Free Motion in Limine - District Court of Arizona - Arizona

Case 2:03-cv-02306-JAT Document 60-2 Filed O3/17/2006 Page 1 0f3


1
1 IN THE UNITED STATES DISTRICT COURT ARIZONA
O 2
3 KENNETH 6; TOWANDA LYON, for )-
D. LYON, ) _
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ESTRELLA- FOOTHILL-S HIGH ) `
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,“·.;_ I 12 DEPGS-ITION OF HENRY SCI-IM_IT—‘I'
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• - Phoenix., Arizona-
. 14 November 15.-, 2005
. 11:00 a.m.
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~ 19 CONDENSED COPY I
20 ~ ‘ Oiiwmméir Ima
.280.0. N. Central, Sie. TSO
21 Phoenix, Arizona 8500.4
PREPARE-D FOR; {502) 4,3-5-] 433 _
22 _ _ l—866-4-85-1444 - Mfg
MS. GEORGIA A. STATON gE,C§J‘~’¥=-·
BEC ii EDGE
" if 24 ·(Copy)‘ Reported by:
· Nicole ·Schaffr1ex‘·, RPR GAS
0 25 _ AZ Cezrtified Reporter No. 50671
OTTMAR & ASSOCIATES, INC.
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Case 2:03—cv—02306-JAT Document Eaeci 7/2006 Page 2 Of 3

Digiyictl where did you work? 5 1 A. The only involvement waste nrakesure- that poldy
A, Buckeye Unified School District ‘ 2 was being followed.
. Q, And how long did you wont there? 3- Q. Okay. And was
A Five years. _ . 4- A. Yes.
Q. What was your position? 5 Q- Do you know Kenneth Cody Lyon?
5 A. Superintendent. 5. A. No.
Q. During your time .as a superintendent for Buckeye it Q. Do you know Towarrda Lyon?
Unified School District, did you ever haves chance. to com 8 A. Yes.
` in oontactwlth Tara Lyon? 9 O. How do you know har? .
g A. `Yes. · 10 A As aparent.
1 Ot Do you remember when? `11 Q.. Haveyou ever had an_y contact with her regarding
3 A I would say In-2002. 12 her son Kenneth Lyon'?
.-3 Remember what the nature of that contact was? 13 A. Yes.
4 A-. Used-to follow her athletically. 14 Q. what was that contact?
5 Q. Any other contact with her? 15 A. There were concurrent meetings. _
n A. lilotthat l‘m aware of. 16 Q; Concurrent m`eetings?- What doiyou mean by
7 Q. You ever have any contact regarding a disciplinary 1? A. ‘ Well, with the issue that was involved with Cody.
8 action against Tara Lyon? 13 Q. What was that issue'?
9 A. I Only when it reached the principats level and the 19 A. The issue was initially the relationship with one
hearing officer and want to the- board. 20 of the teachers.
1 Oy Can you tell menwhat you remember regarding that 21 Q. Did you ever.take that issue to the governing
- contact? l _ .-22 board?
A. Iremember that there was consistency, I remember 223 A. Yes.
4 the hearing. officers — 24 O; When was that?
5 MS. ST ATON: Wait a mindte. met Do you 25 A. You know, I don‘l recall. Butwe terminated the
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1 wantto know about his contact with her? Or his role in thas 1 teacher. 8
2 disciplinary process? Because I'm..-a little confused. 2 Q`. Was it priorto the tea.cher‘s terrnination that you
3 MR. COLLINS; Ijustwant to know- what contact he 3 took it to the·goveming.board?
4 had. I was going toask more specific questions; 4 A. The board was informed ofthe investigation. Yes.
5 MS. STATON:. Okay. Contact but with her'? 5 Q. And to what extent were-they informed?
it MR. COLLINS: With Ms. Lyon. yes. 6 A. Just updates.
T MS-. STATON: Okay. _ T Q. Did you tell them that an investigation was
8 Ho wantsto know.-a_bout.any contact you had with .8 occurring or.did you give-them details?
9 her. .9 A Did not give them details.
D THE WlTltlES·S: No; 1`D O. Did you do that in the form of memos or vefcally?
1 BY MR. COLLINS: 11 A Verbally.
2 · O. Okay. Now. you were involved with disciplinary 12 O. Doyou know if there weretany minutes kept —as It
3 action with Tara Lyon, correct? 13 relates to that?
14. A Yes. Correct 14 A. I'm not sure.
i5 Q. Okay. And in that- capacity — well, what-was. your 15 O. You told them in a board meeting, I'm assuming?
16 aoapacity in that disciplinary action? 15 lguess I need to back up, and let me re~ask the
7 A. As is the case in any, in the recommendation from 17 question or ask a aiaerent question.
8 me building level principal. 1B When you informed them verbally, when was that?
9 Q. Okay. And what was your inv.oIvemeht ln that 19 .A. Well, ltwas. prior to the recommendation for
tl recommendation? 20 termination.
_i A. The final recommendation to-theygoverning board. 21 Q. Was it at a board meeting'?.
2 Q. Okay. Well, what was your Involvement? I mean 22 The recommendation tor temiinatlon. yes, was at a
-3 didyou talkto hirnabout Did you tell him what to do? _ 23 board meshing.
4 I mean what was your invohrement? Was there-a meeting. was 24 Q. Okeli- Did you have-any contact or discussions
25 -there·disousslons? what was that involvement? 25 with any board member other than at a board meeting?
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Case 2:O3—cv-02306-JAT Document 60-2 Filed O3/1-7/2006 Page 3 of 3

Case 2:03-cv-02306-JAT

Document 60-2

Filed 03/17/2006

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Case 2:03-cv-02306-JAT

Document 60-2

Filed 03/17/2006

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Case 2:03-cv-02306-JAT

Document 60-2

Filed 03/17/2006

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