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 473 of 505
'f...kkh 

From. Rachael M Siggerud/GKS 

To: Brandy L Williams/GKS@GKS 

Cc: Michael J Hammond/GKSOGKS 

Date 0a/14/2013 02:22 PM 

Subject: Recruiting Feedback 

Hi Brandy, 

I just wanted to share some feedback from the NorthWest RDO call todayl Tony said that 

ha has been very happy with the increased recruiting support In the region and Frank 

Gomez specifically said that you do a great job of conummIcating with him in real time 

Thank you for your help. It's clearly having a positive impact on our regfonl 

Rachael 

Rachael M SIggerud 

Regional Director of Human Resources 

GSA Services 

685 Olive St 

St Paul, MN B5130 

Phone: 851.83M.7002 Cell: 952 232.031116 

Fax: S61.855.7007 

WILLIAMS-000099 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 474 of 505
EXHIBIT Q

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 475 of 505
Job Code Table Page 1 of 2 

&in Now sAilidow ? I lop g P1,190 ,ISA, 110 

.0)0 

Job Description 

G&K Confidential 

vetf. 

11.0 vsmig,. of 51 Lest 

Printer FdendlyVersion I 

FLSA Status Professnl SalaryAdministration Plan: CRP Salar y(rade: K 

V:IrY1..t4L. !Ott, 

,Data e 01/251/2014 

Department 

Reports To: 

Supervises hie of employees) 

Job Summary: 

(Main Job purpose/function, major objectives and ke yworkin g/business relationships) 

Work as a Business Partner supporting a Region, coverin gmultiple locations in multiple states, in an Industr yleadin g 

uniform and facilityservices business. Responsible for partnerin gwith the Re gional Human Resources Director to 

• drive business results by successful Implementation of a human capital plan and pro grams. Specific duties Include 

Implementation of compan ywide and regional human resources pro grams, plans, and services Includin g: talent 

development, work tome plannin g , succession plannin g , labor and employee relations, rewards, trainin gand 

leaderShip development, and performance management. 

Essential Job Functions and % of The Spent On Each: 

(For each Job function, describe what is expected lobe completed, how often, and expected results) % of Time 

Serves as a key HR business partner in a region to ensure human capital objectives are achieved, 

I Partners with the Sureness to provide proactive, client oriented solutions in areas such as workforce 

and succession plannin g, org anizational design and leadership development, 

Provides HR functional consultation and expertise to re gional leaders, 

SupportsTalent Management for the region; staffin g, recruitin g, people development, succession 

; plannin g , training and hi gh potential leadership development. 

Supports In the development of High Potential and EmergingTalent leaders Includin gassessment, 

coachin gand development *riming throughout the region and the compan y. 

• Consults on re gion wide organizational development Intervenlions lo drive strate gic compan y 

inhialives and re gion epecific business pro grams. 

Work with leaders to create positive, safe and productive work environments. 

Responsible for coaching and developing leaders to create hi gh performance accountabilit ycultures 

and highlyengaged work teams. 

Build and maintain a stron gworkingknowledge of the business; the financial position, business plan 

and culture, 

Analyze trends and metrics in partnership with the HR team to develop solutions, programs and 

policies. 

Non-Essential Job Functions and 54 of Time Spent on Each: 

(For each job function, describe what Is expected to be completed, how often, and expected results) le of Tines 

Minimum Qualifications: 

Education.Req uiremente: 3 Rows VirWAI 1, '11■"3-1 Flier 1'5111 of 1 1.1g: Lest 

Set a GiSSRA Job Code: 6776 

Joinode Table 

Effective Date 05/17/2014 

Manager Level 9 

GK Job Description 

Prepared By: 

HR Generalist 

Bachelors de gree Human Resources mana gement, psychology , business or related field. 

Work Experience Roci tArementc 3 rows Mow Ail 1.0i Flts1 or z hi3 

A minimum of 3 to 5 y ears of progressive human resource genenstist experience. 

Experience In managin g multiple business units In multiple locations. 

„,..... 

Specific Skills and Competencies: 5 rows view All l a Fingal 1.5 eta Last 

Proven experience with performance mana gement, succession plannin g , talent management, leadership 

G&K000259 

http://gks098116.gkservices ,com/pse/IMPROD/EMPLOYEE/HRMS/c/G1( Hlt_MENTIJO B_C ODE JBL.GBL 1/21/2016 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 476 of 505
Job Code Table Page 2 of 2 

. i ;Strong conflici management skills, Ability to manage conflicting pfloritles, Be self directed end motivated, Strong ; 

interpersonal, facilliation, and negotiation skills, I 

. . I :ExcellentWriiten, varbahgral.presentollon skills.. •Expenence - In creative problem solving, influencing, ohange 

. M.l'Illanfirri 61.1 f/Ana (ilinfirtang.barriors ei any.oiganizatiotiel level, 

. I 

;AblIlly to develop trusting relationship% to On support and achieve results at all levels of the organization, 

Experience In coaching, training, and developing employees In a high performance culture, 

Ability to take the Initiative to Identify end anticipate client needs end recommend solutions,- Knowledge of and 

experience with employment laws, labor relation% and practices inducting: FML,A, ADA, AAP, PLEA, DOT, EEDC, ; 

litigation, Iselin end dispute resolution, pre-employment drug testing, eta, 

Specialized Knowledge, licenses, otc: 5 rows viow 0,1 ,671 Finn 4.■ 1-2 of 2 PI Lord 

PHR and SPHR preferred, 

Experience wiln Organizational Development Interventions end consultation. 

Working Conditions, Hazard & Physical Work Demander 

(inionally, Duralion and Fregoency): 

Last Update Date/Time 04/29/2014 9:2323AM by RBAILEY 

,V.,,;(;1:1;:c; 

coaching and canting. Strong, business acumen, 

. G&K000260 

http ://gks098116, gks erv cc orn/pse/HRPROD/EMPLOYEE/FIRMS/o/OK_HR,yENU .SOB_CODE_TBL,GBL 1/21/2016 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 477 of 505
EXHIBIT R

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 478 of 505
Memorandum 

gY,11.6.1-4- 

G&K SERVICES 

TP: Brandy Williams 

Date: September 24, 2013 

RE: SEPARATION AGREEMENT AND GENERAL RELEASE 

Enclosed you will find copies of the Separation Agreement and General Release. Please 

review the Information carefully and consider the agreement fully utilizing any resources you 

feel necessary prior to signing the agreement. 

There are certain items to note in connection with your separation. They are: 

▪ Your employment termination date is September 27,2013 

• You were provided original copies of the Separation Agreement and General Release 

for consideration. Please sign all copies and return to the Employee Solution Center at 

5995 Opus Parkway Suite 500, Minnetonka, MN 55343. A signed copy will be returned 

to you after the designated waiting period, 

• Information concerning your benefits such as medical, dental and 401K can be 

referenced on the benefits overview, Rights to continuation of certain benefits under 

COBRA will also be sent to you soon, Any questions regarding benefits can be 

answered by calling the HR Solution Center at 1.85S.GK.HR4ME, or by email at 

hrsolutions@gicservices,com, 

▪ Your final paycheck and any unused vacation has been paid to you. 

• Please verify your address. 

Feel free to contact The Employee Relations team by calling the Employee Solution Center at 

1,355,GK.HR4ME (1,B55.454.7463), or by email at hrsolutions@gkservices.com . 

WILLIAMS-000100 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 479 of 505
THIS CONFIDENTIAL SEPARATION AGREEMENT AND GENERAL RELEASE 

CONTAINS A RELEASE OF LEGAL RIGHTS. G841( SERVICES, INC. 

RECOMMENDS THAT YOU CONSULT WITH AN ATTORNEY BEFORE SIGNING 

THIS AGREEMENT AND RELEASE. YOU MAY NOT SIGN THIS AGREEMENT AND 

RELEASE UNTILAFTER YOUR SEPARATION DATE. 

CONFIDENTIAL SEPARATION AGREEMENT AND GENERAL RELEASE 

THIS CONFIDENTIAL SEPARATION AGREEMENT AND GENERAL RELEASE 

("Agreement and Release") is made as of the 24th day of September, 2013 by and between G&K. 

SERVICES, INC., a Minnesota corporation, maintaining its principal offices at 5995 Opus 

Parkway, Suite $00, Minnetonka, Minnesota 55343 ("Employer"),and Brandy Williams, an 

individual residing at 2870 W Webster Ct,, Phoenix, AZ 85086 ("Employee"), 

As used in this Agreement and Release, the term 

"Company"means Employer, its subsidiaries, affiliates, divisions and related entities, 

successors, assigns, and its and their respective past and present owners, officers, employees, 

directors, agents, consultants, and representatives, both individually and in their official 

capacities, arid any employment-related pension, welfare or other employee benefit plan and its 

trustees and administrators. 

"Confidential Information" means information of Employer which is not generally 

known to the public, including customer lists or routes, pricing, purchasing, inventory, business 

methods, strategies, financial information, training manuals or other materials developed by or 

for Employer, and any other non-public material information relating to the business of 

Employer. 

In consideration of the mutual covenants and promises hereinafter set forth, Employer 

and Employee hereby agree that: 

I. Separation of Employment. Employee's last day of employment with Employer was 

September 27, 2013 (the "Separation Date"). Employer has paid Employee all wages, salary and 

other compensation and benefits due and owing to Employee as of the Separation Date. 

2. Consideration. In exchange for Employee's general release and waiver of all claims 

against the Company as provided in this Agreement and Release, Employer will provide 

Employee with the following consideration at the time and in the manner set forth below, 

provided Employee does not exercise Employee's revocation right under Section 12 herein (if 

applicable): 

Employer will pay to Employee, as separation pay, which Employee has not 

earned and to which Employee is not otherwise entitled, the amount of $3,913.00, 

equal to lour (4) weeks of Employee's weekly base compensation in effect as of 

the Separation Date, less applicable withholdings, payable in one (1) equal 

weekly installment, in accordance with Employer's normal payroll practices, 

beginning on the first regular payroll date of Employer following seven (7) 

calendar days after Employee signs this Agreement and Release provided that 

4901128v1 

WILLIAMS-000101 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 480 of 505
r 

Employee has not exercised Employee's right to revoke or rescind the release of 

claims as provided in Section 12 herein (if applicable). 

G&K will pay for all reasonable expenses of outplacement services provided by 

Right Management, but not to exceed $2,400.00 in the aggregate, that are incurred 

during the three (3) month period commencing as of the date of termination, by 

direct payment to such provider. 

3. No Admission of Liability. The consideration to be provided to Employee by Employer 

pursuant to this Agreement and Release is not and shall not be construed or represented to be an 

admission of liability of any kind by the Company. 

4. No Other Entitlement. Employee confirms that no monies or compensation other than 

those provided for in this Agreement and Release are due to Employee from the Company (other 

than vested benefits under any employee benefit plan of Employer in which Employee is 

currently a participant) and that the consideration provided in Section 2 hereof is in full 

satisfaction of any and all claims that Employee may have as to salary, expense reimbursement, 

compensation or claims of any kind, including, without limitation, sick and vacation time. 

5. Company Property, Confidential and Financial Information. Employee recognizes 

and acknowledges that the performance of Employee's services for the Company has resulted in 

its disclosure to Employee of certain Confidential Information. Employee represents and agrees 

that Employee will not disclose or directly or indirectly use any Confidential Information for 

Employee's own or any other person's or entity's benefit. Employee has returned to Employer 

all documents and material containing Confidential Information, including, but not limited to, 

original copies and all other copies of customer lists, prospective customer lists, contracts, books, 

records, training manuals, correspondence, business and financial records, operations reports or 

any part thereof acquired by Employee in the course of employment by the Company. 

Employee acknowledges that irreparable harm will result to the Company, its business and 

property, in the event of a breach of this Section 5 by Employee, and that any remedy at law 

would be inadequate; and therefore, in the event this Section 5 is breached by Employee, the 

Company shall be entitled, in addition to all other remedies or damages at law or in equity, to 

temporary and permanent injunctions and orders to restrain the violation hereof by Employee 

and all persons or entities acting for or with Employee. 

6. Other Agreements Superseded, This Agreement and Release replaces, supersedes and 

nullifies any prior oral or written agreements between Employee and Employer, except that 

certain Non-Competition and Confidentiality Agreement previously entered into between 

Employee and Employer which such agreement shall remain in full force and effect. 

7. General Waiver. In exchange for the consideration set forth in Section 2 of this 

Agreement, Employee, for Employee and Employee's dependents, heirs, creditors, executors, 

administrators, representatives, successors and assigns, and anyone claiming by or through 

Employee or such other persons, hereby covenants not to sue and releases and forever discharges 

the Company from and against any and all actions, causes of action, damages, claims, debts, 

demands, obligations, costs, expenses, and liabilities for any reason whatsoever, including, but 

2 

9901128%1 

WILLIAMS-000102 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 481 of 505
not limited to, those for bonuses, wages, salary, benefits or other forms of compensation, or any 

other complaints and demands whatsoever, in law or equity, including any claim for attorneys' 

fees, whether accrued or not accrued, whether known or unknown, foreseen or unforeseen, 

including, but not limited to, all claims regarding wrongful termination, breach of express or 

implied contract, discrimination, retaliation, harassment, defamation, negligent or intentional 

infliction of emotional distress, violation of public policy, promissory estoppel, fraud, 

misrepresentation, good faith and fair dealing, negligence, invasion of privacy, or any other 

common law, statutory, or equitable causes of action which have or that may later arise out of the 

relationship between Employee and the Company to date, including, without limitation, the 

separation of Employee's employment. This total and complete release and waiver includes, 

without limitation, claims which have or could arise under the National Labor Relations Act, 

Title VII of the Civil Rights Act of 1964, the Employee Retirement Income Security Act of 1974 1 

the Age Discrimination in Employment Act of 1967 as amended by the Older Workers Benefit 

Protection Act, the Equal Pay Act, 42 U.S.C. § 1981, the Sarbanes-Oxley Act, the Dodd—Frank 

Wall Street Reform and Consumer Protection Act, the Fair Credit Reporting Act, the Vocational 

Rehabilitation Act, the Family and Medical Leave Act, the Worker Adjustment and Retraining 

Notification Act, the Fair Labor Standards Act, the Lily Ledbetter Fair Pay Act of 2009, the 

Americans With Disabilities Act, the Rehabilitation Act of 1973, the Genetic Information 

Nondiscrimination Act, the Immigration Reform and Control Act of 1986, the Civil Rights Act of 

1991, the Occupational Safety and Health Act, the Consumer Credit Protection Act, the 

American Recovery and Reinvestment Act of 2009, the Asbestos Hazard Emergency Response 

Act, the Employee Polygraph Protection Act, the Uniformed Services Employment and 

Reemployment Rights Act, the Arizona Civil Rights Act, the Arizona Employment Protection 

Act, the Arizona Equal Pay Law, the Arizona Wage Act, the Arizona Occupational Safety and 

Health Law, the Arizona Medical Marijuana Act, the Arizona Consumer Reporting Agencies and 

Fair Credit Reporting Law, the Arizona Blacklisting Law, the Arizona Right to Work Act, the 

Arizona Victims' Leave Law, the Arizona National Guard Leave Law, the Arizona Drug Testing 

of Employees Act, the Arizona Minimum Wage Act, the Arizona Wage Payment Law, the 

Arizona Occupational Health and Safety Act, the Arizona Genetic Privacy Law, the Arizona 

Workers' Compensation Law, Arizona Revised Statutes Section 23-1501, the Arizona 

Constitution, Arizona common law, and all other applicable state, county and local ordinances, 

statutes and regulations, each as may have been amended, and any other federal, state or local 

discrimination, bias, human or civil rights, wage, hour, pension or labor laws and any other rule 

and/or regulation, or public policy, contract (whether oral or written, expressed or implied from 

any source), tort, including, assault, battery, or any other claim, whether known or unknown, of 

any kind whatsoever, subject only to the exceptions set forth in Section 8 below. 

8. No Claims; Exceptions. Employee represents that Employee has not caused or 

permitted to be filed on Employee's behalf any charge, complaint, grievance, or proceeding 

before any federal, state or local administrative agency or court, or any other forum, against the 

Company. Employee agrees that this Agreement and Release shall act as a total and complete 

bar to any recovery of monetary damages by Employee should Employee ever elect to exercise 

the right to file an administrative charge with a government agency. Nothing in this Agreement 

and Release shall prohibit either party from bringing any administrative or judicial action to 

enforce this Agreement and Release or to determine whether the provisions of this Agreement 

and Release comply with the requirements of the Age Discrimination in Employment Act. 

3 

9901128v1 

WILLIAMS-000103 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 482 of 505
Further, nothing in this Agreement and Release shall prohibit Employee from bringing any 

claims that may arise after the date on which Employee signs this Agreement and Release. 

9. Nun-Disclosure, Employee agrees that this Agreement and Release is confidential and 

Employee shall not publicize or disclose (unless required to do so by judicial order or process) to 

any other person or entity that Employee received any separation pay or the terms of or amount 

of any payment made by Employer pursuant to this Agreement and Release. The only other 

exceptions to this non-disclosure requirement are that Employee may disclose this Agreement 

and Release: (i) to Employee's attorneys, accountant, and spouse, provided that any such 

recipient shall first agree to be bound by this section to the same extent as Employee, or (ii) if 

required by law. 

10. Construction. This Agreement and Release shall be binding on the parties, their heirs, 

executors, administrators, successors and assigns, and shall be construed and interpreted under 

the laws of the State of Minnesota, without regard to conflicts of law provisions, to preserve its 

enforceability. Each of the parties hereto agrees that any action for the enforcement of this 

Agreement shall be brought in any court in the state of Minnesota or any federal court sitting 

therein and consents to the jurisdiction of any such court. If any one or more of the terms of this 

Agreement are deemed to be invalid or unenforceable by a court of law, the validity, 

enforceability, and legality of the remaining provisions hereof will not in any way be affected or 

impaired thereby, and it is the intent of the parties that a court should modify or otherwise deem 

unenforceable any clause set forth herein to render this Agreement and Release enforceable to 

the maximum extent possible. 

Ii. Taxes. Employee is solely responsible for any federal, state or local income taxes and 

other taxes imposed on Employee with respect to any payments made under this Agreement. 

Employer shall be entitled to withhold on and report the making of such payments as may be 

required by law as determined in the reasonable discretion of Employer. 

12. Revocation. 

THE FOLLOWING PROVISION IS ONLY APPLICABLE TO EMPLOYEES 

40 YEARS OF AGE OROLDER: 

Employee understands that Employee may revoke Employee's execution of this Agreement and 

Release within the seven (7) calendar day period following the day Employee executes this 

Agreement and Release. Employee understands that this Agreement and Release shall not 

become effective or enforceable until the revocation period has expired and no consideration as 

set forth in Section 2 hereof will be paid during that time. Any revocation must be: 

(i) postmarked within seven (7) calendar days of Employee's execution of 

this Agreement and Release, 

(ii) must be submitted, in writing, to the attention of Payroll, G&K Services, 

Inc., 5995 Opus Parkway, Suite 500, Minnetonka, MN 55343, and 

4 

9901128v1 

WILLIAM S-000104 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 483 of 505
.•Y-1,-iiirSe4 - -44 

(iii) may be delivered by hand or by mail; and if delivered by mail, sent by 

certified mail, return receipt requested. 

13. Older Workers Benefit Protection Act. 

THE FOLLOWING PROVISION IS ONLY APPLICABLE TO EMPLOYEES 

40 YEARS OF AGE OR OLDER: 

Employee acknowledges that Employee has been informed pursuant to the Older Workers 

Benefit Protection Act that Employee: 

(i) has the right to consult with an attorney before signing this Agreement and 

Release; 

(ii) has twenty-one (21) calendar days to consider whether to sign this 

Agreement and Release; 

(iii) has seven (7) calendar days after the date Employee signs this Agreement 

and Release to revoke it and that this Agreement and Release will not be effective until 

that revocation period has expired; 

(iv) does not waive rights or claims under the Age Discrimination in 

Employment Act that may arise after the date this Agreement and Release is executed; 

(v) does not waive any rights or claims that Employee may have that this 

Agreement and Release failed to conform to the legal requirements under the Age 

Discrimination in Employment Act; and 

(vi) has the right to review all aspects of this Agreement and Release with an 

attorney of Employee's choice, that Employee has been advised to consult with an 

attorney, that Employee has had an opportunity to consult with an attorney of Employee's 

choice, and that Employee has fully and carefully read and understands all provisions of 

this Agreement and Release, 

14. Post-Employment Cooperation. Employee agrees that at the request of the Company 

following the separation of Employee's employment, Employee will faithfully cooperate in 

connection with any and all matters (including actual or potential claims that have been asserted 

or threatened against the Company) that relate to alleged facts that arose during Employee's 

employment with the Company. As part of Employee's commitment to cooperate with the 

Company, Employee will promptly respond to all questions and cooperate with all inquiries from 

the Company's agents and attorneys regarding any matters raised by the Company as deemed 

necessary by the Company in its full discretion, and such obligation shall include, but is not 

limited to, answering questions, preparing truthful testimony, and providing truthful testimony in 

pending or future litigated matters, 

5 

9901128v1 

WILLIAMS-000105 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 484 of 505
H 

15, Employee's Representations. Employee represents that Employee is legally able and 

entitled to receive the consideration being provided to Employee pursuant to this Agreement and 

Release; that Employee has not been involved in any personal bankruptcy or other insolvency 

proceedings at any time since Employee began employment with Employer; and that no child 

support orders, garnishment cutlers, or other orders requiring that money owed to Employee by 

Employer be paid to any other person or entity are now in effect. 

THE PARTIES HAVE READ AND FULLY CONSIDERED THE FOREGOING AGREEMENT 

AND RELEASE AND ARE MUTUALLY DESIROUS OF ENTERING INTO THIS 

AGREEMENT AND RELEASE, EMPLOYEE HAS BEEN AFFORDED A REASONABLE 

OPPORTUNITY TO CONSIDER THE MEANING AND PRECLUSIVE EFFECT OF THIS 

AGREEMENT AND RELEASE AND WAS ENCOURAGED BY EMPLOYER TO CONSULT 

WITH AN ATTORNEY. 

HAVING ELECTED TO EXECUTE THIS AGREEMENT AND RELEASE, TO FULFILL THE 

PROMISES SET FORTH HEREIN, AND TO RECEIVE HEREBY THE CONSIDERATION 

SET FORTH IN SECTION 2 ABOVE, EMPLOYEE FREELY AND KNOWINGLY, AND 

AFTER DUE CONSIDERATION, ENTERS INTO THIS AGREEMENT AND RELEASE 

INTENDING TO WAIVE, SETTLE AND RELEASE ALL CLAIMS THAT EMPLOYEE HAS 

OR MAY NOW HAVE AGAINST EMPLOYER. 

DIRECT DEPOSIT: (only if currently enrolled) 

LIVE CHECK MAILED TO MY HOME: 

CURRENT ADDRESS: 

(EMPLOYEE NAME] Date 

G&K SERVICES, 

By 

Date 

Its: 

6 

9401 t2liv! 

WI LLIAMS-000106 

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 485 of 505
7 

H 

99011241 

WILLIAMS-000107 

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EXHIBIT S

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Document info

Result type: Fam Med Limited H&P

Result date: Jul 15, 2013, 10:12 a.m.

Result status: authenticated

Performed by: Linda Pachuta

Modified by: Linda Pachuta

Multiple issues

Patient: BRANDY

WILLIAMS DOB: Jun 28, 1981

 

Patient: WILLIAMS, BRANDY L MRN: 7-724-009-1 FIN: 3325329

Age: 32 years Sex: Female DOB: 28-Jun-1981

Author: Pachuta R.N., C.N.P., Linda

 

Chief Complaint

.

Multiple concerns

History of Present Illness

.

This is a pleasant 32-year-old female who presents today stating that she was evaluated at John C.

Lincoln Hospital recently with return of extreme migraine. Patient with history of migraines in the past and

last migraine being in March. Her most recent migraine was more severe than usual. She went to urgent

care at John C. Lincoln and was given injections of Toradol and Phenergan. She was then given an

injection of Stadol which caused patient to have increased tremors, convulsions and disorientation. She

was then sent to the emergency department at John C. Lincoln-North where MRI and other labs were

done which were normal. She states the migraines have resolved. In the past, she prescription for Relpax

which she used one migraine with start. She does not have this medication on hand at this time.

 

She is also concerned regarding recent weight loss. She states that she's not exercising regularly and has

not modified her diet to lose weight, although she seems to be losing weight fairly fast. She also states on

June 21 she had polyps removed from her uterus secondary to menorrhagia. Since having these polyps

removed, she states she continues to have spotting from one. 2 the next. Denies any pelvic or abdominal

pain. She also continues to have intermittent issues with soreness in her mouth. She was seen by ORL

recently and biopsy was done which was not suggestive of autoimmune disease, Sjogren's. However, she

does have an appointment pending with rheumatology that was requested at the advice of ORL.

 

Because of all her issues and problems, she has had tetanus and increased time off of work. She is

concerned about the security of her job with so much time off. She is requesting intermittent FMLA

paperwork to be completed.

Histories

.

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Document info

Result type: Allergy Consult

Result date: Jul 31, 2015, 12:00 a.m.

Result status: authenticated

Performed by: John Lewis

Modified by: John Lewis

Patient: BRANDY

WILLIAMS DOB: Jun 28, 1981

Mayo Clinic in Arizona

CLINICAL NOTES

 

Patient Name: Williams, Brandy L Mrs. Service Date: 07/31/2015

Medical Record Number: 77240091 Facility Name: MCA

DOB: June 28, 1981 Provider Name: John Christopher Lewis, M.D.

Age: 34 Account Number: 3325329

Service: Allergy Visit Type: Consultation

 

 

REFERRAL SOURCE:

Elizabeth Winscott.

 

REASON FOR CONSULTATION:

Mrs. Williams is a 34-year-old young lady referred by Dr. Winscott for evaluation of a history of chronic

oral and vaginal irritation and concerns regarding autoimmune disease and immunodeficiency.

 

HISTORY OF PRESENT ILLNESS:

Unfortunately, she went to the wrong campus today so our visit was somewhat foreshortened on account

of that, but I did have a chance to review ENT notes of PA Mendez who performed a minor salivary gland

biopsy for Sjögren's 08/05/2013 which was negative for Sjögren's, and Dr. Yiannias' consult note from

12/16/2013 regarding her burning mouth syndrome. His advice at that time and the finding is a low zinc

and iron level and supplementation recommended. She also had a history of atopic dermatitis, possible

allergic contact dermatitis, keratosis pilaris, and she has a history of rosacea, and she believes that she

has had a history of oral and vaginal lichen planus. She has not had an oral biopsy of this. She has had

a vaginal biopsy done elsewhere that she said was consistent with lichen planus. She has also had

problems with chronic glabrata infections. With regard to her oral symptoms, she said she gets a burning

and red appearance inside her cheeks, gums, and on her tongue. The vaginal and oral symptoms tend to

flare and remit. Joseph Brooks is her gynecologist.

 

She said that many of her symptoms seemed to occur when she was preeclamptic with her second

pregnancy. Since then she feels like she has been left with chronic inflammation and pain of varying

intensities.

 

She said she has had positive connective tissue disease tests. For instance, here she had a positive

ANA, and they were worried about Sjogren's. She said one of the other connective tissue tests was

Case 2:15-cv-01744-DJH Document 76-1 Filed 10/26/16 Page 489 of 505
 Height 161.3 cm

 Weight 65.2 kg

 Body Mass Index 25.1 kg/m2

 Vital Signs Activity Doctor Visit

 Temperature Mode Tympanic

 Temperature Value 36.9 DegC

 Heart Rate 82 bpm

 Heart Rate/Pulse Rate Source Radial

 Non-Invasive SBP 104 mmHg

 Non-Invasive DBP 64 mmHg

 Patient Position/Activity Level Sitting

 NIBP Source/Cuff Location Arm, Manual Cuff

 Respiratory Rate 16 Br/min

 Pain Intensity 4

 Pain Location vaginal and mouth

.

The patient was anxious, tearful and expressed frustration throughout the visit.

 

Impression and Plan

.

1. Burning mouth pain of uncertain etiology.

2. Recurrent vaginal pain.

3. Suicidality.

4. Depression and anxiety.

Patient reported that she did not feel safe leaving the clinic (due to suicidal thoughts) and I was

concerned to have her leave the clinic as well. We had a long discussion. She initially did not feel

that she wanted to call her husband. She mentioned that they are having difficulties in their

relationship and she did not want to call him out of work, that it would "only make things worse". The

Banner Crisis Hotline was contacted and we were advised by them that she could present there.

However, transportation was an issue and I did not feel comfortable having her drive there. As such,

911 was called. She was monitored in the clinic until paramedics arrived and transported her and

her son to the Emergency Room. She eventually asked to have her husband called so that he could

pick up their son. He was notified by nursing staff and was advised to present to the Emergency

Room to meet up with her. I will place orders and consultation for Dermatology as well as

Gynecology in regards to her burning mouth pain, as well as her recurrent vaginal symptoms.

kl

DD: 09/20/2013 17:35

DT: 09/20/2013 19:49

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EXHIBIT T

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G&K SERVICES Join Our Talent Network 

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WI LLIAMS-000052 

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EXHIBIT U 

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Page 1 of 12

Preliminary Expert Report of Caren B. Goldberg, Ph.D. 

05/30/16 

I have been asked by Mills & Woods Law, PLLC, to provide an expert report in the 

matter Williams v. G&K Services, Inc.. My testimony is based on my broad knowledge of the 

field of Human Resource Management and my experience as an expert witness in similar cases. 

I reserve the right to modify my opinion, as additional information becomes available at 

subsequent points in time or in response to a request by counsel to opine on additional issues that 

have not been addressed in this report. 

SUMMARY OF QUALIFICATIONS AND EXPERIENCE 

I am currently an Associate Professor of Management at Bowie State University. Prior to 

that, I spent the seventeen years in the Management Departments at American University and 

George Washington University and one year in the Industrial-Organizational Psychology 

Department at George Mason University. During two of my nine years at George Washington 

University, I served as the Program Director for Human Resources. For the past two decades, I 

have taught undergraduate, masters and doctoral level courses in Human Resource Management, 

Industrial Psychology, Organizational Behavior, and Research Design. 

I have written more than 50 articles for peer-reviewed journals and conferences. I have 

also authored seven invited book chapters. My research has been published in Journal of 

Applied Psychology, Human Resource Management, Human Relations, Group and Organization 

Management, Journal of Organizational Behavior, Psychology of Women Quarterly, Academy of 

Management Best Paper Proceedings, Sex Roles, Assessment, Journal of Business Research, 

Representative Research in Social Psychology, Journal of Career Planning and Development, 

Business Journal of Hispanic Research, and Journal of Managerial Psychology. I have also 

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conducted numerous media interviews, including several television, radio, and print news pieces. 

I have engaged in a variety of important leadership roles in my profession, including a 

three-year term as an Associate Editor of Group and Organization Management, an editorial 

board member of Group and Organization Management, Human Resource Management, 

Journal of Business and Psychology, and Journal of Management, and Track Chair for the 

Human Resource Division of the Southern Management Association. I served on a joint 

taskforce created by the Society for Human Resource Management (SHRM) and the American 

National Standards Institute (ANSI), charged with creating workplace standards for Diversity 

and Inclusion. In addition, I am currently serving as Treasurer of the Academy of Management’s 

Gender and Diversity in Organizations Division, where I recently completed a three-year term as 

an Executive Committee Member. 

I received my B.A. degree in Psychology from the State University of New York at Stony 

Brook in 1987, my M.B.A. degree from the State University of New York at Binghamton in 

1990, and my Ph.D. degree in Human Resource Management from Georgia State University in 

1997. 

From 1988 to 1989, I worked in the compensation department at United Health Services. 

In February, 2008 I provided expert testimony (deposition) in Sullivan v. Brodsky, 

Kayne, and Morgan Stanley, United States District Court, Southern District of New York Index 

No. 07-CV-00003 (BSJ) (KNF). In March, 2009, I provided expert testimony (deposition) in 

Apsley, et al. v. The Boeing Company, The Onex Corporation, and Spirit Aerosystems, United 

States District Court, District of Kansas Case No.: 05-1368-MLB-KMH. I provided expert 

testimony in the matter of Prentice and Francis v. OfficeMax North America, Inc. and 

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OfficeMax, Inc., District Court of the Virgin Islands. Civil No.: 2009/5 and in the matter of 

Desir v. Hovensa, LLC., District Court of the Virgin Islands. Civil Action No.: 2007/97 (both 

depositions March 2011; both Daubert hearings October, 2011). In August, 2011, I was deposed 

in the matter of Bennett v. CSX Transportation, Inc. United States District Circuit for the Eastern 

District of North Carolina Western Division, Civil Action No: 5:10-CV-00493-BO. In 

September, 2011, I provided expert testimony (deposition) in the matter of EEOC v. Xerxes 

Corporation, Untied States District Court for the District of Maryland Northern Division, Civil 

Action No: CCB-008-1882. In February, 2012, I was deposed in the matters of Paul v. Hovensa 

(District Court of the Virgin Islands, Civil No. 1:07-CV-00051-RLF-GWC) and Gautier-James 

v. Hovensa (District Court of the Virgin Islands, Civil No. 2006/106 F/C). In March, 2013 and 

May 2013, I was deposed in the matter or Marini v. Costco Wholesale Corp. (United States 

District Court for the District of Connecticut, Civil Action No: 3:11-CV-00331-MRK). In the 

matter of Seguin vs. Northrop Grumman Corporation (2012-SOX-00037), I was deposed in July, 

2013 and testified at a hearing in July, 2014. 

Included with this report is a current copy of my curriculum vitae, which contains a more 

detailed description of my professional background, including a list of my publications. 

MATERIALS CONSIDERED

In preparing this report, I considered all documents provided to date, by both Plaintiff and 

Defendant (see Disclosure Statements), the transcript of the deposition of Rachel Siggerud 

Raskovich, and the official investigation of the Federal Equal Employment Opportunity 

Commission. Additionally, throughout my report, I reference some of the scholarly literature on 

Human Resource Management. The full references for these works appear at the end of this 

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report. 

Compensation 

For my time working on this matter, I am paid $400.00 per hour, plus actual or estimated 

travel and expenses. For depositions and trials, a nonrefundable payment of $3,200 per day, plus 

estimated travel time and estimated travel costs, is required two weeks prior to the scheduled 

date of testimony. In the event that the deposition and/or trial is cancelled, postponed, or 

rescheduled, no refund will be issued. In the event that the deposition, hearing, or trial exceeds 8 

hours in a day, I bill at the $400 per hour rate, with the terms set forth in my retention agreement. 

EXPERT OPINION

1. The stated reason for eliminating Ms. Williams’ position was pretextual. Although G & K 

asserted that Ms. Williams position was eliminated because of overstaffing, from an HR 

perspective, this claim is untenable. 

a. G & K claimed that the creation new HR Generalist position was the result of a 

restructuring which entails long-range planning. Henneman & Judge (2006) note that 

Human Resource Planning includes long-term (three years or more), intermediate 

(one to three years), and short-term (one year or less). Given that G & K purports to 

have mechanisms in place to address short-term staffing needs,1

the creation of the 

new HR Generalist position was clearly part of a longer-term strategy to restructure 

 

1

 That G & K had distinct mechanisms for addressing short-term human resource planning is evidenced by the fact 

that in G & K’s response to the EEOC charge, they noted, “Siggerud learned that the Talent Acquisition team was 

planning to hire a temporary contract recruiter.”

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the HR function. However, there is a disconnect, in that G & K created Ms. Williams 

position in February, 2013 and eliminated it in September, 2013. 

b. When Ms. Williams was put into a temporary recruiting role in summer, 2013, she 

was told that if she didn’t stay in the recruiting role, she could come back as an HR 

Generalist. Again, considering the time-frames involved in HR planning, it is hard to 

imagine that G & K would not have foreseen the need to eliminate her position in the 

two months between when she started the recruiting role in July and when it was 

eliminated in September. 

c. It bears noting that in contrast to what the response to the EEOC complaint stated 

(that the decision to eliminate the position was made in August), Ms. Siggerud 

testified that the decision to eliminate the position had been made in June. However, 

from an HR perspective (or business perspective, in general), it makes no sense to 

continue to pay an employee for two months, knowing that her position will be 

eliminated, as soon as the temporary assignment ends. Further, given that import of 

eliminating a position or terminating an employee, from an HR perspective, it is 

unlikely that there would be no contemporaneous mention of such a decision in any

of the discovery materials, had the decision, in fact, been made prior to Ms. Williams’ 

ADA accommodation request.

d. During the time during which Ms. Williams occupied the Human Resource Generalist 

role, there was no job description for this position (the record reflects that the job 

description was created in April, 2014, several months after Ms. Williams was 

terminated). As noted in the Society for Human Resource Management’s (SHRM’s) 

Instructor Materials, “job performance must be evaluated with an understanding of 

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the assigned duties and at the prescribed level. The job description and performance 

standards that flow from job analysis provide a common framework for employees 

and supervisors to assess work performance.”2

 Without a description of the job, G & 

K’s contention that Ms. Williams performance was below expectations is without 

foundation. 

e. Even if G & K had deemed Ms. Williams’ job performance to fall below 

expectations, the company violated its own policy and practice, by not putting her on 

a Performance Improvement Plan. Ms. Siggerud testified (107) that unless they did 

something egregious, when a performance problem was documented, employees were 

typically put on a Performance Improvement Plan. However, Ms. Williams was 

denied this opportunity. 

f. It is also noteworthy that there is no evidence that Ms. Williams did, in fact, have a 

performance problem. Given that G&K does have a process for documenting 

performance and/or attendance problems, it makes no sense that they would choose to 

refrain from using such a vehicle. Ms. Siggerud’s testimony reveals that the crux of 

the alleged performance problem was attributable to the fact that Mr. Briscoe did not 

understand what the functions of the HR Generalist role were and vague 

“perceptions” that Ms. Williams was not engaged in her job. Given that there was no 

job description for the position (per my point 1d, above), it is not at all surprising that 

managers (or the HR Generalists, themselves) would not understand what the job 

functions were. 

 

2

Although I use SHRM’s instructor materials as an example, nearly every introductory HR textbook would say 

something to this effect. 

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2. G & K’s performance appraisal system was an invalid basis for making decisions regarding 

Ms. Williams’ termination. 

a. As noted above in point 1c., the performance appraisal could not reflect the key duties 

of the HR Generalist position, given that the key duties of the position were never 

specified during the time when Ms. Williams occupied the position. Further evidence 

of this is provided in Ms. Siggerud’s testimony (p. 25), as she indicated that, “there 

were questions from both business and from the HR team as to how we approached 

our roles differently.” 

b. The performance appraisals were largely based on employee’s own personal 

objectives. This is problematic in that it precludes comparability. Gomez-Mejia, 

Balkin, and Cardy (2010) define comparability as, “the degree to which the 

performance ratings... in an organization are based on similar standards.” Given that 

each HR Generalist created her own goals, it would be impossible to use the same 

yardstick to assess performance. 

c. Beyond the content of the objectives that were being appraised, there was also lack of 

comparability in the supervisors’ assessments. Whereas Ms. Siggerud added several 

comments in the open-ended sections on each of the criteria listed on Janelle 

Benacua’s and Kaela Elliston’s forms, the open-ended sections for each of the criteria 

on Ms. Williams’ performance appraisal were left entirely blank, contrary to the 

standard that appraisers take great care to do the appraisals thoughtfully, accurately, 

and fairly (Latham & Wexley, 1994; Gomez-Mejia, Balkin, & Cardy, 20103

). 

 

3

 Although I cite these texts as examples, one would be hard-pressed to find an introductory HR text that would 

indicate otherwise. 

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d. Although the rating system purports to create a weighted average, as indicated above, 

the criteria, themselves, are problematic because most of them stem from employeegenerated objectives. Moreover, although a weighted average of ratings across the 

criteria seems like a good idea in principal, in practice, the weighted average score is 

entirely separate from the evaluation that is used. Bates 146 has a box for Ms. 

Williams’ weighted average score, which the manager indicated as a 3. After this, 

however, there is a box for ‘Year-End Overall Review Summary’, which is entirely 

separate. In this section, there is a lot of harsh criticism of Ms. Williams’ 

performance, followed by a 2 (below expectations). Essentially, it appears that there 

is a very well-articulated formula for creating a weighted average, but that a manager 

can just ignore that and give whatever s/he wants.4

 

e. By Ms. Siggerud’s own admission in multiple places throughout her deposition, she 

made little effort to document Ms. Williams’ performance throughout the appraisal 

period. This is problematic for a number of reasons. First, the Society for Human 

Resource Management’s Performance Management module states, “Managers need 

to maintain records and documentation of each employee’s performance. If 

performance appraisals are done once a year and the manager has kept no records of 

employee performance, it is difficult to remember what happened, and it is impossible 

to appraise appropriately. Most likely, the manager will remember and appraise only 

the most recent behavior, leading to an incomplete and possibly inaccurate 

assessment of the employee’s work.” In addition to the limits on human memory, 

documentation serves an important role of evidencing that the employee was made 

 

4

Given that G & K noted in its response to the EEOC charge that Ms. Williams’ performance was below 

expectations, Ms. Williams’ ratings on the GK Perform criteria and her own objectives were ostensibly disregarded. 

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aware of a perceived problem with his/her performance. As noted in Gomez-Mejia, 

Balkin, and Cardy (2010), failing to do so suggests that the employer’s actions may 

have been arbitrary or unwanted. 

3. G & K failed to investigate Ms. Williams’ claim of disparate treatment. The Defendant’s 

Employee Handbook (Bates 225) states, “All incidents or concerns will be investigated 

thoroughly and promptly. The company will be as discreet as possible consistent with the 

need to conduct a thorough investigation.” Likewise, G & K’s Individual Treatment Policy 

(Bates 23t) states, “All inquiries and/or complaints will be investigated thoroughly and 

promptly.” However, that is not what happened when Ms. Williams expressed concerns to 

Ms. Siggerud about being treated differently because of her medical issues. Rather than 

attempt to investigate, Ms. Siggerud testified (137), “I tried to understand, not necessarily 

this conversation, but tried to understand kind of what that meant, so what did she mean by 

she was being treated differently and she couldn’t really give me any specific things to 

investigate.” Simply saying that she tried to understand, does not constitute an investigation. 

After Ms. Williams expressed that she felt that she was being treated differently because of 

her disability, the burden was on Ms. Siggerud to actively seek more information. 

4. G & K retaliated against Ms. Williams for seeking ADA accommodations. Section 8 

(Retaliation) of the EEOC’s Compliance Manual indicates there are three essential elements 

in a retaliation claim; protected activity, adverse action, and causal connection between the 

protected activity and the adverse action. Direct evidence of retaliatory intent is rare; thus, 

EEOC provides a framework for establishing circumstantial evidence of retaliation. 

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According to The Compliance Manual, an initial inference of retaliation arises when: “(1) the 

adverse action occurred shortly after the protected activity, and (2) the person who undertook 

the adverse action was aware of the complainant's protected activity before taking the 

action.” 

Shortly after receiving Ms. Williams’ request on July 7, 2013, for an accommodation of 

missing a few hours per week for medical appointments, Ms. Siggerud e-mailed Marie 

Smith, who normally handles ADA requests, and told her “I would like to manage this 

request very closely,” even though Ms. Siggerud testified (153) that, “the way the process, I 

believe, was designed to work,” was that she would pass along the request to Ms. Smith or 

Ms. Kietzer. The message to Ms. Smith further indicated, “I would like to look at having her 

work at least eight hours in the office either before or after her appointments because I have 

previously experienced situations where an appointment ‘first thing in the morning’ means 

she doesn’t roll in until noon.” However, forcing her to work eight hours before or after her 

appointments would not only deny Ms. Williams the accommodation to which she is entitled, 

it would punish her for it. Per Ms. Siggerud’s testimony, Ms. Williams was an exempt 

employee, and therefore, not beholden to a formal eight-hours-per-day schedule. However, 

given that she further testified that the HR Generalists were complaining that they were bored 

in their new role, requiring that Ms. Williams put in eight hours before or after her 

appointments was punitive. Moreover, Ms. Siggerud was unable to provide a rationale for 

doing so. This is noteworthy, as the EEOC’s Compliance Manual states that, “a violation is 

established if... the respondent fails to produce evidence of a legitimate, non-retaliatory 

reason for the challenged action, or if the reason advanced by the respondent is a pretext to 

hide the retaliatory motive.” 

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Conclusion 

In summary, it is my professional opinion that: 1. G & K’s claim that Ms. Williams’ 

position was being eliminated due to overstaffing is pretextual; 2. G & K’s performance 

appraisal of Ms. Williams was an invalid basis for making a decision about terminating her; 

3. G & K failed to investigate Ms. Williams’ claim that she was being treated differently, due 

to her medical condition; and 4. G & K retaliated against Ms. Williams for requesting ADA 

accommodations. 

Signed on 5/30/2016 

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Works Cited 

Gomez-Mejia, L. R., Balkin, D. B., & Cardy, R. L. (2010). Managing Human Resources, 6th

Ed. Pearson/Prentice-Hall Publishing. 

Heneman, H. G., & Judge, T. A. (2006). Staffing Organizations, 5th Ed. McGraw-Hill/Irwin 

Publishing. 

Latham, G. P., & Wexley, K. N. (1994). Increasing Productivity through Performance 

Appraisal, 2nd Ed. Addison-Wesley Publishing. 

Society for Human Resource Management (2009). Performance Management and Appraisal 

Learning Module. 

https://www.shrm.org/academicinitiatives/universities/teachingresources/pages/performanceman

agementandappraisal.aspx. 

United States Equal Employment Opportunity Commission (1998). EEOC Compliance Manual, 

Section 8: Retaliation. https://www.eeoc.gov/policy/docs/retal.html.

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