Case 1 :04-cv-01394-G IVIS Docu ment 174-3 Filed 03/28/2006 Page 2 of 3
Conley v. Chaffinch, et al.
. Lisa Blunt-Bradley C.A. # 04-1394-GMS December 19, 2005
` Page 14 Page 16
l 1 minorities in the workplace? 1 was recruitment and hiring. Do you see that on page 4 of
_' 2 A. Correct. Revlewlng l:tre process. 2 your Table of Contents —
3 Q. Right. I mean, process is Important? 3 A. Yes.
4 A. Yes. 4 Q. —— concemlng your evaluation of what they were
5 Q. Because of your long background in labor law, 5 doing in the areas of recruitment and hiring, was it,
6 the Delaware labor laws, as welt as the state personnel 6 again, one of your goals to ensure that women and
7 director, have you conducted that having a process in 7 minorities were not the victims of discrimination in
8 place is something l:hat's important to seeing that all B those areas?
9 people are treated ln a nondiscriminatory fashion? 9 A. Well, in temrs of -- you said was lt the goal to
10 MS. BALLARD: Objection to the fomi. 10 ensure there wasn't discrimination in terms of
11 A. Carr you repeat t:lre question? 11 recruitment and hiring?
12 Q. Sure. l'll have her read it back to you. 12 Q. Yes.
13 (The reporter read from the record as 13 A. And, I mean ··- yes.
14 requested.) 14 Q. You looked into the recruitment process there?
15 A. And -- this ls funny. I feel like a drum 15 A. Con·e¢:t.
16 roll -- the answer ls: Yes, lt's important to have a 16 Q. You locked into the hiring process?
17 process. 17 A. Correct.
18 BY MR. NEUBERGER: 18 Q. In fact, you may remember in the court case that
19 Q. Sure. Once agaln, we are into equal employment 19 I took your testimony in, the Bullen and Giles court case
20 opportunity. Okay? 20 that - you remember we had a trial before Judge Faman?
21 was it one of your purposes to require the 21 A. Yes.
22 Delaware State Police to follow a process so that it 22 Q. Do you remember there was a big dispute in that
23 would avoid discrimination against minorllis and women? 23 case about whether in 1998 and earlier there were
24 A. Well, I drink I might have shared wlt:Ir you ln 24 actually written quotas that the Delaware State Police
l
r Page 15 Page 17
1 the past the role ofthe State Personnel otrioe In terms 1 was following for recrultrnent into their academy? Dc you
2 of requiring t:lrat agency — even In the report you will 2 remember we had a —
3 notice part of our charge was to say that we would have 3 A. No.
4 more ofa role, as you mentioned, particularly as it 4 Q. Do you remember talking about green people and
5 relates to monitoring. 5 blue people and widgets and stuff like that at trial?
6 So, again, we have individuals ln the 6 A. Ys.
7 otlloe who were responsibility for, you know, ensuring 7 MS. BALLARD: I want to place an objection
B the laws were actually Implemented, but you said 8 on the record to relevance to the prior trial.
9 "requlre" them to do lt. 9 MR. NEUBERGER: You don't have to object to
10 Q. Let me go bad:. I'|l change my word. 10 relevance, Counsel.
11 A. Yes. 11 MS. BALLARD: I can place an objection on
12 Q. Go ahead and tinish. 12 the record.
13 A. Go ahead. 13 MR. NEUBERGER: You don't have to object to
14 Q. Was lt one of your goals to ensure that the 14 relevance. You retain all that. I'm just saying you are
15 Delaware State Police was following a process so that -— 15 interfering with the How here.
16 A. Yu. 16 MS. BAlJ.ARD: I want to -
17 Q. - it would avoid - let me linlsh. We mnt 17 MR. NEUBERGER: The rules don't require you
18 step on each others answers. 18 to object to relevance. 'l'hat's all I'm saying, Counsel.
19 A. Sorry. 19 You don't have to do that under the rules. You retain
20 Q. Was lt one of your goals to require the Delaware 20 all your relevance objections for later.
21 State Polloe to follow a process so that ltwould avoid 21 MS. BALLARD: Hne. Ijust wanted to place
22 discriminating against women and minorities? 22 Ural: particular one because we will object to the
Q 23 A. Yes. 23 introduction of any evidence of any prior matters
24 Q. Now, another one of the areas you looked into 24 involving Delaware State Police.
5 (Pages 14 to 17)
‘ Wilcox & Fetzer, Ltd. Professional Court Reporters (302)655-0477
Case 1 :04-cv-01394-G IVIS Docu ment 174-3 Filed 03/28/2006 Page 3 of 3
Conley v. Chaflinch, et al.
Lisa Blunt—BraclIey C.A. # 04-1394-GMS December 19, 2005
l Page 18 Page 20 -.\
1 BY MR, NEUBERGER; . 1 necessarily, but I would have noted that, definitely. A
2 Q. The point is, you remember that there were some 2 Q. The point is you were looklns otlhlrlss that
3 things that the Delaware State Police were doing thatl 3 were ln the process that would be Illegal hlndrances to
4 was challenging and said that they were violating the 4 the employment of women and minorities?
5 laws against quotas. Do you remember that? 5 A. correct.
6 A. Ya. 6 Q. lf you found something, one of the things you
7 Q. I think you explained to us at an earlier time 7 would have done would have been to point those out?
8 that the law does not pemilt quotas. Dc you agree with 8 A. Correct.
9 l:hat? 9 Q. Right. I understand. You are telling me you
10 A. Right. 10 had no authority to order the Department of Homeland
11 Q. But there are a lot of things that are legal 11 Securltyto make changes in the State Police; right? It
12 that can be done to diversify a work force. You remember 12 wasnt your department?
13 that? 13 A. That's true.
14 A. Yes. 14 Q. The governor had issued an Executive Order
15 Q. In fact, Greg Chambers who worked under you - 15 No. 19; right?
16 you remember him, don‘t you? 16 A. Contact.
17 A. Yes. 17 Q. That had given you some authority direcliy from
18 Q. ls il: fair to say that Mr. Chambers Is a very, 1B the governor; right?
19 very experienced and quallhed person in state govemment 19 A. Correct.
20 as far as what is and Is not allowed in the areas of 20 Q. But you didn't think lt made you the colonel of
21 promoting diversity? 21 the State Police?
22 A. Yes. 22 A. That's correct.
23 Q. But my point is here: You looked Into the areas 23 Q. So a lot of things ln Your report Y¤¤'r¤ Swine
24 of recruitment and hiring at the State Police during your 24 were couched in tenns of recommendations and improvements
Page 19 Page 21 )
1 lnvstigatlcn; right? 1 that should be made?
2 A. Yes. 2 A. Correct.
3 Q. was it one of your goals to ensure that women 3 Q. Just to hnish up about recruitment and hiring,
4 and mlnorlues were not being the victims of 4 to ask the same question I asked earlier about equal
5 dlsctmlnatlon in the areas of recrultrnent and hlnng? 5 employment opportunity, was It a goal to enable the State
6 A. Again, yes. 6 Police to follow a prooas so that they werent
7 Q. was it one or your goals to see that the 7 tnscriminating against women and minorities?
B Delaware State Police was using a procss In the areas of 8 MS. BAI.LARD: Objection to the form.
9 recruitment and hiring that wasn't dlscdrnlnatlng_agalnst 9 A. Yes.
10 women and minorities? 10 Q. Then you see you addressed promotions at the
11 A. can 1 clarify? 11 State Police; right?
12 Q. Sure. Go ahead. 12 A. Yes.
13 A. Agaln, we were looking at the situation to malta 13 Q. Is it true that one of your goals was to ensure
14 recommendations for Improvement So. agaln. that was the 14 that women and minorities were not the victims of
15 UM'- 15 discrimination in the promotion process at the State
16 Q. Sure. 16 Police?
17 If the Delaware State Police had a sign up 17 A. Yes. We were trying to elwure hir process for
18 at its office that said "Blacl
zo A. correct. 20 the areas of promotions, was it one of your goals to see
21 Q. ifthey had a sign up that says “Blacks ant 21 that the Delaware State Police wasn't using a promotion
22 use the water cooler when they are Hliing out employment 22 process that did discriminate against women and
23 appIlcatlons," you would have noted that; right? 23 minorltls?
24 A. I wouldnt have written It in the report 24 A. Correct.
6 (Pages 18 to 21)
Wilcox & Fetzer, Ltd. Professional Court Reporters (302)655-0477
United States Free Forms
Canada Free Forms
United Kingdom Free Forms
Australia Free Forms