Free Other Notice - District Court of Arizona - Arizona

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Equal Employment Opportunity Commission, Plaintiff,
vs .

)

) No. CIV-04 0627 PHX JAT )

CIGNA Healthcare of Arizona, Inc., and Connecticut General Life Insurance Company, Defendants.

DEPOSITION OF TIFFANIE DILLARD

Phoenix, Arizona May 25, 2005 8:56 a.m.

REPORTED BY:

WILMA A. WEINREICH, CSR, RPR Certified Court Reporter Certificate No. 50530
PREPARED FOR:

MS. KRISTIN CULBERTSON (Copy)

_ IATES
court reporters

3030 North Central Avenue Suite 1102 Phoenix, Arizona 85012 T 602.264.2230 888.529.9990 F 602.264.2245

Case 2:04-cv-00627-JAT

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EON OF TIFFANIE DILLARD - 5/25/05

DEPOSITION OF TIFFANIE DILLARD was taken on 2005, commencing at 8:56 a.m. at the law offices le Equal Employment Opportunity Commission, 3300 North *al Avenue, Suite 690, Phoenix, Arizona, before WILMA IfilNREICH, a Certified Court Reporter in the State of tona.
»"

ISEL APPEARING:
LITTLER MENDELSON

By: Ms. Kristin R. Culbertson 2425 East Camelback Road Suite 900 Phoenix, Arizona 85016
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

By: Ms. Katherine J. Kruse 3300 North Central Avenue, Suite 690 Phoenix, Arizona 85012 10 PRESENT: Ms. Korena Carlyon Ms. Shayna Balch.

Case 2:04-cv-00627-JAT

WWW.GRIFFINREPORTERS.COM

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GRIFFIN & ASSOCIATES - 602.264.2230

DEPOSITION OF TIFFANIE DILLARD - 5/25/05

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employee handbook? MS. CULBERTSON: THE WITNESS: BY MS. KRUSE: Q. And when you say "positions," what do you mean by Form, foundation.

Yes.

is
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that as opposed to policies? A. I mean our position that we do not discriminate

against any group, that we treat everyone fairly in our environment. Q. That's the corporation's position, CIGNA

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Corporation? A. Q. Correct. Employees also have access -- you described as

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training that they have access to the EEO policy on their application, on the website, and in other documents? A. Q. A. Q. Correct. And you also referenced postings; right? Correct. What postings about equal employment opportunity

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do you have at the Phoenix Service Center? A. We have the required -- we have the required

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Five-In-One posting. Q. A. Q. Excuse me? We have the required Five-In-One posting. What's the Five-In-One?

ks

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DEPOSITION OP TIFPANIE DILLARD - 5/25/05

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A.

It's got the required documents that we have to

post in the building. Q. What's the equal employment opportunity component

of the Five-In-One posting? A. I think -- I have not looked at that recently to

be able to recite what's on it. Q.
A. Q. A.

But it does have some? Yes, it does. Do you know -- what do you mean by Five-In-One? It's five posters on one document. Where is that posting at at the Phoenix Service

Q.
Center?

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A. Q. A. Q.

That Five-In-One is in the lunch room. Anywhere else?

No.
Are there any other postings of the Phoenix

Service Center regarding equal employment opportunity? A. There's the reaffirmation statement in the lunch

room next to the Five-In-One as well as outside of human resources. Q. When you say outside human resources, do you mean

like on a door as you enter the human resources area? A. Q. It's on the wall outside of my office. Are there any other postings on equal employment

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opportunity at CIGNA Phoenix Service Center at the present

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DEPOSITION OF TIFFANIE DILLARD - 5/25/05

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time? A. Q. A. I don't believe so. What's the size of the Five-In-One poster? (Indicating). I'm going to guess inches here. This is a guesstimate.

It's maybe two feet by three feet. Q.
A.

It's bigger than an 8 1/2 x 11 piece of paper?

Yes.
MS. CULBERTSON: Can you compare it to

anything on the wall perhaps? THE WITNESS: (indicating). BY MS. KRUSE: Q. A. Q. The size of the I Have a Dream poster? Roughly. Does either the reaffirmation statement or the Roughly that size

Five-In-One poster indicate who individuals can contact if they feel they have been discriminated A. Yes. against?

There is the affirmation statement which

indicates local human resources as one point of contact. Q. A. Q. A. Any other point of contacts? Also our corporate employee relations department.

Is that listed on the affirmation statement? I believe it is. I believe it also references

our internal dispute resolution process which is called a speak easy process.

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DEPOSITION OF TIFFANIE DILLARD - 5/25/05

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Q.

Does it tell employees that they can contact any

of these processes? A. Q. I believe so. Does it provide any -- does it state any other --

anyone else that can be contacted? A. I believe it also states your manager as a

potential point of contact. Q. A. Anyone else? I think those are the four I can remember off the

top of my head. Q. A. | 3 |4 15 16 | 7 |8
| 9

From the affirmation statement? Uh-huh. Does the Five-In-One poster have any information

Q.

on who employees can contact if they believe they have been discriminated against? A. Q. I believe it does reference the EEOC. The United States Equal Employment Opportunity

Commission?
A.

Yes.

| 0 !1 12 13 14 !5 BY MS. KRUSE: Q. little bit. next to you.

MS. CULBERTSON:

You need to speak up a

I can barely hear you and I'm sitting right

THE WITNESS:

I'm sorry.

Has the Five-In-One poster been up continuously

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since your arrival at the Phoenix Service Center in 2002?
A.

Yes.

Q.

And how about the affirmation statement?

A.

Yes.
MS. KRUSE: This is a good time to stop.

It's 12:30.

We have agreed to resume the deposition of

Tiffanie Dillard on Friday after we complete the continued deposition of Heather Casey. (The deposition adjourned at 12:30 p.m.)

(Signature reserved)

TIFFANIE DILLARD
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