Case 1:06-cv-00027-SLR Document 56-13 Filed 05/23/2007 Paige 1 of 4 Q
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Case1:06—cv-00027-SLR Document 56-13 Filed 05/23/2007 Page20f4
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IN THE UNITED STATES DISTRICTCDURT
DISTRICT DF DELAWARE ` `
PAULA PAGDNAKIS, )
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_PTaint1Ff, ) F
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VS. ) Ca$e_No. _ Q
_ i - ` ) 06—O27—5LR 2
I EXPRESS, LLC., _A/K/A ‘ ) 5
LIMITED BRANDS, INC. , ). ·
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Detendant. ) S
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VIDEOGRAPHIC TELEPHDNIC DEPDSITIDNE DF
- RDSIE ROCK FI .
THREE at the ofFiceS of g
_ VORYS, SATER, SEYMOUR-Sz PEASE, LLP
_ 52 East Say Street __ ‘ g
Columbus, Ohio 43216-1008
on March 29, 2007, at 9:00 a.m. ‘ §
Reported by: Rhonda Lawrence, RPRfCRR . §
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COLUMBUS oi-no
2007—Mc;1y—23 07 : 08 PM Bolt ley gr Ehrenberg PLLC 2023 18707 1 3/4
- LLL- Case 1 :06—cv—00027-SLR Document 56-13 Filed 05/23/2007 Page 3 of 4
onakis vs. Express, LLC, aka Limited Brands, Inc. 03-29-07 · I Rqgig Rug];
JH ` PHQE 54 I Page 55
.1 1 teamed from our other HR representative was 1 who would that be in human resources,
2 that Anna Klancic was using race as a 2 what -— whatjolj title? 3
I 3 decision - as a hiring decision for certain 3 A. Eltewould work with the HR manager.
_ I 4 stores in her location, which is against our 4 O. And would that be -— today, let's
l 5 policy. 5 say — ‘
6 Cl. For certain stores. Okay. And is 6 A. Uh-huh. . I 1
7 that- do you know anything else, or is 7 Q. — it - ifl were a district j
8 that all that you know? S manager, would you ce one of the HR managers g
9 A. Tht -- that's the extent of it, _ 9 that I would discuss this with?
'ICI yes. 10 A. Yes, I would be. l I
11 O. Okay. And do you know whether the 11 Ct. Okay. So you yourself in your role ?
12 company would have kept a personnel tile for 12 as a, l guess, tield or zone `HR manager, -
13 Ms. Klancic? . 13 deal with these kinds ot issues? .
14. A. I don't know for certain, no. 14 A. It is under my realm of . ·
15 Ct. But if it did, that wouldhave been 15 responsibility, yes. I have never _ ` L,
1 5 kept in a regional office? 1 E personally dealt with it, though. ,`
- 17 A. Yes, itwould have been. l 17 Ct. Okay. And do you knowwho the HR Q
18 Q. And do you know what Illls. Klanoids I 1B manager was at the time that Paula Pagonakis `
19 title was when she left the company? 19 requested her accommodation?
20 A. District manager. 20 A,. l've -- l've heard through a company i
21 Q. And as a district manager, what 21 representative that it was Tara Kessler.
22 would her — who would she report to? 22 Ct. Okay. So if Anrra ltlancic was the - _
23 A. She would report than to the 23 distnct manager at the time Paula Pagonakls
24 regional manager. 24 had her issue with an accommodation, and il
~ 1
Page 55 Page 57
1 - O. And do you know who the regional 1 Tara Kessler was the relevant HR manager,
2 manager was at- at the time of her 2 then Tara and Anna would have been the ones {I
3 departure? 3 to make the decision? Q
4 A. No, I don't. I 4 A. Well, they would have taken
5 O. Okay. And I think from what you . 5 partnership. So the HR manager would have 9
B told me before, a regional manager would 5 partnered with the HRvice president, the E
7 report to a zone VP? 7 director and the VP, and with our general F,
. S A. Ym, B counsel if necessary. ` ` I
I 9 O. Okay. Now, as a district manager, 9 Ct. Okay. And what would the role of HR g
_ 10 would Nts- Klancic have any role in — would 10 direct be, if any, in all of this?
11 she — should she have any role in any — if 11 A. Well, when the per — when the I
12 an associate within her umbrella had an 12 associate would first come to us for a need g
l 13 issue with a —= an accommodation in the 13 of accommodation, we -- we first and
E 14 workplace, is that something that 14 foremost send them to HR direct, because
1 · 15 Ms. Klancic as a district manager would be 15 we — the infomation that we get in the `
, I 15 made aware of? 15 brand as a human resource manager is just
" y I 17 A. Yes. 17 what the accommodation needs are, not why.
J . I 19. _ O. Okay. And what would her role be 18 That's_only given to HR direct. So then HR
_ _ ` ` 19- in e with regard to that issue? 19 direct communicates to us what the -— the 3
_ ilii LEU A; Her role would he to work with human 20 necessary accommodations are and then we
L . _ 21 resource —- human rwourcee to determine if 21 Work with our partners to detem1ine then if gl
E1-‘;.` _>; f ;; 22 the a‘ccornrnodation could be met. I 22 we can accommodate that. ;
ge ,i“,l_ l·, 23 Q. And when you say work with human 23 O. Okay. Okay. All right. lf you can
_Q . _-`_ ¤ §3_ If: 24 resouroes, would that be — well, _I guess, 24__ just hold _on for one second. g
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II'. -I-`fl if I ` 15 (Pages 54 to 57) l
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2007—Mr;1y—23 07:09 PM Bailey 8; Ehrenberg PLLC 2023187071 -4/4
I-- -. --- -. . .. Case 1:06-cv-00027-SLR Document 56-.13 Filed 05/23/2007 Page 4 0 W ___>__ g -.
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V 1 .- 7‘·_ 9 . i Pagonakis vs. Express. LLC, aka Limited Brands, ine. crseze-rn Rum
3*- ` ‘ ‘ . i . PBQP 50 - Page 52 _ g
· ‘ lil ‘ A. NO, SI1', I do DDI KNOW. ‘ 1 pgrggngl Capacity Why M5 j,
_, _- _ 3 the name of Anna Klahcic? 3 A_ Nd 3
l 4 A. No, l do not. 4 O. Okay. Now, with regard to Anna l
{ 5 O. Okay. So you wouldnt know the 5 j·(|gm;jr;, { bgjjgvg ym, Stated wu du mt ~
5 circumstances surrounding her departure from 6 know why she jeg the mmpgnyo
I T E"P'Pi"·$? 7 ` I A. I know why she left the company
B A lklo. I S based off of our coniprrter swtem which l
9 MR. CAMPBELL; Jason, thiswas a · 3 looked up. -
10 topic as to it, so she’s investigated but 10 O. Okay. j
11 she doesn't have personal knowledge.- 11 A. And that was a termination based off ;
12 A. No, I do not. 12 of a policy violaijon. E
13 MR. EHRENBERG: Dave, can you repeat 13 MR. CAMPBELL: And 4- and, Jason, Q
14 that, I — 14 she further invmtigated that, but is this ?
15 MR CAMPBELL: This was a topre and 15 subject to a protective order'? ~
15 so she investigated the reasons why Anna 16 NIR. EHRENBERE EVEFYHTITIH is Y
17 Klancic was let go and can testify to those 17 subject to a protective order. 1
13 eases as a company representative. she does 13 MR. CAMPBELL: Okay. Because I
19 not have personal knowledge because she was 19 don't want to discuss specilic reasons for i
20 not involved in it. 20 another employe‘s discharge and have it 4 5
21 MR. EHRENBERG: Right. Fm — I'm 21 have it out there not subject to a j
· 22 asking her, and she just said -she doesn't 22 protective order. .
23 know. · 23 MR. EHRENBERG: No. And we'd be .
24 MR. CAMPBELL: Okay. Well, she - 24 IHBIPPY to enter into (indiscerrrible). =
Page 51 Page 53 i
1 she now understands the role. Yotfre asking 1 MR. CAMPBELL: Okaye Arid she can go Q
2 her about she believed is her personal 2 into the the specitics from what she i
3 knowledge. lf you irrrantto eek her as a 3 teamed through discussions with other HR ·
4 company rep, she can answer that because she 4 representatives at the-time. She wasn't i
5 did investigate it. 5 involved. But she can talk -—- talk in 3
6 MR; EHRENBERG: And the other B géneralities as to that, subject to the .
7 questions that I asked? 7 protective order.
8 MR. CAMPBELL: Jason, there is a - 3 BY MR. EHRENBERG: _ Q
9 spectlic topic, the reasons defendant 5 O. I believe, llrls. Rock, you said that {
10 tenninated Anna Klarrcic - 10 the termination was based on — 1
11 MFP. EHRENBERG: (lndiscemiblej 11 A. Policy violation. _
12 Dave, before you answer, I'm -- l'r1·r going to 12 0. And do you know approximately when _
13 ask the Witness again before we get to 13 Ivls. Klancic left the company'? -
14 Ms. Klancic whether she knows why Kristin 14 A. I do not. 1
15 Bosley left the company. _ 15 Cl. Okay. And can you tell me from what
15 A. Kristin Bosley, rro, I do hot. ` 15 you've leamed what the circumstsnee —~ _
17 Cl. And you ril¤l'l't l¢¤¤W.irr your capacity 17 well, strike that. E
1 B as a corporate representative? ' 15 Do you know what the policy }
19 A. No. 15 violation was'?
20 C!. Okay- And the same would hold true ao A. No;
21 for Tara Kessler? 21 O. Okay, From your discussions with I
22 Ar Correct 22 other people at the company, do you know
23 O. Okay. And I'm not asking you to 23 anything more than what you‘ve told mc? ·
24 tell me the reason, but dg you know in your A.__‘res, sir, I do. What - what I i
14 (Pages 50 to 53)
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