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

Case 1:04-cv—OO970-JJF Document 105-4 Filed O2/21/2007 Page 1 013

Case 1 :O4—cv—OO970-JJF Document 105-4 Filed O2/21/2007 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
TERRY L. SNYDER, )
)
Plaintiff, ) C.A. N0. 04—970(.IJF)
)
v. )
)
CITISTEEL USA, INC. )
)
)
Defendant. )
AF FIDAVIT OF TERRY L. SNYDER
STATE OF DELAWARE )
) ss
COUNTY OF NEW CASTLE )
I, Terry Snyder, being duly sworn according to law, hereby depose and say as follows:
l . I am the Plaintiffin the abovecaptioncd case.
2. I tape recorded a conversation that took place between Randolph Harris, the
alleged harasser, and me while I was employed at Citi Steel. I also tape recorded a conversation
that took place between Jerry Downie, the Human Resources Director for Citi Steel, and me
during a meeting on my final day of employment.
3. While listening to the original tape(s), I reviewed the transcript of the
conversation between Randolph Harris and me, as well as, the transcript of my meeting with
Jerry Downie.
4. Some of the statements on Defendant’s transcriptions of the tapes were
inaccurate. Based on my review of the original tape(s), I made the appropriate edits to both
transcripts.

Case 1 :04-cv—OO970-JJF Document 105-4 Filed O2/21/2007 Page 3 of 3
5. The transcri ts, with m edits, accurate] rellect the ta e recorded conversations
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that I had with both Randolph Harris and Jerry Downie.
6. l did not complete my review of the tapes in a timely fashion for two reasons.
First. 1 am not trained in the area of transcriptionQ therefore, it was very difficult to listen to the
tapes and transcribe the res ective conversations. Second., listening to the ta es was extremcl
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upsetting because it was a constant reminder of my unfortunate experience while employed at
Citi Steel.
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