Free Motion in Limine - District Court of Delaware - Delaware

Case 1:04-cv-01394-GIVIS Document 176-4 Filed O3/28/2006 Page 1 012

Case 1 :04-cv-01394-G IVIS Docu ment 176-4 Filed O3/28/2006 Page 2 of 2
Conley v. Chafhnch, etal.
David Baylor C.A. # 04-1395-GMS __ June 27, 2005
Page 46 V Page 48 i
1 and left early? 1 for the moon. I was trying to focus on that. l
2 A. Yes. 2 Q. what was thls comment that you heard about _.
3 Q. Okay. Now, did you ever attend a traffic 3 lauer?
4 records forum in Colorado in July of 20037 4 A. I heard that, later heard that he said -- that
5 A. No. But I was in Colorado in July of 2003. I 5 he made reference to Watermelon Gaines. Gaines ls a 5.
6 was at the FBI conference. 6 retired Delaware State Police corporal. ‘
7 Q. Okay. I've heard rumors about some kind of a 7 Q. Why was he calling hlm watermelon? _
8 dinner whld·l took place. I'd like to ask you some B A. In the context of why lt was said, there was ‘
9 questions about that. 9 watemlelon apparently on the menu or he saw watermelon or
10 A. Okay. 10 the server offered watermelon as a dessert and that's
11 Q. Were there any other Delaware State Police 11 when he blurted lt.
12 Officers out in Colorado at the same lime that you were 12 Q. I'm sorry. Whats the trooper's full name?
13 out there? 13 A. Ronald i.. W. Gaines. `
14 A. Yes, sir. 14 Q. Is he a white or black trooper? L
15 Q. Okay. Who were the officers? 15 A. Black trooper, rel:lred corporal. He was In
16 A. At the FBI conference it was myself, Colonel 16 Colonel Chafflnclrs academy dass.
17 Chaffinch and his wife. Retired Major Mike McDonald was 17 Q. Got you. Who did you hear about it later from? .
18 at the trafhc records forum. Captain Laird and his wife 18 A. Captain Conley and Lieutenant Dixon. ` _
19 were at the FBI conference. And at that time Captain 19 Q. Now, do you understand that this ls a —— Captain
20 Hughes was just informed that he was a major and he was 20 Conley, she has a sex discrimination claim?
21 at the FBI conference. And l:hen Lieutenant Dixon was at 21 A. Yer., slr.
22 the traffic records forum. 22 Q. Did you understand that coming ln here today? Q
23 Q. Okay. Did everyone get togelher for dinner? 23 A. Yes, sir.
24 A. Yes, sir - when I say ”everyone,“ it was 24 Q. Do you remember anything else which you think
Page 47 Page 49 ?
1 myself, the colonel and his wife, my daughter who 1 the colonel may have done in the workplace whlch would r
2 traveled with me, and Major McDonald, Captain Conley and 2 have reflected either gender stereotypes -— .
3 Lieutenant Dixon were all at a restaurant outside of 3 A. That's a broad question. Can you be more
4 Denver. 4 specific? ·
S Q. Okay. Now, how old was your daughter at that 5 Q. Sure. You have already testified a little bit ¥·
6 tlme? 6 about some inappropriate Iirnerlcks or jokes that the
7 A. That was two years ago. what year was that? 7 colonel told. Do you recall that testimony? _
8 20037 8 A. Yes, sir.
9 Q. I belleve so. 9 Q. You have talked a litde bit about certain
1D A. Here you go —- 10 things that the colonel has said to a female secretary
11 Q. I'm sony. 11 in, I guess, I think it was in headquarters?
12 A. I'm having a hard time trying to keep up wllh 12 A. Maybe I said about. I don't think he actually
13 thegradeshere. Shewotdd be—shewllIbefourteen 13 saldlttothem.
14 this year. She would have been eleven. QEWDQ ready to 14 Q. About certain female secretaries in
15 tum twelve. 15 headquarters. Is there any other inappropriate workplace ,
16 Q. At this dinner did Colonel Chaffindl engage ln 16 behavior whidm you think might be relevant to Captain
17 any inappropriate either speech or jokes or llmeridrs or 17 Conleys case?
18 things IiI 19 A. I don't specifically remember, because I was 19 Q. You can answer.
20 down at the other end of the table. I had heard 20 A. Not right off the top of my head. I mean,
21 afterwards that there was a comment made, but to be quite 21 unless you have something specific, I don't.
22 honest with you, I was sitting there trying to figure out 22 Like I said, there was — my head Is still
23 the menu and make sure that my daughter dldn‘t order me 23 spinning from my time, especially alter the rank of T
24 out of house and home, because when she orders she goes 24 captain in the state police, because I was treated unfair L
13 (Pages 46 to 49)
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