Free Reply to Response to Motion - District Court of Arizona - Arizona

Jack Colson - 25339 Patrice Jeromgl Midway Holdings, Inc., et al.
1
4 i` l IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
2 .
3
PATRICE JEROME, )
4 · )
_ Plaintiff, . )
5 )CIVIL ACTION .
vs. )
6 )FILE NO.
MIDWAY HOLDINGS, INC., )CV '03 l9l3 PHX MHM
7 MIDWAY AUTO TEAM, MIDWAY )
INFINITI, MIDWAY NISSAN, )
S MIDWAY GMC, MIDWAY BUICK, )
MIDWAY PONTIAC, MIDWAY ’ )
9 CHEVROLET, AND THE )
AUTOMOTIVE INVESTMENT l CSFUIEFTU
lO GROUP, ARIZONA, )
2;; l
" ll Defendants. )
l2 .
V 13
l4 VIDEOTAPED DEPOSITION OF
l5 , JACK LEE COLSON
l6
February 8, 2006
`I7 l0:l0 a.m.
18
Atlanta Airport Marriott
l9 47ll Best Road
Atlanta, Georgia
2O
2l Andrea B. White, CCR—B—2072
2 2 I ll
23
24
’ 25
EXHIBIT
"T E
RLS Legal Solutions g C
214-273-6760
Case 2:03-cv—01913-IVIHIVI Document 92-4 Filed 08/07/2007 ' - - - 9 `

Jack Colson - 25339 Patrice Jeromi. Midway Holdings, Inc., et al.
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Nm- 1 A. Yeah. That was pretty much when I just
2 kind of decided hey, we'll have to go in a different
3 direction.
4 Q. Do you recall whether or not you issued
5 I any type of a written write—up to Ms. Jerome in I
6 response to that situation?
7 A. Yeah, I do. I know I did because I was
8 doing memos at the time, you know.
9 Q. And, I'm sorry, did Ms. Jerome ever offer
10 any type of explanation or reason as to why that job
11 fair didn't go very well?
12 A. It was a personal thing, something _
" 3 13 happened with a babysitter or sickness. I just —— I
14 mean, I can't remember. It's been so —— it was
15 something personal. But the only thing I told her, I
16 said why didn't you call me, and then maybe I could
17 have took the phone because we had all these calls
18 coming in and, you know. That was pretty much —— I
19 think at that point it was —— it was —— it was —— it
2O was just the end of it, and she kind of figured it
21 was the end of it. Like I said earlier, I think she
22 just kind of gave up and just, you know, was going to
23 maybe try and go do something else. I
24 Q. Do you know why Ms. Jerome's employment
25 with Midway ended?
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Case 2:03-cv—01913-IVIHIVI Document 92-4 Filed 08/07/2007 Page 2 of 3

Jack Colson — 25339 Patrice Jeromi. Midway Holdings, Inc., et al.
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fwd 1 Q. Did you ever hear him use any type of age
2 biased remarks in the workplace at Midway?
3 A. No.
4 Q. Ms. Jerome is also suing Midway for age
5 discrimination. Do you know how old Ms. Jerome is?
6 L A. No. H
7 Q. Do you know how old she was when you
_ 8 worked with her?
9 A. No.
10 Q. Did anyone ever tell you how old she was?
11 A. Didn't need to know. I'm not —— she was
12 an adult. I mean, I don't know.
;'°% ‘``' 13 Q. Did you treat her differently in any way
li I 14 because of her age?
15 A. No.
16 Q. Did her age play any part in your decision
17 to terminate her?
18 A. No.
19 Q. Finally, Mr. Colson, Ms. Jerome is
20 alleging in this lawsuit that she was terminated for
21 complaining about a certain alleged hiring directive
22 that she says she refused to follow. And -
23 specifically she claims that she was instructed by
24 Patrick Beaman to recruit only white males in their
25 20s with flat guts. Do you have any knowledge of any
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‘ Case 2:03-cv—01913-IVIHIVI Document 92-4 Filed 08/07/2007 Page 3 of 3

Case 2:03-cv-01913-MHM

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