Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1:04-cv—OO970-JJF Document 105-5 Filed O2/21/2007 Page 1 013

Case 1 :04-cv—OO970-JJF Document 105-5 Filed O2/21/2007 Page 2 0* 3
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1 i Q Have you listened to any tapes of conversations
2 I between you and Terry Snyder?
3 S A No. {
4 Q Like I said, I'd like to play you a portion of a
5 tape. And then we can talk about it. If you need me at any
6 time to stop it or can't hear or something. l mean you‘ll
7 listen to the tape and then let me know your thoughts.
8 Okay?
9 (The tape was played for the witness.)
10 Q Do you need me to rewind or anything? Would you
11 like me to?
l2 I A Some of it 1 cou1dn't understand. l understand 1
13 apologized for something, which 1 told you that earlier in
14 the statement.
15 Q Just some preliminaries. Dc you recognize the
16 voices on the tapes?
17 A. Yes. It's Terry's voice and it sounds like mine in `
18 the background.
19 Q Do you recall that conversation?
20 A Yes, vaguely. 1 don't know when it was. But, yeah, 5
21 E vaguely, F
22 g Q Do you know approximately when it was? i
23 A No. }
24 I Q Was it during the month of her termination?
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Case 1:O4—cv—OO970-JJF Document 1 (jllggggii/QL /2007 Page 3 GT 3 N2
l I A I wouldn't know. I wouldn’t even know.
2 u Q Do you recall laughing during this oonversation?
3 A Well, probably. Not laughing but probably smiling I
4 D like what are you talking about, you know.
5 Q Did you deny saying to Terry that you should wear a
6 dress with no panties?
7 A Repeat that.
8 Q Did you deny saying to Terry that she should wear a
9 dress with no panties?
IO .A Yes, I denied that.
ll i Q Did you deny it that day?
12 A I asked her what was she talking about, I believe.
I3 Q Did you tell her you didn't say that?
ld A I don't know what I said. I just asked her what are
I5 you talking about.
I6 Q Did you apologize to Terry Snyder?
l7 A If she said I was being rude to her, I probably
IB said, hey, you know, I apologize for yelling at you or
IQ whatever. I mean that's what was on the tape. She said I
20 was yelling at her. `
2l - Q Do you recall her saying that she didn‘t mind the 3
22 i yelling, that it was your job to yell? i
23 f A No, I don't remember that. F
24 Lxv Q lYou didnlt hear that part? _;_l i
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