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Case 2:04-cv-00790-EHC Document 141-2 Filed O4/17/2006 Page1 013

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A JOHNSON VS. CHARLES SCHWAB CORPORATION
MARCELA JOHNSON
A 3/8/06
LEA, SHERIVIAN & HABESKI
A PHOENIX, ARIZONA (602)257·8514
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Case 2:04-cv-00790-EHC Document 141 -2 Filed O4/17/2006 Page 2 013

1 MARCELA JOHNSON Multi-Pagem
1 3/8/06 JOHNSON VS. CHARLES SCHWAB CORPORATI(
l 1 A. I am sorry? 1 Q. Your sister, your parents, your Godmother — did
2 Q. BY Ms. GILIEN: You gossiped a lot while you were 2 you say your Godmother, I’m sorry?
3 at Schwab? 3 A. Yes.
1 4 A. Everybody did. 4 Q. — are they closer to you than Brad Allen?
1 5 Q. You did, correct? 5 A. Brad is closer to me in regards to being I am
1 6 A. Yes. Everybody did. 6 intimate with him, I am not intimate with my parents or my
j 7 Q. Do you think you are better off now than you 7 Godmother.
j 8 were when you were at Schwab? 8 Q. And when you say you are intimate you are having
1 9 Ms. VAIDIVIA: Object to the form. 9 sex with Mr. Allen, correct?
10 A. I don’t understand what you mean by "better 10 A. Yes.
11 off." ll Q. And when did the sexual relationship start?
12 Q. BY Ms. GILLEN: Sure. Do you think you are in a 12 A. I don’t know exactly the date of when we
1 13 better place now than you were when you were at Schwab? 13 started.
. 14 Ms. VALDIVIA; Object to the form. 14 Q. If I told you that there were several E—mails
1 15 A. I don’t understand. 15 and the E-mails indicated that June of 2002 was when you
1 16 Q. BY MS. GILLEN: Happier now than when you were at 16 started dating would that help you to tell me when the sex
y 17 Schwab? 17 started?
A 18 A. As far as my co-workers? 18 A. Possibly. I don’t know the exact date.
`1 19 Q. Your job, your life. 19 Q. Was it shortly after you began dating?
1 20 A. I am a single mother, the same like I was at 20 A. That’s correct.
21 Schwab, I don’t have medical insurance, I can’t go and 21 Ms. VALDIVIA: Object to the form.
1 22 tind a job now until this is over to fmd medical 22 Q. BY Ms. GILLBN; So probably since the summer of
23 insurance because Schwab will subpoena, so at this point I 23 2002, is that an approximate date?
24 wouldn’t say I have a better life. I am making less money 24 Ms. VALDIVIA: Object to the form.
1 25 now than I did before. 25 A. Approximate.
Page 109 Page
1 So as far as a better life, I have to work 1 Q. BY MS. GILLEN: And at that time you were
1 2 extra hours to make up and I have to work longer hours. I 2 married?
* 3 have to make other arrangements for my kids to be baby-sat 3 A. Correct.
i\ 4 versus when I worked at Schwab I got off at 3:00 so I was 4 Q. And your husband was Kirk, correct?
1 5 able to spend quality time with my kids in regards to 5 A. That is correct.
6 picking them up or being there for their activities, we 6 Q. Have you spoken to Mr. Allen about the two of
l 7 had a routine. I don’t have a routine very often 7 you getting married at some point? ·
1 8 anymore. I was able to cook dinner on a daily basis. So 8 MS. VALDIVIA: Object to the form.
1 9 as far as being better off I don’t know if I want to even 9 A. Not of us getting married.
10 say that. 10 Q. BY MS. GILLEN: Has Mr. Allen told you that he i
\ 11 Q. So would the answer be no? 11 going to leave his wife?
, 12 A. At this point I would say no. 12 MS. VALDIVIA: Object to the form.
1 13 Q. Let’s talk a little bit about your relationship 13 A. He has never said he is going to leave.
1 14 with Brad Allen. 14 Q. BY MS. GILLEN: Have you asked him to do that?
1 15 A. Okay. 15 Ms. VALDIVIA: Object to the form.
1 16 Q. How would you characterize that relationship? 16 A. I have never asked him to leave.
M 17 A. As far as what do you mean "characterize it"? 17 MS. VALDIVIA: Marcela, give me a minute to
18 Q. How would you characterize the relationship with 18 object before you answer.
19 Brad Allen? 19 A. Okay.
20 A. We have a relationship with each other. 20 Q. BY Ms. GILLEN: Do you anticipate that you have
ij 21 Q. And what is the relationship? 21 future with MI. Allen?
22 A. I love him. 22 MS.VALD1V1A; Object to the form.
23 Q. Is he the closest person to you? 23 A. We do -- I mean we are together. As far as a
il 24 A. Yes. Besides my parents and my Godmother and my 24 future meaning?
21 25 sister. 25 Q. BY Ms. GILLEN: Well, he is married now, right?
1 Page 110 Pag
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PHOE , ARIZONA (602)2S7·

Case 2:04-cv-00790-EHC

Document 141-2

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Case 2:04-cv-00790-EHC

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