03-08-2016 justin biggs testimony - vukadinovich trial
TRANSCRIPT
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA
HAMMOND DIVISION BRIAN VUKADINOVICH, ) )vs. 2:13-CV-144 ) )HANOVER COMMUNITY SCHOOL )CORPORATION, et al. )
TRANSCRIPT OF EXCERPT TESTIMONY OF JUSTIN BIGGS March 8, 2016
BEFORE THE HONORABLE PHILIP P. SIMON UNITED STATES DISTRICT JUDGE
A P P E A R A N C E S:
FOR THE PLAINTIFF:
BRIAN VUKADINOVICH 1129 E 1300 N Wheatfield, Indiana 46392 (219) 956-2462
FOR THE DEFENDANTS:
MARSHA VOLK BUGALLA CHAD M. BUELL Frost Brown Todd LLC 201 North Illinois Street, Suite 1900 P.O. Box 44961 Indianapolis, Indiana 46244 (317) 237-3800
Court Reporter: Stacy L. Drohosky, FCRR, CRR, RPR Official Court Reporter United States District Court 5400 Federal Plaza, Suite 4005 Hammond, Indiana 46320
(219) 852-3462 Proceedings reported by stenotype. Transcript produced by computer-aided transcription.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
(The following is an excerpt transcript of the testimony
of Justin Biggs called in the plaintiff's case in chief:)
THE COURT: All right. You all may be seated.
Mr. Vukadinovich, you may call your next witness.
MR. VUKADINOVICH: Thank you, Your Honor.
I call Justin Biggs.
THE COURT: Mr. Biggs, if you would, please come
forward, sir.
Please raise your right hand, sir, to take an oath.
(The oath was administered.)
THE WITNESS: I do.
THE COURT: All right. You may be seated.
JUSTIN BIGGS, PLAINTIFF WITNESS, SWORN
DIRECT EXAMINATION
BY MR. VUKADINOVICH:
Q. Could you please state your name and spell your name,
please.
A. Justin Biggs; B-, as in boy, I-G-G-S.
Q. Are you currently employed?
A. Yes.
Q. Where is that?
A. Michigan City area schools.
Q. What is your position?
A. I am an assistant principal.
Q. And how long have you been employed there?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
A. This is my second year.
Q. Were you previously employed to that? Prior to going to
Michigan City.
A. I was previously employed, yes.
Q. And where was that?
A. Hanover Community School Corporation.
Q. What was your position there?
A. Principal.
Q. Were you my principal?
A. Yes.
Q. Now, prior to coming to Hanover Central, where were you
employed?
A. The School City of Hammond.
Q. Did you enjoy your time at the School City of Hammond?
A. I did.
Q. Are you loyal to the School City of Hammond?
A. I don't understand.
Q. Do you feel any sense of loyalty because they employed you
and you worked there for a period of time?
A. I don't --
Q. Are you grateful for that?
A. Sure, I'm grateful for the employment.
Q. You couldn't say if you feel like you were being loyal to
the school system?
A. I'd like to answer your question. I just don't know how.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. If there was anything you could do to make the School City
of Hammond feel better, would you do it?
A. Not anything, no.
Q. Okay. But you would do some things?
A. It is hard for me to understand how I would make a whole
school city of Hammond feel better. I don't understand.
Q. You said you wouldn't do anything, but then would you do
some things? Were there some things you would say, yeah, I'll,
you know, if I can do something to make them feel better, if I
can, I will?
A. I don't think so, no.
Q. You would not do that?
A. (No audible response.)
Q. But a little while ago you said that there are any -- some
things you would do. Are you changing your answer?
A. I don't understand.
Q. The bottom line is, would you do anything -- is there
anything that you would do for the School City of Hammond if it
would make -- if you know that it would make them feel better?
A. I don't understand how I could make a whole school city
feel better, so I can't answer the question.
Q. Okay. What were the positions you held with the School
City of Hammond?
A. I was a dean, and then I was assistant principal.
Q. Where were you the assistant principal?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
A. At Morton High School and then Hammond Clark Middle
School/High School.
Q. Now, how is it that you came about being employed at
Hanover?
A. I applied for the position.
Q. Okay. And what position did you apply for?
A. Principal.
Q. For what school?
A. The middle school/high school at the time.
Q. That's the position you applied for?
A. Yes.
Q. Okay. I'm looking at Plaintiff's Exhibit No. 72.
THE COURT: Is this document in evidence or not?
MR. VUKADINOVICH: Yes, Your Honor, it is.
THE COURT: Is it, Noel?
MS. BUGALLA: We don't have a record of it.
DEPUTY CLERK: I don't show it.
THE COURT: Approach the bench.
(Bench conference.)
THE COURT: Here is the deal: You have to stop
representing to me that things have been admitted into
evidence --
MR. VUKADINOVICH: No, it is not in evidence.
THE COURT: -- and it has not.
I just asked you, has this been admitted into evidence,
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
and you said, yes.
MR. VUKADINOVICH: Your Honor, I thought you meant is
it in the evidence book. I'm sorry.
THE COURT: There's a term of art I'm using. Has it
been formally admitted into evidence.
MR. VUKADINOVICH: No, it hasn't. I meant in the
book.
THE COURT: Fair enough. It is important.
MR. VUKADINOVICH: Yes. Yes, sir. Thank you.
(End of bench conference.)
BY MR. VUKADINOVICH:
Q. Mr. Biggs, this document, Plaintiff's Exhibit No. 72,
could you describe that document.
A. Yes. It is an e-mail message from Karleen Adler -- from
me to human resources at Hanover, et cetera.
Q. Now, you just testified that you applied for the principal
position at the middle school, is that correct?
A. At the middle school/high school, yes.
Q. Yes. Now, this document here, is this your actual letter
of application for employment at Hanover?
A. That's an e-mail message as -- a message to Ms. Adler
regarding a different position.
Q. Okay. And what position was that for?
A. Assistant principal at Jane Ball Elementary School.
Q. At the elementary school, correct?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
A. Yes.
Q. But you said you applied to be the principal at the middle
school and the high school?
A. I did.
Q. Well, which one did you apply for first?
A. Assistant principal at Jane Ball.
Q. But when I asked you what position you applied for, you
didn't say at the elementary school. You said at the high
school.
MS. BUGALLA: Your Honor, I'm going to object.
THE COURT: That's argumentative. That's not --
that's not how it went down, Mr. Vukadinovich. That's
argumentative. Sustained.
MR. VUKADINOVICH: Okay. I move to admit Plaintiff's
Exhibit 72.
THE COURT: Do you have any objection to 72?
MS. BUGALLA: No.
THE COURT: All right. Seventy-two is admitted.
(Plaintiff's Exhibit No. 72, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. So then at some point then you did become the principal at
the middle school/high school, correct?
A. Yes.
Q. Okay. Now, were you the principal of both the middle
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
school and the high school at the same time?
A. Yes, for the 2011-2012 school year.
Q. And were both the middle school and the high school within
the one building?
A. Yes, they were within one building. Although the middle
school was nearer the cafeteria than the high school, which was
closer to my office.
Q. And why are you no longer employed by the Hanover
Community School Corporation?
A. I accepted a position at the Michigan City area schools.
Q. Was there any push by Hanover to -- for you to leave?
MS. BUGALLA: Your Honor, I'm going to object.
THE COURT: Sustained.
BY MR. VUKADINOVICH:
Q. What position do you have with the Michigan City schools?
A. Assistant principal.
Q. But you were the principal at Hanover, is that correct?
A. That's correct.
Q. In status, wouldn't that be a lesser position?
A. I guess that depends on who's asking and whose question it
is.
Q. I'm asking you. It is my question.
A. Do I believe it is a lesser status? No.
Q. To be an assistant principal over a principal?
A. Correct.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. But you were an assistant principal when you were in
Hammond and then you went to the principal position at Hanover.
Wasn't that an elevation in status?
A. Some would say that, yes.
Q. Okay. Well, if it was an elevation in status, if you went
back to assistant principal, wouldn't that be --
A. Again, I don't see it that way.
Q. All right. Are you making -- how much money are you
making?
MS. BUGALLA: Your Honor, I'm going to object.
THE COURT: Sustained.
BY MR. VUKADINOVICH:
Q. Are you making less money than you were making at Hanover?
MS. BUGALLA: I'm going to object again.
THE COURT: Overruled. I think that's fair.
THE WITNESS: No.
BY MR. VUKADINOVICH:
Q. So you took a position of an assistant principal with a
less paying position, is that correct?
A. No.
Q. That's not correct?
A. No.
Q. You took an assistant principal position at Michigan City,
correct?
A. Yes.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. And it is a lower paying position, is it not?
A. No.
Q. You are making more money at Michigan City than you were
making at Hanover?
A. Yes.
Q. Did you make more money the first year you were at
Michigan City than you made at Hanover?
A. Yes.
Q. I'm looking at Plaintiff's Exhibit No. 73. Could you
please describe that document.
A. Yes. It looks to be my contract for the Hanover Community
School Corporation.
Q. When you were the principal, correct?
A. Yes.
Q. All right. And what does that contract call for pay?
A. It shows effective date July 8, 2011. Contract amount
$85,000.
Q. Okay.
MR. VUKADINOVICH: I move to admit Plaintiff's
Exhibit 73.
THE COURT: Any objection?
MS. BUGALLA: I guess not.
THE COURT: All right. It is admitted.
Seventy-three is admitted.
(Plaintiff's Exhibit No. 73, previously marked, was
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Okay. I'm looking at Plaintiff's Exhibit No. 74. Could
you please describe that document.
A. That appears to be a regular teacher contract for my
Michigan City area schools for -- it looks like beginning
August 15, 2014.
Q. Okay. Now, what's the salary for in that contract?
A. $78,000.
Q. But you were making 85 at Hanover, correct?
A. Yes.
Q. And you were making 78,000 at Michigan City. Isn't 78,000
less than 85,000?
A. There's two questions there.
Q. Were you making -- I asked you earlier, and you said that
you were making more money at Michigan City. But according to
this contract isn't that less -- isn't $78,000 less than
$85,000?
A. $78,000 is less than $85,000, yes.
Q. But you testified that you were making more money on your
job at Michigan City than you were making?
A. I do.
Q. Could you explain that.
A. Sure. Over the summer I'm given a stipend to run the
summer school program. I'm principal during that time, and for
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
that I receive $10,000 additional.
Q. Okay. So that's an extra stipend position, correct?
A. Yes.
Q. As far as being principal, you were making less money,
correct?
A. No.
Q. As far as your actual contractual duties as principal, you
were making 78,000 at Michigan City, correct?
A. An assistant principal.
Q. Assistant principal.
A. And my total salary last year was $88,462 I believe.
Q. I'm talking about just for principal, not any stipends or
anything.
A. That's for principal because I do those two positions.
Q. Well, then why doesn't it say that in here?
A. That's my original contract, which is 78,000; but then I
also work over the summer, and that's an additional month's pay
at my hourly rate.
Q. At a stipend?
A. Yes.
Q. Okay.
MR. VUKADINOVICH: I move to admit No. 74.
THE COURT: Any objection to 74?
MS. BUGALLA: No.
THE COURT: It is admitted.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
(Plaintiff's Exhibit No. 74, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Before you went to -- when you left Hanover, did you apply
for any other jobs before you went to Michigan City?
A. I'm trying to think. Yes, there were a couple of
positions.
Q. Did you apply for any teaching jobs?
A. I don't recall.
Q. I'm looking at Plaintiff's Exhibit No. 75. Could you
please describe that?
A. It looks like a letter to River Forest School Corporation;
any available position, whether it is intermediate, assistant
principal, or art teacher.
Q. What is the date of it?
A. That looks like 2014.
Q. That's after Hanover, correct?
A. No, I was still employed there.
Q. Okay. But you were applying to be an art teacher at River
Forest, correct?
A. That was one of my letters of interest there, yes.
Q. Okay. And is an art teacher at River Forest, the pay
there, is it greater than a principal makes at Hanover Central?
MS. BUGALLA: Your Honor, I'm going to object. I
just don't see the relevance of this.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
THE COURT: Sustained.
BY MR. VUKADINOVICH:
Q. Were you happy at Hanover Central?
A. No.
Q. Why weren't you happy?
A. There were things that were difficult at Hanover.
Q. What was difficult?
A. This litigation, I think, was one. I think that was
primarily it.
Q. What was difficult about it?
A. It was difficult to undergo the constant defamation of my
character that you made me undergo.
Q. In what way?
A. By making up statements that I was alleged to have made
when I handed you that RIF letter.
Q. And then did you tell -- did you tell the Hanover people
that you did not make those statements?
A. Yes.
Q. When did you tell them that?
A. Must have been after I had learned of your statements to
that effect over the summer sometime.
Q. After I had been terminated?
A. Yes.
Q. Who did you tell?
A. I imagine, although I'm not certain, but the legal
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
counsel.
Q. Did you tell anybody at Hanover?
A. I don't believe so.
Q. You didn't tell Ms. Kaiser?
A. I may have. I may have.
Q. Did you tell Ms. Dixon?
A. No --
Q. Why not?
A. -- I don't believe so.
I didn't speak with her on that level about this
particular case.
Q. What prompted you to speak to Ms. Kaiser?
A. Because it was litigation, and it was something that I
needed to speak with her about because of the attorneys
involved and the case as it went forward.
Q. Well, isn't the school board relevant there? Shouldn't
they know? They are your employer, correct?
A. I didn't have a clear line of communication with the
school board members that way.
Q. When you say you didn't have a clear line of
communication, what do you mean?
A. I did not directly address the Board members with respect
to my day-to-day operations.
Q. Could you have e-mailed them?
A. No.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. You could not?
A. No. I would typically just speak with Carol, Ms. Kaiser.
Q. I asked you if you could e-mail them. Could you have
e-mailed them?
A. Was it physically possible for me to type in the e-mail
address, yes.
Q. Could you have called them on the telephone?
A. I don't know what their extensions were. I did have
Ms. Dixon's cell phone number. I do have that ability to
communicate.
Q. So you didn't have any ability to find out what the school
board members' phone numbers were?
A. I could have asked if I had chosen to do that, yeah.
Q. But you chose not to?
A. That's correct.
Q. How about Ms. Kounelis, do you know her?
A. I do.
Q. Could you have called Ms. Kounelis and said, Hey, I want
this particular school board member's telephone number?
A. Yes, I could have asked that.
Q. Could you have said to Ms. Kounelis, Could you please
leave a message for me for this school board member. I need to
talk to her about this particular thing?
A. I'm sorry. Could you repeat that.
Q. Could you have asked Ms. Kounelis to leave a message for a
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
school board member, that you needed to discuss something with
the school board member?
A. I could possibly have done that, yes.
Q. But you didn't, is that correct?
A. That's correct.
Q. Okay. Now -- so the only person that you spoke to about
this was Ms. Kaiser, is that correct?
MS. BUGALLA: Your Honor, I believe that's a
mischaracterization of the evidence.
THE COURT: Sustained. I think he also testified
that he talked to counsel. That's sustained.
The question is stricken. You are admonished to disregard
it.
Proceed.
BY MR. VUKADINOVICH:
Q. What did you tell Ms. Kaiser?
A. I don't recall.
Q. You have any idea what you told her? Anything?
A. We spoke about lots of things. I can't say specifically
what I said with respect to that.
Q. You don't remember saying to Ms. Kaiser,
Brian Vukadinovich is making these claims about that I said --
you know, about the settlement with the School City of Hammond
and I called him an old man. You didn't tell Ms. Kaiser that?
A. I don't recall. If she already know -- or if she had
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
already known or if it were even mentioned. I don't know what
her knowledge was our conversation would have been. I don't
recall.
Q. Well, how would she already know if you didn't tell her?
Did you tell anybody else?
A. No, sir. You wrote it in the e-mail, and that's how I
first understood that it existed.
Q. Okay. And that e-mail was from me to you, correct?
A. If I recall correctly, yes.
Q. Well, then how would Ms. Kaiser know it?
A. I imagine that I forwarded it on to the counsel and Board.
Yes, I must have forwarded it to counsel and to her.
Q. Did you forward it to counsel -- but you never forwarded
it to Ms. Kaiser?
A. I imagine that I would have. That kind of message I
probably would have sent directly to her.
Q. Would it have been on a school e-mail?
A. Yes.
Q. Do you know if that e-mail was ever provided to me in this
litigation?
A. I know that every e-mail I have ever written from the time
I started work at Hanover until now has been provided to you.
Q. Including the e-mail that you forwarded to Ms. Kaiser
about --
A. Whatever I wrote, it was there.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. Would you have any problem with bringing that e-mail here
and showing it to the Court?
MS. BUGALLA: Your Honor --
THE COURT: Sustained.
BY MR. VUKADINOVICH:
Q. At what point did you forward that e-mail out? What
proximate time period? What date was it?
A. If it happened, which I believe it probably did, I would
have forwarded it immediately.
Q. I'm sorry?
A. Immediately upon my receipt of it.
Q. Okay. All right. Now, how many e-mails did I send to you
particularly about the comments and the litigation?
A. Several. I don't have an exact number.
Q. Did you respond back to me on any of them?
A. No.
Q. Why not?
A. Because they were attacking my personal character, and I
didn't believe that a response was warranted because it would
probably just fuel further argument.
Q. But you chose not to deny the statements, is that correct?
A. Not to you.
Q. You chose not to deny the statements back to me, correct?
A. I chose not to deny them to you, that's correct.
Q. When somebody makes an allegation against somebody, you
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
don't feel that if the allegation is unwarranted there should
be a denial?
A. I'm sorry. Could you repeat the question.
Q. If you feel that an allegation is being made against you
that is unwarranted, you don't feel that a denial of it is
appropriate?
A. There's a lot of negatives in that question, so could you
please rephrase it. I don't understand.
Q. If somebody makes an allegation against you that you feel
is not -- wasn't true or whatever, you do not feel that it is
appropriate to deny and say, I did not make those statements,
you're harassing me, or whatever? You didn't feel that would
be appropriate?
A. I didn't feel any communication with you, sir, was
appropriate at that point.
Q. Okay. Was I still a teacher at the school?
A. Yes.
Q. So you said that you didn't feel that any communication
with me was appropriate at that point, correct?
A. Yes.
Q. Did you have any communication with me after that?
A. Yes.
Q. But you just said that you didn't think any communication
was appropriate after that.
A. That's correct.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. Okay. What communication did you have with me after that?
A. Things relating to your behavior and disrespect.
Q. Tell us about that.
A. The first notice that I gave to you, I handed you the
letter; and you took it and left. And then I had to call you
back in to sign and date it, which you did. And at that point
you asked me, you know, if there was anything about your
performance that had to do with this letter, and I said no, and
you thanked me and left. From that point forward, there were
several instances where you behaved in a way that I felt was
disrespectful.
Q. Tell us about that.
A. The first was the receipt that you asked me for in my
office. Initially, I refused because it was accompanied by a
letter that was extensive, and I didn't want to sign something
that I didn't agree to. Then after reading the letter and
acknowledging that, I signed the receipt, and I gave it to you.
When I presented it to you in the classroom, I gave it to you;
and then you stared at me and yelled, Anything else? And then,
again, as I backed away in front of this classroom, you yelled
at me again, Anything else? And that was one instance.
Q. I'm gonna stop you there for a second. Did you say that
you didn't want to sign the receipt for that letter because it
was expensive?
THE COURT: He said it was extensive.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
MR. VUKADINOVICH: Oh, I'm sorry. I thought you said
expensive.
BY MR. VUKADINOVICH:
Q. What was extensive, the receipt or the actual letter?
A. The letter was a page long. The receipt accompanying it
was very short.
Q. So it was a page-long letter. You thought that was
extensive?
A. Yes.
Q. And what was the letter?
A. I don't have it in front of me. I can't recall.
Q. You don't remember what it was?
A. I believe it dealt with a request for your personnel file
in my office.
Q. Okay. That's for my records of my employment, correct?
A. Those were some of the records, yes.
Q. Okay. And are you required to give me my personnel
records when I ask for them?
A. Yes.
Q. And you said that it was an extensive thing that you chose
not to accommodate with me at the time, correct?
MS. BUGALLA: Your Honor, I'm going to object. He
did not -- the testimony was not that he did not accede to the
request. The testimony was that he wished to review the
request.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
THE COURT: All right. Ladies and gentlemen, you've
heard the evidence. It is for you to decide what your -- in
your collective judgment what the evidence is in that regard.
So proceed.
BY MR. VUKADINOVICH:
Q. Now, at what point did you then change your mind and come
into my classroom? How long of a time period from the time I
was in your office and asked you to sign the receipt for the
letter to the time you came into my classroom?
A. Half an hour.
Q. Half an hour.
So did you talk to Ms. Kaiser between that time about
that, about me being in there?
A. No.
Q. Did you fax the request to Ms. Kaiser?
A. No.
MR. VUKADINOVICH: I just need a minute, Your Honor,
to -- are these the exhibits that have been admitted?
THE COURT: Yes.
BY MR. VUKADINOVICH:
Q. Mr. Biggs, this is Plaintiff's Exhibit 33. It has been
previously admitted. What is that?
A. This is -- appears to be a letter to me from you, and the
first line says, "I request that the following information be
provided for my inspection and copying pursuant to IC 5-14-3."
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. And what's the date of that letter?
A. May 8.
Q. Is that the one that I'm asking for my personnel file and
so forth?
A. I believe so.
Q. All right. Now, look at the upper left corner there.
What do you see there?
A. It is blank. Next to your name? Twenty-four doesn't
show.
Q. There it is.
A. "May 8, 2012, 15:42, Fax 374-4408."
Q. That was May 8. That was the same day that this happened
in the classroom, is that correct?
A. I believe so.
Q. Okay. And then whose fax number is that?
A. I want to say it is my own -- or the Hanover High School.
Q. So you're saying somebody faxed that to you?
A. It's possible. Honestly, I don't recall.
Q. Okay. So -- well, according to this document here, this
letter was faxed by somebody to somebody, correct?
A. It appears to be, yes.
Q. Okay. Well, do you know who that was?
A. I don't.
Q. You didn't fax this?
A. I don't recall.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
THE COURT: He's already answered he doesn't know.
BY MR. VUKADINOVICH:
Q. Okay. Now, when you came into my classroom, was actually
class in session?
A. Yes.
Q. And was I teaching the class?
A. I think you were reviewing a video or playing a video or
about to play a video.
Q. Classroom related?
A. I don't know.
Q. Well, you were in the room, weren't you?
A. I did enter the room, yes.
Q. It wasn't a Bugs Bunny cartoon, was it?
A. I don't know.
Q. Well, if it would have been a Bugs Bunny cartoon, would
you have said something to me?
A. I can't guess.
Q. Would that be appropriate to be showing a Bugs Bunny
cartoon in class?
A. It depends on the course.
Q. Well, I was the industrial arts teacher, correct? You
didn't bother to see what was on the video?
A. I didn't look. I didn't notice. I don't recall what was
there.
Q. All right. Now, you said that I yelled at you, is that
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
right?
A. Yes.
Q. What did I yell?
A. "Anything else?"
Q. Okay. Did you tell me what you were doing in the room
when you walked in there?
A. I believe I handed you the letter and I said,
Mr. Vukadinovich.
Q. Okay. Now -- so would you say it was a real loud yell?
A. Yes.
Q. How far away from me were you standing from me?
A. About 10 feet.
Q. Ten feet. Okay.
And I yelled real loud?
A. Yes.
Q. Okay. Now -- and how long did you stand there at that
point in time?
A. I wasn't standing. I was backing away.
Q. I'm sorry?
A. I was backing away.
Q. Okay. Well, how long did you stay in the room?
A. As I backed toward the door, I waited -- I didn't wait. I
backed and I found the door and I left.
Q. And then was I written up for that?
A. Not as far as I know.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. Did you tell Ms. Kaiser what happened?
A. Yes.
Q. When did you tell her?
A. Soon thereafter.
Q. Okay. Do you recall ever calling me into the office and
giving me a letter on behalf of Ms. Kaiser?
A. Yes.
Q. And then do you remember what the letter said?
A. No.
Q. Did you discuss with Ms. Kaiser about when you came into
the room?
A. I'm not sure.
Q. Did you tell Ms. Kaiser what happened when you came into
the room?
A. Are you speaking about the video --
Q. Yes.
A. -- and the receipt?
Q. Yes.
A. Then yes.
Q. And now, in my classroom, is there a video camera in
there?
A. I don't know.
Q. Are there video cameras throughout the building in the
school?
A. Yes.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. Okay. So if there was a video camera in the room, you
could have actually have had a video of this where you say I
was yelling at you in front of the students, that would
actually be on the video if there was a camera in the room,
correct?
A. I can't guess because I don't know if there was a camera
in there.
Q. So as a principal, you didn't know if there was a camera
in my room?
A. I don't know now.
Q. You what?
A. I don't know now if there's a camera in that room.
Q. Okay. And you didn't know at the time?
A. I don't recall. There is 105 cameras in that building.
Q. Okay.
Then was there any other instances?
A. Instances of what?
Q. Of anything where I disrespected you or anything like that
along those lines?
A. Yes.
Q. Okay. Go ahead.
A. There was a meeting where you spoke brusquely to me when I
poked my head in. And there was a meeting that we had, I
believe it was May 22nd, that dealt with my intent to address
you about an issue with a meeting with the special education
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
cooperative.
Q. Tell us about that.
A. I received an e-mail message explaining that you had been
rude toward the presenter and that you had left. I called you
in to discuss that.
MR. VUKADINOVICH: Can I take these over with me,
Your Honor?
THE COURT: Sure. Just make sure they return to the
table when you're done.
BY MR. VUKADINOVICH:
Q. You said that the e-mail you received stated that I
disrespected the presenter, is that correct?
A. Yes.
Q. Okay. Do you remember -- did the e-mail say it was me?
A. No.
Q. What did it say?
A. From what I recall, it gave a description of the person
that had made a comment and then left. I don't think that the
presenter knew who you were; and after some investigation, I
discovered that it was you.
Q. And tell us about this investigation.
A. From what I recall, I spoke with -- or I looked at the
sign-in log. I asked for some clarification from the presenter
and from the special education director at the time, and from
the description that I could glean, it was you.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. Was my name ever stated by anybody?
A. I don't -- I don't understand, sir.
Q. In your investigation to try to figure out who this person
was that disrespected the presenter, did anybody say it was
Brian Vukadinovich? Did anybody say that to you?
A. It is possible. I don't -- I don't know.
Q. The person that actually sent the e-mail didn't say it was
me, correct?
A. That's true.
Q. And you don't know if anybody else said it was me?
A. It could have happened. I don't know.
Q. Okay. Did you know all the people that work in the
Hanover building?
A. Yes, I know most of them.
Q. Do you think it would have been hard to find out if it was
me or anybody else?
A. No.
Q. Mr. Biggs, I'm gonna show you Plaintiff's Exhibit No. 13
[verbatim] and ask you to describe that, identify it.
A. That looks like a message from me to Candi Cress and
copying Carol Kaiser and Jane Winkoff, subject is regarding
"your failure to respond." Candi -- yes, I do recognize it as
an e-mail.
Q. You said the subject is, "your failure to respond" --
THE COURT: Is this in evidence?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
MR. VUKADINOVICH: Yes, it has been, Your Honor.
THE COURT: Okay.
MR. VUKADINOVICH: It is 113.
THE COURT: Let me just display it for the jury then,
so they can follow along.
MS. BUGALLA: Is that 13, Mr. Vukadinovich?
MR. VUKADINOVICH: 113.
MS. BUGALLA: 113.
BY MR. VUKADINOVICH:
Q. Who was trying to get a response?
A. I don't understand.
Q. You said this is an e-mail about a response. Who was
trying to get a response?
A. An e-mail -- e-mail messages are about responses. I don't
understand.
Q. Now, what is she telling you in this e-mail, Ms. Cress?
A. Ms. Cress?
Q. Yes.
A. It looks like she's saying FYI, and she's forwarding me
this message.
Q. Okay. And then did you respond back to Ms. Cress?
A. Yes.
Q. And then what was your response?
A. You want me to read it?
Q. Yeah, please read it.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
A. "Candi, I'm so sorry to have brought you into this issue.
I believe, though I need to confirm with Carol, that you
needn't respond. I tried you yesterday, but it was after
hours. Is there a good time to call."
Q. Okay. So are you telling Candi Cress that she needn't
respond back to me about my concerns about what was happening?
A. I'm saying that I believe, though I need to confirm with
Carol, that she needn't respond.
Q. Okay. And then did you also tell her specifically -- did
you say to her that you're sorry that you brought Cress into
the issue? Did you say that in the e-mail?
A. That's implied, yes.
Q. Well, did you say that in the e-mail?
A. No.
Q. You did not say, I am so sorry to have brought you into
this issue, with an exclamation mark after it?
A. I did say that.
Q. Okay. So you said that you brought her in, correct?
A. Like I said, that's implied in what I'm saying. I'm so
sorry to have brought you into that issue, yes, that implies
that it was me.
Q. What were you sorry about?
A. Because she sent -- you sent her several messages that
were haranguing, disparaging, and, I felt, intimidating.
Q. Was I asking her about who this presenter was?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
A. I don't recall.
Q. Take a look underneath where it says, "Dear Mrs. Cress."
Read the first five sentences there.
A. It says, "Dear Mrs. Cress. As you know, I sent you an
e-mail on May 25, 2012, regarding an e-mail you sent to Mr.
Biggs on May 15, 2012, wherein you made certain accusatory
statements that have resulted in severe admonishments and
threat of job action against me."
Q. Okay. Just for a second, I want to stop you there. Is
there anything disparaging about that sentence?
A. You want me to characterize the sentence?
Q. You said that the e-mail was disparaging, and was there
anything disparaging -- I'm asking her about these accusations
that are being made, correct?
A. There's a couple questions there. I'm not sure how to
answer.
Q. Was that first sentence disparaging?
A. When -- yes. When you say that she made certain
accusatory statements that have resulted in severe
admonishments and threat of job action against me, that's
disparaging.
Q. Did she make any accusatory statements?
A. I'm sorry?
Q. Did she make any accusatory statements?
A. No.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. Did I get called in -- you called me in on a discipline
for it off her e-mail, did you not?
A. No.
Q. We didn't have a meeting over that?
A. We did.
Q. Did you call me in for a meeting?
A. I did.
Q. Was it a disciplinary meeting?
A. It was not.
Q. The e-mail wouldn't say disciplinary meeting at the top?
A. The e-mail said it may be disciplinary.
Q. But you're saying it wasn't disciplinary?
A. That's correct.
Q. Okay. Did you ever find out who this person was that
abused the presenter?
A. You're assuming that there was someone who abused a
presenter, and I disagree with that.
Q. Didn't you call me in for that?
A. I didn't call you in to accuse you of abusing someone.
Q. Was there any other incidents after that?
A. After our May 22 meeting, there was another incident that
involved the -- whether or not you had administered a final
exam to all students at the allotted time.
Q. You remember the date of that?
A. It was around June 6, June 7; that was when our meeting, I
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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believe, was.
Q. Was there anything that happened before that?
A. Lots of things happened before that. I don't understand
what you're asking.
Q. Tell us what they were.
THE COURT: You need to be specific. To just say,
what happened, in a three week period of time doesn't help him
in what you're trying to get at.
BY MR. VUKADINOVICH:
Q. Did anything happen on May 11? Was there an incident on
May 11.
A. Was there an incident on May 11?
Q. Uh-huh.
A. Can you please be more specific.
Q. Did you walk in -- did you know that I was having a
meeting with Ms. Kaiser on May 11?
A. Did I know ahead of time?
Q. Yeah.
A. I can't recall.
Q. Okay. Did you -- do you recall ever coming into the
meeting I was having with Ms. Kaiser?
A. I do.
Q. Okay. Do you remember if that was May 11?
A. Yes, it was.
Q. Okay. Well, how did you know about that meeting with
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Ms. Kaiser?
A. I must have heard about it from someone at the time.
Q. You know who that was?
A. I don't recall.
Q. Okay. And were you actually allowed to be in that
meeting?
A. Looking back, no, I was not.
Q. Okay. Well, looking forward, before the meeting, did you
check out -- did Ms. Kaiser tell you to come to the meeting?
A. No.
Q. So you just came on your own?
A. I did.
Q. And you knew I was in there with Ms. Kaiser, correct?
A. I did.
Q. Okay. And do you know why I was in there with Ms. Kaiser?
A. I know now.
Q. You didn't know at the time?
A. I don't think I was specific on exactly why you were
meeting.
Q. Okay. And what is it -- you said you know now. What was
the meeting?
A. I believe that you were discussing your continued
employment with Ms. Kaiser.
Q. Well, actually, not continued employment, correct?
A. Yes.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. You made a decision for my employment not to continue,
correct?
A. I issued the letter that talked about a preliminary
decision, yes.
Q. Okay. And then that was my discussion with Ms. Kaiser as
you say, correct?
A. As I said, I was there for about 10 seconds and then I
left, so from looking back at the records, yes.
Q. Okay. Exactly what happened when you came into the room
when I was with Ms. Kaiser? Exactly what happened?
A. I entered the room. I asked Ms. Kaiser if she needed me
there. And you made some comments that were accusatory, maybe
loud, certainly not very kind, and saying that I needed to
leave.
Q. What were the comments?
A. I don't recall.
Q. Ms. Kaiser say anything to you?
A. She said I needed to go.
Q. You were told to leave by the superintendent, correct?
A. That's correct.
Q. Did you get in trouble for that?
A. I don't know what you mean.
Q. Did you get reprimanded for coming into a meeting that you
weren't supposed to be in?
A. No.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
Q. Did I? Did I get in trouble for it?
A. I don't think so.
Q. This has been previously admitted as Plaintiff's Exhibit
40. What is this document, Mr. Biggs?
A. It is a letter to you from Ms. Kaiser May 15th.
Q. Of 2012, correct?
A. Yes.
Q. And then on the bottom there, did you receive this letter?
A. Yes.
Q. Okay. And then does it talk about the incident on May 11
in the administration building?
A. It mentions an incident on May 11, yes.
Q. Is it fair to say that's the incident when you came into
the room?
A. Yes.
Q. Okay. Now, was there a threat against me in this letter?
A. No.
Q. Did it state in the letter that any further incident in
the above regard will result in a recommendation for
administrative leave?
A. That's what it says, yes.
Q. Is that a threat of adverse job action, administrative
leave?
A. (No response.)
Q. Would that be a threat of adverse job action to say to an
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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employee you may be placed on administrative leave out of your
job, administrative leave? Would that be adverse job action?
A. You've asked a couple of questions there. I'm not sure
how to answer.
Q. Would the threat to an employee of an -- being placed on
administrative leave be considered an adverse job action?
A. I can't guess.
Q. Now, you're a principal -- you're an administrator in an
Indiana public school system, correct?
A. Yes.
Q. Have you ever heard the term "administrative leave"?
A. Yes.
Q. What is that?
A. It can mean a variety of different things. It could mean
anything from a conference to a sickness to some separation of
time during which an investigation takes place.
Q. And could it be for behavior; a penalty, a consequence?
A. I think it goes with whatever consequence comes, but
typically it is kind of a stay-put provision that comes when
there's an investigation going on.
Q. Well, in the context of this letter that you received a
copy of here, in that context, was this for a behavior thing, a
threat?
A. I don't understand.
Q. When the superintendent, Ms. Kaiser, is telling me --
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she's talked about the incident in my classroom that you came
into, the incident in the office that you came into, and an
incident in the library, three separate incidents, and she's
saying to me that because of those incidents and anything
further that happens like that that it will result in
administrative leave to me, would you consider that to be
adverse job action, a penalty that I have been threatened with?
A. No.
Q. Is that something -- would you be happy to receive a
letter from your superior saying, all of this conduct here,
anything further, you're gonna be put on administrative leave?
Would you be happy to receive a letter like that?
A. I can't guess.
Q. Now, the letter you gave me for your decision -- you made
the decision, correct?
A. Yes.
Q. Okay.
A. Well, I made the preliminary decision.
Q. Was that also made in conjunction with Ms. Kaiser?
A. She sent me the letter.
Q. She actually sent you the letter?
A. Uh-huh.
Q. Okay. And then did the letter -- what did the letter say
to me?
A. I would have to have it up on the screen. I don't want to
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misquote.
Q. Was it a justifiable decrease in the number of teaching
positions?
A. Again, I can't guess without having it in front of me.
Q. Did you have any discussions with Ms. Kaiser about class
sizes in the schools at Hanover Central?
A. Yes.
Q. Did you have any discussions particularly about my
classes?
A. Yes.
Q. And what were those discussions?
A. They varied. We talked about enrollment. We talked about
the scope of the course. We talked about CTE, the career and
technical education. We talked about funding for different
courses. We talked about career preparation. I think that
was --
Q. Yeah, I'm gonna stop you for just a second. In terms of
actual numbers for the classes, what was talked about?
A. The numbers of yours and all classes that were on the
master schedule in terms of students' interest in taking those
courses.
Q. Okay. And what was talked about? What was said?
A. I explained --
Q. Was there a number given for we have to have so many
students in a particular class?
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A. No.
Q. There was no number at all for my class?
A. No.
Q. Okay. So was there any criteria at all for -- to decide
as to whether or not my classes should continue or not continue
due to a class size number? Was there any criteria for that?
A. You're putting things into the question that I don't agree
with so I can't answer.
Q. Well, you may not agree with it, but I'm asking you the
question. Was there any criteria, was there anything stated by
Ms. Kaiser to you or to you to Ms. Kaiser where it was stated,
this is what has to happen for this class to continue or not
continue in terms of numbers of students?
A. I don't understand.
MR. VUKADINOVICH: Judge, I don't know how to be more
clear about it.
THE COURT: He's saying he doesn't understand the
question, so maybe you can try to break it up. I don't know.
BY MR. VUKADINOVICH:
Q. Did you have any discussion about student numbers for my
classes?
A. Yes.
Q. Okay. And what were those discussions?
A. What the numbers were? I mean, there were lots of
conversations about yours and other classes with respect to
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student course requests and where those would fit in which time
slots.
Q. Was there ever a specific number that was stated that said
we have to have this number of students for this class to
continue?
A. No.
Q. Now, I taught the Project Lead the Way classes at the
middle school, is that right?
A. Yes.
Q. Did you know about my Project Lead the Way training when
you were the principal there?
A. No.
Q. I'm looking at Plaintiff's Exhibit No. 80. Excuse me.
Yes.
THE COURT: Is this in evidence, Noel?
DEPUTY CLERK: (No response.)
MR. VUKADINOVICH: No, it is not.
MS. BUGALLA: I'm sorry. What number is this?
MR. VUKADINOVICH: This is No. 80.
MS. BUGALLA: Eighty.
BY MR. VUKADINOVICH:
Q. Could you please describe that.
A. It is an e-mail message from me to Dana Bogathy.
Q. And then what is the date of it?
A. April 3, 2012.
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Q. And what are you asking her?
A. I'm asking, "Is Brian Vukadinovich, do you know, trained
to teach PLTW?"
Q. And why were you asking her that?
A. We were looking at high school course requests and
accommodating those as far as I can tell.
Q. And did you get an answer?
A. I don't recall.
MR. VUKADINOVICH: I move to admit Plaintiff's
Exhibit No. 80.
MS. BUGALLA: No objection.
THE COURT: Eighty is admitted.
(Plaintiff's Exhibit No. 80, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. You don't remember if she answered you back?
A. I don't recall.
Q. Okay. I'm looking at Plaintiff's Exhibit No. 81. It
hasn't been admitted.
THE COURT: Has not?
MR. VUKADINOVICH: Has not.
THE COURT: It might be helpful to try to admit the
exhibit, so when you are asking the questions the jury can have
an opportunity to follow along with you if it does get
admitted.
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MR. VUKADINOVICH: Okay.
BY MR. VUKADINOVICH:
Q. Could you please describe it.
A. Sure.
It is an e-mail message from me to Michelle Davlantis
May 1, 2012.
Q. And then I'm gonna take you to the first paragraph.
THE COURT: Are you gonna have an objection to this?
MS. BUGALLA: I'm looking at it.
THE COURT: Okay. Just take a minute to look at it
and that way the jury can follow along if you don't have an
objection.
MS. BUGALLA: Your Honor, I don't believe I have an
objection depending, of course, on how Mr. Vukadinovich tends
to use it. On the face of it, I don't.
THE COURT: Are you gonna offer it?
MR. VUKADINOVICH: Yes, Your Honor.
THE COURT: What number is it?
MR. VUKADINOVICH: It is No. 81.
THE COURT: All right. It is admitted. I will
display it for the jury. Go ahead.
(Plaintiff's Exhibit No. 81, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Mr. Biggs, in the first paragraph, it is starting at the
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third line where it says, "Arden Smith and Brian Vukadinovich,"
do you see that?
A. I do.
Q. What does that say?
A. That says -- do you want me to read the sentence?
Q. Yes.
A. It says, "Arden Smith and Brian Vukadinovich are currently
involved with the engineering branch of PLTW, so they a couple
of good options."
Q. So she's telling you that I would be a good option to be
what?
A. (No response.)
Q. To be what?
A. I'm just reading the sentence. I don't have the context.
Q. Yeah. It's in the second sentence on the top.
A. Are you asking me to do something?
Q. Yeah. Well, what is she telling you that I would be a
good option for?
A. It looks --
THE COURT: Just take a moment to read it to
yourself.
THE WITNESS: Okay. Thank you.
THE COURT: Yeah.
THE WITNESS: Okay.
THE COURT: What's your question, sir?
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BY MR. VUKADINOVICH:
Q. What is she telling you that I would be a good option for,
to be what?
A. In that paragraph it is saying that you would be a good
district delegate.
Q. For what?
A. For PLTW, Project Lead the Way.
Q. Okay. And then what was the date of that document?
A. That's May 1.
Q. Is that the day before you gave me the termination letter?
A. Yes.
Q. So you're being told that I would be a good option for
district delegate for Project Lead the Way and then you
terminated me the following day, is that correct?
A. Yes.
Q. Was there a mess going on with the student enrollment with
the students for the following school year, the 2012-2013
school year?
A. I don't understand.
Q. There is a registration process with the students
registering for classes, correct?
A. Yes.
Q. Were you involved in that process?
A. Yes.
Q. Was there a mess going on?
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THE COURT: What do you mean? He doesn't understand
what you're talking about, "was there a mess?" That's too
ill-defined. You need to be specific.
BY MR. VUKADINOVICH:
Q. Were there problems going on to the point with
registration that you had to have discussions with the guidance
counselor?
A. There were problems.
Q. Yes.
A. There were -- yes. I did have discussions with the
guidance counselor.
Q. How about with any other administrators? For example,
Mr. Brooks. Did you have any discussions with him?
A. Yeah. Yes, I did.
Q. Did you specifically call him in to discuss the problems
with the student registration?
A. I don't recall.
Q. Okay. And were the problems with the students becoming
registered for the classes?
A. Could you rephrase the question. I'm not sure.
Q. The problems with the registration process, were there
problems with the students getting registered for classes for
the following school year, 2012-2013?
A. No more than usual. I think that -- problems, I think, is
severe to characterize that. I mean, we had course requests,
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and we were accommodating those. We were working them through
the schedule. You know, part of administration is dealing with
problems and finding solutions; so in answer to your question,
yes.
Q. And did you terminate the guidance counselor over the
problems with the registration?
A. I did not, no.
Q. Did you recommend termination?
A. I did not.
MR. VUKADINOVICH: I'm sorry. Excuse me.
BY MR. VUKADINOVICH:
Q. Did there come a time that you allowed another teacher to
put posters up around the school building to create interest
for students to sign up for his classes?
A. Yes.
Q. Who was that teacher?
A. Jason Yurechko.
Q. Who?
A. Jason Yurechko.
Q. These were previously admitted yesterday as No. 48. Is
that your signature on the bottom of that poster?
A. Yes.
Q. And then what were you approving?
A. That flier.
Q. And were there several different fliers?
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A. Yes.
Q. Okay. And you were approving the students to come in and
sign up for Mr. Yurechko's classes today, is that correct?
A. Yes.
Q. Okay. Was there a problem with Mr. Yurechko's enrollment
numbers in his classes?
A. His enrollment numbers could have been better. Was it a
problem, no.
Q. Did you fire him?
A. No.
Q. Could my enrollment numbers have been better?
A. Yes.
Q. Did I get fired?
A. Yes.
Q. Did I ask you to let me put the posters up around the
building?
A. You did.
Q. Did you let me?
A. No.
Q. Did I ask you to let me get on the PA system like you let
Mr. Yurechko?
A. Yes.
Q. Did you let me?
A. No.
Q. Why not?
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A. Your courses were already discontinued.
Q. So it was a done deal?
A. Pending Board action; but according to the schedule, they
were taken out of the course schedule.
Q. Okay. Pending Board action. Did you discuss that with
Ms. Kaiser?
A. Yes.
Q. What did she tell you?
A. I don't understand what you're asking.
Q. Did Ms. Kaiser tell you that it was a done deal that my
classes -- he can't do the posters and so forth because we're
not going to have his classes?
A. No.
Q. So why didn't you let me put the posters out?
A. Because your classes weren't on the schedule.
Q. But why weren't they on the schedule?
A. Because they were taken out.
Q. Why? Why were my classes taken out?
A. Because of the preliminary notice to discontinue your
contract for the next year.
Q. But what's the reason for that? Why did I receive that
preliminary notice? Why were my classes taken off the
curriculum?
A. In answer to your question, there were a lot of reasons
why your classes were discontinued. One of them was that the
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courses that you taught did not adequately prepare students for
careers, college, et cetera.
Q. Did you say that to me in the notice letter that I got?
You're gonna be fired because the courses you taught didn't
prepare the middle school -- did you say that to me in the
notice letter?
A. No.
Q. When is the first time that came up?
A. I don't recall.
Q. What else?
A. Don't understand your question.
Q. What were the other reasons that my courses weren't
continued?
A. Those were the reasons.
Q. You said there were many reasons.
A. Those were them.
Q. This is Plaintiff's Exhibit No. 100. It is an e-mail from
--
THE COURT: I want to make sure it is in evidence,
ladies and gentlemen.
MR. VUKADINOVICH: This one is not.
THE COURT: Okay. Proceed.
BY MR. VUKADINOVICH:
Q. So could you please describe that. Identify it.
A. Sure. It's an e-mail message from Karleen Adler to me.
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I'm copying Jennifer Grcich.
Q. You received that e-mail, correct?
A. It appears so, yes.
MR. VUKADINOVICH: I move to admit Plaintiff's
Exhibit 100.
THE COURT: Any objection to 100?
MS. BUGALLA: No objection, Your Honor.
THE COURT: All right. It is admitted. I'll display
it for the jury. You may proceed.
(Plaintiff's Exhibit No. 100, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Okay. Now, what is the e-mail all about?
A. I would have to read it. If you give me a moment, I'll do
that.
It appears that Ms. Adler is referencing a couple "issues"
as she says.
Q. Well, specifically, what is the subject of the e-mail?
What does it say for subject?
A. "Student counts."
Q. Student counts. Let's take a look. Is there a list of
teachers down there?
A. There is.
Q. What does the list demonstrate?
A. It is a list of teachers. That's as much as I can guess.
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Q. And then is it about student counts?
A. I would presume so given the subject title.
Q. You didn't follow-up on that e-mail?
A. I don't recall.
Q. Okay. Does it say, "Yurechko, first hour"?
A. It does say that.
Q. For student counts, correct?
A. Yes.
Q. Did he get fired?
A. No.
Q. Does it say, "Szanyi, third, sixth, and seventh hour,"
three periods?
A. Yes, it does.
Q. Did he get fired?
A. No.
Q. Does it say, "Lechien, fifth hour"?
A. Yes.
Q. Did he get fired?
A. Yes.
Q. For that?
A. No.
Q. How about Mr. Landis, is his name on there?
A. It is.
Q. He get fired?
A. No.
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Q. Of course my name is on there for removed, right?
A. It shows, "SRT, remove."
Q. How about Mosak, is her name on there?
A. It is.
Q. Does it say for first and second semester?
A. It looks -- it doesn't say first and second semester, no.
Q. It does not say first and second semester?
A. No.
Q. By Mosak?
A. No.
Q. Oh, "first hour, second semester"?
A. Yes.
Q. Did she get fired?
A. Not as far as I know.
Q. How many teacher's names are on there?
A. Do you want me to count everyone in the subject title too
or no?
Q. I asked how many teacher's names are on there for the
actual subject where it is talking about the student count
issues.
A. One, two, three, four, five, six.
Q. Out of those six teachers that are listed with student
count issues, how many of them got fired?
A. Two.
Q. For student count issues. Not for anything else, about
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anything else that might have happened, about something else.
For student issues, how many got fired?
A. I don't understand the question.
Q. Of these teachers how many got fired because there was a
problem with student counts in their classes?
A. Zero.
Q. I didn't?
A. You're asking me something that I dispute in your
question, so I can't answer that.
Q. So you're saying I didn't get fired because of the student
numbers in my classes?
A. That's correct.
Q. Student numbers didn't have anything to do with it?
A. That's not correct.
Q. You said it's correct but it's not correct. Did student
numbers in my classes, was that a reason that was used to get
me fired?
A. Yes.
Q. So out of that list of six, how many teachers got fired
for that?
A. Zero.
Q. Out of that list of six how many teachers got fired for
student count issues?
A. Zero.
Q. Not me?
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A. Not you.
MR. VUKADINOVICH: I move to admit 100 here.
THE COURT: I think it has been admitted already but
maybe not. Do you object to 100 if it hasn't been admitted.
MS. BUGALLA: No, Your Honor, I don't object.
THE COURT: If it hasn't been admitted, it is now.
MR. VUKADINOVICH: Thank you.
THE COURT: Mr. Vukadinovich, about how much longer
do you think you are going to have with this witness on --
MR. VUKADINOVICH: It is probably an hour.
THE COURT: Okay. You can keep going. We are gonna
break in 10 minutes.
BY MR. VUKADINOVICH:
Q. This is Plaintiff's Exhibit No. 99. It has not been
admitted. Could you please describe that.
A. It is a document that shows PowerSchool at the top. It is
hard for me to read much else. It says, "Teacher Schedule,
Spencer, Ryan."
Q. Okay. And for what school year was that?
A. I don't know.
Q. It is real hard to tell on there. Underneath where it
says "term," do you see where it says "term"?
A. No.
Q. Okay. Second column?
A. Yes.
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Q. Okay. Can you make out if it says "12-13"?
A. It looks like it says "12-13."
Q. You'd take my word for it if I said it was 12-13?
A. I would say so.
Q. Okay. I'm gonna direct your attention over to where it
says "enrollment" over to the right side?
A. Uh-huh.
Q. All right. Now, for this particular teacher is -- did he
have a class with zero students?
A. Who?
Q. This particular teacher Ryan Spencer.
A. I can't tell.
THE COURT: Would you give him the document because
it is just difficult to look at it on the screen?
MR. VUKADINOVICH: Yes.
BY MR. VUKADINOVICH:
Q. I'm sorry.
A. Okay. It looks like in the enrollment column for this
particular printout it shows a variety of numbers. Your
question was were there any of these rows and lines that showed
zero in the enrollment column? Yes.
Q. Is there any numbers in there with nine students in them?
A. Yeah, it looks like.
Q. Anything under nine students?
A. There's one that's six. There's one that's four.
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Q. So we have zero, nine, six, four students in a class,
correct?
A. If I recall what I just said correctly, then yes.
Q. That teacher get fired?
A. No.
MR. VUKADINOVICH: I move to admit No. 99, Your
Honor.
MS. BUGALLA: No objection.
THE COURT: All right. It is admitted.
(Plaintiff's Exhibit No. 99, previously marked, was
admitted in evidence.)
THE COURT: Mr. Vukadinovich, just to remind you,
once they've been admitted, I want them up here so we can track
which ones have been admitted and which ones haven't.
MR. VUKADINOVICH: Yes, Your Honor.
THE COURT: So this is a repository for those,
please.
MR. VUKADINOVICH: Yes, Your Honor.
BY MR. VUKADINOVICH:
Q. This document number 98 has not been admitted. Would you
please describe that document.
A. It appears to be a fax, although I can't say for sure. It
looks like maybe an e-mail message.
MR. VUKADINOVICH: I'm gonna hand it to the witness,
okay?
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THE COURT: Sure.
(Document tendered.)
THE WITNESS: Okay.
BY MR. VUKADINOVICH:
Q. What does the document say?
A. It says, "Begin forwarded message. From, Justin Biggs.
Date, July 4, 2012. To, Dana Bogathy. Subject, regarding info
for software."
I state, "There are 12 students in biotech, 25 or so in
biomed."
Then, "Happy Fourth of July. Justin."
Q. Okay. Now, you received that, correct?
A. Well, I sent that.
Q. Okay. You sent it. So you are telling somebody there's
12 students in a class, correct?
A. It appears so, yes.
Q. That teacher get fired?
A. Could I have a look -- can you put it on the screen again.
I'm not sure which teacher it was.
Q. (Complied.)
A. No.
MR. VUKADINOVICH: I move to admit No. 98, Your
Honor.
MS. BUGALLA: No objection.
THE COURT: Ninety-eight is admitted.
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(Plaintiff's Exhibit No. 98, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. This is document number 85. It has not been admitted.
Could you please describe that.
A. That's an e-mail from me to Nicole Satterfield, Thursday,
May 3, 2012. There it is.
Q. Okay. And did you actually -- is that a back and forth
between you and Nicole Satterfield?
A. I don't understand what you mean by back and forth.
Q. Is this an e-mail string -- on May 3 there are several
e-mails between you and Ms. Satterfield?
A. It appears that there's a dialogue there, yes.
Q. Okay.
MR. VUKADINOVICH: I move to admit Plaintiff's
Exhibit 85.
MS. BUGALLA: No objection.
THE COURT: All right. It is admitted.
(Plaintiff's Exhibit No. 85, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Okay. Now, what is -- is Ms. Satterfield the guidance
counselor?
A. She is not.
Q. At the time she wasn't?
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A. At the time she was.
Q. But she's not now, correct?
A. Correct.
Q. Did she get terminated?
A. Yes.
Q. Okay. Now, is she telling you that a certain number of
students are requesting my classes?
A. Yes.
Q. Okay. And then what did you tell her?
A. I said, "Yes, we need to counsel them into other classes."
Q. But she's telling you they want my classes, is that
correct?
A. It says, "Fourteen students requested transportation
systems and construction systems."
Q. And are those the classes that I taught?
A. Yes.
Q. Okay. And you told her to put them in other classes,
correct?
A. That's correct.
Q. Okay. Well, those numbers there, 14 for the one and 15
for the other one, are those higher numbers than some of those
other teachers that had six, nine, and zero in their classes?
A. Is 14 higher than six or nine or others, yes.
Q. And those teachers didn't lose their jobs though, correct?
A. Some --
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Q. For the student numbers?
A. Correct.
Q. Okay.
MR. VUKADINOVICH: Has that been admitted, 85?
THE COURT: Yes.
BY MR. VUKADINOVICH:
Q. How many years were you the principal at Hanover Central?
A. Three.
Q. How many full-time teachers did you make a decision to
terminate, full-time teachers?
A. Full-time?
Q. Yes.
A. One.
Q. Who was that?
A. You.
THE COURT: Is this a convenient spot to break for
you, Mr. Vukadinovich?
MR. VUKADINOVICH: It would be, Your Honor.
THE COURT: We're gonna take our lunch recess at this
time. Remember the admonitions I've been giving you during the
trial. Don't discuss the case amongst yourselves over the
lunch break. Of course, you have to continue to keep an open
mind. We'll pick back up here at 1:15. We'll pick up at that
time.
(Jury out at 12:01 p.m.)
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THE COURT: You may step down.
THE WITNESS: Thank you.
THE COURT: All right. Just be back here by 10 after
one just in case there's any issues you want to take up before
the jury gets in here at 1:15.
MR. VUKADINOVICH: Thank you, Your Honor.
(A recess was had at 12:02 p.m.)
(The proceedings resumed in open court, reported as
follows:)
DEPUTY CLERK: All rise.
THE COURT: You can be seated. Everybody ready to
proceed?
MS. BUGALLA: Yes, Your Honor.
THE COURT: You ready to go, Mr. Vukadinovich?
MR. VUKADINOVICH: Yes, Your Honor.
Your Honor, just for a minute, could we set some kind of a
timetable as far as so we can get the things concluded and so
forth so we know exactly the time factors that are gonna be
involved? What I would like to request, Your Honor -- I really
would like to be able to have tomorrow. I've still got several
witnesses and so forth that are really very important, and if I
could have tomorrow -- I mean, I'm gonna promise you --
THE COURT: You mean take the day off?
MR. VUKADINOVICH: No, no. I mean for me to have
tomorrow for my part of the case.
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THE COURT: Yeah, absolutely.
MR. VUKADINOVICH: Okay. I just wanted to make sure.
THE COURT: I mean, I think you're moving things
along.
MR. VUKADINOVICH: Okay.
THE COURT: Here is the thing: You are doing fine,
but you are belaboring things. You don't have to continue to
say things over and over again. These are smart people, you
know, so --
How long do you think your case is gonna take?
MS. BUGALLA: Part of a day.
THE COURT: Okay. So we're gonna get this done this
week, right?
MS. BUGALLA: Oh, I hope so. I hope so.
THE COURT: So who do you have left besides
Mr. Biggs? We'll finish up with him. You're gonna call
Ms. Kaiser?
MR. VUKADINOVICH: Ms. Kaiser and then -- actually,
after Mr. Biggs, I'm gonna call Mr. Landis.
MS. BUGALLA: Can I just say something?
THE COURT: Sure. You asked us to have Mr. Hiatt
here.
MR. VUKADINOVICH: Yes.
MS. BUGALLA: And he is here.
MR. VUKADINOVICH: I intend to put him on.
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MS. BUGALLA: Okay. Just saying.
MR. VUKADINOVICH: And then Mr. Landis. Ms. Adler
who's a former employee, briefly, put her on. Mr. McCray,
former principal, briefly put him on, and then Mr. Hiatt. My
plan is to have those people finish today.
THE COURT: Okay. Well, we'll see how it goes.
MS. BUGALLA: I would just hate for Mr. Hiatt to have
to come back.
THE COURT: I'm gonna instruct you to put Mr. Hiatt
on next just to verify -- so we get him out of here.
MR. VUKADINOVICH: Yes, Your Honor.
THE COURT: Okay.
MR. VUKADINOVICH: Yes.
THE COURT: You willing to do that?
MR. VUKADINOVICH: Absolutely.
THE COURT: Okay. Mr. Biggs, you want to come on
back up here.
And, Carlos, if you want to call the jury.
(Jury in at 1:18 p.m.)
THE COURT: All right. You may be seated.
All right. Mr. Vukadinovich, you may continue with your
direct examination.
MR. VUKADINOVICH: Thank you, Your Honor.
JUSTIN BIGGS, PLAINTIFF WITNESS, SWORN
DIRECT EXAMINATION - RESUMED
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BY MR. VUKADINOVICH:
Q. Mr. Biggs, you had earlier testified that you actually
came into the room -- you entered the room when I was having my
due process meeting with Ms. Kaiser.
A. Yes.
Q. So did you actually -- you came into the room then,
correct, so there's no question about that?
A. Yes.
Q. Okay. Did you hear your attorney yesterday tell the jury
in the opening statement that you peeked your head into the
room?
A. Yes.
Q. Was that true?
A. Yes.
Q. But didn't you testify under oath that you actually came
into the room?
A. Yes.
Q. Which one was it?
A. It is the same thing.
Q. The same thing as peeking your head in as opposed to
coming into the room?
A. My head and body was in the room.
Q. Okay. So you didn't just peek your head in, so we're
clear, you came -- your whole body came into the room?
A. Yes.
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JUSTIN BIGGS- DIRECT
Q. What areas -- as principal, my supervisor, did you know
what areas I was able to teach -- that I was licensed for?
A. Yes.
Q. What were they?
A. Drivers ed instruction and industrial arts. I also was
aware that you were teaching middle school Gateway to
Technology, which is the same thing as Project Lead the Way at
the middle school.
Q. When you say industrial arts and you said construction,
there are actually a number of classes under industrial arts,
isn't that correct?
A. I didn't say construction.
Q. I might have misheard. I thought you did. I thought you
did. If you didn't, that's fine. So what classes would be
included under industrial arts?
A. There are a variety of classes. The State publishes a
grid of the licenses and the subjects that a teacher with that
license can teach. Without having that in front of me, I can't
give you an exhaustive list of those classes.
Q. Actually, there is no such thing as industrial arts
anymore, is there?
A. I'm not aware of that.
Q. It is industrial technology, instructional technology?
A. I'm not aware of that.
Q. Okay. That's fine.
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Was there an opening for the 2012-2013 school year for an
instructional technology teacher?
A. Not that I know of.
Q. Was I licensed to be an instructional technology teacher?
A. I don't know what course you're referring to. I'd have to
know that, and I'd have to have the course number for that to
match up to your license and then match that to the grid that
the state publishes without being able to say for sure if you
can teach that class.
Q. Okay. If there was -- you are not aware if there was a
technology teacher opening for the following school year?
A. I don't know specifically what technology means in this
case to be able to say whether or not there was an opening for
that position.
Q. If there was an opening for that position, would you as
the principal have been -- part of your job responsibilities
would be to find a person to teach that position that was
licensed for the position?
A. It was my duty as principal to place staff appropriately,
yes.
Q. And then would it be your duty as a principal if there was
an opening there and there was already a teacher there within
the corporation to teach that class, would you investigate that
teacher teaching that class if he was licensed for that class?
A. I don't understand, sir.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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Q. If there was an opening for a technology teacher, would it
be your duty that if there was a teacher within the corporation
that was already employed in the corporation that was qualified
for that class, would you consider that teacher to teach that
class if you had one there already with that license that
wanted to teach that class?
A. Again, it is hard for me to answer the question. I don't
understand.
Q. If there was a technology position open, a teaching
position for the following school year, and you had at Hanover
Central somebody that was licensed to teach that course and
would have taught that course, would you have had a duty as the
principal then to pursue that with that teacher?
A. Yes.
Q. Okay. This is not an admitted exhibit. It is Plaintiff's
Exhibit No. 82. Would you please describe that.
A. Okay. It is a message from --
MS. BUGALLA: What number? I'm sorry.
MR. VUKADINOVICH: It's 82. Eighty-two.
THE WITNESS: It is a message from me to Susan
Kounelis and Carol Kaiser regarding instructional technology
teacher.
BY MR. VUKADINOVICH:
Q. And what are you asking Miss Kounelis?
A. I'm asking her to jot down a reminder to create a posting
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
for the above.
Q. Does that mean that there was going to be a position?
A. I would say yes.
Q. Okay. And then what was the date of that e-mail?
A. April 9.
Q. Of what year?
A. Of 2012.
Q. Okay. And is that actually about three weeks before you
gave me my decision that you were going to terminate my
employment?
A. That is one --
Q. I'm sorry?
A. It is several weeks, yes, before then.
Q. It was shortly before that though, correct?
A. Uh-huh. Yes.
MR. VUKADINOVICH: I move to admit Exhibit No. 82,
Your Honor.
THE COURT: Any objection?
MS. BUGALLA: No.
THE COURT: All right. Eighty-two is admitted.
(Plaintiff's Exhibit No. 82, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Am I a technology teacher?
A. I don't know.
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Q. You don't know -- I was under your supervision for the
school year, correct?
A. Yes.
Q. And you knew I was teaching high school and middle school
classes under your supervision, correct?
A. Yes.
Q. Okay. And you don't know what I was licensed to teach?
A. I do know what you were licensed to teach.
Q. What was I licensed to teach?
A. Drivers education and industrial arts under Rules 46, 47 I
believe.
Q. What about instructional technology?
A. I don't believe that was on your license.
Q. Did you check my personnel file?
A. No.
Q. Did you call Ms. Kaiser as the former superintendent and
ask her about what my qualifications were?
A. No.
Q. Do you remember during the testimony here when I submitted
a letter into evidence about when I went to a workshop and was
deemed the technology teacher? Do you remember that?
A. No.
Q. Okay. We'll move on from that right now. But you clearly
did not investigate as to whether or not I would be qualified
for that position, is that correct?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
A. I can't answer that question. It is assuming something I
don't agree with.
Q. I'm sorry?
A. You're assuming in your question something that I disagree
with.
Q. What is it that you disagree with?
A. Part of your question.
Q. What part of the question?
A. Could you repeat the question.
Q. Did you investigate what my qualifications were?
A. Yes.
Q. And did you determine that I was not qualified to teach
the technology classes the following school year?
A. Again, I'm not sure what you mean by "technology classes."
Q. This job that you were talking about here, the
instructional technology teacher position, that's the job I'm
talking about right there.
A. Okay. I don't recall that particular posting.
Q. Well, you don't deny that you sent that e-mail to Susan
Kounelis with carbon copy to Carol Kaiser, do you?
A. No.
Q. Now, I was -- was I RIF'd?
A. Yes.
Q. Under the corporation's guidelines for the -- under the
contract, would I have -- would the corporation have had to
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hire me for that job?
A. I don't know.
Q. This is No. 103 that has not been admitted. Would you
please describe that.
A. That looks like the front cover page that says "Master
Agreement." It goes on to say "between Hanover Organization of
Professional Educators and Hanover Community School
Corporation. January 1, 2008 to December 31, 2009."
Q. Was that in effect at the time that you made the decision
to terminate my employment?
A. My decision was preliminary.
Q. That's not what I asked you.
A. Well, again you are assuming --
MR. VUKADINOVICH: Your Honor, he is not answering my
question. I asked was that --
THE COURT: He had a question about your question.
He was unclear about something so just clarify it.
BY MR. VUKADINOVICH:
Q. Was this master agreement in effect at the time you made
the decision to terminate my employment?
MS. BUGALLA: Your Honor, I'm going to object because
the question assumes something that is not in evidence. It
assumes that Mr. Biggs made the decision to cancel
Mr. Vukadinovich's contract, and he did not make that decision.
THE COURT: Rephrase the question.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- DIRECT
BY MR. VUKADINOVICH:
Q. Are you familiar with what the requirements were if a
teacher is RIF'd from the corporation as to whether or not
there was any kind of a requirement that the corporation would
have to recall the teacher or give the teacher a job that is
open that the teacher is qualified for?
A. I want to answer your question, but I need some clarity on
it. Could you be more specific.
Q. Are you familiar -- as the principal, did you have to be
familiar with what the master agreement said?
A. Yes.
Q. And were you familiar with it?
A. Yes.
Q. Were you familiar with the provision on the policy about
when a teacher is RIF'd what the policy was for what the
corporation's responsibilities were to recall the teacher or to
give the teacher another available position if the position was
open? Are you familiar with that part of the policy, that
contract?
A. I'm familiar with part of what you said but not all.
Q. What is it that you're familiar with?
A. I'm familiar with the RIF process. I'm familiar with the
fact that teachers who are qualified to teach certain courses
who have been RIF'd may be called back if those courses are
then available the following year, having been cut the previous
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year. However, I'm not familiar with any process that places
teachers into those classes without proper certification.
Q. Now, you said the teachers may be called back. Is it they
may be called back or they must be called back under the
contract?
A. They must if they are qualified to teach those courses or
at least be given the option to come back. They don't have to.
MR. VUKADINOVICH: I'm gonna move to admit Exhibit
No. 103, Your Honor.
THE COURT: Any objection?
MS. BUGALLA: Well, Your Honor, the ongoing objection
that a collective bargaining agreement is not at issue in this
case, and so I question its relevance.
THE COURT: Sustained. I don't think it has any
relevance at all to the case. And it has the possibility that
it could confuse the issues to the jury. Whatever marginal
relevance it might have I think just came out in the
questioning with Mr. Biggs. To then introduce the entirety of
the collective bargaining agreement I think has very little
probative value and, again, has a danger of confusing the
issues for the jury. So it is sustained.
MR. VUKADINOVICH: Your Honor, could I respond?
THE COURT: Sure. Why don't you do it at sidebar?
MR. VUKADINOVICH: Your Honor, the letter --
THE COURT: At sidebar.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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MR. VUKADINOVICH: Oh, I'm sorry.
(Bench conference.)
MR. VUKADINOVICH: Your Honor, the letter that Ms.
Kaiser wrote to the school board recommending my termination
stated that it is consistent with the policy. It is right in
her letter to the School Board when she made the recommendation
that it is consistent with the master agreement with the
teachers union; that was part of the termination process.
THE COURT: Okay. And so what are you trying to
offer it to show?
MR. VUKADINOVICH: Because it shows that no matter
what he was gonna make sure that I wasn't gonna be able to come
back to Hanover to teach. No matter what the contract said,
yes or no, you are out of here because I'm retaliating against
you even though the contract --
THE COURT: I don't think -- you've just elicited
testimony from this witness along those lines what the contract
calls for. What I'm saying is that the totality of this
contract, which is about a 30-page document, is not germane to
this case. It's not relevant, and it has -- there's a very
real risk that this jury is gonna confuse the issues. In other
words, they're gonna think that this is a case about their
alleged violations of the collective bargaining agreement;
that's not what this case is about. That wasn't an allegation
in your complaint, or at least a claim in your complaint, and
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so I think it clutters the record and confuses the issues for
the jury. That's my ruling.
MR. VUKADINOVICH: Even about just putting that
particular one page in as opposed to the whole document?
THE COURT: I've ruled. You made your record.
MR. VUKADINOVICH: Okay.
(End of bench conference.)
BY MR. VUKADINOVICH:
Q. As the principal of the school and your familiarity with
what the obligations were of the corporation, was the
corporation required to hire me for a technology position that
was open the following school year that you refer to in that
e-mail?
A. I don't believe so.
Q. And why is that? If I was qualified, you don't believe
that the school should have hired me for that position?
A. Again, you're assuming something that I don't agree with,
and it is difficult to answer that question.
Q. If I was qualified for the position, should the school
have hired me for that position?
A. I can't guess.
Q. Pardon?
A. I cannot make a guess.
Q. I'm not asking you to guess. I'm asking you as the
principal should the school have been required to do that?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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A. I can't speculate.
Q. I'm not asking you to speculate. I'm asking as the
principal to answer the question.
A. It requires me to speculate, and I can't make a guess.
There's a lot of factors that deal with hiring, some that are
specific to license requirements, some that are specific to
interviews, and the best fit for the position. There's a lot
of different factors.
Q. Okay. When you say, "a lot of different factors," could
those factors also be if there was something going on that you
didn't like about the teacher that you just didn't want to let
that teacher have that job, does that also come into play as
those factors?
A. No.
Q. No?
A. (No audible response.)
Q. Okay. This exhibit has not been admitted. It is No. 118.
Could you please describe it.
A. You wanting me to describe it? I'm sorry. I'm reading it
at this moment.
THE COURT: Give him an opportunity to read the
document.
THE WITNESS: It looks like a definition printed
page. Looks like page 1 of 5. It says vaguely at the top,
Hanover Community Schools Bylaws and Policies. It looks like
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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one such policy, specifically, administrative guideline.
BY MR. VUKADINOVICH:
Q. Are you familiar with that policy?
A. Having read over it briefly, I would say yes.
Q. All right. You see on the very bottom what it says there?
What's those two words there?
A. On the very bottom is a website link.
Q. The two words. They stand out.
A. Above that is the two words "due process."
Q. Okay. Are you familiar with that portion of the policy?
MS. BUGALLA: I need to interrupt, and I apologize.
What page are you looking at because what I'm looking at on
your exhibits is not the same as what's showing up, and I want
to make sure.
THE COURT: Will you show her the exhibit, so we are
all on the same page here.
MS. BUGALLA: Are you looking at the first page of
the exhibit?
(Document tendered.)
MS. BUGALLA: Your Honor, we don't have the first
page in the exhibit that Mr. Vukadinovich provided to us.
THE COURT: I have it here. He -- it may have just
not copied.
MS. BUGALLA: I'm just saying I just don't have the
first page.
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THE COURT: Well, what is the first page? Is the
first page the one that says, "Administrative Guidelines" on
the top?
MR. VUKADINOVICH: Yes.
MS. BUGALLA: Is that in your copy?
THE COURT: That's in my copy.
MS. BUGALLA: All right. Then it must not --
THE COURT: It is not in your --
MS. BUGALLA: It is not in our copy.
THE COURT: Take a moment to take a look at it so
that --
(Discussion held off the record between the parties.)
THE COURT: All right. You may proceed.
MR. VUKADINOVICH: Thank you.
BY MR. VUKADINOVICH:
Q. Are you familiar with the due process provision of the
corporation policy?
A. Not specifically with the letter of that particular
guideline, but I am familiar with the idea of due process, yes.
Q. I'm speaking in terms of the actual corporation policy.
Not just per se in general due process but what the corporation
policy was.
A. Not as much as I would like to be.
Q. And also should you be as the principal familiar with the
due process?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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A. I don't know.
Q. Now, when you were trained to be a principal did due
process come into the training? Any classes or anything like
that?
A. Due process certainly was part of the training, yes.
Q. What due process should I have been allowed with the
Hanover Community School Corporation?
MS. BUGALLA: Your Honor, I'm going to object. I
think that is asking this witness to make a legal conclusion
regarding one of the issues pending in this case.
THE COURT: Yeah, I agree. That's really a legal
conclusion that the Court will decide when I instruct the jury
on the meaning of that term.
MR. VUKADINOVICH: Very good.
BY MR. VUKADINOVICH:
Q. All right. I'm gonna draw your attention to the top where
it starts off, "Procedural due process." Have you ever read
that before --
A. No.
Q. -- as the principal at Hanover?
A. No.
Q. Do you feel as the principal of Hanover that you should
have been familiar with the corporation's due process policy?
A. You're asking something that I disagree with as part of
your question. In answer to that, I am familiar with due
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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process. I'm not familiar with that particular statement and
policy.
Q. As the principal, don't you have to follow the
corporation's due process policy?
A. Yes.
Q. And yet you're not familiar with what the corporation's
due process policy was, correct?
A. Not correct.
Q. Not correct?
A. Correct.
Q. Correct that you are not familiar with it?
THE COURT: All right, guys. Come on. Start over
again 'cause we're on about our third "correct," and we don't
know which one is referencing what. So ask the question again.
BY MR. VUKADINOVICH:
Q. Okay. Did you know what the due process policy was,
particularly for your decision to terminate me, what due
process policy came into play?
MS. BUGALLA: Again, Your Honor, I'm going to object
because it assumes, once again, something that is not in
evidence. Mr. Biggs did not make the decision to end
Mr. Vukadinovich's contract, and he keeps saying that.
THE COURT: Well, okay. I'm gonna overrule the
objection. The witness can answer the question if he can. If
he can't, I'm sure he'll say he can't.
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Could you repeat the question?
BY MR. VUKADINOVICH:
Q. As the principal -- did you make a decision to terminate
my employment?
A. No.
Q. Did your letter say that you made a decision to terminate
my employment?
A. I made a preliminary decision.
Q. Did your letter state that to me?
A. That I made a preliminary decision, yes.
Q. So you did make a decision, is that correct?
A. No.
Q. Even though your letter said that you did?
A. No.
THE COURT: All right. Mr. Vukadinovich, it is
abundantly clear, he calls it a preliminary decision. You
called it a decision. The jury understands the distinction.
MR. VUKADINOVICH: Yes. Very good.
THE COURT: And they'll decide how important that is.
MR. VUKADINOVICH: Yes, Your Honor.
BY MR. VUKADINOVICH:
Q. Mr. Biggs, I'm gonna draw your attention to the actual
policy there. Could you please read that.
THE COURT: You need to scroll it down because it is
cut off on the screen there.
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THE WITNESS: Okay. Says, "Procedural due process
requires an established rule or standard, notice of facts of an
alleged violation and the applicable rule or standard
(accusation), and an opportunity to respond before a decision
is made."
Q. Okay. Now, do you agree that I was entitled to some kind
of due process in my termination?
A. Yes.
Q. Okay. And based on this policy here that you just read,
what was the established rule or standard?
A. I don't know.
Q. Now, in your letter -- what kind of facts did you give me
in the letter?
A. Without having it in front of me, I can't generalize
according to the number or kind or if any facts were in there.
Q. I believe this has been previously admitted as Plaintiff's
Exhibit No. 19.
THE COURT: I think that's right. I'll display it
for the jury.
THE WITNESS: I'm sorry. You're asking me for the
facts in this letter?
BY MR. VUKADINOVICH:
Q. Yes.
A. Okay. "You are hereby notified" -- I'm not sure how to
answer the question, sir, without just reading it.
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Q. The actual facts, what where the facts? Tell us what the
facts are about my termination.
A. That you are being notified of the preliminary decision to
decline the teaching contract at the end of the 2011-2012
school year. That the reason for this preliminary decision is
follows: That the teacher is subject to a justifiable decrease
in the number of teaching positions, more commonly called a
reduction in force, per IC 20-28-7.5-1(b)(3). You have a right
to request a private conference with the superintendent to
discuss the reasons for my preliminary decision.
Q. Okay. That will be fine there.
Now, did you ever hear anything about the -- Ms. Kaiser
informing the School Board in her recommendation letter the
things about my student enrollment declined over the years and
that my middle school Project Lead the Way classes were not
generating interest for the high school?
A. Yes.
Q. Okay. Well, are those facts?
A. Was her letter a fact, yes.
Q. The letter was a fact, correct?
A. The letter does exist.
Q. Okay. And were those facts that she said -- what she said
in the letter, was it a fact that my interest in my middle
school Project Lead the Way classes didn't create interest for
the high school Project Lead the Way classes, is that a fact?
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A. I don't know.
Q. Pardon?
A. I don't know.
Q. Okay. Is it a fact that the student enrollment numbers in
my high school classes had declined over the years? Is that a
fact?
A. Yes.
Q. And how do you justify "yes"?
A. I made an analysis of your enrollment over the last five
years, and the course requests declined by 10 or 20 each
year -- not the last five years, but the years leading up to
2012.
Q. You're positive about that?
A. From my analysis, yes.
Q. Okay. And did you discuss that with Ms. Kaiser?
A. Yes.
MR. VUKADINOVICH: Could I just have a minute, Your
Honor.
THE COURT: Sure.
BY MR. VUKADINOVICH:
Q. Where did you receive the information that you said you
did your analysis on?
A. It's logged in the PowerSchool database; that's the
student information scheduling system that we used.
Q. Okay. Now, this particular document are interrogatories
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that the school corporation submitted in the case. Could you
please take a look at the answer under Interrogatory No. 9.
MS. BUGALLA: Your Honor, I need to know which
interrogatories these are, whose they are. I can't tell with
the page flipped over.
THE COURT: Show those to counsel. Show the entire
document. Yeah.
(Document tendered.)
BY MR. VUKADINOVICH:
Q. Okay. Do you see the figures there underneath
Interrogatory No. 9 where it says "2005-2006"?
A. I do.
Q. Okay. What was the figure there for student numbers?
A. Twenty-three.
Q. Okay. And that would have been 2005-2006, which would
have been my second year at the corporation, correct? Do you
know?
A. I don't know.
Q. If I told you it was my second year in the corporation,
would you believe that?
A. Yes.
Q. Okay. Now, what was the number of the students the
following year?
A. Thirty-nine.
Q. So it actually went up from the first year to the second
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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year, is that correct?
A. Yes.
Q. Okay. What was the enrollment number the third year that
I was employed?
A. Ninety-five.
Q. So isn't that almost four times as much as it was the
first year?
A. Yes.
Q. And then on 2008-2009, the corporation didn't even provide
a number there, did they?
A. It says, "The school's computer system does not have
information."
Q. All right. Now, the 2009-2010 year, what was the numbers
there?
A. Seventy-seven.
Q. Is that over three times as much as it was the first year
there?
A. Yes.
Q. And then what was the number of the 2010-2011 year?
A. Ninety.
Q. Isn't that almost four times what it was the first year?
A. Um --
Q. Close?
A. More or less, yes.
Q. Okay. And how about the last school year, 2011-2012,
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which was the actual year that you made the preliminary
decision to terminate me, what was the numbers then?
A. Eighty-seven.
Q. Okay. Now, you said in your analysis, I believe you said
that they had went down, like, 20 I believe you said?
A. Yes.
Q. Well, according to this, didn't they actually go up almost
four times as much?
A. When you say "they," we're speaking about different
numbers.
Q. Okay.
A. I was looking at course requests.
Q. I'm talking about numbers, the student enrollment.
A. I'm responding to the course requests.
Q. But I'm asking --
THE COURT: Let him explain his answer. Don't cut
him off. Go ahead.
THE WITNESS: The student course requests declined
over time. The student enrollment was what you had just shown
me.
BY MR. VUKADINOVICH:
Q. I'm actually a little confused. The student requests went
down. Don't the students sign up for the classes?
A. When a student signs up or asks to be placed in a course,
that's a little bit like a ballot. They fill out a course
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request sheet. It has lots of different electives and lots of
different core content areas. They submit that to the guidance
counselor. The guidance counselor then reviews that sheet and
decides where the students should be placed.
The course request that I'm referring to is that sheet,
and according to my research and my look at the last five
years, the course requests declined. The number of actual
students enrolled stayed the same. That has to do more with
the guidance counselor than the actual student course request.
Q. So the guidance counselor is the one that actually makes
the decision to put the students in the classes?
A. It is a combination and discussion and dialogue between
the principal and the guidance counselor. Superintendent often
weighs in on that.
Q. In my particular classes, did you not tell the guidance
counselor not to put them into my classes, to put them into
other classes, students that were actually requesting my
classes?
A. That's a lot for me to take in. Can you simplify that
question, please.
Q. In my particular case, the 2011-2012 school year, for the
following school year, didn't students make requests to take my
classes; and the guidance counselor asked you about what she
should do with them, and you told her not to -- I wasn't gonna
teach those classes, that she should put them in another class?
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A. Yes.
MS. BUGALLA: Your Honor, may I request a
clarification. Can we make a distinction as to whether we are
talking about middle school or high school.
THE COURT: You'll have an opportunity on
cross-examination to make those clarifications. And, again, if
the witness needs clarification, you can ask.
THE WITNESS: Okay.
BY MR. VUKADINOVICH:
Q. Is it more desirable to have a teacher who's qualified as
opposed to not highly qualified?
A. Yes.
Q. This is No. 101 that has not been admitted. Could you
please identify that.
A. That's a message from Karleen Adler to me and Jason
Yurechko. Subject, HQ status visual arts.
Q. And then what is Ms. Adler telling you in the first
sentence there?
A. "Hi, Jason and Justin. It was determined last year that
Jason is not highly qualified for the courses he's teaching
second semester. For these two courses, a visual arts teacher
license is required."
Q. Okay. Two things are said there. Is this correct now, he
is not highly qualified, and he also has a problem for two
courses with a license, is that correct?
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A. It was determined that he's not highly qualified according
to Karleen Adler, yes, that's what that says.
Q. And also that there's a problem with his teaching license,
is that correct?
A. It says that there's a visual arts teaching license that's
required.
Q. Do you have any reason to doubt that?
A. I don't doubt that that was the statement.
Q. Did you check into it?
A. Yes.
Q. And then what was your analysis?
A. He had an emergency permit.
Q. Okay. So these statements were false?
A. Yes.
Q. Who is Karleen Adler?
A. She is the former secretary in the central office.
Q. Okay. Do you know how long she worked there?
A. I don't.
Q. Okay. Did she get fired?
A. I don't know.
MR. VUKADINOVICH: I move to admit 101, Your Honor.
THE COURT: Any objection?
MS. BUGALLA: No objection.
THE COURT: 101 is admitted.
(Plaintiff's Exhibit No. 101, previously marked, was
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admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Did this particular teacher get fired?
A. I don't know.
Q. Did you fire this teacher?
A. Which particular teacher?
Q. The subject of the e-mail is -- actually, tell us who it
is. Up on the top there.
A. The message is addressed to me and to Jason Yurechko.
Q. So who is the teacher?
A. I don't understand.
Q. Who is the teacher that's the subject of this e-mail? Who
are they talking about, you and Karleen Adler, who are you
talking about?
A. Jason Yurechko.
Q. Okay. He's the teacher that we're talking about here,
correct?
A. Yes.
Q. Is that the same teacher that you allowed to put the
posters up around the building and to also go on the PA system
to generate interest for his classes?
A. Yes.
Q. But you didn't fire that teacher, did you?
A. No.
Q. Did that teacher continue teaching?
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A. No.
Q. Why not?
A. I don't know.
Q. Was there a problem with his license situation that you
were aware of?
A. There was a problem that his emergency permit had expired
at the end of the 2012 school year -- 2011-2012 school year.
Q. You knew that, correct?
A. Yes.
Q. You didn't fire that teacher, did you?
A. No.
Q. Was there a problem with any of my licenses?
A. No, not so far as I know.
Q. This exhibit is number 111, and it has not been admitted.
Could you please describe it.
A. It says -- it's a message from me to Carol, Ms. Kaiser,
saying, "Please find enclosed the description of events from
May 8 with respect to Brian Vukadinovich."
Q. And then what is that exhibit there?
A. Okay. It shows a log entry. Looks like it is a
description of an event probably in reference to the e-mail
message that I just described to you.
Q. Okay. And then is that the situation where you were
telling Ms. Kaiser that when you came into the room about
the -- you said that you gave me an envelope, and I was yelling
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at you and that type of thing?
A. Yeah.
Q. Okay. And then -- what was the date of this?
THE COURT: Are you going to offer this exhibit?
MR. VUKADINOVICH: It is No. 111, Your Honor.
THE COURT: Are you going to offer it?
MR. VUKADINOVICH: Yes.
THE COURT: Are you objecting to this?
MS. BUGALLA: No.
THE COURT: It is admitted.
(Plaintiff's Exhibit No. 111, previously marked, was
admitted in evidence.)
THE COURT: I just want the jury to be able to follow
along.
MR. VUKADINOVICH: Yes.
THE COURT: So it's helpful if you admit the exhibit
before you start talking about it, so it is admitted. I'll
turn it on for the jury if you want to have them look at it too
as you are asking him about it. Go ahead.
BY MR. VUKADINOVICH:
Q. Was that on May 14?
A. The e-mail message is marked May 14, yes.
Q. That would have been approximately 12 days after the May 2
situation when we actually had the meeting and so forth?
A. Yes.
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Q. Okay. And was that three days after the meeting I was
having with Ms. Kaiser when you actually came into the room and
were asked to leave?
A. Was what three days after?
Q. That situation, when you came in to my room, was that
three days after you had came into the meeting I was having
with Ms. Kaiser on May 11?
A. No. No.
Q. It wasn't?
A. No.
Q. It says it was May 14 on your e-mail, correct?
A. The e-mail message, yes.
Q. Okay. What was the date?
A. The date of the e-mail message was May 14.
Q. Okay. Well, when did this happen?
A. When did what happen?
Q. When you came into my room.
A. May 8.
Q. So it was three days then. May 8 is when you came into my
room. May 11 is when you came into the meeting I was having
with Ms. Kaiser, is that correct?
A. Yes.
Q. And on May 14 then, actually three days, three days, and
three days later then you e-mailed Ms. Kaiser and gave her what
you called a description of events, is that correct?
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A. Yes.
Q. Okay. Why did you feel you had to e-mail Ms. Kaiser about
that?
A. It was a distressing situation that I thought she should
know about.
Q. Why did she have to know about it?
A. Because it was a distressing situation that I thought she
should know about. In my capacity as principal it is important
to ensure that there's communication about issues that cause
distress, and that was certainly one of them.
Q. This is No. 114, which is not been admitted. Could you
please describe this document.
A. It is an e-mail message from me to Ms. Kaiser. It is,
subject, FW, Brian Vukadinovich. So forward,
Brian Vukadinovich, and my signature is down at the bottom.
Q. Okay. And then what's the subject of this e-mail?
Without reading it, what is the e-mail all about?
A. Well --
Q. Without reading it out loud, just tell us what the e-mail
is about. You can read it, but tell us what the e-mail is
about. What were you trying to say?
A. Would you like me to read it, or would you like me to tell
you what it is about?
Q. Well, go ahead and read it then. Go ahead and read it.
A. "Yesterday at the end of our conference, I informed Brian
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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that the conference was over. Mr. Landis and Mr. Brooks stood
up and left the office. Brian remained seated. I asked Brian
to leave the office. He remained. I repeated my request twice
more and informed him that I would log this insubordinate
behavior. He finally stood up and left the office. The above
occurred at 9:25 a.m. yesterday, Tuesday, May 22, 2012."
THE COURT: Are you going to offer this exhibit?
MR. VUKADINOVICH: Yes, I am, Your Honor.
THE COURT: Do you have any objection to it?
MS. BUGALLA: No.
THE COURT: It is admitted. I'll display it for the
jury.
(Plaintiff's Exhibit No. 114, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. And then what was the date of the actual e-mail?
A. The e-mail is Thursday May 24th.
Q. And then when did supposedly this situation happen?
A. Tuesday, May 22.
Q. Okay. And then you made sure that Ms. Kaiser knew about
that, is that correct?
A. Yes.
Q. Okay. Now, when you say in the e-mail that I remained
seated, did I just remain seated, or was I trying to ask you
anything?
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A. I don't recall.
Q. Well, tell us -- put us in the room when that happened.
What happened?
A. I had called you in for a meeting.
Q. Was it a disciplinary meeting?
A. I had informed you that it may have been disciplinary,
but, no, it was not. I had asked for some information
regarding the special ed meeting, I believe, in which you were
-- I received an e-mail message, and I was following up on
that.
Q. Is that the e-mail message that my name was never in nor
was anybody else's name?
A. There were several people named.
Q. As the subject of whoever abused the presenter according
to the e-mail. Is that the e-mail you are talking about where
there was no person identified?
A. It is hard for me to answer the question, sir.
Q. So you can't answer the question?
A. There's lots of components to it. Could you simplify it.
Q. The e-mail that you're talking about right now that you
said you just called me in for for this situation, is that
about the so-called thing that supposedly happened in the
library with some kind of abuse of the presenter?
A. Um --
Q. Is that why that e-mail came into play?
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A. I disagree with the words that you use to characterize the
situation, but, yes, that's what it refers to.
Q. Okay. And my question was: Now, is that e-mail that you
were talking about that you received, nobody was identified who
the person was, is that correct?
A. There were lots of people who were identified in the
situation.
Q. In that particular situation, who abused the presenter?
A. Nobody abused anybody.
Q. Well, then why did you call me in?
A. To discuss an e-mail that I had received about some rude
behavior in a presentation in which you were implicated.
Q. Was my name implicated?
A. Yes.
Q. By who?
A. By me.
Q. Anybody else?
A. Yes.
Q. Who?
A. I don't recall.
Q. And then did you tell Ms. Kaiser in this e-mail that you
were gonna log insubordinate behavior against me? Did you tell
her that in the e-mail?
A. Yes, that's what I wrote.
Q. Now, this is three weeks approximately after you had
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already given me my walking papers, is that correct?
A. I didn't give you walking papers, but, yes, it is three
weeks after the preliminary letter.
THE COURT: How much longer do you have?
MR. VUKADINOVICH: I was gonna ask you if we could
take a 10-minute break, ten minutes and I'll be -- or should I
go ahead and finish up?
THE COURT: No, finish. We have only been going for
less than an hour.
MR. VUKADINOVICH: Yes, Your Honor. Yeah.
I'm gonna wrap it up here, Your Honor.
BY MR. VUKADINOVICH:
Q. This has not been -- this is No. 79. It has not been
admitted. Can you identify it.
MS. BUGALLA: I'm sorry. What's the number?
MR. VUKADINOVICH: Number 79.
THE WITNESS: Looks to be an administrative guideline
1400b printout. Position, middle/high school principal.
Responsible to, superintendent of schools.
Q. Okay. Are you familiar with that document?
A. I'm waiting for it to focus.
THE COURT: Why don't you show him the actual
document so he can look at it and thumb through it.
MR. VUKADINOVICH: Sure. I'm wrapping it up, Your
Honor.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
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(Document tendered.)
THE WITNESS: Thank you.
Yes, this looks like my job description, and I've signed
it at the bottom.
BY MR. VUKADINOVICH:
Q. Okay. I'm gonna draw your attention to item J at the top
there. Could you please read that.
A. "J) Keeping current on all statutes, rules, regulations,
case law, and corporation policies and administrative
guidelines."
Q. So were you required by the corporation to keep up-to-date
on all what the statutes and rules and case law and all those
things are?
A. That's what that says, yes.
Q. Well, my question is: Were you required to do that, to
keep up on all those things?
A. Not case law.
Q. Does it not say case law in there?
A. Yes, it does. You are right.
Q. So were you required to keep up on that?
A. Yes, that's what that says.
Q. Okay. Now, were you required to keep up on the
corporation policies?
A. Yes.
Q. Did you keep up on the corporation's due process policy?
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A. Yes.
Q. Well, when I asked you, you seemed to not be able to tell
us what the due process policy was. What was it?
A. What was what?
Q. The corporation's due process policy?
A. It is what I read.
Q. And I'm asking you, what was it? You were supposed to
keep up-to-date on it.
A. Are you asking me to recite the due process policy I just
read?
Q. What was Hanover's due process policy?
THE COURT: Mr. Vukadinovich, this isn't a game of
gotcha. He read the policy into the record.
MR. VUKADINOVICH: Okay. All right.
THE COURT: We're not gonna have him try --
MR. VUKADINOVICH: Basically one more question and
I'm done, Your Honor.
THE COURT: You take as much time as you need. I'm
not gonna tell you that goes beyond the pale.
MR. VUKADINOVICH: Sure.
BY MR. VUKADINOVICH:
Q. Okay. Please take a look at item M, M as in M&Ms, M.
A. M.
Q. Could you read that to us.
A. "Treating all individuals in a fair, professional, and
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ethical manner."
Q. So were you required as an administrator at Hanover to
treat everybody in a fair, ethical manner?
A. Yes.
Q. So when you told me that I couldn't put the posters up
around the building and go on the PA system and get students'
interest for the classes but you let the other one, is that
fair?
A. Yes.
Q. You say that's fair to let the other teacher do it and not
me?
A. Yes.
MR. VUKADINOVICH: That's all, Your Honor.
THE COURT: Okay.
Ms. Bugalla, cross?
MS. BUGALLA: Yes, Your Honor.
MR. VUKADINOVICH: Oh, I move to admit that, Your
Honor.
THE COURT: You have any objection to that position
description?
MS. BUGALLA: No.
THE COURT: All right. What number was that, sir?
NEW SPEAKER: Seventy-nine.
MR. VUKADINOVICH: Seventy-nine.
THE COURT: All right. Seventy-nine is admitted.
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Leave it up here on the table.
(Plaintiff's Exhibit No. 79, previously marked, was
admitted in evidence.)
CROSS-EXAMINATION
BY MS. BUGALLA:
Q. Good afternoon.
A. Hi there.
Q. When you gave Mr. Vukadinovich the preliminary
determination on May 2, 2012, who else was present?
A. No one.
Q. Just the two of you?
A. Yes.
Q. And I believe you testified earlier that the letter had
been written by Ms. Kaiser, is that correct?
A. Yes.
Q. And did you give this preliminary determination to
Mr. Vukadinovich at Ms. Kaiser's direction?
A. Yes.
Q. You were a first-year principal, correct?
A. Yes.
Q. Had you ever gone through a RIF process prior to that?
A. No.
Q. In addition, had the statute in Indiana regarding the
process recently changed?
A. Yes.
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Q. Would it be fair to say that you were not entirely sure of
exactly all the procedures to be followed?
A. Yes.
Q. And as a first-year principal, would you have taken it
upon yourself to have issued that preliminary determination to
Mr. Vukadinovich without Ms. Kaiser's direction or authority?
A. Absolutely not.
Q. Now, when you were in that room with Mr. Vukadinovich, did
you hand him the letter?
A. Yes.
Q. Do you remember what you said to him?
A. I said, I'm sorry. I think I said, I'm sorry, Brian. I
think I read him the letter, and then he left. Then I looked
at the letter and noticed that it said put in a date at the
bottom. I called Mr. Vukadinovich back to my office, and I
said, you know, I need to put the date in here. Could you
please initial it that you've received it. He did, and then he
asked me, is this notice -- does this have anything to do with
my performance? And I said, no. And he said, thank you, and
left.
Q. Did you make any disparaging remarks to him?
A. No.
Q. Did you call him a name?
A. No.
Q. Did you call him an old man?
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A. No.
Q. Has it been distressing to you for those allegations to
have been made all these years?
A. Yes.
Q. Did you mention anything to him about the settlement of
the Hammond lawsuit?
A. No.
Q. Did you know about the Hammond lawsuit?
A. I had no idea.
Q. When you worked at Hammond, did you know that
Mr. Vukadinovich had brought such a lawsuit?
A. No.
Q. Did you know it was settled?
A. No.
Q. Is there any possibility that you could have made those
comments to him at all?
A. Absolutely not.
Q. At any time during 2011-2012 did Mr. Vukadinovich ever
mention to you the Hammond lawsuit?
A. No.
Q. Did he ever mention to you the settlement?
A. No.
Q. Did you communicate directly with any member of the Board
regarding the preliminary determination that you gave to
Mr. Vukadinovich?
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A. No.
Q. Was your chain of command from you to the superintendent,
Ms. Kaiser?
A. Yes.
Q. And did you hear about the Hammond lawsuit and the
settlement sometime after the litigation began by
Mr. Vukadinovich?
A. Yes.
Q. Now, you've also been asked about several issues of
alleged harassment. Did you harass Mr. Vukadinovich?
A. No.
Q. In these incidents, did you respond to his behavior?
A. Yes.
Q. He asked you about the meeting on May 11 with Ms. Kaiser.
Again, was this your first RIF process?
A. Yes.
Q. Were you uncertain whether you were required to be in that
meeting?
A. I was.
Q. Had you discussed that meeting with Ms. Kaiser in advance?
A. No.
Q. Did you influence Ms. Kaiser in any way regarding that
meeting?
A. No.
Q. Did you tell her what to say or not to say?
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A. No.
Q. Was your influence such with Ms. Kaiser that you could
sway her to do your bidding?
A. Absolutely not.
Q. So when you opened the door into that meeting on May 11,
were you trying to be rude?
A. No.
Q. Were you trying to interfere where you were not supposed
to be?
A. No.
Q. Did you simply ask, Should I be here?
A. Yes.
Q. And were you prepared to leave?
A. Yes.
Q. And was Mr. Vukadinovich rude to you?
A. Yes.
Q. Was he loud?
A. Yes.
Q. Was he belligerent?
A. Yes.
Q. You've also been asked about the incident where you
brought the signed receipt for his request for records into his
classroom. You remember that?
A. Yes.
Q. And, again, did he yell at you?
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A. Yes.
Q. Was he inappropriate in front of the students?
A. Yes.
Q. Did you yell at him?
A. No.
Q. He has alleged that you just stood there and stared at
him. Is that true?
A. No.
Q. Were you exiting the room?
A. Yes.
Q. There was another incident involving a speaker, a special
ed speaker?
A. Yes.
Q. And did you determine that the person who was rude to the
speaker, did you determine that was Mr. Vukadinovich?
A. Yes.
Q. And did you call him into your office to address that
behavior?
A. I did.
Q. Is that something you would do to any staff member who had
behaved in a rude fashion?
A. Absolutely.
Q. Now, did you discipline him in any way?
A. No.
Q. Did you reprimand him?
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A. No.
Q. Did you know that Ms. Kaiser was going to send the letter
of May 15 to Mr. Vukadinovich?
A. No.
Q. In advance?
A. No.
Q. And to the best of your knowledge, did Ms. Kaiser
discipline him in any way?
A. No.
Q. Did he have a loss of pay, anything?
A. No.
Q. Did you ever discipline him in any way?
A. No.
Q. In your opinion -- and you were involved in all these
incidents -- did Mr. Vukadinovich manufacture these incidents
of harassment?
A. Yes.
Q. Did he manufacture the allegation of the comments you
allegedly said to him on May 2?
A. Yes.
Q. Between May 2 and June 11, 2012 -- and June 11 is the day
the Board voted to end Mr. Vukadinovich's contract -- from
May 2 to June 11, did you speak to anyone on the Board of
School Trustees at Hanover about Mr. Vukadinovich?
A. No.
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Q. Did you speak to them about the settlement of the lawsuit
at Hammond?
A. No.
Q. Did you speak to them about the alleged -- your allegedly
calling him an old man?
A. No.
Q. So there would have been no way that the Board could have
known of those alleged statements from you?
A. Correct.
Q. Did you tell Ms. Kaiser about those statements between
May 2 and June 11?
A. Yes.
Q. And beyond that, do you know what she did with that
information?
A. No.
Q. Do you remember when you told her that?
A. There were several e-mail messages that I forwarded
directly to her. I didn't speak as much as I just forwarded
the messages, and that's where those were from him.
Q. Did you make the decision to end Mr. Vukadinovich's
contract based upon a reduction in force?
A. I made a preliminary decision, yes.
Q. Did you make the final decision?
A. No.
Q. Was that even in the realm of your authority?
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A. No.
Q. You talked about meeting with Ms. Kaiser to discuss which
classes would be canceled, which would be continued, which
would be added. Do you remember that?
A. Yes.
Q. And did you meet with her throughout the school year
2011-2012?
A. Yes.
Q. And ultimately was the determination as to which classes
would be offered, which would be ended, was that Ms. Kaiser's
decision?
A. Yes.
Q. Now, you talked about the things that were considered in
making this decision. Were the numbers of students who
requested classes taken into consideration?
A. Yes.
Q. Was that the only factor?
A. No.
Q. Now, when we talk about requesting classes, the students
in the high school request classes, correct?
A. Yes.
Q. They request electives?
A. Yes.
Q. There are certain classes that they are required to take
by the state, is that correct?
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A. Yes.
Q. Now, do the students at the middle school have the same
prerogative to select classes?
A. No.
Q. So are the classes for the middle schoolers predetermined?
A. Most cases, yes.
Q. And the middle school PLTW classes that both
Mr. Vukadinovich and Mr. Smith taught, they were rotation
classes, were they not?
A. Yes.
Q. Now, a rotation class means that all the middle schoolers
take it, is that correct?
A. No. There were band students that would take those
classes, band only. Everybody else who wasn't in band would
then take that rotation.
Q. All right. So just to make sure we're clear, the kids who
are in band did not take PLTW?
A. Right.
Q. Every other middle schooler took PLTW?
A. Yes.
Q. So whether the numbers were up or down was a function of
how many middle schoolers there were, correct?
A. Right.
Q. When you talked about doing an analysis of whether the
request for Mr. Vukadinovich's classes had declined over five
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years, were you referencing his high school classes?
A. Yes.
Q. That exhibit -- and let me see if I can find it --
MS. BUGALLA: Chad, perhaps you can help me. It was
recently admitted. It was the PowerSchool exhibit. I
apologize for not having it handy.
THE COURT: Mr. Vukadinovich, do you have that
exhibit? Do you know what --
MS. BUGALLA: It was the PowerSchool exhibit.
MR. VUKADINOVICH: I didn't put it up there?
MS. BUGALLA: I need the number. That's all I need.
Was it 99?
MR. VUKADINOVICH: I'll go up there and look right
now.
THE COURT: Yeah, it is 99. I'm looking at it right
here.
MS. BUGALLA: All right. Could we have 99, please.
Okay.
THE COURT: Let me display it for the jury.
I think we are all set, Mr. Vukadinovich. Thank you.
MS. BUGALLA: All right. Now -- I'm sorry. This is
not the one I wanted. There was an exhibit showing the class
numbers, and it was for the middle school.
MR. BUELL: The interrogatories that he showed?
MS. BUGALLA: Yes.
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MR. BUELL: We don't have those.
MS. BUGALLA: Can I have the interrogatories that you
showed, Hanover's interrogatories.
You can take that off.
Thank you. Okay. Here we have it.
BY MS. BUGALLA:
Q. You saw this? These were Hanover's answers to
interrogatories.
A. Yes.
Q. And you were asked about numbers?
A. Yes.
Q. Those are middle school numbers, are they not?
A. They do include those, yes.
Q. All right. So as we previously discussed, whether the
numbers were 85, 97, whatever the numbers were, that had
nothing to do with students requesting anyone's classes. That
had to do with every middle schooler except band going through
PLTW, correct?
A. Yes.
Q. So, again, when we're talking about requests declining
over time, you were referencing high school, correct?
A. That's correct.
Q. All right. I'd like to show you --
MS. BUGALLA: And we're going to do this in as
logical a fashion as possible.
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We have four schedules to compare. They can't all be up
here, and we have a summary of it.
THE COURT: Okay.
MS. BUGALLA: Okay. All right. I need the --
Chad, I need the hard copy first, please. I need the hard
copy of ours, N, O, P, and Q.
THE COURT: I'll tell you what, why don't we take our
midafternoon recess at this time and give Ms. Bugalla a chance
to get her materials together. Don't discuss the case amongst
yourselves over this recess. We'll be back in 15 minutes.
(Jury out at 2:27 p.m.)
(A recess was had at 2:27 p.m.)
(The proceedings resumed in open court, reported as
follows:)
DEPUTY CLERK: All rise.
THE COURT: You can be seated. You all ready to go,
Ms. Bugalla?
MS. BUGALLA: Yes, Your Honor.
THE COURT: Okay. Carlos, you want to call the jury
in here, please.
(Jury in at 2:45 p.m.)
THE COURT: All right. You may be seated. Mr.
Biggs, everyone.
You may continue, Ms. Bugalla.
\\\
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BY MS. BUGALLA:
Q. Mr. Biggs, is it, in your opinion, the role of
professional educators to determine the curriculum that is
offered to the students?
A. Yes.
Q. And is curriculum, the classes offered, is that for the
benefit of the students?
A. Yes.
Q. Does the curriculum exist for the benefit of the teachers?
A. No.
Q. I'd like to chat with you a moment about Jason Yurechko.
In 2011-2012, was he teaching a combination of classes, some of
which fell into the designation of fine arts as provided by the
State of Indiana?
A. Yes.
Q. And did others of his classes fall within the designation
of CTE classes?
A. Yes.
Q. Now, you've heard us mention CTE here in the courtroom.
Are CTE classes specially designated by the Indiana Department
of Education?
A. They are.
Q. And do the teachers who are qualified to teach CTE have to
have specialized training?
A. Yes.
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Q. Are there two ways to qualify, either through specialized
education or through having worked in the workplace?
A. Yes.
Q. And will a school receive the additional CTE funding
provided by the State if the instructor is not CTE qualified?
A. No.
Q. So, in other words, to receive the money, you have to have
people who are specially qualified beyond a routine license, is
that correct?
A. Yes.
Q. So Mr. Yurechko taught in 2011-2012 some CTE classes,
correct?
A. Yes.
Q. And did -- was he qualified to do so?
A. Yes.
Q. And was his qualification based on his having worked in
the workplace?
A. Yes.
Q. He had been a graphic artist, is that correct?
A. Yes, he has a business locally.
Q. So for the classes that fell under the category of fine
arts, did he have an emergency permit for 2011-2012?
A. Yes.
Q. So that we understand this, is an emergency permit given
by the State of Indiana when a school cannot find a licensed
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teacher in a particular area?
A. That's correct.
Q. Okay. Now, for 2012-2013, did Mr. Yurechko resign in the
summer of 2012?
A. He did.
Q. Now, even if he had not resigned, in 2012-2013, would he
have only taught CTE classes?
A. Yes.
Q. And he would not have taught any of the fine arts classes?
A. Correct.
Q. Now, in 2012-2013, did you find, did you have, a licensed
teacher in the fine arts area?
A. I do -- I mean, I did.
Q. Was that Stephanie Spencer?
A. Yes.
Q. And had she taught previously at one of the elementary
schools at Hanover?
A. Yes.
Q. And was she transferred to the middle school and the high
school in 2012-2013?
A. Yes.
Q. So that we're clear, the fine arts classes in 2012-2013
were taught by a licensed teacher?
A. Yes.
Q. They were not taught by someone on an emergency permit?
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A. That's correct.
Q. Was Mr. Vukadinovich licensed in fine arts?
A. No.
Q. Was he qualified to teach any CTE class?
A. No.
Q. Okay. So Mr. Yurechko resigned in August of 2012?
A. Yes.
Q. And so did you need to find someone to teach his CTE
classes at the high school for 2012-2013?
A. Yes.
Q. And did you find someone?
A. We were lucky enough to find someone, yes.
Q. And was that Ryan Spencer?
A. It was.
Q. And did Ryan -- was Ryan Spencer qualified to teach CTE?
A. Yes, he had a workplace specialist qualification.
Q. What does that mean?
A. That means that he had also had his own business. It was
in graphic design and other commercial enterprises. It
qualified under the State for a number of work hours to allow
him to teach that class.
Q. So he was a qualified CTE instructor?
A. Yes.
Q. And the classes he taught in 2012-2013 for CTE made the
school eligible to receive the extra funding, is that correct?
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A. Yes.
Q. Was Mr. Vukadinovich qualified to teach any of
Mr. Spencer's CTE classes?
A. No.
Q. All right. I'm going to show you -- and this becomes a
little bit difficult logistically if everyone will bear with
us.
The master schedules for the middle school for 2011-2012,
2012-2013, the master schedules for the high school for
2011-2012, 2012-2013, okay. I'd like you to take a look at
these. We're going to be talking about the classes that were
canceled and the classes that were added so you know what I'm
asking you to look at.
A. Okay.
Q. Okay. These are Defendant's Exhibit N, O, P, and Q. So
let me know after you've had a chance to look through them.
A. Okay. I've seen the first page. I haven't seen all of
it.
Q. Just peruse them quickly. If you just sort of review
them.
A. Okay. Okay.
Q. Do they appear to be accurate?
A. Yes.
Q. All right.
MS. BUGALLA: We would move admission of N, O, P, and
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Q, Your Honor.
MR. VUKADINOVICH: Your Honor, could we see them?
MS. BUGALLA: You have them.
THE COURT: Do you have the copies of them?
MS. BUGALLA: He has copies of ours. I can't put all
four of them up.
MR. VUKADINOVICH: Okay.
MS. BUGALLA: You have them in our book.
MR. VUKADINOVICH: No objection, Your Honor.
THE COURT: All right. N, O, P, and Q are admitted.
(Defendants' Exhibits N, O, P, and Q, previously marked,
were admitted in evidence.)
MS. BUGALLA: For ease of reference because I can't
figure out how to do it electronically, Your Honor, we have a
demonstrative exhibit that summarizes the testimony if I might
refer to this.
THE COURT: Fair enough. Let me let you display it
for the jury.
MS. BUGALLA: Okay. And you have a copy of this
double Y. You have a copy?
MR. VUKADINOVICH: Yes.
MS. BUGALLA: Okay.
BY MS. BUGALLA:
Q. All right. Let's talk about the middle school and the
classes that were canceled after 2011-2012. So the
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discontinued classes that are listed here, was it Business
Information Technology?
A. Yes.
Q. PLTW?
A. Yes.
Q. Foreign Language Exploration, is that correct?
A. Yes.
Q. Now, in parentheses, are those the names of the teachers
who taught the canceled classes?
A. Yes.
Q. Now, it says Mr. Bachinski. He was the assistant
principal, right?
A. That's correct.
Q. Was it actually Mr. Dimitrovich who taught the class?
A. Yes.
Q. All right. And then PLTW, as we know, was taught by both
Mr. Vukadinovich and Arden Smith, correct?
A. Yes.
Q. And Foreign Language Explorations was taught by Jennifer
Macleod?
A. Yes.
Q. So it was not just Mr. Vukadinovich's classes that were
canceled, correct?
A. Correct.
Q. These other teachers' classes were also canceled, correct?
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A. Yes.
Q. And none of these classes listed there, Business
Information, PLTW, Foreign Language Exploration, none of those
were offered in 2012-2013 at the middle school, is that
correct?
A. Yes.
Q. Okay. Let's look at the added courses.
Before we do that though, in August of 2012 did a brand
new middle school building open?
A. Yes.
Q. Was it a larger facility than had previously existed?
A. Yes.
Q. Was it, obviously, new?
A. Yes.
Q. And did it have new facilities?
A. Yes.
Q. Did it have state-of-the-art technology?
A. Yes.
Q. And did this new facility influence the classes that would
be offered there in 2012-2013?
A. Yes.
Q. Would it make sense to have a new facility and not utilize
it?
A. No.
Q. All right. Is that part of the reason why the classes
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that were canceled from 2011-2012 were canceled?
A. Yes.
Q. I believe you've said this repeatedly, but were only class
numbers, numbers of kids, was that the only criteria for
whether a class was canceled?
A. No.
Q. Was there some magic number that would insulate a class
from ever being canceled?
A. No.
Q. All right. So we have added courses here for the middle
school. Does FACS stand for Family and Consumer Science?
A. Yes.
Q. And did the brand new middle school have a new
state-of-the-art Family and Consumer Science area?
A. Yes.
Q. So is that why these classes were added?
A. I believe so.
Q. Now, were additional sections of PE added?
A. Yes.
Q. And was this so that greater numbers of kids could take
PE?
A. Yes.
Q. And fine arts rotation, was that added?
A. Yes.
Q. When it says, "fine arts rotation," does that mean that
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every student at the middle school except those in band took
fine arts?
A. Yes.
Q. And as you previously testified, Stephanie Spencer taught
those classes, correct?
A. Yes. Although I must mention that band does count as a
fine arts.
Q. All right. But fine arts rotation for the nonband
students?
A. Yes.
Q. Stephanie Spencer was licensed, correct?
A. Yes.
Q. And then there were additional sections of computer
applications added, is that correct?
A. Yes.
Q. All right. These courses that were added at the middle
school, 2012-2013, was Mr. Vukadinovich by license or
certification qualified to teach any of them?
A. No.
Q. Okay. Let's talk about the high school. First of all,
those that were discontinued. All three of Mr. Vukadinovich's
classes were discontinued; Construction, Manufacturing and
Transportation, is that correct?
A. Yes.
Q. All right. We have two of Mr. Yurechko's classes that
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were canceled, correct?
A. Yes, I see both Item 4 and Item 9.
Q. So 3D Computer Animation and Visual Communications were
both canceled?
A. Yes.
Q. Those were his fine arts classes, weren't they?
A. Yes.
Q. And as you've just explained, they were canceled because
of his emergency permit, correct?
A. Yes, it expired at the end of the 2011-2012.
Q. In addition, Digital Citizenship was canceled, is that
correct?
A. Yes.
Q. And that was taught by Mr. Harrison and Mr. Monroe?
A. Mrs. Monroe.
Q. All right.
A. But, yes.
Q. French III was canceled, correct?
A. Yes.
Q. Taught by Angela Lowe?
A. Yes.
Q. Introduction to Accounting was also canceled taught by
Carey Monroe, correct?
A. Yes.
Q. And we have Principles of Engineering taught by Arden
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Smith, correct?
A. Yes.
Q. Let's stop there for a moment. Arden Smith had all of his
classes at the middle school canceled, correct?
A. Yes.
Q. And in addition, he had one of his classes at the high
school canceled, correct, that one right here, Principles of
Engineering?
A. Yes.
Q. Now, Mr. Smith was not RIF'd, was he?
A. No.
Q. And is the reason he wasn't RIF'd because he had a license
that allowed him to teach more classes --
A. Yes.
Q. -- including math at the high school?
A. Yes.
Q. Let's stop there for just a minute. Is any teacher free
to take any additional education they wish to add to their
license, additional subjects they may teach?
A. Yes.
Q. Is it common for teachers to do this?
A. Yes.
Q. And is one of the reasons they do it to insulate them
against a RIF?
A. Yes.
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Q. If Mr. Smith had not been able to teach math in the high
school, might he have been RIF'd?
A. Yes.
Q. Did Mr. Smith also have PLTW training for the high school?
A. He did.
Q. Mr. Vukadinovich did not, did he?
A. No.
Q. So Mr. Smith was in a position where he taught more
classes, correct?
A. Yes.
Q. Or at least was authorized to?
A. Yes.
Q. All right. Let's look at the classes that were added for
the high school for 2012-2013. There are nine of them, are
there not?
A. Yes.
Q. Advanced Business Management, did that qualify for CTE?
A. Yep.
Q. And did Carey Monroe qualify as a CTE instructor?
A. Yes.
Q. Biotech Engineering, did that qualify for CTE?
A. Yes.
Q. Did Jennifer McQuade qualify as a CTE instructor?
A. Yes.
Q. Dramatic Literature was taught by Ashley Bult, correct?
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A. Yes.
Q. Entrepreneurship, is that another CTE class?
A. Yes.
Q. And, again, Carey Monroe is teaching that one, correct?
A. Yes.
Q. We have Introduction to 2D Art and 3D Art, both taught by
Stephanie Spencer. Were these fine arts classes?
A. Yes.
Q. Was she a licensed fine arts teacher?
A. Yes.
Q. We then have Introduction to Agriculture Food and Natural
Resources, which was a CTE class. Did it actually turn out in
2012-2013 that this class wound up not being offered?
A. It was not offered, that's correct.
Q. Was that because you could not find a CTE authorized
instructor?
A. Correct.
Q. Next, Introduction to Physical Therapy. Was that a CTE
class?
A. Yes.
Q. And did that wind up actually being given during
2012-2013?
A. No.
Q. Was that because you were unable to secure a CTE qualified
instructor?
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A. True. That's correct.
Q. And at last is Principles of Biomedical Science. Is that
a CTE class?
A. Yes.
Q. And was Ms. Davlantis qualified?
A. Yes.
Q. Was Mr. Vukadinovich qualified to teach any of the nine
classes that were added in 2012-2013?
A. No.
MS. BUGALLA: Your Honor, can we admit this as a
demonstrative exhibit?
THE COURT: Any objection?
MR. VUKADINOVICH: No, Your Honor.
THE COURT: What was the number on that, ma'am?
MS. BUGALLA: It is double Y.
THE COURT: All right. YY is admitted.
(Defendants' Exhibit YY, previously marked, was admitted
in evidence.)
BY MS. BUGALLA:
Q. I want to just quickly go through a couple of exhibits to
see if we can clarify some things.
This was Plaintiff's Exhibit 100 that you were asked
about. There are names listed, but does this tell you anything
about numbers of students that are signed up for anything?
A. No.
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Q. Does it even -- it says, "I noticed a couple of issues,"
but does it tell you what the issues are?
A. No, but I do see, "Landis, fifth hour, zero students." So
that's -- that did mention a student number, but that's it.
Q. But beyond that this doesn't tell you anything that would
relate to whether Mr. Vukadinovich had numbers or didn't have
numbers, does it?
A. No.
Q. This is Exhibit 99. If you can't see it, let me know.
A. I am having trouble.
THE COURT: Could you blow that up. You can magnify
it.
Mr. Buell, do you know how?
MS. BUGALLA: My technician will assist me.
BY MS. BUGALLA:
Q. Is that better?
A. Yes.
Q. It says, for example, "zero." Now, are we talking about a
particular class, a section, what do you think that zero
relates to?
A. That looks like a section that may occur at the same time
as another section by the same teacher. So if there's -- for
example, if there were some students that enrolled in Graphic
Imaging Tech II and then could take Graphic Imaging Tech I at
the same time, you could have those both in the classroom at
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the same time.
Q. So classes would be combined?
A. Yes.
Q. This does not mean that Mr. Spencer was teaching a class
with nobody in it?
A. No, absolutely not.
Q. And this doesn't actually -- while it says enrollment, it
is not really -- it is really telling you -- is it really
telling you the number of students in particular sections like
period one, period two?
A. Right. And that number fluctuates until the end --
sometimes until the first day of school.
Q. This is Plaintiff's Exhibit 98. And it is talking about
biotech and biomed, correct?
A. Yes.
Q. Are biotech and biomed both high school classes?
A. Yes.
Q. And are they PLTW classes?
A. Yes.
Q. Was Mr. Vukadinovich certified to teach PLTW at the high
school?
A. No.
Q. Could he have taught either of these classes?
A. No.
Q. Now, here is Exhibit 85. This is you saying to Nicole
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Satterfield that we have to cancel students who signed up for
Mr. Vukadinovich's classes into other classes, is that correct?
A. Yes.
Q. Is that because you don't let students sign up for classes
that are canceled?
A. Yes.
Q. Does it make any sense to have students signed up for
classes that have been canceled?
A. No.
Q. Again, was the -- either the cancellation of
Mr. Vukadinovich's classes, of anybody's classes, solely
determined by the number of kids?
A. No.
Q. All right. This is Plaintiff's Exhibit 81. And
Mrs. Davlantis in the second paragraph is talking about
Biomedical Science, correct?
A. Yes.
Q. Biomedical Science is a high school PLTW class, is it not?
A. Yes.
Q. So if Mr. Vukadinovich was going to be able to teach that
class, he would have had to have taken additional PLTW
training, correct?
A. Yes.
MS. BUGALLA: Just a moment, Your Honor.
\\\
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BY MS. BUGALLA:
Q. Did you have any input into Ms. Kaiser's written
recommendation to the Board dated May 17, 2012?
A. No.
Q. That was the written recommendation regarding the RIF of
Mr. Vukadinovich, was it not?
A. Yes.
Q. And you had no input?
A. I'm -- I wrote the letter, but that was directed --
Q. No, no. Ms. Kaiser's letter to the Board?
A. Okay. No.
Q. You had no input, did you?
A. No. I don't know what you're even referring to.
Q. Okay. The same time you gave Mr. Vukadinovich his
preliminary determination concerning the RIF, did you also give
a similar letter to another teacher by the name of Jamie
Julian?
A. Yes.
Q. Jamie Julian was part time, was she not?
A. Yes.
Q. And did she lose her job?
A. Yes.
Q. Now, you talked about the fact that you let Mr. Yurechko
make announcements and put out fliers, is that correct?
A. Yes.
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Q. Did he do so after you had given Mr. Vukadinovich the
preliminary determination letter?
A. Yes.
Q. So allowing Mr. Vukadinovich to put out fliers or make
announcements would have been for classes that were canceled,
correct?
A. Yes.
Q. Well, did it make any sense to encourage students to sign
up for classes that were canceled?
A. No.
MS. BUGALLA: One moment, Your Honor.
THE COURT: Sure.
MS. BUGALLA: Nothing else, Your Honor.
THE COURT: Do you have any redirect of this witness?
MR. VUKADINOVICH: Yes, Your Honor.
If I can have just one minute to get an exhibit.
MS. BUGALLA: I'm sorry. There's some exhibits I
need to put back.
THE COURT: Ms. Bugalla, also don't forget to include
N, O, P, and Q. Okay. They are up there.
REDIRECT EXAMINATION
BY MR. VUKADINOVICH:
Q. Mr. Biggs, every single one of your answers that you
responded to to your attorney here, were every one of those
answers just as truthful as all of your previous answers that
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you testified to when I questioned you?
A. Yes.
Q. Okay. So exactly the same degree of truthfulness?
A. Yes.
Q. You testified, did you not, that the CTE classes -- your
attorney asked you if I could have taught those type classes,
and you testified that I could not, is that correct?
A. Yes.
Q. Excuse me just for one minute.
As principal, are you familiar with the assignment codes
by the State of Indiana Department of Education?
A. Yes.
Q. Okay. What is that?
A. As I mentioned earlier, it is a grid that the State
issues, and in the columns it shows all the different kinds of
licenses that have existed over the years. And in the rows it
gives all the different kinds of subjects; so once you find a
subject that is being taught, then you can look at the
different licenses and see which particular license you would
need to teach that particular course.
Q. Okay. Now, this exhibit has not yet been admitted. It is
No. 153. Would you please describe what that is.
THE COURT: You may need to reduce the size of it.
Just use the handle on the top of the device. That way it will
blow it out. That way you can see the whole document.
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BY MR. VUKADINOVICH:
Q. Does that help you there?
A. Yes, it looks like a print-off of a section of the
assignment codes from the Department of Education in Indiana.
Q. Okay. Now, are you familiar with the Department of
Education CTE funding formula that they use?
A. Yes.
Q. And what is that?
A. It varies by course. There's a grant, and then there's a
CTE funding source that I'm less familiar with. But, yes, it
has -- for each course they designate it as high priority,
middle priority, and low priority; and they attach dollar
amounts to each course that are given according to each
student.
Q. I'm gonna draw your attention --
MR. VUKADINOVICH: Actually, I'm gonna move to admit
Exhibit No. 153, Your Honor.
THE COURT: Any objection?
MS. BUGALLA: Yes, Your Honor. It is only a portion.
It doesn't indicate really who wrote it or which year it
applies to. It is incomplete.
THE COURT: You are gonna need to lay some more
foundation as to what year this comes from, those sorts of
things, so we have some context for it.
MR. VUKADINOVICH: Okay.
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BY MR. VUKADINOVICH:
Q. Are you familiar with Bulletin 400?
A. That appears to be one of the license columns, yes.
Q. Okay. So you know what Bulletin 400 is, correct?
A. Yes.
Q. What is it?
A. It is a license designation.
Q. And then do you know if I was under Bulletin 400?
A. I believe you were. If not, Rules 46, 47. I would have
to look at your license to be sure.
Q. Do you see where it says Bulletin 400 on there?
A. I do.
Q. So would that apply to me then on my Bulletin 400?
A. Again, I would have to look at your license to be certain.
THE COURT: Mr. Vukadinovich, why don't you move on
to a new area, and I ask your assistant to come up and find the
license so we're not wasting time.
Sir, you know what he's looking for.
MR. VUKADINOVICH: It was a real early exhibit, like,
No. 3 or 4.
BY MR. VUKADINOVICH:
Q. Do you see on this exhibit where it says intro to -- it is
on the left side, 4796, you see that there?
A. Yes.
Q. And does it say Intro to Advance Manufacturing and
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Logistics?
A. Yes.
Q. Okay.
MS. BUGALLA: Your Honor, I'm going to object to
discussing this exhibit when we haven't admitted it because
there's not been any foundation.
THE COURT: Yeah. I want you to try to lay some
foundation for the document, and then you'll be free to talk
about it.
BY MR. VUKADINOVICH:
Q. Do you have any doubt that this document is the assignment
codes from the Department of Education?
A. No.
THE COURT: Do you know what year this came from?
MR. VUKADINOVICH: Your Honor, it is not on here. It
is pulled off of the computer here. It's not really stated on
here. So --
THE COURT: Well, I don't think there's a foundation
for it.
MR. VUKADINOVICH: Okay.
THE COURT: Do these things change year over year?
THE WITNESS: Yes.
THE COURT: Okay. I'm not gonna let you get into it
unless we have some foundation what we're talking about.
MR. VUKADINOVICH: Fair enough. Fully understood.
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BY MR. VUKADINOVICH:
Q. Are you familiar with the Indiana Department of Education
Colleges and Career Readiness?
A. I don't understand.
Q. Do you know who Peggy Wild is?
A. I've heard the name.
Q. Okay. If I said she was the state Director of Career and
Technical Education, would that ring a bell to you?
A. Yes.
MS. BUGALLA: What number is this, please?
MR. VUKADINOVICH: This will be a rebuttal exhibit,
actually, Your Honor, to what the attorney was questioning.
THE COURT: You are still in your case in chief, so
it is not technically a rebuttal exhibit. But just tell her
what exhibit number it is.
MR. VUKADINOVICH: Okay. I didn't label it as one,
so actually it will have to be -- the last number is 218, so it
will probably have to be 219 then.
THE COURT: Okay. We'll label it 219. Do you have a
copy of it?
MS. BUGALLA: No.
THE COURT: You need to give them a copy so they can
look at it first.
(Document tendered.)
BY MR. VUKADINOVICH:
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Q. This is No. 219, and it states up there, does it not, that
it's July 31, 2015?
A. Yes.
Q. Okay.
MR. VUKADINOVICH: And I would move to admit that,
Your Honor. It is 219.
MS. BUGALLA: Your Honor, I object. First of all, it
is hearsay because it is written by someone who is not here.
It is also applying to 2015-2016. We're talking about 2012 in
this case, so I don't see its relevance.
THE COURT: What's your response?
MR. VUKADINOVICH: Well, we're also talking about
2016 because part of the issues of the case is whether or not I
should have been terminated. I could have still been working
there today teaching these classes.
THE COURT: I'm gonna sustain the objection.
MR. VUKADINOVICH: Okay.
BY MR. VUKADINOVICH:
Q. Now, this -- your attorney asked you about this Ryan
Spencer. What classes did he teach?
A. He taught career and technical education courses including
Graphic Imaging and Technology, Commercial Art and Graphic
Design; both of those had a one and a two component. That was
it I think.
Q. And then how did that go? Did you actually hire him, you
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as principal?
A. I recommended him for employment.
Q. And how did that go? As far as did he do a good job for
the corporation?
A. Yes.
Q. Did he enjoy -- did he state to you that he enjoined doing
the work teaching --
MS. BUGALLA: Your Honor, I'm going to object to
anything Mr. Spencer stated. He is not here.
THE COURT: It sounds like it is a statement of state
of mind under 803(1), so I'm gonna overrule the objection.
Proceed.
BY MR. VUKADINOVICH:
Q. Did he state to you that he enjoyed working there or not
enjoyed working there?
A. I don't recall any conversations in either direction.
Q. Did he leave the corporation while you were the principal?
A. Yes.
Q. And why did he leave?
A. I don't know.
Q. Did he send you a letter and tell you that he wanted to
leave the corporation?
A. I believe he submitted a letter, but I heard over the
phone that he was resigning.
Q. Over the phone?
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A. He called and told me.
Q. Okay. And did he submit the letter to you?
A. No, I don't think.
Q. Do you know who he sent it to or it was submitted to?
A. I don't know.
Q. Okay. This is Exhibit No. 107 that has not been admitted.
Would you please identify this document.
A. Okay. That's a letter to me from Ryan Spencer.
Q. So when you said earlier that he did not submit a letter
to you, he, in fact, did submit a letter to you, correct?
A. That's correct, yes.
Q. Okay. And what's the date of the letter?
A. July 30, 2014.
Q. Okay. And is he expressing to you anything in the letter
about why he was leaving?
A. If you give me a moment to read over it.
Q. Sure.
A. Okay. Could you ask your question again, please.
Q. Is he expressing to you the reason he's leaving?
A. He says, "I feel that you are always available,
approachable, and provided useful insights. I've enjoyed my
experience. However, I am not cut out for the stress and
multitasking that comes with the job. Ultimately, I do not
feel that teaching is the right fit for me."
Q. Okay. So the teacher that you selected is telling you,
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"teaching is not the right fit for me"?
A. That's correct.
Q. And he left, correct?
A. Yes.
MR. VUKADINOVICH: I move to admit this, Your Honor.
THE COURT: Any objection?
MS. BUGALLA: No objection, Your Honor.
THE COURT: All right. It is admitted.
(Plaintiff's Exhibit No. 107, previously marked, was
admitted in evidence.)
BY MR. VUKADINOVICH:
Q. Did you replace him?
A. Did I put another teacher in to take his courses?
Q. Yeah. Did you take steps to advertise for the position
and so forth?
A. I don't --
THE COURT: What was the date of that just so I'm
clear?
MR. VUKADINOVICH: The letter, Your Honor?
THE COURT: Yeah.
MR. VUKADINOVICH: July 30, 2014.
THE WITNESS: No, I did not.
BY MR. VUKADINOVICH:
Q. Okay. Now, this has not been admitted. This is No. 108.
Would you please identify this document.
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A. I don't -- source, creative job central. It looks like
it's a piece of paper. I can't really give it a title. I
don't know. Graphic arts and design teacher.
Q. Can you see it now?
A. Yes, thank you.
It looks like a job posting, graphic arts and design
teacher wanted at Hanover. Yep.
Q. Okay. Is that also for 2014?
A. Date posted is September 5, 2014.
Q. Okay. And would that be for Mr. Spencer's job?
A. It wasn't his job at that point, but the position -- the
courses that he taught -- it appears that may have been the
same thing, but at that point I was not working for the school
district.
Q. Do you remember when your attorney asked you if I was
qualified to teach those classes?
A. Which classes?
Q. The graphic arts classes.
A. Could you repeat the question, please.
Q. Do you remember that your attorney asked you if I was
qualified to teach the graphic arts classes?
A. Yes.
Q. And what did you tell her?
A. No.
Q. Okay. Now, looking at this posting here for Hanover
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Central, what were the qualifications for that job?
A. Candidate must have a BA in computer applications, web
design, or graphic arts design. No Indiana or Illinois
certification required but preferred. All interested
applicants --
Q. Okay. So there was no certification required at all for
that job, correct?
A. From this statement, it says must have a BA in computer
applications, web design, or graphic arts design.
Q. And no Indiana or Illinois certification required,
correct?
A. That's correct.
Q. Okay.
A. That's what it says.
Q. So I wouldn't have been qualified for that job?
A. No.
Q. Even though there was no certification required?
A. The candidate must have a BA, a Bachelor's of Arts degree,
in computer application or web design or graphic arts design.
Q. Even though I had graphic arts on my license, I wouldn't
have been qualified?
A. You don't have a bachelor's degree in graphic arts though,
do you?
Q. Yes, I do.
THE COURT: This is the period where you ask
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questions. You are not testifying.
MR. VUKADINOVICH: I move to admit 108, Your Honor.
THE COURT: Any objection?
MS. BUGALLA: No objection.
THE COURT: 108 is admitted.
(Plaintiff's Exhibit No. 108, previously marked, was
admitted in evidence.)
THE COURT: Again, Mr. Vukadinovich, I'm gonna remind
you. I'm not trying to tell you how to do your work. It is
more helpful if you move to admit the exhibit and then when you
are talking to the witness about the exhibit I can display it
for the jury so they can follow along with what you're talking
about.
MR. VUKADINOVICH: Got it.
THE COURT: Okay.
MR. VUKADINOVICH: Yes.
THE COURT: Okay. Proceed.
MR. VUKADINOVICH: The N, O, P thing, those were
admitted?
THE COURT: Noel has them.
MR. VUKADINOVICH: Thank you.
BY MR. VUKADINOVICH:
Q. Did I hear you correctly that you said that under the
students -- those numbers underneath there that you said that
those were not the student numbers, is that correct?
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A. They were student numbers.
Q. Pardon?
A. They were student numbers.
Q. So, for example, on -- this is your Exhibit N where it
says under fine arts there, that would be one student in that
class?
A. I'm having trouble finding fine arts.
Q. It is about two-thirds of the way down.
A. I can't tell what this is a listing of.
MS. BUGALLA: What exhibit is this?
MR. VUKADINOVICH: This is N. N.
BY MR. VUKADINOVICH:
Q. Okay.
A. So from Exhibit N. That was the master schedule that I
had looked at previously?
Q. Yes.
A. Okay.
Q. And my question is, is that's class -- that's one student
in that class?
A. Which class now?
Q. The fine arts class taught by --
THE COURT: The Advanced Concert Band about a little
less than halfway down.
THE WITNESS: Okay. So Advanced Concert Band.
There's period one, two -- looks like James Lowry. Okay. And
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then there's Advanced Concert Band; period six; semester two.
Fine arts; one student; max seats, 60.
BY MR. VUKADINOVICH:
Q. So is that one student in that class?
A. Not necessarily.
Q. Isn't that what it says?
A. Yes.
Q. But it is not necessarily one student even though it says
it?
A. You asked me if it is one student in a class.
Q. Yeah.
A. By the time fall hits, if there is one student in that
class, then it would be difficult to have a band in one period.
There are also combined sections occasionally. I don't see
that occurring here. But for one student to be requesting or
enrolling in that course on this master schedule may or may not
mean that there's one student -- there's one student that is in
the class when the class occurs.
Q. This is for the 2011-2012 school year, correct?
A. I can't tell.
Q. You have to --
THE COURT: You have to scroll it down,
Mr. Vukadinovich.
THE WITNESS: Okay. Yes.
\\\
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BY MR. VUKADINOVICH:
Q. That's the same year you made the decision to terminate
me, correct?
A. I disagree with your question, sir.
Q. Did you take steps to have me terminated as a teacher at
Hanover in 2011-2012?
A. Yes.
Q. And this is the same year as this document here, correct?
A. Yes.
Q. Okay. And did I have any classes with just one student in
them?
A. No.
Q. Did that particular teacher there get fired?
A. No.
Q. Okay. Let's take a look at the one down here,
Marcia Gross. It is actually about six or seven right below
it.
A. I see it.
Q. You see the 11 there?
A. Yes.
Q. Did she get fired with 11 students?
A. No, but she also had, it looks like, two sections.
Q. I'm asking you if she got fired with 11 students?
A. No.
MS. BUGALLA: Your Honor, he has --
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THE COURT: He has a right to explain his answer.
THE WITNESS: As I'm looking at this, I'm looking at
the period. In that column where it says "expression," the
expression means which period did the class occur? In this
case --
THE COURT: Sir, don't flip it. He's trying to
answer the question.
MR. VUKADINOVICH: I'm sorry.
THE WITNESS: In this case, I'm looking at period 6A
through C. The A through C is not as important, but the period
six is. So if Marcia Gross has two period sixes, which I
thought I saw that she did. She does not. Then semester one
she would look like she had 11, and then semester two she would
have 13, so, no, she wasn't fired.
Q. And she had 11 students in one class and 13 students in
another class, correct?
A. Same period, different semester.
Q. Okay. Now, when the guidance counselor Ms. Satterfield
told you that 15 students, I believe it was, wanted my
transportation class, and 17 students wanted my manufacturing
class, you told her to put them in other classes, correct?
A. Yes.
Q. And yet we have teachers here with one student and 11
students in their classes and those classes resumed, correct?
A. Yes.
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Q. Okay. Now, I'm not gonna go -- I'm certainly not going to
go through all of these. And let's just look at a couple more
examples, and then we'll move on. This sheet, I'm turning the
page on the same exhibit, and please look at the row -- there
are there a bunch of classes there with, like, one, five, six,
seven students in them?
A. Yes.
Q. Okay. And how about the next page where -- with all of
the -- these are nonspecial ed classes. These are regular
classes.
A. Not true.
Q. How about that row there. What's the highest number of
students in that entire row?
A. Sir, these are special education students.
Q. The government classes and physics classes?
A. Yep.
Q. And math classes?
A. Yep.
Q. Those are all special ed?
A. Yep.
Q. Okay. I stand corrected.
But the other one that we were talking about was not,
correct?
A. On the one that you mentioned the first time, they were
overlapping sections, so the same teacher is listed for the
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same period. So even though there was a single subject shown
with a single student in the class, that teacher was also
responsible for teaching different subjects in the same time
period.
So you'd have Algebra II -- that didn't happen as often as
Algebra I or you'd have Earth Science happening at the same
time as Environmental Science. Pam Maurer is a special ed
teacher and so is Tammy Shepard, and that's why it shows the
number one.
Q. Okay. Was Miss Harrigan a special ed teacher?
A. Though she had probably special education students in her
class, she was not specifically certified for special ed, no.
Q. Well, because don't they put special ed students -- they
try to mainstream them into the classes?
A. Sometimes, yes.
Q. Did I have any special ed students?
A. I don't recall.
Q. But they mainstream them in into the regular classes?
A. It depends on the student's individual plan.
Q. And was Mrs. Harrigan a special ed teacher?
A. No.
Q. She was a regular teacher, is that correct?
A. Yes.
Q. How many students did she have?
A. Nine.
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Q. Did she get fired?
A. Not as far as I know, no.
Q. Did you have her terminated?
A. I'm sorry?
Q. Did you have her terminated?
A. I didn't recommend her for termination, no.
MR. VUKADINOVICH: You want these back, Noel?
THE COURT: Just put them back up there.
BY MR. VUKADINOVICH:
Q. Okay. Now, you talked about -- when your attorney was
questioning you -- about a bunch of classes that were canceled
Do you recall that?
A. There were a bunch of classes that were canceled, yes.
Q. Okay. And then you testified, did you not, that there
were other classes -- these classes were canceled but other
classes then were created and kind of took the place?
A. They were created. I don't think they took the place.
Q. Okay. Now, when those classes were canceled, did any of
those teachers get fired?
A. Yes.
Q. Who?
A. If you pull up the list for me, I can show -- Jamie
Julian's contract was not continued. Angela Lowe's contract
was not continued. I don't want to guess any further, but I
know those two.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- REDIRECT
Q. And let's talk about Jamie Julian. How many classes did
she teach?
A. Two. One or two.
Q. She have any benefits?
A. I don't know.
Q. She got paid for one period a day then, is that correct?
A. I don't recall. It was one or two.
Q. Okay. No other full-time teachers?
A. What's the question, sir?
Q. Did any other -- when these classes were canceled, other
than the teachers who taught one or two classes, did any other
teachers -- full-time teachers get fired after these classes
were canceled?
A. Can you simplify your question 'cause there's a lot to
that one.
Q. When the classes were canceled, I'm talking about
full-time teachers now, not the one- or two-period teachers,
okay, did any of those teachers get fired even though their
classes were canceled?
A. Full-time classes?
Q. Yes.
A. There were the two teachers that I mentioned whose
full-time classes -- I mean, the one period was discontinued.
There was another, I think she taught two periods, that was
discontinued. Were there any other full-time teachers RIF'd at
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that time, no.
Q. Those were not full-time teachers, correct; they only
taught one or two classes?
A. Correct.
Q. So my question is, so we're clear, did any other -- did
any full-time teachers get fired?
A. No.
Q. Even though their classes were canceled?
A. Correct.
Q. They were accommodated?
A. No.
Q. Well, they kept their jobs, correct?
A. I'm not sure what you mean by accommodated.
Q. How did they keep their jobs if their classes were
canceled?
A. I don't understand.
Q. If you -- if you cancel the teachers' classes, how could
the teacher keep the teaching job?
A. They taught other courses.
Q. Okay. And how did that happen when their classes -- were
there other courses that you created for them?
A. No, I didn't create the courses for the teachers.
Q. Well, there were courses there that they stepped into and
taught, correct?
A. Yes.
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Q. Well, they had to be created, didn't they, because they
left their jobs that they canceled the classes and they stepped
into these other classes?
A. They were created for the students, to help the students
be better prepared for life after high school.
Q. Okay. All right. They were classes that were created
after their other classes were canceled, is that fair?
A. They were added, yes.
Q. Pardon?
A. They were added.
Q. Okay. Did -- after -- was there any -- why wasn't any
classes added for me?
A. I don't know.
Q. Did you discuss it with Ms. Kaiser?
A. No.
Q. Why not? You did it for those other teachers.
A. It wasn't my decision.
Q. Whose decision was it?
A. Ms. Kaiser.
Q. Okay. Was it also Ms. Kaiser's decision to cancel my
classes?
A. Yes.
Q. And at what point in time were the classes canceled?
A. At the end of the 2011-2012 school year.
Q. When was the decision made?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- REDIRECT
A. The preliminary decision was made May 2, 2012.
Q. Okay. And when was it set in stone?
A. At the subsequent board meeting. I believe -- I don't
want to guess the date, but it was after that.
Q. So between May 2 when you gave me the letter that you call
the preliminary decision and June 11 those classes actually
weren't set in stone to be canceled?
A. No, they were canceled.
Q. At what point?
A. As soon as we entered it into the master schedule.
Q. And when was that?
A. I'm not sure of the date.
Q. Approximately?
A. Sometime in May.
Q. Pardon?
A. Sometime in May.
Q. Sometime in May. Okay.
THE COURT: Mr. Vukadinovich, you have to start
wrapping it up.
MR. VUKADINOVICH: Yes, Your Honor.
BY MR. VUKADINOVICH:
Q. Now, you had -- you were talking about the new school, the
middle school. You were talking about when your attorney was
asking you about the new classes that were, you know, made out
there to accommodate the new building and so forth. Could
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JUSTIN BIGGS- REDIRECT
there have been classes out there that I taught?
A. Could there have been?
Q. Yes.
A. I can't speculate.
Q. Well, as a principal -- and there was a brand new building
going up. Did you hear me testify that I actually helped
design the class for the industrial technology classes out
there?
A. I did hear your statements, yes.
Q. Okay. So could there have been classes, Project Lead the
Way classes, middle school classes, that I taught?
A. I can't speculate.
Q. Now, you were the principal when I was teaching Project
Lead the Way in middle school, correct?
A. Yes.
Q. Why wasn't I teaching it the following year?
A. Because you were given a notice to discontinue your
contract.
Q. Okay. But why? Why -- I taught high school, and I taught
middle school, correct?
A. Yes.
Q. And what was the specific reason that I was not teaching
the middle school Project Lead the Way the following year, the
specific reason?
A. Because the course was eliminated.
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Q. And what was the reason that it was eliminated?
A. I don't know.
Q. Did you ever talk -- do you know Mr. Hiatt?
A. I do.
Q. Did you ever talk to Mr. Hiatt about my employment?
A. I have.
Q. Okay. Now, was Mr. Hiatt -- was he my principal?
A. No.
Q. Did he have any authority over me at all?
A. I don't know.
Q. He clearly was not my principal, correct?
A. That's true.
Q. Okay. Was Mr. Hiatt involved with meetings with you and
Ms. Kaiser about my employment?
A. No.
Q. No?
A. No.
THE COURT: He just answered no.
MR. VUKADINOVICH: Okay.
BY MR. VUKADINOVICH:
Q. All right. Now, did you have Mr. Hiatt handle any of my
personnel information?
A. No.
MR. VUKADINOVICH: I'm wrapping it up here, Your
Honor.
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BY MR. VUKADINOVICH:
Q. Did Ms. Kaiser consult with you on her recommendation in
any way to -- for my termination?
A. No.
Q. So there was no discussion between you two about my
classes possibly continuing on? It was just decided they
weren't gonna happen, is that correct?
A. That's correct.
Q. Now, you -- your attorney asked you about the meeting that
we had on May 2, 2012, and you say that you didn't make those
comments to me?
A. That's true.
Q. And you said there was nobody else present in the office,
is that correct?
A. Yes.
Q. Okay. You had me come in several times after that for
several disciplinary meetings, is that correct?
A. No.
Q. No?
A. (No response.)
Q. Did you not have me come in about the thing about the
library?
A. I did.
Q. Okay. Did you not have me come in about the thing about
the testing procedure?
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- REDIRECT
A. I did.
Q. Didn't you call that a disciplinary meeting?
A. No.
Q. You didn't put that on the e-mail?
A. I said it may be disciplinary.
Q. Okay. Was there -- did you have anybody else in there
when I came in there for the meeting?
A. Yes.
Q. Okay. And who was it?
A. Mr. Brooks.
Q. Okay. Anybody else?
A. Not that I recall.
Q. How about Mr. Bachinski?
A. Yes, he was there.
Q. Okay. Now, why is it that you had -- were they there as
witnesses?
A. Not both. One was. One was not.
Q. Which one was?
A. Mr. Brooks was.
Q. Okay. Did you have a witness when you called me in on May
2?
A. No.
Q. So when we had our face-to-face in there, you didn't have
any other witnesses in there then?
A. No.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- REDIRECT
Q. Correct?
A. Correct.
Q. But then after that you did, correct?
A. Yes.
Q. This is Plaintiff's Exhibit 110. I'll ask you to identify
it.
A. It's an affidavit of Justin Biggs, that's me.
MR. VUKADINOVICH: I move to admit 110, Your Honor.
THE COURT: Any objection?
MS. BUGALLA: I need to see the whole thing, Your
Honor. I've only seen part of it.
THE COURT: Give her the entirety of the document,
please.
(Document tendered.)
THE COURT: This was 110, is that correct?
MR. VUKADINOVICH: Yes. Your Honor.
MS. BUGALLA: Your Honor, this is Mr. Biggs'
affidavit submitted in conjunction with the motion for summary
judgment. I'm not sure what relevance it has here since he's
sitting here on the stand.
THE COURT: Yeah. It's an out-of-court statement.
You can confront him if he has said something different here in
court and confront him with his prior statement, but the
document itself is not admissible.
MR. VUKADINOVICH: Very good.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- REDIRECT
BY MR. VUKADINOVICH:
Q. Did you submit an affidavit, sign your name to it?
A. Yes.
Q. To this Court?
A. I don't know if it was this Court.
Q. Okay. Did you deny on the affidavit that you made the
comments to me on May 2?
A. I don't recall if it says that on the affidavit or not.
MR. VUKADINOVICH: I'd like to ask permission to show
it to him, Your Honor.
THE COURT: Sure.
THE WITNESS: No, I didn't say that.
BY MR. VUKADINOVICH:
Q. You didn't say what?
A. I didn't deny that you -- that I had made any statements
on May 2 on that affidavit.
MS. BUGALLA: Your Honor, I object to this.
THE COURT: Yeah, sustained. This isn't impeachment.
It is -- he didn't testify to the contrary here.
MS. BUGALLA: Can we move to strike that answer?
THE COURT: Yeah, it is stricken, and the jury is
admonished to disregard that.
MR. VUKADINOVICH: Just one minute, Your Honor, and
we're gonna be finished here.
\\\
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- RECROSS
BY MR. VUKADINOVICH:
Q. You remember telling your attorney that the enrollment
numbers fluctuate?
A. Yes.
Q. So they do change once -- the number may be low then later
on the number can become a higher number, correct?
A. Yes.
Q. Could my class numbers have fluctuated and became higher
numbers?
A. No.
Q. No?
A. No.
Q. Why not?
A. Because they were canceled.
MR. VUKADINOVICH: That's all, Your Honor.
THE COURT: Any recross?
MS. BUGALLA: Very briefly, Your Honor.
RECROSS-EXAMINATION
BY MS. BUGALLA:
Q. Mr. Biggs, you were in the courtroom when Mr. Vukadinovich
took the stand and testified, were you not?
A. Yes.
Q. And since you were here you heard him tell the jury that
he attended Indiana State University and received a Bachelor's
of Science in 1974 in Physical Education and Health and Drivers
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Page 169
Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS- RECROSS
Ed, did you not?
A. Yes.
Q. And that does not indicate that he had a bachelor's in
graphic arts, does it?
A. No.
Q. He has asked you repeatedly about numbers, who had this
number, who had that number. Did numbers determine which
classes got canceled?
A. No.
Q. You were also asked about couldn't classes have been
created for him. Are classes created for the teachers?
A. No.
Q. Are they created for the students?
A. Yes.
Q. He asked you about how come teachers had their classes
canceled but didn't lose their jobs. Was that because they had
licenses that allowed them to teach the classes that were
offered?
A. Yes.
Q. And was it Mr. Vukadinovich's choice to have a license
that didn't allow him to teach any classes that were offered?
A. Yes.
Q. When you met with Mr. Vukadinovich on May 2, up until that
time, had you had any difficulty with him?
A. No.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS - REDIRECT
Q. Had he been friendly to you?
A. Yes.
Q. After that meeting, did his behavior change?
A. Yes.
Q. Is that why you thought it was necessary to have witnesses
whenever you met with him again?
A. Yes.
MS. BUGALLA: Nothing further, Your Honor.
THE COURT: Very briefly. Limited to what she asked?
MR. VUKADINOVICH: Yes, very brief, Your Honor.
Actually, basically, one question.
REDIRECT EXAMINATION
BY MR. VUKADINOVICH:
Q. Now, you said that the classes are for the students, is
that correct?
A. Yes.
Q. And did the students want -- did they request my classes?
A. There were several that did, yes.
Q. Okay. And were they able to take the classes after they
requested my classes?
A. No.
Q. But it is for the students, the classes, correct?
A. Yes.
Q. Okay. Thank you.
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Stacy L. Drohosky, FCRR, CRR, RPR(219) 852-3462 - [email protected]
JUSTIN BIGGS - REDIRECT
MR. VUKADINOVICH: That's all, Your Honor.
THE COURT: All right. Sir, you may step down.
Thank you.
* * *
(End of requested transcript.)
CERTIFICATE
I, Stacy L. Drohosky, certify that the foregoing is a
correct transcript from the record of proceedings in the
above-entitled matter.
Date: March 28, 2016 S/Stacy L. Drohosky S/STACY L. DROHOSKY Court Reporter U.S. District Court
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BY MR. VUKADINOVICH: [81] 2/14 6/10 7/20 8/13 9/11 9/16 11/1 13/2 14/1 17/14 19/4 22/2 23/4 23/19 25/1 29/9 31/8 35/8 42/18 43/20 44/14 45/1 45/23 46/25 48/3 49/10 52/22 53/11 57/12 58/15 59/18 60/3 61/2 61/20 63/5 66/25 70/22 71/22 74/17 74/25 78/7 80/1 81/14 82/14 83/14 84/1 84/20 85/21 87/19 88/8 90/20 92/8 94/1 96/19 99/14 102/11 103/4 104/20 138/21 139/25 140/25 141/20 142/9 142/25 143/24 144/17 145/12 147/10 147/22 150/21 151/11 152/2 152/24 157/8 161/20 163/19 163/25 166/25 167/12 167/24 170/12 BY MS. BUGALLA: [8] 106/4 117/5 118/24 124/22 133/18 134/14 136/24 168/18 DEPUTY CLERK: [4] 5/16 43/15 64/9 118/14 MR. BUELL: [2] 116/23 116/25 MR. VUKADINOVICH: [124] 2/4 5/13 5/22 6/1 6/5 6/8 7/13 10/18 12/21 21/25 23/16 29/5 30/25 31/2 31/6 42/14 43/16 43/18 44/8 44/20 44/25 45/16 45/18 49/9 52/20 53/3 57/1 57/6 57/9 58/14 59/5 59/14 59/17 59/23 60/21 61/14 63/3 63/17 64/5 64/14 64/23 65/1 65/4 65/17 65/22 65/24 66/1 66/10 66/12 66/14 66/22 70/18 71/15 74/13 76/7 76/21 76/23 76/25 77/2 77/10 78/2 78/5 81/3 81/13 82/13 84/17 84/19 87/16 93/20 96/4 96/6 96/14 99/7 102/4 102/9 102/15 102/23 104/13 104/15 104/19 105/12 105/16 105/23 116/9 116/12 124/1 124/6 124/8 124/20 133/12 138/14 140/15 140/24 141/18 142/14 142/19 142/24 143/10 143/15 144/4 144/11 144/16 147/4 147/18 147/20 150/1 150/13 150/15 150/17 150/20 151/10 154/7 157/6 161/19 163/18 163/23 166/7 166/15 166/24 167/8 167/22 168/14 170/9 170/24 MS. BUGALLA: [92] 5/15 7/9 7/16 8/11 9/9 9/13 10/21 12/23 13/23 17/7 19/2 22/21 31/5 31/7 43/17 43/19 44/10 45/8 45/12 53/6 57/4 59/7 60/23 61/16 64/12 65/10 65/13 65/19 65/23 65/25 66/6 70/17 71/18 74/20 76/10 80/10 80/16 80/19 80/23 81/4 81/6 81/8 82/7 83/18 88/2 92/1 93/22 96/8 99/9 102/14 105/15 105/20 116/3 116/8 116/10 116/16 116/20 116/24 117/1 117/23 118/3 118/17 123/24 124/2 124/4 124/7 124/12 124/18 124/21 133/9 133/14 134/13 136/23 138/10 138/12 138/16 140/18 142/3 143/9 143/20 144/6 145/7 147/6 150/3 151/9 153/24 166/9 166/16 167/16 167/19 168/16 170/7 NEW SPEAKER: [1] 105/22 THE COURT: [193] THE WITNESS: [21] 2/10 9/15 46/21 46/23 60/2 64/1 70/19 79/22 84/25 85/19 90/17 92/7 102/16 103/1 142/21 147/21 151/23 152/23 154/1 154/8 167/11
$$10,000 [1] 12/1
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''cause [2] 83/13 158/14
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55-14-3 [1] 23/255400 [1] 1/22
660 [1] 152/26A [1] 154/9
772 [5] 5/12 6/12 7/15 7/16 7/19
773 [3] 10/9 10/20 10/2574 [4] 11/3 12/22 12/23 13/175 [1] 13/1078,000 [4] 11/12 11/12 12/8 12/1679 [3] 102/13 102/16 106/2
880 [4] 43/13 43/19 44/10 44/13803 [1] 145/1181 [4] 44/18 45/19 45/22 136/1482 [4] 70/16 70/19 71/16 71/2185 [7] 11/10 61/4 61/16 61/19 63/4 117/15 135/2585,000 [1] 11/13852-3462 [1] 1/23
9956-2462 [1] 1/1397 [1] 117/1598 [4] 59/20 60/22 61/1 135/1399 [7] 57/14 59/6 59/10 116/12 116/15 116/17 134/9
Aa.m [1] 99/6ability [2] 16/9 16/11able [10] 64/20 68/2 69/8 69/13 77/12 96/13 104/2 131/1 136/20 170/19about [167] 5/3 12/12 14/10 15/10 15/14 16/16 16/23 17/6 17/19 17/22 17/23 18/24 19/13 21/3 21/7 21/12 23/12 23/13 25/8 26/12 27/10 27/15 28/25 29/2 29/21 31/12 31/14 32/6 32/6 32/22 32/25 33/10 33/13 35/25 36/2 37/3 37/7 38/10 40/1 41/5 41/8 41/12 41/12 41/13 41/14 41/15 41/18 41/22 42/16 42/20 42/25 43/10 48/2 48/12 53/13 54/1 54/22 55/3 55/19 55/25 56/1 57/8 67/7 71/8 72/12 72/17 72/20 73/15 73/17 74/16 74/17 75/14 77/19 77/22 77/24 78/3 79/11 83/13 86/2 86/12 86/14 87/13 89/25 90/9 90/13 91/23 92/4 94/13 94/14 94/16 95/24 96/17 96/19 98/2 98/5 98/6 98/8 98/9 98/17 98/20 98/21 98/23 99/20 100/15 100/20 100/22 101/4 101/11 108/5 108/8 109/5 109/9 109/14 110/21 112/24 113/1 113/4 113/10 114/2 114/13 114/19 115/24 117/10 117/20 119/11 123/11 124/24 128/20 133/23 133/24 134/18 135/13 136/15 137/23 142/9 142/24 144/9 144/12 144/19 146/15 150/11 150/13 151/8 151/22 153/16 155/8 155/12 155/22 157/10 157/11 158/1 158/16 161/22 161/23 161/24 163/5 163/14 164/5 164/9 164/21 164/21 164/24 164/24 165/13 169/6 169/10 169/15above [5] 38/19 71/1 80/9 99/5 171/9above-entitled [1] 171/9absolutely [7] 65/1 66/15 107/7 108/17 110/4 111/22 135/6abundantly [1] 84/16abuse [1] 100/23abused [5] 34/15 34/16 100/14 101/8 101/9abusing [1] 34/19accede [1] 22/23accepted [1] 8/10
accommodate [2] 22/21 161/25accommodated [2] 159/10 159/13accommodating [2] 44/6 49/1accompanied [1] 21/14accompanying [1] 22/5according [9] 11/16 24/19 51/3 85/15 90/7 91/6 93/1 100/14 140/13Accounting [1] 129/22accurate [1] 123/22accusation [1] 85/4accusations [1] 33/13accusatory [5] 33/6 33/19 33/22 33/24 37/12accuse [1] 34/19acknowledging [1] 21/17action [9] 33/8 33/20 38/22 38/25 39/2 39/6 40/7 51/3 51/5actual [13] 6/19 12/7 22/4 41/18 55/19 81/20 84/22 86/1 90/1 91/7 91/9 99/16 102/22actually [36] 25/3 28/2 28/4 30/7 36/5 36/24 40/21 61/8 65/18 67/2 67/6 67/15 68/10 68/20 71/8 88/25 90/7 90/22 91/10 91/17 94/7 96/24 97/2 97/23 125/14 132/12 132/21 135/7 140/16 143/12 143/17 144/25 153/16 161/6 162/6 170/11add [1] 130/18added [14] 114/4 123/12 126/7 127/10 127/16 127/18 127/23 128/14 128/16 131/13 133/8 160/8 160/10 160/12addition [3] 106/23 129/11 130/6additional [8] 12/1 12/17 120/4 127/18 128/13 130/18 130/19 136/21address [4] 15/22 16/6 28/24 111/17addressed [1] 94/9adequately [1] 52/1Adler [10] 6/14 6/21 52/25 53/16 66/2 92/15 92/17 93/2 93/15 94/13administered [2] 2/10 34/22administration [2] 38/11 49/2administrative [12] 38/20 38/22 39/1 39/2 39/6 39/11 40/6 40/11 80/1 81/2 102/17 103/9administrator [2] 39/8 105/2administrators [1] 48/12admissible [1] 166/24admission [1] 123/25admit [22] 7/14 10/19 12/22 44/9 44/22 53/4 57/2 59/6 60/22 61/15 71/16 76/8 93/21 96/16 105/17 133/10 140/16 144/5 147/5 150/2 150/10 166/8admitted [70] 5/21 5/25 6/5 7/18 7/20 10/23 10/24 11/1 12/25 13/2 23/18 23/22 38/3 44/12 44/14 44/19 44/25 45/20 45/23 49/20 53/8 53/11 57/3 57/4 57/6 57/15 59/9 59/11 59/13 59/14 59/20 60/25 61/2 61/4 61/18 61/20 63/4 70/15 71/20 71/22 74/3 79/17 85/16 92/13 93/24 94/1 95/14 96/10 96/12 96/17 98/11 99/11 99/14 102/14 105/25 106/3 116/5 124/10 124/12 133/16 133/17 139/21 142/5 146/6 147/8 147/10 147/24 150/5 150/7 150/19admonished [2] 17/12 167/22admonishments [2] 33/7 33/20admonitions [1] 63/20advance [3] 109/20 112/5 141/25Advanced [4] 131/17 151/22 151/24 152/1
adverse [5] 38/22 38/25 39/2 39/6 40/7advertise [1] 147/14affidavit [6] 166/7 166/18 167/2 167/6 167/8 167/16after [33] 13/17 14/20 14/22 20/21 20/24 21/1 21/16 29/19 32/3 32/16 34/20 34/21 64/3 65/19 96/23 97/1 97/4 97/6 101/25 102/3 109/6 123/16 124/25 138/1 158/12 160/5 160/7 160/11 161/4 164/16 166/3 170/3 170/19afternoon [1] 106/6again [26] 9/7 9/14 21/20 21/21 41/4 60/18 65/8 70/7 73/14 74/13 76/20 78/17 83/13 83/14 83/19 83/20 92/6 109/15 110/25 117/20 132/4 136/10 141/14 146/18 150/8 170/6against [9] 19/25 20/4 20/9 33/8 33/20 38/16 77/14 101/22 130/24ago [1] 4/14agree [7] 21/16 42/7 42/9 73/2 78/17 82/11 85/6agreement [7] 74/6 74/19 75/10 76/12 76/19 77/7 77/23Agriculture [1] 132/11ahead [8] 28/21 35/17 45/21 90/17 96/19 98/24 98/24 102/7aided [1] 1/25al [1] 1/5Algebra [2] 156/5 156/6all [100] 2/3 2/3 2/12 7/18 9/8 10/15 10/23 19/12 23/1 24/6 25/25 30/12 34/23 40/10 41/19 42/2 42/4 45/20 53/8 53/13 58/8 59/9 61/18 64/3 64/10 66/20 66/21 71/20 75/20 76/15 80/5 80/16 81/7 81/13 82/16 83/12 84/15 89/13 98/17 103/8 103/12 103/12 103/16 104/14 104/25 105/13 105/22 105/25 107/2 108/3 108/16 112/14 115/11 115/16 116/11 116/17 116/20 116/21 117/14 117/23 118/1 118/4 118/15 118/16 118/22 123/5 123/17 123/24 124/5 124/10 124/24 125/16 126/25 127/10 128/8 128/16 128/20 128/21 128/25 129/16 130/3 131/13 133/16 136/14 138/25 139/15 139/17 144/7 147/8 149/4 149/6 155/2 155/8 155/19 160/6 163/9 163/21 168/15 171/1 171/2allegation [6] 19/25 20/1 20/4 20/9 77/24 112/18allegations [1] 108/2alleged [7] 14/14 77/23 85/3 109/10 111/6 113/4 113/8allegedly [2] 112/19 113/4allotted [1] 34/23allow [2] 122/20 169/21allowed [6] 36/5 49/12 82/6 94/19 130/13 169/17allowing [1] 138/4almost [3] 89/6 89/21 90/7along [8] 28/19 31/5 44/24 45/11 65/4 77/17 96/14 150/12already [10] 17/25 18/1 18/4 25/1 51/1 57/3 69/22 70/3 70/5 102/1also [27] 12/17 17/10 32/9 40/19 68/5 79/10 79/12 81/24 92/24 93/3 94/20 109/9 110/21 122/18 125/25 129/22 131/4 137/15 138/19 144/9 144/12 148/8 152/14 153/22 156/2 160/20 169/10although [4] 8/5 14/25 59/22 128/6
Aalways [1] 146/20am [8] 2/24 32/15 71/24 81/19 82/25 99/8 134/10 146/22amongst [2] 63/21 118/9amount [1] 10/16amounts [1] 140/13analysis [6] 87/9 87/14 87/22 90/4 93/11 115/24Angela [2] 129/20 157/23Animation [1] 129/3announcements [2] 137/24 138/5another [11] 34/21 49/12 75/17 91/25 111/11 132/2 134/22 137/16 147/13 154/16 158/24answer [25] 3/25 4/15 4/21 33/16 39/4 42/8 44/7 49/3 51/24 56/9 70/7 73/1 75/7 78/18 79/3 82/25 83/24 85/25 88/2 90/16 100/17 100/18 154/1 154/7 167/20answered [3] 25/1 44/16 163/18answering [1] 74/14answers [4] 117/7 138/23 138/25 138/25any [96] 3/18 4/14 7/16 8/11 10/21 12/12 12/23 13/5 13/8 13/13 16/11 17/18 19/1 19/15 20/14 20/18 20/21 20/23 28/16 33/22 33/24 34/20 38/18 41/5 41/8 42/4 42/6 42/10 42/20 48/12 48/13 53/6 58/20 58/22 64/4 71/18 75/4 76/1 76/10 76/14 82/3 85/15 93/7 93/22 95/12 99/9 105/19 107/21 108/15 108/18 108/23 109/22 111/20 111/23 112/8 112/12 121/9 122/4 123/2 128/18 130/17 130/18 133/7 133/12 136/7 137/2 138/8 138/14 140/18 142/6 142/11 145/16 147/6 150/3 153/10 156/16 157/18 157/24 158/4 158/10 158/11 158/18 158/25 159/5 159/6 160/11 160/11 163/9 163/21 164/3 165/24 166/9 167/15 168/16 169/21 169/24anybody [12] 15/2 18/5 30/1 30/4 30/5 30/10 30/16 100/12 101/9 101/17 165/6 165/11anybody's [1] 136/11anymore [1] 68/21anyone [1] 112/23anyone's [1] 117/16anything [37] 4/1 4/3 4/7 4/17 4/18 12/13 17/18 21/7 21/19 21/21 26/4 28/18 28/18 33/10 33/13 35/2 35/10 37/17 39/15 40/4 40/11 42/10 55/25 56/1 56/13 58/24 82/3 86/12 99/25 107/18 108/5 112/10 133/23 133/24 134/5 145/9 146/14apologize [2] 80/11 116/6appear [1] 123/22appears [10] 11/5 23/23 24/21 53/3 53/16 59/22 60/16 61/13 141/3 148/12applicable [1] 85/3applicants [1] 149/5application [2] 6/20 149/19applications [3] 128/14 149/2 149/9applied [5] 5/5 5/10 6/16 7/2 7/7applies [1] 140/21apply [5] 5/6 7/5 13/4 13/8 141/13applying [2] 13/19 144/9Approach [1] 5/18approachable [1] 146/21
appropriate [7] 20/6 20/11 20/13 20/15 20/19 20/24 25/18appropriately [1] 69/19approving [2] 49/23 50/2approximately [3] 96/23 101/25 161/13April [2] 43/25 71/5April 3 [1] 43/25April 9 [1] 71/5Arden [5] 46/1 46/7 125/17 129/25 130/3are [129] 2/19 3/16 3/21 4/14 4/15 8/8 9/8 9/8 9/13 10/3 15/17 17/12 22/17 23/18 27/15 27/23 31/14 32/5 33/14 44/1 44/23 45/8 45/16 46/7 46/16 55/15 55/18 55/22 57/9 57/11 60/9 60/14 61/11 62/7 62/15 62/21 64/18 64/21 65/6 65/7 65/8 68/10 68/16 69/10 70/24 74/13 75/2 75/9 75/18 75/23 75/24 76/6 77/9 77/14 79/5 79/6 80/3 80/10 80/12 80/15 80/17 81/16 83/11 85/24 86/2 86/3 86/18 87/25 88/4 88/4 92/3 92/23 94/13 94/13 96/4 96/6 96/8 96/19 99/7 100/15 102/20 103/13 103/19 104/9 114/24 114/24 115/5 115/17 116/20 117/12 117/12 119/20 119/22 119/23 120/1 120/8 123/15 124/10 125/1 125/8 131/14 131/14 133/23 133/24 134/2 134/18 135/16 135/18 136/5 138/20 139/10 140/5 140/13 140/22 141/2 143/2 143/13 146/20 150/1 150/11 152/14 155/5 155/9 155/9 155/14 155/19 169/11 169/13 170/14area [7] 2/22 8/10 11/6 121/1 121/12 127/14 141/16areas [3] 68/1 68/2 91/2argument [1] 19/20argumentative [2] 7/11 7/13around [5] 34/25 49/13 50/15 94/20 105/6art [9] 6/4 13/14 13/19 13/22 126/17 127/14 132/6 132/6 144/22artist [1] 120/19arts [39] 25/21 68/5 68/9 68/10 68/15 68/20 72/10 92/16 92/21 93/5 119/13 120/22 121/9 121/12 121/22 122/2 127/23 127/25 128/2 128/7 128/8 129/6 132/7 132/9 148/3 148/6 148/18 148/21 149/3 149/9 149/18 149/19 149/20 149/22 151/5 151/7 151/21 152/2 169/4as [113] 2/18 6/21 12/4 12/4 12/7 12/7 12/7 15/15 21/20 26/22 26/25 26/25 28/8 30/22 33/4 37/5 37/7 38/3 42/5 44/6 44/6 49/20 53/17 53/25 53/25 55/14 55/14 64/8 64/17 64/17 67/20 67/20 68/1 68/7 68/20 69/15 69/19 69/21 70/12 72/16 72/24 75/3 75/9 78/4 78/9 78/24 79/2 79/12 80/13 81/23 81/23 81/24 82/20 82/22 82/24 83/3 84/3 85/16 89/6 89/6 89/16 89/16 90/8 92/3 92/10 95/13 96/19 98/8 100/14 104/18 104/18 104/22 105/2 107/4 113/18 113/18 114/9 117/14 117/24 117/25 118/13 119/13 125/16 128/4 128/6 129/8 131/19 131/23 133/10 134/22 138/25 138/25 139/10 139/14 140/11 140/23 143/16 145/1 145/3 145/3 153/5 153/8 154/2 154/10 156/5 156/5 156/7 157/2 157/2 161/10 161/10 162/5 165/15Ashley [1] 131/25
ask [15] 22/18 30/19 50/15 50/20 72/17 83/14 92/7 99/24 102/5 110/11 141/16 146/18 149/25 166/5 167/9asked [38] 5/25 7/7 11/15 16/3 16/13 16/20 16/25 21/7 21/13 23/8 29/23 37/11 39/3 55/18 65/21 74/12 74/15 91/23 97/3 99/2 100/7 104/2 107/18 109/9 109/14 110/21 117/10 133/22 139/6 144/19 148/15 148/20 152/10 164/9 169/6 169/10 169/15 170/9asking [30] 8/20 8/22 24/3 32/25 33/13 35/4 42/9 44/1 44/2 44/4 44/23 46/16 51/9 56/8 70/24 70/25 78/24 78/24 79/2 79/2 82/9 82/24 85/20 90/15 96/19 104/7 104/9 123/13 153/23 161/24asks [1] 90/24assignment [3] 139/10 140/4 142/11assist [1] 134/14assistant [16] 2/24 4/24 4/25 6/24 7/6 8/16 8/24 9/1 9/6 9/18 9/23 12/9 12/10 13/13 125/11 141/16assumes [3] 74/22 74/23 83/20assuming [5] 34/16 73/1 73/4 74/13 78/17at 9:25 a.m [1] 99/6attach [1] 140/12attacking [1] 19/18attended [1] 168/24attention [5] 58/5 82/16 84/22 103/6 140/15attorney [11] 67/9 138/24 139/6 143/12 144/19 148/15 148/20 157/10 161/23 164/9 168/2attorneys [1] 15/14audible [2] 4/13 79/16August [3] 11/7 122/6 126/8August 15 [1] 11/7authority [3] 107/6 113/25 163/9authorized [2] 131/11 132/15available [4] 13/13 75/17 75/25 146/20aware [5] 68/6 68/22 68/24 69/10 95/5away [4] 21/20 26/11 26/18 26/20
BBA [3] 149/2 149/8 149/18bachelor's [4] 149/18 149/22 168/24 169/3Bachinski [2] 125/11 165/13back [26] 9/6 19/15 19/23 21/6 31/21 32/6 36/7 37/8 44/16 61/8 61/10 63/23 64/3 66/8 66/17 75/24 76/3 76/4 76/4 76/7 77/13 107/15 118/10 138/18 157/7 157/8backed [3] 21/20 26/22 26/23backing [2] 26/18 26/20Ball [2] 6/24 7/6ballot [1] 90/25band [11] 115/13 115/14 115/14 115/17 117/17 128/1 128/6 151/22 151/24 152/1 152/13bargaining [3] 76/12 76/19 77/23based [3] 85/9 113/21 120/16basically [2] 104/16 170/11be [114] 2/3 2/12 7/2 8/19 8/24 9/6 10/11 11/5 13/19 20/2 20/13 23/23 23/24 24/21 25/18 25/18 28/4 34/11 35/6 35/14 36/5 37/24 38/25 39/1 39/2 39/6 39/17 40/6 40/9 40/11 40/12 42/15 44/22 46/10 46/10 46/13 46/17 47/2 47/3 47/4 47/12 48/3 52/4 59/22 63/18
Bbe... [69] 64/3 64/11 64/18 64/20 66/20 68/14 69/4 69/13 69/17 69/21 70/2 71/2 72/24 75/8 75/9 75/24 76/3 76/4 76/4 76/7 77/12 79/10 81/23 81/24 82/2 86/11 90/24 91/4 96/13 102/6 102/17 104/2 107/1 107/2 109/17 110/6 110/9 110/11 114/3 114/3 114/4 114/10 114/10 118/1 118/10 118/16 118/22 123/11 123/22 126/20 135/2 136/20 141/3 141/10 141/14 142/8 143/11 143/17 143/18 148/10 151/5 152/13 152/15 160/1 160/5 161/7 165/5 167/24 168/5bear [1] 123/6became [1] 168/8because [41] 3/18 12/14 15/13 15/14 19/18 19/19 21/14 21/23 28/6 32/23 40/4 51/11 51/15 51/17 51/19 52/4 56/4 56/10 58/13 74/21 77/11 77/14 80/12 83/20 84/24 98/7 124/13 129/8 130/12 132/15 132/24 136/4 142/5 144/8 144/13 156/13 160/1 162/17 162/25 168/14 169/16become [2] 7/22 168/6becomes [1] 123/5becoming [1] 48/18been [74] 2/25 5/21 5/25 6/5 14/20 14/22 18/2 18/17 18/22 23/18 23/21 25/15 29/3 30/15 31/1 38/3 40/7 44/19 50/7 50/11 57/3 57/4 57/6 57/14 59/13 59/14 59/20 61/4 63/4 63/20 69/16 74/3 75/24 75/25 78/25 79/17 82/6 82/23 85/16 88/15 88/16 92/13 95/14 96/23 98/11 100/6 102/8 102/13 102/13 106/14 108/2 108/3 109/9 110/21 113/7 120/19 131/1 131/2 136/8 138/5 139/21 142/6 144/14 144/14 146/6 147/24 148/12 149/15 149/21 162/1 162/2 162/10 169/10 170/1before [15] 1/7 13/4 13/5 35/2 35/3 36/8 47/10 64/4 71/8 71/13 71/14 82/18 85/4 96/17 126/8began [1] 109/6Begin [1] 60/6beginning [1] 11/6behalf [1] 27/6behaved [2] 21/10 111/21behavior [9] 21/2 39/17 39/22 99/5 101/12 101/22 109/12 111/18 170/3being [14] 3/23 5/3 12/4 20/4 23/13 33/14 39/5 47/12 69/8 86/3 127/8 132/13 132/21 139/18belaboring [1] 65/7believe [33] 8/23 12/11 15/3 15/9 17/8 19/8 19/19 22/13 24/5 24/14 26/7 28/24 32/2 32/7 35/1 36/22 45/13 72/11 72/13 78/14 78/15 85/16 88/20 90/4 90/5 100/8 106/13 127/3 127/17 141/9 145/23 154/19 161/3bell [1] 143/8belligerent [1] 110/19below [1] 153/16bench [5] 5/18 5/19 6/10 77/2 78/7benefit [2] 119/7 119/9benefits [1] 158/4besides [1] 65/15best [2] 79/7 112/7better [9] 4/2 4/6 4/9 4/19 4/21 50/7 50/11 134/16 160/5
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Ccafeteria [1] 8/6call [20] 2/4 2/6 10/15 21/5 32/4 34/6 34/18 34/19 48/15 65/16 65/19 66/18 72/16 101/10 107/23 107/25 111/17 118/19 161/5 165/2
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16/17 18/19 20/10 21/8 24/7 24/22 27/5 27/8 29/14 30/15 30/22 35/20 35/22 35/23 36/15 44/2 46/2 46/3 46/5 46/16 48/1 51/11 53/14 55/16 56/13 57/4 57/9 57/22 65/10 65/15 66/14 72/8 72/19 72/21 73/20 76/23 78/25 82/22 85/6 87/8 88/10 88/12 88/16 91/8 91/24 93/7 93/17 99/9 102/4 103/15 105/10 107/11 107/18 110/3 111/20 113/13 113/16 114/4 115/2 116/7 116/8 117/13 117/16 117/17 117/24 119/23 120/14 121/13 123/22 124/4 124/14 126/8 130/21 130/23 134/3 134/13 134/19 138/1 138/14 141/8 141/11 141/12 141/22 142/11 142/14 142/21 143/5 143/19 145/3 146/4 146/23 148/15 148/20 149/23 149/24 150/9 157/12 163/3 163/4 168/5document [37] 5/13 6/12 6/13 6/19 10/10 11/4 24/19 38/4 47/8 57/16 58/13 59/20 59/21 60/2 60/5 61/4 77/19 78/4 79/22 80/19 87/25 88/7 88/8 98/12 102/20 102/23 103/1 139/25 142/8 142/11 143/24 146/7 147/25 153/8 166/12 166/14 166/24does [38] 10/15 38/10 44/24 46/4 53/19 53/24 54/5 54/6 54/11 54/13 54/16 55/5 55/7 60/5 71/2 79/12 86/21 89/11 103/18 103/19 107/18 119/9 122/17 127/11 127/25 128/6 133/23 134/1 134/2 134/7 135/4 136/7 140/2 141/25 144/1 154/12 169/3 169/4doesn't [10] 12/15 24/8 25/1 35/7 42/17 48/1 55/6 134/5 135/7 140/20doing [4] 26/5 65/6 115/24 145/6dollar [1] 140/12don't [150] 3/17 3/20 3/25 4/6 4/11 4/16 4/20 5/16 5/17 9/7 13/9 13/25 15/3 15/9 16/8 17/17 17/21 17/25 18/1 18/2 19/14 20/1 20/5 20/8 22/11 22/12 24/18 24/23 24/25 25/10 25/14 25/23 27/22 28/6 28/10 28/12 28/14 29/18 30/2 30/2 30/6 30/6 30/10 30/11 31/11 31/14 33/1 35/3 36/4 36/18 37/16 37/22 38/2 39/24 40/25 42/7 42/14 42/15 42/18 44/8 44/16 44/17 45/11 45/13 45/15 46/14 47/19 48/17 51/9 52/9 52/11 54/4 56/3 57/5 57/20 61/10 63/21 65/7 69/5 69/12 69/25 70/7 71/25 72/1 72/7 72/13 73/2 73/18 73/19 74/2 76/7 76/14 76/23 77/16 78/14 78/15 78/17 80/20 80/24 82/1 83/3 83/13 85/11 87/1 87/3 88/18 90/16 90/23 93/8 93/18 93/20 94/4 94/11 95/3 100/1 101/20 102/22 117/1 118/7 118/9 136/4 137/13 138/19 141/15 142/18 143/4 144/10 145/16 145/20 146/3 146/5 147/16 148/1 148/3 149/22 152/14 154/6 156/13 156/17 157/17 157/24 158/5 158/7 159/16 160/13 161/3 163/2 163/10 167/5 167/8done [6] 17/3 29/9 51/2 51/10 65/12 104/17door [3] 26/22 26/23 110/5double [2] 124/20 133/15doubt [3] 93/7 93/8 142/11down [14] 7/12 53/22 64/1 70/25 84/24 90/5 90/23 98/15 115/21 151/8 151/23 152/22 153/15 171/2Dramatic [1] 131/25draw [4] 82/16 84/22 103/6 140/15
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Ee-mail [71] 6/14 6/21 16/3 16/5 18/6 18/8 18/17 18/19 18/21 18/23 19/1 19/6 29/3 29/11 29/14 30/7 30/23 31/12 31/14 31/14 31/16 32/11 32/13 33/5 33/5 33/12 34/2 34/10 34/11 43/23 45/5 52/17 52/25 53/2 53/13 53/18 54/3 59/23 61/6 61/11 71/4 73/19 78/13 94/7 94/12 95/21 96/22 97/11 97/12 97/14 98/2 98/13 98/16 98/17 98/19 98/20 99/16 99/17 99/23 100/9 100/11 100/15 100/15 100/20 100/25 101/3 101/11 101/21 101/23 113/17 165/4e-mailed [3] 15/24 16/4 97/24e-mails [2] 19/12 61/12each [4] 87/10 140/11 140/13 140/13earlier [5] 11/15 67/2 106/13 139/14 146/9early [1] 141/19Earth [1] 156/6ease [1] 124/13ed [12] 68/5 100/8 111/12 155/9 155/19 156/7 156/10 156/12 156/13 156/16 156/20 169/1education [17] 28/25 29/24 41/14 72/10 119/21 120/2 130/18 139/11 140/4 140/6 142/12 143/2 143/8 144/21 155/14 156/11 168/25educators [2] 74/7 119/3effect [3] 14/21 74/9 74/19effective [1] 10/16eight [1] 60/25Eighty [5] 43/20 44/12 70/19 71/20 90/3Eighty-seven [1] 90/3Eighty-two [2] 70/19 71/20either [4] 120/1 135/23 136/10 145/16electives [2] 91/1 114/22electronically [1] 124/14elementary [4] 6/24 6/25 7/8 121/16elevation [2] 9/3 9/5elicited [1] 77/16eligible [1] 122/25eliminated [2] 162/25 163/1else [18] 18/5 21/19 21/21 26/4 30/10 30/16 52/10 55/25 56/1 56/1 57/17 101/17 106/9 115/14 138/13 164/13 165/6 165/11else's [1] 100/12emergency [6] 93/12 95/6 120/22 120/24 121/25 129/9employed [11] 2/19 2/25 3/2 3/4 3/12 3/18 5/3 8/8 13/18 70/3 89/4employee [3] 39/1 39/5 66/3employer [1] 15/17employment [14] 3/22 6/20 22/15 36/23 36/24 37/1 71/10 74/10 74/20 84/4 84/7 145/2 163/5 163/14enclosed [1] 95/17
encourage [1] 138/8end [12] 6/10 78/7 83/21 86/4 95/7 98/25 112/22 113/20 129/10 135/11 160/24 171/5ended [1] 114/10engineering [4] 46/8 129/25 130/8 131/21enjoined [1] 145/6enjoy [2] 3/14 145/6enjoyed [3] 145/14 145/15 146/21enough [4] 6/8 122/12 124/17 142/25enrolled [2] 91/8 134/23enrolling [1] 152/16enrollment [16] 41/12 47/16 50/5 50/7 50/11 58/6 58/18 58/21 86/14 87/4 87/9 89/3 90/13 90/19 135/7 168/2ensure [1] 98/9enter [1] 25/12entered [3] 37/11 67/3 161/10enterprises [1] 122/19entire [2] 88/6 155/13entirely [1] 107/1entirety [2] 76/18 166/12entitled [2] 85/6 171/9Entrepreneurship [1] 132/2entry [1] 95/20envelope [1] 95/25Environmental [1] 156/7established [2] 85/2 85/10et [3] 1/5 6/15 52/2ethical [2] 105/1 105/3even [15] 18/1 77/15 78/3 84/13 89/9 113/25 121/6 134/1 137/13 149/17 149/20 152/8 156/1 158/18 159/8event [1] 95/21events [2] 95/17 97/25ever [17] 18/19 18/21 27/5 30/1 34/14 35/20 39/11 43/3 82/17 86/12 106/21 108/18 108/21 112/12 127/8 163/3 163/5every [6] 18/21 115/19 117/17 128/1 138/23 138/24everybody [3] 64/11 105/3 115/14everyone [3] 55/16 118/23 123/6evidence [33] 5/13 5/22 5/23 5/25 6/3 6/5 7/20 11/1 13/2 17/9 23/2 23/3 30/25 43/15 44/14 45/23 52/19 53/11 59/11 61/2 61/20 71/22 72/20 74/22 83/21 94/1 96/12 99/14 106/3 124/12 133/18 147/10 150/7exact [1] 19/14exactly [6] 36/18 37/9 37/10 64/18 107/2 139/3exam [1] 34/23examination [8] 2/14 66/22 66/25 92/6 106/4 138/21 168/18 170/12example [4] 48/12 134/18 134/23 151/4examples [1] 155/3except [2] 117/17 128/1excerpt [2] 1/6 2/1exclamation [1] 32/16Excuse [3] 43/13 49/10 139/9exhaustive [1] 68/19exhibit [79] 5/12 6/12 7/15 7/19 10/9 10/20 10/25 11/3 13/1 13/10 23/21 30/18 38/3 43/13 44/10 44/13 44/18 44/23 45/22 52/17 53/5 53/10 57/14 59/10 61/1 61/16 61/19 70/15 70/16 71/16 71/21 76/8 79/17 80/15 80/18 80/21 85/17 93/25 95/14 95/19 96/4
96/11 96/16 99/7 99/13 106/2 116/3 116/5 116/8 116/9 116/22 123/15 124/15 133/11 133/17 133/22 134/9 135/13 135/25 136/14 138/16 139/21 140/17 141/19 141/22 142/5 143/11 143/14 143/15 146/6 147/9 150/6 150/10 150/11 151/4 151/10 151/14 155/4 166/5Exhibit 85 [1] 135/25Exhibit 99 [1] 134/9exhibits [5] 23/18 80/13 124/11 133/20 138/17exist [2] 86/21 119/9existed [3] 18/7 126/11 139/16exiting [1] 111/9expensive [2] 21/24 22/2experience [1] 146/22expired [2] 95/6 129/10explain [3] 11/23 90/16 154/1explained [2] 41/23 129/8explaining [1] 29/3Exploration [2] 125/6 126/3Explorations [1] 125/19expressing [2] 146/14 146/19expression [2] 154/3 154/4extensions [1] 16/8extensive [5] 21/15 21/25 22/4 22/8 22/20extra [2] 12/2 122/25
Fface [3] 45/15 165/23 165/23face-to-face [1] 165/23facilities [1] 126/15facility [3] 126/11 126/19 126/22FACS [1] 127/11fact [9] 75/23 86/19 86/20 86/23 86/25 87/4 87/6 137/23 146/10factor [1] 114/17factors [6] 64/18 79/5 79/8 79/9 79/10 79/13facts [9] 85/2 85/12 85/15 85/21 86/1 86/1 86/2 86/18 86/22failure [2] 30/22 30/24fair [11] 6/8 9/15 38/13 104/25 105/3 105/8 105/10 107/1 124/17 142/25 160/7fall [2] 119/16 152/12false [1] 93/13familiar [27] 75/2 75/9 75/10 75/12 75/14 75/18 75/20 75/21 75/22 75/22 76/1 80/3 80/10 81/16 81/19 81/24 82/23 82/25 83/1 83/6 83/11 102/20 139/10 140/5 140/10 141/2 143/2familiarity [1] 78/9Family [2] 127/11 127/14far [10] 12/4 12/7 26/11 26/25 44/6 55/14 64/17 95/13 145/3 157/2fashion [2] 111/21 117/25fax [5] 23/15 24/11 24/15 24/24 59/22faxed [2] 24/17 24/20FCRR [1] 1/21Federal [1] 1/22feel [19] 3/18 3/23 4/2 4/6 4/9 4/19 4/21 20/1 20/4 20/5 20/9 20/10 20/12 20/14 20/18 82/22 98/2 146/20 146/24feet [2] 26/12 26/13fell [2] 119/13 120/21felt [2] 21/10 32/24fifth [2] 54/16 134/3
Ffigure [3] 30/3 88/13 124/14figures [1] 88/10file [3] 22/13 24/3 72/14fill [1] 90/25final [2] 34/22 113/23finally [1] 99/5find [14] 16/11 30/15 34/14 69/17 95/17 116/3 120/25 121/11 122/8 122/11 122/12 132/15 139/17 141/16finding [2] 49/3 151/7fine [22] 65/6 68/14 68/25 86/11 119/13 120/21 121/9 121/12 121/22 122/2 127/23 127/25 128/2 128/7 128/8 129/6 132/7 132/9 151/5 151/7 151/21 152/2finish [4] 65/16 66/5 102/7 102/8finished [1] 167/24fire [4] 50/9 94/5 94/23 95/10fired [27] 50/13 52/4 54/9 54/14 54/18 54/24 55/13 55/23 56/2 56/4 56/10 56/17 56/19 56/22 59/4 60/17 93/19 94/3 153/13 153/21 153/23 154/14 157/1 157/19 158/12 158/18 159/6first [36] 7/5 10/6 18/7 21/4 21/13 23/24 33/3 33/17 45/7 45/25 52/8 54/5 55/5 55/6 55/7 55/11 80/17 80/20 80/25 81/1 81/2 88/25 89/7 89/16 89/21 92/17 106/19 107/4 109/15 118/5 123/17 128/20 135/12 143/23 144/7 155/24first-year [2] 106/19 107/4fit [4] 43/1 79/7 146/24 147/1five [8] 33/3 55/21 87/9 87/11 89/5 91/6 115/25 155/5flier [1] 49/24fliers [3] 49/25 137/24 138/4flip [1] 154/6flipped [1] 88/5fluctuate [1] 168/3fluctuated [1] 168/8fluctuates [1] 135/11focus [1] 102/21follow [7] 31/5 44/24 45/11 54/3 83/3 96/13 150/12follow-up [1] 54/3followed [1] 107/2following [15] 2/1 23/24 47/14 47/17 48/23 69/11 70/10 73/13 75/25 78/12 88/23 91/22 100/9 162/16 162/23follows [3] 64/9 86/6 118/14Food [1] 132/11force [2] 86/8 113/21foregoing [1] 171/7Foreign [3] 125/6 125/19 126/3Forest [3] 13/12 13/20 13/22forget [1] 138/19formally [1] 6/5former [4] 66/3 66/4 72/16 93/16formula [1] 140/6forth [9] 24/4 51/11 61/8 61/10 64/18 64/21 96/24 147/15 161/25forward [7] 2/8 15/15 18/13 19/6 21/9 36/8 98/14forwarded [8] 18/11 18/12 18/13 18/23 19/9 60/6 113/17 113/18forwarding [1] 31/19found [1] 26/23foundation [5] 140/23 142/6 142/8 142/18 142/24four [9] 24/8 55/21 58/25 59/1 89/6 89/21 90/8 118/1 124/6
Fourteen [1] 62/13Fourth [1] 60/11free [2] 130/17 142/8French [1] 129/18friendly [1] 170/1front [8] 21/20 22/11 28/3 41/4 68/18 74/5 85/14 111/2Frost [1] 1/17fuel [1] 19/20full [11] 63/9 63/10 63/11 158/8 158/12 158/17 158/20 158/23 158/25 159/2 159/6full-time [11] 63/9 63/10 63/11 158/8 158/12 158/17 158/20 158/23 158/25 159/2 159/6Fully [1] 142/25function [1] 115/21funding [5] 41/14 120/4 122/25 140/6 140/10further [6] 19/20 38/18 40/5 40/11 157/24 170/8FW [1] 98/14FYI [1] 31/19
Ggame [1] 104/12Gateway [1] 68/6gave [13] 21/4 21/17 21/18 29/17 40/14 47/10 71/9 95/25 97/24 106/8 108/24 137/14 161/5general [1] 81/21generalize [1] 85/14generate [1] 94/21generating [1] 86/16gentlemen [2] 23/1 52/20germane [1] 77/19get [37] 31/10 31/13 34/1 35/8 37/21 37/23 38/1 44/7 44/24 50/13 50/20 54/9 54/14 54/18 54/24 55/13 56/10 56/16 59/4 60/17 62/4 64/17 65/12 66/10 93/19 94/3 105/6 118/9 138/16 142/23 153/13 153/21 157/1 157/19 158/12 158/18 159/6gets [1] 64/5getting [1] 48/22give [16] 22/17 53/14 58/13 68/19 75/5 75/17 79/21 85/12 102/2 106/16 118/8 137/15 143/22 146/16 148/2 166/12given [10] 11/24 41/24 54/2 76/7 102/1 120/24 132/21 138/1 140/13 162/17gives [1] 139/17giving [2] 27/6 63/20glean [1] 29/25go [19] 28/21 37/18 45/21 64/14 90/7 90/17 94/20 96/19 98/24 98/24 102/7 105/6 116/13 118/16 133/20 144/25 145/3 155/1 155/2goes [4] 39/18 66/6 74/6 104/19going [34] 3/2 7/10 8/12 9/10 9/14 13/24 22/22 39/20 47/16 47/25 48/5 51/12 57/9 57/11 71/2 71/9 74/21 79/10 82/8 83/19 96/4 96/6 99/7 102/8 112/2 117/17 117/24 123/5 123/11 136/20 142/4 145/8 155/1 162/6gone [1] 106/21gonna [44] 21/22 30/18 40/11 41/17 45/7 45/8 45/16 52/4 57/11 58/5 59/24 63/19 64/18 64/22 65/10 65/12 65/16 65/19 66/9 76/8 77/12 77/12 77/21 77/22 82/16 83/23 84/22 91/24 101/22
102/5 102/11 103/6 104/15 104/19 140/15 140/16 140/22 142/23 144/16 145/11 150/8 155/1 164/7 167/24good [12] 32/4 46/9 46/10 46/18 47/2 47/4 47/12 82/14 84/18 106/6 145/3 166/25got [11] 52/3 55/23 56/2 56/4 56/19 56/22 64/20 150/14 153/23 158/6 169/8gotcha [1] 104/13government [1] 155/15grant [1] 140/9graphic [16] 120/19 122/19 134/23 134/24 144/22 144/22 148/3 148/6 148/18 148/21 149/3 149/9 149/19 149/20 149/22 169/4grateful [2] 3/21 3/22Grcich [1] 53/1greater [2] 13/23 127/20grid [3] 68/17 69/7 139/14Gross [2] 153/16 154/11guess [14] 8/20 10/22 25/17 28/6 39/7 40/13 41/4 53/25 78/21 78/23 78/24 79/4 157/24 161/4guidance [12] 48/6 48/11 49/5 61/22 91/2 91/3 91/9 91/10 91/13 91/15 91/23 154/18guideline [3] 80/1 81/19 102/17guidelines [3] 73/24 81/2 103/10guys [1] 83/12
Hhad [85] 14/20 14/22 16/13 17/25 21/5 21/8 28/2 28/23 29/3 29/4 29/18 34/22 48/6 48/25 62/22 64/7 67/2 70/5 70/10 70/12 73/25 74/16 87/5 90/5 90/19 93/12 95/6 96/24 97/6 98/2 100/4 100/6 100/7 101/11 101/25 106/13 106/21 106/23 108/9 108/11 109/20 111/20 115/25 117/15 117/17 118/12 120/19 121/6 121/16 122/16 122/18 122/18 123/16 126/11 130/3 130/6 130/12 131/1 134/6 136/21 137/8 137/12 138/1 144/23 149/20 151/15 153/22 154/13 154/15 156/11 160/1 161/22 164/10 164/16 165/15 165/23 167/15 169/3 169/6 169/7 169/15 169/16 169/24 169/24 170/1Half [2] 23/10 23/11halfway [1] 151/23HAMMOND [18] 1/2 1/23 3/13 3/14 3/16 4/2 4/6 4/18 4/23 5/1 9/2 17/23 108/6 108/8 108/10 108/19 109/5 113/2hand [3] 2/9 59/24 107/9handed [3] 14/15 21/4 26/7handle [2] 139/24 163/21handy [1] 116/6HANOVER [41] 1/5 3/6 3/11 5/4 6/15 6/20 8/8 8/11 8/17 9/2 9/13 10/4 10/7 10/11 11/10 13/4 13/17 13/23 14/3 14/6 14/16 15/2 18/22 24/16 30/13 41/6 63/7 70/10 74/6 74/7 77/13 79/25 82/7 82/20 82/22 105/2 112/24 121/17 148/7 148/25 153/6Hanover's [3] 104/11 117/3 117/7happen [8] 35/10 42/12 97/15 97/16 99/18 156/5 159/20 164/7happened [14] 19/8 24/12 27/1 27/13 30/11 35/2 35/3 35/7 37/9 37/10 56/1 100/2 100/3 100/22happening [2] 32/6 156/6
Hhappens [1] 40/5happy [5] 14/3 14/5 40/9 40/12 60/11haranguing [1] 32/24harass [1] 109/10harassing [1] 20/12harassment [2] 109/10 112/16hard [8] 4/5 30/15 57/17 57/21 70/7 100/17 118/5 118/5Harrigan [2] 156/10 156/20Harrison [1] 129/14has [45] 5/24 5/25 6/4 18/22 23/21 31/1 38/3 42/12 44/20 44/21 57/3 57/14 59/20 61/4 63/4 74/3 76/14 76/15 76/19 76/20 77/20 79/17 85/16 91/1 91/8 92/13 92/24 95/14 102/13 102/13 108/2 111/6 120/20 124/5 139/21 140/11 146/6 147/24 150/20 153/25 154/1 154/11 166/19 166/22 169/6hasn't [4] 6/6 44/19 57/4 57/6hate [1] 66/7have [235] haven't [3] 59/14 123/17 142/5having [16] 35/15 35/21 41/4 67/3 68/18 75/25 80/4 85/14 97/2 97/6 97/20 116/6 120/2 120/16 134/10 151/7he [116] 17/10 17/11 21/25 22/22 22/23 22/24 25/1 42/17 48/1 51/11 54/9 54/14 54/18 54/24 58/8 65/24 69/24 74/14 74/16 74/17 74/24 77/12 80/22 83/22 83/24 83/25 83/25 84/16 92/23 92/24 93/12 99/3 99/5 102/23 104/13 107/13 107/17 107/17 107/19 108/21 109/14 110/17 110/19 110/25 111/2 111/6 112/10 112/18 116/24 119/12 120/14 120/19 120/20 120/22 121/5 121/6 121/6 121/9 122/4 122/16 122/18 122/22 122/24 124/5 125/11 130/6 130/10 130/12 130/12 131/2 131/5 131/6 131/8 135/23 136/21 138/1 144/20 144/21 145/3 145/6 145/6 145/6 145/9 145/14 145/14 145/17 145/19 145/21 145/21 145/23 145/24 146/1 146/2 146/4 146/9 146/10 146/14 146/15 146/19 146/20 147/3 148/12 153/25 154/1 163/7 163/9 163/11 163/18 165/14 166/22 167/19 168/24 169/3 169/6 169/15 170/1he'll [1] 83/25he's [9] 25/1 42/17 92/20 93/1 94/16 141/18 146/19 154/6 166/19head [5] 28/23 67/10 67/20 67/22 67/23Health [1] 168/25hear [6] 67/9 86/12 109/5 150/23 162/6 162/9heard [7] 23/2 36/2 39/11 119/19 143/6 145/23 168/23hearsay [1] 144/8held [2] 4/22 81/12help [4] 35/7 116/4 140/2 160/4helped [1] 162/6helpful [3] 44/22 96/16 150/10her [48] 15/10 15/14 16/16 16/23 17/18 18/2 18/4 18/12 18/16 27/3 32/9 32/10 32/18 32/23 32/25 33/13 34/2 44/1 44/4 55/3 62/9 62/17 66/3 70/25 72/17 77/6 80/15 86/13 86/19 91/24 97/24 101/23 109/25 110/3 113/16 113/18 114/6 118/9 137/21 143/14 148/23 154/21 156/11 157/3 157/5 157/6 164/2 166/12
here [55] 5/20 6/19 12/15 19/1 24/19 39/22 40/10 57/2 59/13 63/23 64/3 64/5 65/6 65/22 65/24 66/10 66/17 72/19 73/15 77/14 80/16 80/22 85/9 94/16 102/11 106/1 107/16 110/11 116/16 117/5 118/2 118/20 119/19 125/1 127/10 130/7 135/25 138/24 142/15 142/16 142/17 144/8 145/9 148/25 152/15 153/8 153/15 154/23 163/24 166/19 166/20 166/22 167/19 167/24 168/23hereby [1] 85/24Hey [1] 16/18Hi [2] 92/19 106/7Hiatt [9] 65/21 66/4 66/7 66/9 163/3 163/5 163/7 163/13 163/21high [36] 5/1 5/2 5/9 6/18 7/3 7/8 7/23 8/1 8/3 8/6 24/16 44/5 72/4 86/16 86/25 87/5 92/4 102/18 114/20 116/1 117/21 121/19 122/9 123/9 128/20 130/6 130/15 131/1 131/4 131/14 135/16 135/20 136/18 140/11 160/5 162/19higher [4] 62/21 62/23 168/6 168/8highest [1] 155/12highly [4] 92/11 92/20 92/24 93/1him [48] 17/24 35/7 48/13 48/15 50/9 58/13 65/16 65/25 66/4 66/10 79/21 90/16 90/17 96/19 99/4 102/22 104/15 107/9 107/11 107/13 107/21 107/23 107/25 108/5 108/16 111/4 111/7 111/17 111/23 111/25 112/8 112/12 112/19 113/5 113/19 122/21 130/13 144/25 145/2 147/12 166/22 166/23 167/10 168/23 169/11 169/21 169/24 170/6hire [3] 74/1 78/11 144/25hired [2] 78/16 78/20hiring [1] 79/5his [29] 49/14 50/6 50/7 51/12 54/22 90/16 93/3 94/21 95/4 95/6 109/12 110/22 110/22 116/1 119/16 120/16 120/16 122/8 122/18 129/6 129/9 130/3 130/6 137/14 147/13 148/11 154/1 166/23 170/3hits [1] 152/12Honestly [1] 24/18Honor [92] 2/5 5/14 6/2 7/10 8/12 9/10 13/24 17/8 19/3 22/22 23/17 29/7 31/1 45/13 45/17 53/7 57/5 59/7 59/15 59/18 60/23 63/18 64/6 64/13 64/15 64/16 64/19 66/11 66/23 71/17 74/14 74/21 76/9 76/11 76/22 76/24 77/3 80/20 82/8 83/19 84/20 87/18 88/3 92/2 93/21 96/5 99/8 102/10 102/11 102/25 104/17 105/13 105/16 105/18 118/18 124/1 124/2 124/9 124/14 133/10 133/13 136/24 138/11 138/13 138/15 140/17 140/19 142/4 142/15 143/12 144/6 144/7 145/8 147/5 147/7 147/19 150/2 153/25 161/20 163/25 166/8 166/11 166/16 166/17 167/10 167/17 167/23 168/15 168/17 170/8 170/10 171/1HONORABLE [1] 1/7hope [2] 65/14 65/14hour [9] 23/10 23/11 54/5 54/11 54/16 55/11 57/10 102/9 134/3hourly [1] 12/18hours [2] 32/4 122/20how [57] 2/25 3/25 4/5 4/20 5/3 7/12 9/8 16/16 18/4 18/6 18/10 19/12 23/7
26/11 26/16 26/21 33/15 35/25 39/4 42/15 45/14 48/12 54/22 55/3 55/15 55/18 55/23 56/2 56/4 56/19 56/22 57/8 63/7 63/9 65/10 66/6 84/19 85/24 87/8 89/25 93/17 102/4 115/22 124/14 134/13 144/25 145/3 150/9 155/8 155/12 156/24 158/1 159/14 159/17 159/20 165/13 169/15However [2] 76/1 146/22HQ [1] 92/16huh [4] 35/13 40/22 58/7 71/15human [1] 6/15
II'd [7] 3/25 69/5 69/6 117/23 119/11 123/10 167/9I'll [10] 4/8 53/8 53/14 85/18 96/17 99/11 102/6 116/13 118/7 166/5I'm [137] 3/22 5/12 6/3 6/4 7/10 8/12 8/22 9/10 9/14 10/9 11/3 11/24 11/25 12/12 13/6 13/10 13/24 14/25 16/24 19/10 20/3 21/22 22/1 22/22 24/3 26/19 27/12 30/18 32/1 32/7 32/19 32/19 33/13 33/15 33/23 39/3 41/17 42/9 43/13 43/18 44/2 44/18 45/7 45/9 46/14 48/20 49/10 53/1 58/5 58/17 59/24 60/19 64/22 65/19 66/9 68/22 68/24 70/18 70/25 71/12 73/3 73/14 73/16 74/21 75/20 75/22 75/22 76/1 76/8 77/1 77/14 77/18 78/24 78/24 79/2 79/2 79/19 79/19 80/12 80/24 81/20 82/8 82/16 83/1 83/19 83/23 83/25 84/22 85/20 85/24 90/13 90/14 90/15 90/22 91/5 102/11 102/15 102/21 102/24 103/6 104/7 104/17 104/18 107/12 107/12 116/15 116/21 123/5 123/12 137/9 138/17 140/10 140/15 140/16 142/4 142/23 144/16 145/8 145/11 147/17 150/8 150/9 151/7 153/23 154/2 154/2 154/8 154/9 155/1 155/1 155/3 157/4 158/16 159/13 161/12 163/24 166/19I've [8] 63/20 64/20 78/5 103/3 123/17 143/6 146/21 166/11I-G-G-S [1] 2/18IC [2] 23/25 86/8idea [3] 17/18 81/19 108/9identified [3] 100/16 101/4 101/6identify [7] 30/19 52/24 92/14 102/14 146/7 147/25 166/5II [2] 134/24 156/5III [1] 129/18ill [1] 48/3ill-defined [1] 48/3Illinois [3] 1/17 149/3 149/10imagine [3] 14/25 18/11 18/15Imaging [3] 134/24 134/24 144/22immediately [2] 19/9 19/11impeachment [1] 167/18implicated [2] 101/12 101/13implied [2] 32/12 32/19implies [1] 32/20important [5] 6/8 64/21 84/19 98/8 154/10inappropriate [1] 111/2incident [12] 34/21 35/10 35/12 38/10 38/12 38/13 38/18 40/1 40/2 40/3 110/21 111/11incidents [6] 34/20 40/3 40/4 109/12 112/15 112/15
Iinclude [2] 117/13 138/19included [1] 68/15including [3] 18/23 130/15 144/21incomplete [1] 140/21INDIANA [15] 1/1 1/13 1/18 1/23 39/9 106/23 119/14 119/20 120/25 139/11 140/4 143/2 149/3 149/10 168/24Indianapolis [1] 1/18indicate [2] 140/20 169/3individual [1] 156/19individuals [1] 104/25industrial [9] 25/21 68/5 68/9 68/10 68/15 68/20 68/23 72/10 162/7influence [3] 109/22 110/2 126/19info [1] 60/7information [9] 23/24 87/21 87/24 89/12 100/7 113/14 125/2 126/3 163/22informed [3] 98/25 99/4 100/6informing [1] 86/13initial [1] 107/17Initially [1] 21/14input [3] 137/2 137/8 137/12insights [1] 146/21inspection [1] 23/25instance [1] 21/21instances [3] 21/10 28/16 28/17instruct [2] 66/9 82/12instruction [1] 68/5instructional [6] 68/23 69/2 69/4 70/21 72/12 73/16instructor [6] 120/5 122/22 131/19 131/23 132/16 132/25insubordinate [2] 99/4 101/22insulate [2] 127/7 130/23intend [1] 65/25intent [1] 28/24interest [8] 13/21 41/20 49/13 86/16 86/23 86/24 94/21 105/7interested [1] 149/4interfere [1] 110/8intermediate [1] 13/13interrogatories [6] 87/25 88/4 116/24 117/2 117/3 117/8Interrogatory [2] 88/2 88/11interrupt [1] 80/11interviews [1] 79/7intimidating [1] 32/24intro [2] 141/22 141/25introduce [1] 76/18Introduction [4] 129/22 132/6 132/11 132/18investigate [3] 69/23 72/24 73/10investigation [5] 29/19 29/21 30/3 39/16 39/20involved [7] 15/15 34/22 46/8 47/23 64/19 112/14 163/13involving [1] 111/11is [411] isn't [10] 11/12 11/17 11/17 15/16 68/11 89/6 89/21 104/12 152/6 167/18issue [6] 28/25 32/1 32/11 32/16 32/20 76/12issued [2] 37/3 107/5issues [18] 53/16 55/20 55/23 55/25 56/2 56/23 64/4 76/16 76/21 77/21 78/1 82/10 98/9 109/9 134/1 134/2 139/15 144/13it [541] it's [15] 24/18 46/15 52/25 56/15 56/15
70/19 77/20 87/23 95/16 96/16 142/16 144/2 148/2 166/7 166/21item [4] 103/6 104/22 129/2 129/2its [2] 76/13 144/10itself [1] 166/24
JJames [1] 151/25Jamie [4] 137/16 137/19 157/22 158/1Jane [3] 6/24 7/6 30/21January [1] 74/8January 1 [1] 74/8Jason [8] 49/17 49/19 92/15 92/19 92/20 94/9 94/15 119/11Jennifer [3] 53/1 125/19 131/23job [27] 11/21 33/8 33/20 38/22 38/25 39/2 39/2 39/6 40/7 69/16 73/15 73/16 74/1 75/5 79/12 103/3 137/21 145/3 146/23 148/1 148/6 148/10 148/11 149/1 149/7 149/15 159/18jobs [7] 13/5 13/8 62/24 159/12 159/14 160/2 169/16jot [1] 70/25JUDGE [2] 1/8 42/15judgment [2] 23/3 166/19Julian [3] 137/17 137/19 158/1Julian's [1] 157/23July [6] 10/16 60/7 60/11 144/2 146/13 147/21July 30 [2] 146/13 147/21July 31 [1] 144/2July 4 [1] 60/7July 8 [1] 10/16June [7] 34/25 34/25 112/21 112/21 112/23 113/11 161/6June 11 [5] 112/21 112/21 112/23 113/11 161/6June 6 [1] 34/25June 7 [1] 34/25jury [28] 31/4 44/23 45/11 45/21 53/9 63/25 64/5 66/18 66/19 67/9 76/16 76/21 77/21 78/2 82/12 84/17 85/19 96/13 96/18 99/12 116/19 118/11 118/19 118/21 124/18 150/12 167/21 168/23just [72] 3/25 5/25 6/16 12/12 13/25 16/2 19/20 20/23 23/17 29/8 31/4 33/9 35/6 36/11 41/17 45/10 46/14 46/20 58/14 59/3 59/12 64/3 64/4 64/16 65/2 65/20 66/1 66/7 66/10 67/23 74/17 76/17 77/16 78/3 79/11 80/22 80/24 80/24 81/21 85/9 85/25 87/17 90/19 95/22 96/13 98/19 99/24 100/21 104/9 106/11 111/6 113/18 115/16 123/19 123/19 125/22 129/8 130/17 133/20 136/24 138/16 138/25 139/9 139/24 143/14 147/17 153/10 155/2 157/8 163/18 164/6 167/23justifiable [2] 41/2 86/6justify [1] 87/8JUSTIN [10] 1/6 2/2 2/6 2/13 2/18 60/6 60/11 66/24 92/19 166/7
KKaiser [69] 15/4 15/12 16/2 17/7 17/16 17/21 17/24 18/10 18/14 18/23 23/12 23/15 27/1 27/6 27/10 27/13 30/21 35/16 35/21 36/1 36/9 36/13 36/15 36/23 37/5 37/10 37/11 37/17 38/5 39/25 40/19 41/5 42/11 42/11 51/6
51/10 65/17 65/18 67/4 70/21 72/16 73/20 77/4 86/12 87/15 95/16 95/24 97/2 97/7 97/21 97/24 98/2 98/13 99/20 101/21 106/14 109/3 109/14 109/20 109/22 110/2 112/2 112/7 113/10 114/2 160/14 160/19 163/14 164/2Kaiser's [6] 106/17 107/6 114/10 137/2 137/10 160/20Karleen [6] 6/14 52/25 92/15 93/2 93/15 94/13keep [10] 57/11 63/22 103/11 103/16 103/20 103/22 103/25 104/8 159/14 159/18Keeping [1] 103/8keeps [1] 83/22kept [1] 159/12kids [4] 115/16 127/4 127/20 136/12kind [10] 18/15 37/13 39/19 64/16 75/4 85/6 85/12 85/15 100/23 157/16kinds [2] 139/15 139/17knew [5] 29/19 36/13 72/4 95/8 99/20know [107] 3/25 4/9 4/19 15/17 16/8 16/16 17/23 17/25 18/1 18/4 18/10 18/19 18/21 21/7 24/22 25/1 25/10 25/14 26/25 27/22 28/6 28/8 28/10 28/12 28/13 30/6 30/10 30/11 30/12 30/14 33/4 35/15 35/17 35/25 36/3 36/15 36/16 36/17 36/20 37/22 42/15 42/18 43/10 44/2 49/2 55/14 57/20 64/18 65/9 68/1 69/3 69/5 69/6 69/12 71/25 72/1 72/7 72/8 74/2 82/1 83/14 83/16 85/11 87/1 87/3 88/3 88/17 88/18 93/17 93/20 94/4 95/3 95/13 98/5 98/6 98/8 107/16 108/8 108/10 108/13 112/2 113/13 116/8 123/12 123/16 125/16 134/9 134/13 137/13 141/4 141/8 141/18 142/14 143/5 145/20 146/4 146/5 148/3 157/2 157/25 158/5 160/13 161/24 163/2 163/3 163/10 167/5knowledge [2] 18/2 112/7known [2] 18/1 113/8Kounelis [7] 16/16 16/18 16/21 16/25 70/21 70/24 73/20
Llabel [2] 143/16 143/19ladies [2] 23/1 52/20Landis [5] 54/22 65/19 66/2 99/1 134/3Language [3] 125/6 125/19 126/3larger [1] 126/11last [8] 12/11 87/9 87/11 89/25 91/6 92/19 133/2 143/17later [2] 97/24 168/5law [4] 103/9 103/12 103/17 103/18lawsuit [6] 108/6 108/8 108/11 108/19 109/5 113/1lay [2] 140/22 142/7Lead [11] 43/7 43/10 47/7 47/13 68/7 86/15 86/24 86/25 162/10 162/14 162/23leading [1] 87/11learned [1] 14/20least [3] 76/7 77/25 131/11leave [20] 8/11 16/22 16/25 37/14 37/19 38/20 38/23 39/1 39/2 39/6 39/11 40/6 40/11 97/3 99/3 106/1 110/13 145/17 145/19 145/22leaving [2] 146/15 146/19Lechien [1] 54/16left [16] 13/4 21/5 21/9 24/6 26/23 29/4
Lleft... [10] 29/18 37/8 65/15 99/2 99/5 107/13 107/20 141/23 147/3 160/2legal [3] 14/25 82/9 82/11less [11] 9/13 9/19 11/13 11/17 11/17 11/19 12/4 89/24 102/9 140/10 151/23lesser [2] 8/19 8/23let [20] 31/4 50/15 50/18 50/20 50/20 50/23 51/14 79/11 90/16 105/7 105/10 116/3 116/19 123/16 124/17 124/17 134/9 136/4 137/23 142/23let's [10] 53/21 124/24 126/7 128/20 130/3 130/17 131/13 153/15 155/2 158/1letter [71] 6/19 13/12 14/15 21/5 21/8 21/15 21/16 21/23 22/4 22/5 22/7 22/10 23/9 23/23 24/1 24/20 26/7 27/6 27/8 37/3 38/5 38/8 38/16 38/18 39/21 40/10 40/12 40/14 40/20 40/21 40/23 40/23 47/10 52/3 52/6 72/20 76/24 77/3 77/6 81/18 84/6 84/9 84/13 85/12 85/13 85/21 86/13 86/19 86/20 86/21 86/23 102/3 106/13 107/9 107/13 107/14 112/2 137/9 137/10 137/16 138/2 145/21 145/23 146/2 146/8 146/9 146/10 146/12 146/14 147/19 161/5letters [1] 13/21level [1] 15/10library [3] 40/3 100/23 164/22license [22] 68/18 69/7 70/5 72/13 79/6 92/22 92/25 93/3 93/5 95/4 120/8 128/17 130/12 130/19 139/19 141/3 141/7 141/10 141/14 141/17 149/20 169/20licensed [14] 68/2 69/4 69/18 69/24 70/11 72/7 72/8 72/9 120/25 121/11 121/23 122/2 128/11 132/9licenses [5] 68/17 95/12 139/16 139/19 169/17life [1] 160/5like [46] 3/23 3/25 11/6 13/12 13/16 28/18 30/20 31/19 32/19 40/5 40/12 50/20 58/2 58/18 58/23 59/23 64/19 64/20 74/5 79/11 79/23 79/24 79/25 81/23 82/3 90/5 90/25 95/20 98/22 98/22 103/3 117/23 119/11 123/10 134/21 135/9 140/3 141/19 145/10 148/1 148/6 151/25 153/22 154/13 155/5 167/9Limited [1] 170/9line [5] 4/17 15/18 15/20 23/24 46/1lines [3] 28/19 58/20 77/17link [1] 80/7list [7] 53/21 53/24 53/25 56/19 56/22 68/19 157/22listed [5] 55/22 125/1 126/2 133/23 155/25listing [1] 151/9Literature [1] 131/25litigation [5] 14/8 15/13 18/20 19/13 109/6little [6] 4/14 76/19 90/22 90/25 123/6 151/22LLC [1] 1/17locally [1] 120/20log [4] 29/23 95/20 99/4 101/22logged [1] 87/23logical [1] 117/25logistically [1] 123/6Logistics [1] 142/1
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Mme... [101] 33/20 34/1 34/6 34/18 37/11 38/16 39/25 40/4 40/6 40/14 40/20 40/24 41/4 43/13 43/23 45/5 46/5 46/16 47/10 47/14 49/10 50/15 50/18 50/20 50/23 51/14 52/3 52/5 52/25 53/14 55/16 56/8 56/17 56/25 57/17 61/6 64/24 68/18 70/7 70/20 71/9 74/1 78/11 78/16 78/20 79/4 79/19 83/17 84/9 85/12 85/14 85/20 90/2 90/20 91/19 92/15 94/9 95/16 95/25 98/13 98/22 98/22 100/17 100/21 101/10 101/16 101/22 102/1 104/9 105/5 105/11 107/18 116/3 116/4 116/19 123/16 124/17 134/9 134/14 139/9 141/13 146/1 146/8 146/16 146/24 147/1 152/10 153/3 153/5 157/22 160/12 161/5 162/6 163/9 164/11 164/16 164/21 164/24 165/20 166/7 167/7mean [21] 15/21 37/22 39/14 39/14 42/24 48/1 48/25 61/10 64/22 64/23 64/24 65/3 71/2 73/14 121/13 122/17 127/25 135/4 152/17 158/23 159/13meaning [1] 82/13means [4] 69/12 115/11 122/18 154/4meant [2] 6/2 6/6meet [1] 114/6meeting [37] 28/22 28/23 28/25 34/4 34/6 34/8 34/10 34/21 34/25 35/16 35/21 35/25 36/6 36/8 36/9 36/19 36/21 37/23 67/4 96/24 97/1 97/6 97/20 100/4 100/5 100/8 109/14 109/18 109/20 109/23 110/5 114/2 161/3 164/9 165/2 165/7 170/3meetings [2] 163/13 164/17member [5] 16/22 17/1 17/2 108/23 111/20member's [1] 16/19members [2] 15/19 15/22members' [1] 16/12mention [6] 108/5 108/19 108/21 119/19 128/6 134/4mentioned [4] 18/1 139/14 155/24 158/22mentions [1] 38/12mess [3] 47/16 47/25 48/2message [26] 6/14 6/21 6/21 16/22 16/25 18/15 29/3 30/20 31/20 43/23 45/5 52/25 59/23 60/6 70/17 70/20 92/15 94/9 95/16 95/22 96/22 97/12 97/14 98/13 100/9 100/11messages [4] 31/14 32/23 113/17 113/19met [2] 169/23 170/6Michelle [1] 45/5Michigan [13] 2/22 3/3 8/10 8/15 9/23 10/3 10/7 11/6 11/12 11/16 11/21 12/8 13/5midafternoon [1] 118/8middle [43] 5/1 5/9 6/17 6/18 7/2 7/23 7/25 8/3 8/5 43/8 52/5 68/6 68/8 72/4 86/15 86/23 92/4 102/18 115/2 115/5 115/7 115/11 115/19 115/22 116/23 117/12 117/17 121/19 123/8 124/24 126/4 126/9 127/10 127/13 128/1 128/16 130/4 140/12 161/23 162/11 162/14 162/20 162/23middle/high [1] 102/18might [6] 44/22 56/1 68/13 76/17 124/15 131/2
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Pp.m [6] 63/25 64/7 66/19 118/11 118/12 118/21P.O [1] 1/18PA [3] 50/20 94/20 105/6page [18] 22/5 22/7 74/5 77/19 78/4 79/24 79/24 80/12 80/16 80/17 80/21 80/25 81/1 81/2 88/5 123/17 155/4 155/8page 1 [1] 79/24page-long [1] 22/7paid [1] 158/6pale [1] 104/19Pam [1] 156/7paper [1] 148/2papers [2] 102/1 102/2paragraph [4] 45/7 45/25 47/4 136/15Pardon [5] 78/22 87/2 151/2 160/9 161/15parentheses [1] 125/8part [15] 49/2 64/25 65/11 69/16 73/7 73/8 75/18 75/20 77/8 82/5 82/24 126/25 137/19 144/13 166/11particular [23] 15/11 16/19 16/23 41/25 58/8 58/11 58/19 73/18 78/4 81/18 83/1 87/25 91/15 91/21 94/3 94/6 101/8 121/1 134/19 135/9 139/19 139/20 153/13particularly [3] 19/13 41/8 83/17parties [1] 81/12pay [4] 10/15 12/17 13/22 112/10paying [2] 9/19 10/1PE [2] 127/18 127/21peek [1] 67/23
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position [40] 2/23 3/7 5/5 5/6 5/10 6/17 6/22 6/23 7/7 8/10 8/15 8/19 9/2 9/18 9/19 9/23 10/1 12/2 13/13 69/14 69/15 69/17 69/18 70/9 70/10 71/2 72/25 73/16 75/17 75/17 78/11 78/16 78/19 78/20 79/7 102/18 105/19 131/8 147/14 148/11positions [5] 4/22 12/14 13/7 41/3 86/7positive [1] 87/13possibility [2] 76/15 108/15possible [4] 16/5 24/18 30/6 117/25possibly [2] 17/3 164/6posted [1] 148/9poster [1] 49/21posters [6] 49/13 50/15 51/11 51/14 94/20 105/5posting [4] 70/25 73/18 148/6 148/25PowerSchool [4] 57/16 87/23 116/5 116/9predetermined [1] 115/5preferred [1] 149/4preliminary [22] 37/3 40/18 51/19 51/22 74/11 84/8 84/10 84/16 86/3 86/5 86/10 90/1 102/3 106/8 106/16 107/5 108/24 113/22 137/15 138/2 161/1 161/6preparation [1] 41/15prepare [2] 52/1 52/5prepared [2] 110/13 160/5prerogative [1] 115/3present [2] 106/9 164/13presentation [1] 101/12presented [1] 21/18presenter [11] 29/4 29/12 29/19 29/23 30/4 32/25 34/15 34/17 100/14 100/23 101/8presume [1] 54/2previous [2] 75/25 138/25previously [29] 3/2 3/4 7/19 10/25 13/1 23/22 38/3 44/13 45/22 49/20 53/10 59/10 61/1 61/19 71/21 85/16 93/25 96/11 99/13 106/2 117/14 121/16 124/11 126/11 128/4 133/17 147/9 150/6 151/15primarily [1] 14/9principal [64] 2/24 3/8 3/9 4/24 4/25 5/7 6/16 6/24 7/2 7/6 7/22 7/25 8/16 8/17 8/24 8/24 9/1 9/2 9/6 9/18 9/23 10/13 11/25 12/4 12/7 12/9 12/10 12/12 12/14 13/14 13/23 28/8 39/8 43/11 63/7 66/4 68/1 69/16 69/19 69/21 70/13 75/9 78/9 78/25 79/3 81/24 82/2 82/20 82/22 83/3 84/3 91/13 98/8 102/18 106/19 107/4 125/12 139/10 145/1 145/17 162/5 162/13 163/7 163/11Principles [3] 129/25 130/7 133/2print [1] 140/3print-off [1] 140/3printed [1] 79/23printout [2] 58/19 102/18prior [4] 3/2 3/11 106/21 166/23priority [3] 140/11 140/12 140/12private [1] 86/9probably [7] 18/16 19/8 19/20 57/10 95/21 143/18 156/11probative [1] 76/20problem [9] 19/1 50/5 50/8 56/5 92/24 93/3 95/4 95/6 95/12problems [9] 48/5 48/8 48/15 48/18 48/21 48/22 48/24 49/3 49/6Procedural [2] 82/17 85/1
procedure [1] 164/25procedures [1] 107/2proceed [8] 17/14 23/4 52/22 53/9 64/12 81/13 145/12 150/17proceedings [4] 1/24 64/8 118/13 171/8process [32] 47/20 47/23 48/21 67/4 75/22 76/1 77/8 80/9 81/16 81/19 81/21 81/25 82/3 82/5 82/6 82/17 82/23 83/1 83/4 83/7 83/16 83/18 85/1 85/7 103/25 104/3 104/5 104/9 104/11 106/21 106/24 109/15produced [1] 1/24professional [3] 74/7 104/25 119/3program [1] 11/25Project [11] 43/7 43/10 47/7 47/13 68/7 86/15 86/24 86/25 162/10 162/13 162/23promise [1] 64/22prompted [1] 15/12proper [1] 76/2provide [1] 89/9provided [7] 18/19 18/22 23/25 80/21 119/13 120/5 146/21provision [3] 39/19 75/14 81/16proximate [1] 19/7public [1] 39/9publishes [2] 68/16 69/8pull [1] 157/22pulled [1] 142/16pursuant [1] 23/25pursue [1] 70/13push [1] 8/11put [30] 39/19 40/11 49/13 50/15 51/14 60/18 62/17 65/25 66/3 66/4 66/9 91/11 91/16 91/16 91/25 94/19 100/2 105/5 107/14 107/16 116/10 124/5 137/24 138/4 138/18 147/13 154/21 156/13 157/8 165/4putting [2] 42/7 78/3
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relates [1] 134/20relating [1] 21/2relevance [6] 13/25 76/13 76/15 76/17 144/10 166/19relevant [2] 15/16 77/20remain [1] 99/24remained [3] 99/2 99/3 99/23remarks [1] 107/21remember [17] 17/21 22/12 27/8 29/14 34/24 35/23 44/16 63/20 72/19 72/21 107/11 110/23 113/16 114/4 148/15 148/20 168/2remind [2] 59/12 150/8reminder [1] 70/25remove [1] 55/2removed [1] 55/1repeat [5] 16/24 20/3 73/9 84/1 148/19repeated [1] 99/3repeatedly [2] 127/3 169/6rephrase [3] 20/8 48/20 74/25replace [1] 147/12reported [3] 1/24 64/8 118/13Reporter [3] 1/21 1/21 171/13repository [1] 59/16representing [1] 5/21reprimand [1] 111/25reprimanded [1] 37/23request [17] 22/13 22/24 22/25 23/15 23/24 64/19 86/9 91/1 91/5 91/9 92/2 99/3 110/22 114/20 114/22 115/25 170/17requested [4] 62/13 114/15 170/20 171/5requesting [5] 62/7 91/17 114/19 117/16 152/15requests [11] 43/1 44/5 48/25 87/10 90/12 90/14 90/18 90/22 91/7 91/22 117/20required [16] 22/17 78/11 78/25 92/22 93/6 103/11 103/15 103/20 103/22 105/2 109/17 114/24 149/4 149/6 149/10 149/17requirement [1] 75/4requirements [2] 75/2 79/6requires [2] 79/4 85/2research [1] 91/6resign [1] 121/3resigned [2] 121/6 122/6resigning [1] 145/24resources [2] 6/15 132/12respect [4] 15/22 17/20 42/25 95/18respond [10] 19/15 30/22 30/24 31/21 32/3 32/6 32/8 76/22 85/4 109/12responded [1] 138/24responding [1] 90/14response [12] 4/13 19/19 31/10 31/12 31/13 31/23 38/24 43/16 46/12 79/16 144/11 164/20responses [1] 31/14responsibilities [2] 69/16 75/16responsible [2] 102/19 156/3result [2] 38/19 40/5resulted [2] 33/7 33/19resumed [4] 64/8 66/25 118/13 154/24retaliating [1] 77/14return [1] 29/8review [2] 22/24 123/19reviewing [1] 25/7reviews [1] 91/3RIF [7] 14/15 75/22 106/21 109/15
130/24 137/5 137/15RIF'd [8] 73/22 75/3 75/15 75/24 130/10 130/12 131/2 158/25right [78] 2/3 2/9 2/12 7/18 9/8 10/15 10/23 19/12 23/1 24/6 25/25 26/1 43/8 45/20 53/8 55/1 58/6 58/8 59/9 61/18 64/3 65/13 66/20 66/21 71/20 72/23 73/17 77/5 80/5 81/7 81/13 82/16 83/12 84/15 85/18 86/8 89/13 100/20 103/19 104/14 105/22 105/25 115/16 115/18 115/23 116/13 116/15 116/17 116/21 117/14 117/23 118/4 118/22 123/5 123/24 124/10 124/24 125/12 125/16 126/25 127/10 128/8 128/16 128/25 129/16 130/7 131/13 133/16 135/11 136/14 146/24 147/1 147/8 153/16 154/1 160/6 163/21 171/2ring [1] 143/8rise [2] 64/10 118/15risk [1] 77/21River [3] 13/12 13/19 13/22role [1] 119/2room [29] 25/11 25/12 26/5 26/21 27/11 27/14 28/1 28/4 28/9 28/12 37/9 37/11 38/14 67/3 67/3 67/6 67/11 67/16 67/21 67/22 67/24 95/24 97/2 97/5 97/17 97/20 100/2 107/8 111/9rotation [6] 115/8 115/11 115/15 127/23 127/25 128/8routine [1] 120/8row [3] 155/4 155/12 155/13rows [2] 58/20 139/16RPR [1] 1/21rude [6] 29/4 101/11 110/6 110/15 111/14 111/21rule [3] 85/2 85/3 85/10ruled [1] 78/5rules [4] 72/10 103/8 103/12 141/9ruling [1] 78/2run [1] 11/24Ryan [7] 57/18 58/11 122/13 122/15 122/15 144/19 146/8
SS/Stacy [2] 171/12 171/12said [70] 4/7 4/14 6/1 7/2 7/8 11/15 16/18 16/21 17/20 17/22 20/18 20/23 21/8 21/25 22/1 22/20 25/16 25/25 26/7 27/8 29/11 30/10 30/24 31/12 32/18 32/19 33/12 34/11 36/20 37/7 37/18 41/22 43/3 52/15 56/15 58/3 59/3 62/10 68/9 75/10 75/20 76/3 77/13 84/13 86/22 86/22 87/21 90/4 90/4 90/5 92/23 95/25 100/21 107/11 107/12 107/12 107/14 107/16 107/19 107/19 112/19 127/3 143/7 146/9 150/23 150/24 164/13 165/5 166/22 170/14salary [2] 11/8 12/11same [25] 8/1 24/12 67/19 67/20 68/7 80/13 80/16 91/8 94/19 115/2 134/21 134/22 134/25 135/1 137/14 139/3 148/13 153/2 153/8 154/17 155/4 155/25 156/1 156/3 156/6Satterfield [6] 61/6 61/9 61/12 61/22 136/1 154/18saw [2] 117/7 154/12say [68] 3/23 4/8 7/8 9/4 12/15 15/20 17/19 20/11 21/22 24/16 26/9 28/2 29/14 29/16 30/4 30/5 30/7 32/10 32/11 32/13 32/15 32/17 33/18 34/10 35/6
Ssay... [43] 37/6 37/17 38/13 38/25 40/23 46/4 52/3 52/5 53/19 54/5 54/6 54/11 54/16 55/5 55/6 55/7 58/4 59/22 60/5 65/8 65/20 68/9 68/12 69/8 69/13 71/3 74/6 79/9 80/4 83/25 84/6 90/9 98/21 99/23 103/18 105/10 107/1 109/25 109/25 141/25 164/10 167/12 167/14saying [18] 17/21 24/17 31/19 32/7 32/19 34/12 37/13 40/4 40/10 42/17 47/4 56/10 66/1 77/18 80/24 83/22 95/17 135/25says [44] 23/24 33/2 33/4 38/21 46/1 46/5 46/7 53/17 57/17 57/22 57/22 58/1 58/2 58/6 60/6 62/13 74/5 79/24 80/5 81/2 85/1 88/11 89/11 93/2 93/5 95/16 97/11 103/14 103/21 125/11 127/25 134/1 134/18 135/7 141/11 141/22 146/20 149/8 149/14 151/5 152/6 152/8 154/3 167/8schedule [10] 41/20 49/2 51/3 51/4 51/15 51/16 57/17 151/14 152/16 161/10schedules [3] 118/1 123/8 123/9scheduling [1] 87/24school [140] 1/5 3/6 3/13 3/14 3/16 3/24 4/1 4/6 4/18 4/20 4/22 5/1 5/2 5/2 5/8 5/9 5/9 6/17 6/18 6/18 6/24 6/25 7/3 7/3 7/8 7/9 7/23 7/23 8/1 8/1 8/2 8/3 8/3 8/6 8/6 8/9 10/12 11/25 13/12 15/16 15/19 16/11 16/19 16/22 17/1 17/2 17/23 18/17 20/16 24/16 27/24 39/9 43/8 44/5 47/17 47/18 48/23 49/13 52/5 57/19 68/6 68/8 69/1 69/11 70/10 72/2 72/4 72/4 73/13 74/7 77/4 77/6 78/9 78/12 78/16 78/19 78/25 82/7 86/5 86/13 86/15 86/16 86/24 86/25 87/5 88/1 89/25 91/21 91/22 92/4 92/4 95/7 95/7 102/18 112/24 114/6 114/20 115/2 115/7 116/1 116/23 117/12 117/21 120/4 120/25 121/19 121/20 122/9 122/25 123/8 123/9 124/24 126/4 126/9 127/11 127/13 128/1 128/17 128/20 130/4 130/7 130/15 131/2 131/4 131/14 135/12 135/16 135/21 136/18 148/13 152/19 160/5 160/24 161/22 161/23 162/11 162/14 162/19 162/20 162/23school's [1] 89/11school/high [4] 5/2 5/9 6/18 7/23schooler [2] 115/19 117/17schoolers [3] 115/5 115/11 115/22schools [8] 2/22 8/10 8/15 11/6 41/6 79/25 102/19 121/17Science [8] 127/11 127/14 133/2 136/16 136/18 156/6 156/7 168/25scope [1] 41/13screen [4] 40/25 58/14 60/18 84/25scroll [2] 84/24 152/22se [1] 81/21seated [9] 2/3 2/12 64/11 66/20 99/2 99/24 99/24 118/16 118/22seats [1] 152/2second [15] 3/1 21/22 33/9 41/17 46/15 55/5 55/6 55/7 55/11 57/24 88/16 88/19 88/25 92/21 136/15seconds [1] 37/7secretary [1] 93/16section [4] 134/19 134/21 134/22 140/3sections [6] 127/18 128/13 135/9
152/14 153/22 155/25secure [1] 132/24see [26] 9/7 13/25 24/7 25/22 46/2 57/22 66/6 80/5 88/10 116/3 124/2 129/2 133/21 134/3 134/9 139/19 139/25 141/11 141/22 141/23 144/10 148/4 152/14 153/18 153/19 166/10seemed [1] 104/2seen [3] 123/17 123/17 166/11select [1] 115/3selected [1] 146/25semester [9] 55/5 55/6 55/7 55/11 92/21 152/1 154/12 154/13 154/17send [3] 19/12 112/2 145/21sense [4] 3/18 126/22 136/7 138/8sent [12] 18/16 30/7 32/23 32/23 33/4 33/5 40/20 40/21 60/13 60/14 73/19 146/4sentence [7] 33/10 33/11 33/17 46/5 46/14 46/15 92/18sentences [1] 33/3separate [1] 40/3separation [1] 39/15September [1] 148/9September 5 [1] 148/9session [1] 25/4set [4] 64/16 116/20 161/2 161/7settled [1] 108/13settlement [5] 17/23 108/5 108/21 109/6 113/1seven [4] 89/15 90/3 153/16 155/6seventh [1] 54/11Seventy [6] 7/18 10/24 89/15 105/23 105/24 105/25Seventy-nine [3] 105/23 105/24 105/25Seventy-seven [1] 89/15Seventy-three [1] 10/24Seventy-two [1] 7/18several [13] 19/14 21/10 32/23 49/25 61/11 64/20 71/13 100/13 109/9 113/17 164/16 164/17 170/18severe [3] 33/7 33/19 48/25she [63] 17/25 17/25 18/4 31/16 32/5 32/8 32/23 33/18 33/22 33/24 37/11 37/18 40/20 40/21 44/16 46/17 47/2 51/8 53/17 55/13 61/24 61/25 62/1 62/4 62/6 77/6 86/22 86/22 91/23 91/25 93/16 93/17 93/19 98/4 98/6 98/7 113/13 121/16 121/19 132/9 137/19 137/21 143/7 153/21 153/22 153/23 154/12 154/12 154/13 154/13 154/13 154/14 154/15 156/11 156/12 156/22 156/24 157/1 158/2 158/4 158/6 158/24 170/9she's [7] 31/19 31/19 40/1 40/3 46/10 62/2 62/11sheet [4] 91/1 91/3 91/5 155/3Shepard [1] 156/8short [1] 22/6shortly [1] 71/14should [16] 20/1 42/5 78/16 78/19 78/25 81/24 82/6 82/22 91/4 91/24 91/25 98/4 98/8 102/6 110/11 144/14Shouldn't [1] 15/16show [12] 5/17 24/9 30/18 77/10 80/15 88/6 88/6 102/22 117/23 123/5 157/22 167/9showed [3] 58/20 116/24 117/3showing [4] 19/2 25/18 80/13 116/22shown [2] 90/19 156/1
shows [8] 10/16 55/2 57/16 58/19 77/11 95/20 139/15 156/8sickness [1] 39/15side [2] 58/6 141/23sidebar [2] 76/23 76/25sign [11] 21/6 21/15 21/23 23/8 29/23 49/14 50/3 90/23 136/4 138/8 167/2sign-in [1] 29/23signature [2] 49/21 98/15signed [6] 21/17 103/3 110/22 133/24 136/1 136/7signs [1] 90/24similar [1] 137/16SIMON [1] 1/7simplify [3] 91/19 100/19 158/14simply [1] 110/11since [2] 166/19 168/23single [3] 138/23 156/1 156/2sir [17] 2/8 2/9 6/9 18/6 20/14 30/2 46/25 69/25 85/25 100/17 105/22 141/18 153/4 154/6 155/14 158/9 171/2sitting [1] 166/20situation [11] 95/4 95/23 96/24 97/5 98/4 98/7 99/18 100/21 101/2 101/7 101/8six [12] 55/21 55/22 56/19 56/22 58/25 59/1 62/22 62/23 152/1 153/16 154/11 155/5sixes [1] 154/11sixth [1] 54/11size [2] 42/6 139/23sizes [1] 41/6slots [1] 43/2smart [1] 65/8Smith [10] 46/1 46/7 115/8 125/17 130/1 130/3 130/10 131/1 131/4 131/8so [169] 4/11 4/21 7/22 9/18 12/2 15/3 15/9 16/11 17/6 20/7 20/18 22/7 23/4 23/12 24/4 24/5 24/14 24/17 24/19 26/9 28/1 28/8 31/5 32/1 32/5 32/15 32/18 32/19 36/11 37/8 38/2 41/24 42/4 42/8 42/18 44/23 46/8 46/10 47/12 49/3 51/2 51/11 51/14 52/24 53/3 54/2 56/9 56/10 56/19 58/4 59/1 59/13 59/16 60/9 60/14 60/16 64/17 64/17 64/18 64/21 65/9 65/12 65/14 65/14 65/15 66/10 67/6 67/7 67/23 67/23 68/14 74/17 76/13 76/21 77/9 78/1 78/14 80/15 81/10 83/14 84/11 88/25 89/6 91/10 93/13 94/10 95/13 96/16 96/17 96/24 97/19 98/14 100/18 100/22 102/23 103/11 103/20 105/2 105/5 110/5 113/7 115/5 115/16 115/21 117/14 117/20 120/7 120/11 120/14 120/21 120/24 121/22 122/6 122/8 122/22 123/12 123/15 124/25 125/22 127/10 127/16 127/17 127/20 129/3 131/8 134/3 134/22 135/2 136/20 138/1 138/4 139/3 139/17 140/24 141/4 141/13 141/17 142/17 143/13 143/17 143/17 143/22 144/10 145/11 146/9 146/25 147/15 147/17 149/6 149/15 150/12 151/4 151/14 151/24 152/4 154/11 154/14 155/25 156/1 156/5 156/8 159/5 159/5 161/5 161/25 162/10 164/5 165/23 168/5so-called [1] 100/22software [1] 60/8solely [1] 136/11solutions [1] 49/3some [31] 4/4 4/8 4/8 4/14 7/22 9/4
Ssome... [25] 22/16 29/19 29/23 37/12 39/15 62/21 62/25 64/16 75/7 79/5 79/6 85/6 100/7 100/23 101/11 119/12 120/11 127/7 133/21 134/23 138/17 140/22 140/24 142/7 142/24somebody [8] 19/25 19/25 20/9 24/17 24/20 24/20 60/14 70/11someone [8] 34/16 34/19 36/2 121/25 122/8 122/11 122/12 144/8something [20] 4/9 15/13 17/1 21/15 25/16 40/9 46/16 56/1 56/8 65/20 73/1 73/4 74/17 74/22 78/17 79/10 82/24 83/20 111/20 166/22sometime [5] 14/21 109/6 161/14 161/16 161/17sometimes [2] 135/12 156/15soon [2] 27/4 161/10sorry [28] 6/3 16/24 19/10 20/3 22/1 26/19 32/1 32/10 32/15 32/20 32/22 33/23 43/18 49/10 58/17 70/18 71/12 73/3 77/1 79/19 85/20 102/15 107/12 107/12 116/21 138/17 154/8 157/4sort [1] 123/19sorts [1] 140/23sounds [1] 145/10source [2] 140/10 148/1speak [8] 15/10 15/12 15/14 16/2 112/23 113/1 113/4 113/18speaker [3] 111/11 111/12 111/15speaking [3] 27/15 81/20 90/9special [13] 28/25 29/24 100/8 111/11 155/14 155/19 156/7 156/10 156/11 156/12 156/13 156/16 156/20specialist [1] 122/16specialized [2] 119/24 120/1specially [2] 119/20 120/8specific [10] 35/6 35/14 36/18 43/3 48/3 75/8 79/6 79/6 162/22 162/24specifically [8] 17/19 32/9 48/15 53/18 69/12 80/1 81/18 156/12speculate [5] 79/1 79/2 79/4 162/4 162/12spell [1] 2/16Spencer [12] 57/18 58/11 121/14 122/13 122/15 128/4 128/11 132/7 135/4 144/20 145/9 146/8Spencer's [2] 123/3 148/10spoke [4] 17/6 17/19 28/22 29/22spot [1] 63/16SRT [1] 55/2Stacy [4] 1/21 171/7 171/12 171/12staff [2] 69/19 111/20stand [6] 26/16 80/8 127/11 155/21 166/20 168/21standard [3] 85/2 85/3 85/10standing [2] 26/11 26/18stared [2] 21/19 111/6start [3] 83/12 96/17 161/18started [1] 18/22starting [1] 45/25starts [1] 82/17state [20] 2/16 38/18 60/9 68/16 69/8 84/9 114/25 119/14 120/5 120/25 122/20 126/17 127/14 139/11 139/14 143/7 145/6 145/10 145/14 168/24state-of-the-art [2] 126/17 127/14stated [8] 29/11 30/1 42/10 42/11 43/3 77/5 142/16 145/9statement [7] 67/10 83/1 93/8 145/10
149/8 166/21 166/23statements [15] 14/14 14/17 14/20 19/21 19/23 20/11 33/7 33/19 33/22 33/24 93/13 113/8 113/10 162/9 167/15states [4] 1/1 1/8 1/22 144/1status [5] 8/19 8/23 9/3 9/5 92/16statute [1] 106/23statutes [2] 103/8 103/12stay [2] 26/21 39/19stay-put [1] 39/19stayed [1] 91/8stenotype [1] 1/24step [2] 64/1 171/2Stephanie [4] 121/14 128/4 128/11 132/7stepped [2] 159/23 160/2steps [2] 147/14 153/5still [5] 13/18 20/16 64/20 143/13 144/14stipend [3] 11/24 12/2 12/19stipends [1] 12/12stone [2] 161/2 161/7stood [3] 99/1 99/5 111/6stop [6] 5/20 21/22 33/9 41/17 130/3 130/17Street [1] 1/17stress [1] 146/22stricken [2] 17/12 167/21strike [1] 167/20string [1] 61/11student [47] 42/20 43/1 47/16 48/16 53/20 53/21 54/1 54/7 55/19 55/22 55/25 56/2 56/5 56/10 56/13 56/15 56/23 63/1 86/14 87/4 87/24 88/13 90/13 90/18 90/19 90/22 90/24 91/9 128/1 134/4 140/14 150/25 151/1 151/3 151/5 151/18 152/2 152/4 152/8 152/10 152/12 152/15 152/17 152/17 153/10 154/23 156/2student's [1] 156/19students [65] 28/3 34/23 41/25 42/13 43/4 47/17 47/20 48/18 48/22 49/14 50/2 52/1 58/9 58/22 58/24 59/1 60/9 60/15 62/7 62/13 88/22 90/23 91/4 91/8 91/11 91/17 91/22 111/2 114/14 114/19 115/2 115/13 117/16 119/4 119/7 128/9 133/24 134/3 134/23 135/9 136/1 136/4 136/7 138/8 150/24 153/21 153/23 154/15 154/15 154/19 154/20 154/24 155/6 155/13 155/14 156/11 156/13 156/16 156/24 160/4 160/4 169/13 170/14 170/17 170/22students' [2] 41/20 105/6subject [17] 30/21 30/24 53/18 53/19 54/2 55/16 55/19 60/7 86/6 92/16 94/7 94/12 98/14 98/16 100/14 139/18 156/1subjects [4] 68/17 130/19 139/17 156/3submit [5] 91/2 146/2 146/9 146/10 167/2submitted [5] 72/19 88/1 145/23 146/4 166/18subsequent [1] 161/3such [4] 68/20 80/1 108/11 110/2Suite [2] 1/17 1/22summarizes [1] 124/15summary [2] 118/2 166/18summer [5] 11/24 11/25 12/17 14/21 121/4superintendent [7] 37/19 39/25 72/16 86/9 91/13 102/19 109/2
superior [1] 40/10supervision [2] 72/1 72/5supervisor [1] 68/1supposed [3] 37/24 104/7 110/8supposedly [2] 99/18 100/22sure [36] 3/22 11/24 27/12 29/8 29/8 33/15 39/3 45/4 48/20 52/19 52/25 59/22 60/1 60/19 65/2 65/21 69/8 73/14 76/23 77/12 80/14 83/25 85/24 87/19 99/20 102/24 104/20 107/1 115/16 138/12 141/10 146/17 159/13 161/12 166/19 167/11Susan [2] 70/20 73/19sustain [1] 144/16sustained [10] 7/13 8/13 9/11 14/1 17/10 17/11 19/4 76/14 76/21 167/18sway [1] 110/3SWORN [2] 2/13 66/24system [7] 3/24 39/9 50/20 87/24 89/11 94/20 105/6systems [2] 62/14 62/14Szanyi [1] 54/11
Ttable [2] 29/9 106/1take [36] 2/9 29/6 33/2 45/7 45/10 46/20 53/21 58/3 63/19 64/4 64/23 65/10 81/10 81/10 88/2 91/19 91/22 102/6 104/18 104/22 114/24 115/12 115/13 115/15 115/17 117/4 118/7 123/10 127/20 130/18 134/24 147/13 147/14 153/5 153/15 170/19taken [7] 51/4 51/17 51/18 51/22 107/4 114/15 136/21takes [1] 39/16taking [1] 41/20talk [10] 16/23 23/12 38/10 114/19 124/24 128/20 142/8 158/1 163/3 163/5talked [15] 17/11 37/3 40/1 41/12 41/12 41/13 41/14 41/15 41/18 41/22 114/2 114/13 115/24 137/23 157/10talking [28] 12/12 48/2 55/19 73/15 73/17 90/13 92/4 94/13 94/14 94/16 96/17 100/15 100/20 101/4 117/20 123/11 134/18 135/13 136/15 142/24 144/9 144/12 150/11 150/12 155/22 158/16 161/22 161/23Tammy [1] 156/8taught [40] 43/7 52/1 52/4 62/15 70/12 115/8 120/11 121/7 121/9 121/16 121/23 121/25 122/24 125/9 125/14 125/16 125/19 128/4 129/14 129/20 129/22 129/25 131/8 131/25 132/6 135/23 139/6 139/18 144/21 148/12 151/21 158/11 158/24 159/3 159/19 159/24 162/1 162/11 162/19 162/19teach [37] 44/3 68/2 68/18 69/9 69/17 69/23 70/4 70/6 70/11 72/7 72/8 72/9 73/12 75/23 76/6 77/13 91/25 119/23 122/4 122/8 122/15 122/21 123/2 128/18 130/13 130/19 131/1 133/7 135/20 136/20 139/20 144/20 148/16 148/21 158/2 169/17 169/21teacher [71] 11/5 13/14 13/19 13/22 20/16 25/21 49/12 49/16 57/17 58/8 58/11 59/4 60/17 60/19 68/17 69/2 69/4 69/11 69/22 69/24 70/1 70/2 70/4 70/13 70/22 71/24 72/21 73/16 75/3 75/5 75/5 75/6 75/15 75/16 75/17 79/11 79/12 86/6 92/10 92/21 94/3 94/5 94/6 94/10
Tteacher... [27] 94/12 94/16 94/19 94/23 94/25 95/10 105/10 121/1 121/12 121/23 130/17 132/9 134/22 137/16 146/25 147/13 148/3 148/7 153/5 153/13 155/25 156/2 156/8 156/10 156/20 156/22 159/18teacher's [2] 55/15 55/18teachers [35] 53/22 53/25 55/22 56/4 56/19 56/22 62/22 62/24 63/9 63/10 75/23 76/2 76/3 77/8 119/9 119/23 125/8 130/21 154/23 157/19 158/8 158/11 158/12 158/12 158/17 158/17 158/18 158/22 158/25 159/2 159/6 159/22 160/16 169/11 169/15teachers' [2] 125/25 159/17teaching [25] 13/8 25/6 41/2 68/6 69/24 70/9 72/4 86/4 86/7 92/20 93/3 93/5 94/25 119/12 132/4 135/4 144/15 145/7 146/24 147/1 156/3 159/18 162/13 162/16 162/22Tech [2] 134/24 134/24technical [3] 41/14 143/8 144/21technically [1] 143/14technician [1] 134/14technology [21] 68/7 68/23 68/23 69/2 69/4 69/11 69/12 70/1 70/9 70/21 71/24 72/12 72/21 73/13 73/14 73/16 78/11 125/2 126/17 144/22 162/7telephone [2] 16/7 16/19tell [54] 14/16 14/16 14/19 14/24 15/2 15/4 15/6 17/16 17/24 18/4 18/5 21/3 21/12 26/5 27/1 27/3 27/13 29/2 29/21 32/9 35/5 36/9 44/6 51/8 51/10 57/21 58/12 62/9 67/9 86/1 88/4 91/15 94/7 98/19 98/20 98/22 100/2 101/21 101/22 104/2 104/19 109/25 113/10 118/7 133/23 134/2 134/5 143/14 145/21 148/23 150/9 151/9 152/20 168/23telling [15] 31/16 32/5 39/25 46/10 46/17 47/2 60/14 62/6 62/11 92/17 95/24 135/8 135/9 146/25 168/2ten [2] 26/13 102/6Ten feet [1] 26/13tendered [6] 60/2 80/19 88/8 103/1 143/24 166/14tends [1] 45/14term [5] 6/4 39/11 57/22 57/22 82/13terminate [10] 49/5 63/10 71/9 74/10 74/20 83/17 84/3 84/6 90/2 153/2terminated [7] 14/22 47/14 62/4 144/14 153/5 157/3 157/5termination [8] 47/10 49/8 77/4 77/8 85/7 86/2 157/6 164/3terms [4] 41/17 41/20 42/13 81/20testified [11] 6/16 11/20 17/10 67/2 106/13 128/4 139/1 139/5 139/7 157/14 168/21testify [3] 67/15 162/6 167/19testifying [1] 150/1testimony [7] 1/6 2/1 22/23 22/24 72/19 77/17 124/15testing [1] 164/25than [17] 8/6 9/13 10/3 10/7 11/13 11/17 11/19 11/21 13/23 48/24 62/21 62/23 91/9 102/9 126/11 151/23 158/11thank [16] 2/5 6/9 46/22 57/7 64/2 64/6 66/23 81/14 103/2 107/19 116/20 117/5 148/5 150/21 170/24 171/3thanked [1] 21/9
that [823] that's [86] 5/10 6/21 7/11 7/11 7/12 7/12 8/18 9/15 9/21 12/2 12/14 12/16 12/17 13/17 16/15 17/5 17/8 17/11 18/6 19/24 20/25 22/15 30/9 32/12 32/19 33/20 34/13 37/20 38/13 38/21 47/9 48/2 53/25 56/12 56/14 58/25 58/25 61/6 62/19 68/14 68/25 73/16 74/12 77/24 78/2 81/6 82/11 85/18 87/23 90/25 91/19 92/15 93/2 93/5 94/12 101/2 101/24 103/14 103/21 105/10 105/13 113/19 116/11 117/22 121/2 122/1 125/13 132/14 133/1 134/4 134/4 146/8 146/11 147/2 149/12 149/14 151/18 151/18 153/2 156/8 163/12 164/8 164/12 166/7 168/15 171/1their [17] 16/8 56/5 62/22 62/24 77/22 130/18 154/24 158/18 159/8 159/12 159/14 159/14 159/20 160/2 160/7 169/15 169/16them [48] 4/9 4/19 14/19 15/24 16/3 16/4 16/7 19/15 19/24 22/18 30/14 49/1 51/25 52/16 55/23 58/22 59/13 62/10 62/17 91/16 91/16 91/24 91/25 96/18 98/10 113/1 113/4 123/16 123/19 123/20 124/2 124/3 124/4 124/6 124/8 128/18 130/23 131/14 143/22 150/20 153/11 154/21 155/6 156/14 156/18 157/8 159/21 169/17then [97] 4/7 4/24 5/1 7/22 7/22 9/2 12/15 12/16 14/16 18/10 21/5 21/16 21/19 21/19 23/6 24/15 26/24 27/8 27/19 28/16 29/18 31/4 31/21 31/23 32/9 37/5 37/7 38/8 38/10 40/23 43/24 45/7 47/8 47/13 49/23 54/1 59/3 60/11 62/9 65/18 66/2 66/4 67/6 69/7 69/21 70/13 71/4 71/13 75/25 76/18 81/7 89/9 89/19 90/2 91/3 92/17 93/11 95/19 95/23 96/3 97/19 97/23 97/24 98/16 98/24 99/16 99/18 99/20 101/10 101/21 107/13 107/13 107/17 115/15 125/16 128/13 132/11 134/24 139/18 140/9 141/8 141/13 142/8 143/18 144/25 150/10 152/1 152/13 154/12 154/13 155/3 157/14 157/16 158/6 165/24 166/3 168/5Therapy [1] 132/18there [214] there's [30] 6/4 11/14 20/7 28/12 33/15 39/20 58/25 58/25 60/14 61/13 64/4 67/7 77/20 79/5 79/7 93/3 93/5 98/9 100/19 134/22 138/17 140/9 140/9 142/6 142/18 151/25 152/1 152/17 152/17 158/14thereafter [1] 27/4these [35] 17/22 23/18 29/6 33/13 49/20 56/4 58/20 65/8 88/4 92/21 93/13 108/3 109/12 112/14 112/15 117/7 123/11 123/15 125/25 126/2 127/16 128/16 132/7 135/23 142/21 144/15 155/2 155/9 155/9 155/14 157/7 157/15 158/10 158/12 160/3they [84] 3/18 8/5 15/17 15/17 19/18 29/8 31/5 35/5 41/12 46/8 51/3 51/16 51/17 62/11 68/4 76/3 76/4 76/6 76/6 76/7 80/8 88/4 89/10 90/5 90/7 90/9 90/25 91/2 94/13 114/22 114/24 115/8 115/9 117/12 117/13 118/1 119/22 121/25 123/22 129/6 129/8 130/18 130/19 130/23 135/18 138/20 140/6
140/11 140/12 143/22 150/12 151/1 151/3 155/24 156/13 156/13 156/18 157/17 157/17 159/2 159/10 159/12 159/14 159/19 159/23 160/1 160/1 160/1 160/2 160/2 160/4 160/6 160/8 160/10 161/8 164/6 165/15 168/5 168/14 169/13 169/16 170/17 170/19 170/19they'll [1] 84/19they're [1] 77/22they've [1] 59/13thing [15] 16/23 22/20 39/22 65/6 67/19 67/20 68/7 68/20 96/1 100/22 148/13 150/18 164/21 164/24 166/10things [23] 4/4 4/8 4/8 4/15 5/21 14/6 17/19 21/2 35/3 39/14 42/7 64/17 65/3 65/7 65/8 86/14 92/23 103/13 103/16 114/13 133/21 140/24 142/21think [37] 4/11 9/15 13/6 14/8 14/8 17/10 20/23 25/7 29/18 30/15 36/18 38/2 39/18 41/15 48/24 48/24 57/3 57/9 65/3 65/10 76/14 76/17 76/19 77/16 77/22 78/1 82/9 85/18 107/12 107/13 116/20 134/19 142/18 144/24 146/3 157/17 158/24third [4] 46/1 54/11 83/13 89/3thirds [1] 151/8Thirty [1] 88/24Thirty-nine [1] 88/24this [180] those [71] 12/14 14/17 20/11 22/16 28/19 40/4 41/11 41/20 42/23 43/1 44/6 49/1 52/14 52/16 55/22 59/16 62/15 62/20 62/21 62/21 62/24 66/5 68/19 75/24 76/2 76/6 77/17 79/10 79/13 80/6 86/18 86/22 88/6 91/25 92/6 103/12 103/16 108/2 108/15 113/8 113/10 113/19 115/13 117/1 117/12 117/13 125/8 126/3 128/1 128/5 128/21 129/6 134/25 138/24 139/6 140/23 144/23 148/16 150/18 150/24 150/25 154/24 155/19 157/18 157/19 157/25 158/18 159/2 160/16 161/6 164/10though [15] 32/2 32/7 62/24 71/14 77/15 84/13 126/8 149/17 149/20 149/22 152/8 156/1 156/11 158/18 159/8thought [9] 6/2 22/1 22/7 68/13 68/13 98/4 98/7 154/12 170/5threat [7] 33/8 33/20 38/16 38/22 38/25 39/5 39/23threatened [1] 40/7three [19] 10/24 35/7 40/3 54/12 55/21 63/8 71/8 88/14 89/16 97/1 97/4 97/6 97/19 97/23 97/23 97/24 101/25 102/2 128/21through [11] 49/1 102/23 106/21 117/17 120/1 120/2 123/16 133/20 154/10 154/10 155/2throughout [2] 27/23 114/6thumb [1] 102/23Thursday [2] 61/6 99/17time [61] 3/14 3/19 5/9 8/1 11/25 18/21 19/7 22/21 23/7 23/7 23/9 23/12 26/17 28/13 29/24 32/4 34/23 35/7 35/17 36/2 36/17 39/16 43/1 49/12 52/8 61/25 62/1 63/9 63/10 63/11 63/20 63/24 64/18 74/9 74/19 90/19 104/18 108/18 117/21 118/8 134/21 134/25 135/1 137/14 137/19 141/17 152/12 155/24 156/3
Ttime... [12] 156/7 158/8 158/12 158/17 158/20 158/23 158/25 159/1 159/2 159/6 160/23 169/24times [5] 89/6 89/16 89/21 90/8 164/16timetable [1] 64/17title [3] 54/2 55/16 148/2today [3] 50/3 66/5 144/15Todd [1] 1/17together [1] 118/9told [11] 17/18 37/19 47/12 62/17 88/19 91/24 105/5 113/16 146/1 154/19 154/21tomorrow [3] 64/20 64/22 64/25too [3] 48/2 55/16 96/18took [8] 9/18 9/23 21/5 115/19 128/1 157/16 157/17 168/21top [9] 34/10 46/15 57/16 79/24 81/3 82/16 94/8 103/6 139/24total [1] 12/11totality [1] 77/18toward [2] 26/22 29/4track [1] 59/13trained [2] 44/2 82/2training [6] 43/10 82/3 82/5 119/24 131/4 136/22transcript [5] 1/6 1/24 2/1 171/5 171/8transcription [1] 1/25transferred [1] 121/19transportation [3] 62/13 128/23 154/20treat [1] 105/3Treating [1] 104/25trial [1] 63/21tried [1] 32/3trouble [4] 37/21 38/1 134/10 151/7true [8] 20/10 30/9 67/13 111/7 133/1 155/11 163/12 164/12Trustees [1] 112/24truthful [1] 138/25truthfulness [1] 139/3try [6] 30/3 42/18 44/22 104/15 142/7 156/14trying [11] 13/6 31/10 31/13 35/8 77/9 98/21 99/24 110/6 110/8 150/9 154/6Tuesday [2] 99/6 99/19turn [2] 96/18 132/12turning [1] 155/3Twenty [2] 24/8 88/14Twenty-four [1] 24/8Twenty-three [1] 88/14twice [1] 99/3two [34] 7/18 11/14 12/14 55/21 55/24 70/19 71/20 80/6 80/8 80/9 92/21 92/23 92/24 106/11 120/1 128/25 135/10 144/23 151/8 151/25 152/1 153/22 154/11 154/13 157/25 158/3 158/3 158/7 158/11 158/17 158/22 158/24 159/3 164/5two-period [1] 158/17two-thirds [1] 151/8type [3] 16/5 96/1 139/6typically [2] 16/2 39/19
UU.S [1] 171/13Uh [4] 35/13 40/22 58/7 71/15Uh-huh [4] 35/13 40/22 58/7 71/15ultimately [2] 114/9 146/23Um [2] 89/22 100/24unable [1] 132/24
uncertain [1] 109/17unclear [1] 74/17under [17] 58/24 67/15 68/10 68/15 72/1 72/5 72/10 73/24 73/24 76/4 88/2 120/21 122/20 141/8 145/11 150/23 151/5undergo [2] 14/11 14/12underneath [4] 33/2 57/21 88/10 150/24understand [25] 3/17 4/5 4/6 4/16 4/20 20/8 30/2 31/11 31/15 35/3 39/24 42/14 42/17 47/19 48/1 51/9 52/11 56/3 61/10 69/25 70/8 94/11 120/24 143/4 159/16understands [1] 84/17understood [2] 18/7 142/25union [1] 77/8UNITED [3] 1/1 1/8 1/22University [1] 168/24unless [1] 142/24until [4] 18/22 135/11 135/12 169/23unwarranted [2] 20/1 20/5up [61] 14/14 26/24 40/25 42/18 49/13 49/14 50/3 50/15 52/8 54/3 59/13 63/23 63/23 64/4 65/16 66/17 69/7 80/13 87/11 88/25 90/7 90/23 90/24 94/8 94/20 99/2 99/5 100/9 102/7 102/11 102/24 103/11 103/16 103/20 103/22 103/25 104/8 105/5 106/1 115/21 116/10 116/13 118/1 124/6 132/13 132/21 133/24 134/11 136/1 136/4 136/7 138/9 138/20 141/16 144/1 157/8 157/22 161/19 162/6 163/24 169/23up-to-date [2] 103/11 104/8upon [3] 19/11 107/5 113/21upper [1] 24/6us [17] 21/3 21/12 29/2 29/21 35/5 65/21 80/21 86/1 94/7 98/19 98/20 100/2 100/2 104/3 104/24 119/19 123/7use [4] 45/15 101/1 139/24 140/6used [2] 56/16 87/24useful [1] 146/21using [1] 6/4usual [1] 48/24utilize [1] 126/22
Vvaguely [1] 79/24value [1] 76/20varied [1] 41/12varies [1] 140/9variety [3] 39/14 58/19 68/16verbatim [1] 30/19verify [1] 66/10very [13] 22/6 37/13 64/21 76/19 77/20 80/5 80/7 82/14 84/18 166/25 168/17 170/9 170/10video [10] 25/7 25/7 25/8 25/22 27/15 27/20 27/23 28/1 28/2 28/4violation [1] 85/3violations [1] 77/23visual [4] 92/16 92/21 93/5 129/3VOLK [1] 1/16voted [1] 112/22VUKADINOVICH [60] 1/3 1/12 2/4 7/12 17/22 26/8 30/5 31/6 44/2 45/14 46/1 46/7 57/8 59/12 63/17 64/14 66/21 80/21 84/15 95/18 98/14 98/15 104/12 106/8 106/17 107/6 107/8 107/15 108/11 108/18 108/25 109/7 109/10 110/15 111/15 112/3 112/15 112/24
115/8 116/7 116/20 122/2 123/2 125/17 128/17 131/6 133/7 134/6 135/20 136/20 137/6 137/14 138/1 138/4 141/15 150/8 152/23 161/18 168/20 169/23Vukadinovich's [10] 74/24 83/22 112/22 113/20 115/25 125/22 128/21 136/2 136/11 169/20
Wwait [1] 26/22waited [1] 26/22waiting [1] 102/21walk [1] 35/15walked [1] 26/6walking [2] 102/1 102/2want [28] 16/18 21/15 21/23 24/16 31/24 33/9 33/11 40/25 46/5 52/19 55/16 59/13 62/11 64/4 66/16 66/18 75/7 79/11 80/13 96/13 96/18 118/19 133/20 142/7 157/7 157/24 161/4 170/17wanted [7] 65/2 70/6 116/22 145/21 148/7 154/19 154/20wanting [1] 79/19warranted [1] 19/19was [440] wasn't [17] 9/3 20/10 25/13 26/18 34/12 61/25 77/12 77/24 91/24 97/9 115/14 130/12 148/11 154/14 160/11 160/17 162/16wasting [1] 141/17way [25] 9/7 14/13 15/19 21/10 43/7 43/10 45/11 47/7 47/13 68/7 86/15 86/24 86/25 109/22 111/23 112/8 112/12 113/7 139/24 139/25 151/8 162/11 162/14 162/23 164/3ways [1] 120/1we [67] 5/16 17/19 28/23 34/4 34/5 41/12 41/12 41/13 41/14 41/15 41/24 43/4 44/5 48/25 49/1 49/1 57/11 59/1 59/13 62/10 64/16 64/17 64/18 66/10 80/15 80/20 83/13 87/24 92/3 92/3 96/24 102/5 102/8 114/19 116/17 116/20 117/1 117/5 117/14 118/1 118/2 118/7 120/24 122/12 123/25 124/2 124/14 125/16 126/8 127/10 128/25 129/25 132/6 132/11 133/10 133/21 134/18 136/1 140/24 142/5 142/24 154/23 155/22 161/10 164/10 165/23 167/20we'll [8] 63/23 63/23 65/16 66/6 72/23 118/10 143/19 155/3we're [19] 51/11 63/19 65/12 67/23 83/13 90/9 94/16 104/15 115/16 117/20 117/24 121/22 123/11 141/17 142/24 144/9 144/12 159/5 167/24web [3] 149/2 149/9 149/19website [1] 80/7week [2] 35/7 65/13weeks [4] 71/8 71/13 101/25 102/3weighs [1] 91/14well [46] 7/5 9/5 12/15 15/16 18/4 18/10 24/19 24/22 25/11 25/15 25/21 26/21 32/13 35/25 36/8 36/24 39/21 40/18 42/9 46/17 53/18 60/13 62/20 66/6 73/19 74/13 76/11 81/1 83/23 86/18 90/7 97/15 98/18 98/24 100/2 101/10 103/15 104/2 138/8 142/18 144/12 156/13 159/12 159/23 160/1
Wwell... [1] 162/5went [10] 7/12 9/2 9/5 13/4 13/5 15/15 72/20 88/25 90/5 90/22were [228] weren't [9] 14/5 25/11 37/24 51/15 51/16 52/12 129/6 161/7 164/7what [227] what's [12] 11/8 24/1 46/25 51/21 80/6 80/13 98/16 102/15 144/11 146/12 155/12 158/9whatever [6] 18/25 20/10 20/12 39/18 76/16 117/15Wheatfield [1] 1/13when [86] 7/7 9/1 10/13 13/4 14/15 14/19 15/20 19/25 21/18 22/18 25/3 26/6 27/3 27/10 27/13 28/22 29/9 33/18 33/18 34/25 37/9 37/10 38/13 39/19 39/25 43/10 44/23 52/8 67/3 68/9 72/19 72/20 75/15 77/6 79/9 82/2 82/12 90/9 90/24 95/24 96/24 97/2 97/5 97/15 97/16 97/17 97/19 97/20 99/18 99/23 100/2 104/2 105/5 106/8 107/8 108/10 110/5 113/16 114/19 115/24 117/20 120/25 127/25 139/1 142/5 146/9 148/15 150/10 152/18 154/18 157/10 157/18 158/10 158/16 159/20 160/25 161/2 161/5 161/11 161/23 162/13 165/7 165/20 165/23 168/20 169/23whenever [1] 170/6where [33] 2/21 3/5 3/11 4/25 21/10 28/2 28/18 28/22 33/2 42/11 43/1 46/1 55/19 57/21 57/22 58/5 82/16 86/1 87/21 88/11 91/4 95/23 100/15 110/8 110/21 113/19 131/8 141/11 141/22 149/25 151/4 154/3 155/8wherein [1] 33/6whether [14] 13/13 34/22 42/5 69/13 72/24 75/3 92/3 109/17 115/21 115/24 117/14 127/5 134/6 144/13which [36] 7/5 8/6 12/16 19/8 21/6 39/16 43/1 59/14 59/14 60/19 67/18 68/7 77/19 83/14 88/3 88/15 90/1 94/6 98/11 100/8 101/12 114/2 114/3 114/3 114/9 114/10 119/13 132/12 139/19 140/20 148/17 151/20 154/4 154/11 165/18 169/7while [3] 4/14 135/7 145/17who [48] 14/24 24/22 29/19 30/3 31/10 31/12 32/25 34/14 34/16 36/3 49/16 49/18 58/10 63/14 65/15 75/23 75/24 93/15 94/7 94/10 94/12 94/12 94/13 101/4 101/6 101/8 101/15 101/19 106/9 111/14 111/20 114/14 115/14 115/16 119/23 120/8 125/9 125/14 136/1 140/20 143/5 144/8 146/4 157/21 158/11 165/9 169/6 169/7who's [3] 8/20 66/3 92/10whoever [1] 100/14whole [6] 4/5 4/20 67/24 78/4 139/25 166/10whose [5] 8/20 24/15 88/4 158/22 160/18why [39] 8/8 12/15 14/5 15/8 19/17 36/15 36/18 44/4 50/25 51/14 51/16 51/18 51/18 51/21 51/22 51/25 76/23 78/15 95/2 98/2 98/6 100/25 101/10 102/22 118/7 126/25 127/16 141/15 145/19 146/15 156/8 160/11 160/16 162/16 162/19 162/19 165/15 168/13
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Yyeah [23] 4/8 16/13 31/25 35/18 41/17 46/15 46/17 46/23 48/14 58/23 65/1 82/11 88/7 96/2 102/10 116/15 142/7 147/14 147/20 152/11 166/21 167/18 167/21year [52] 3/1 8/2 10/6 12/11 47/17 47/18 48/23 51/20 57/19 69/1 69/11 70/10 71/6 72/2 73/13 75/25 76/1 78/12 86/5 87/11 88/16 88/19 88/23 88/25 89/1 89/3 89/7 89/13 89/16 89/19 89/21
89/25 90/1 91/21 91/22 92/19 95/7 95/7 106/19 107/4 114/6 140/20 140/23 142/14 142/21 142/21 152/19 153/2 153/8 160/24 162/16 162/23years [10] 63/7 86/14 87/5 87/10 87/11 87/11 91/7 108/3 116/1 139/16yell [4] 26/3 26/9 110/25 111/4yelled [4] 21/19 21/20 25/25 26/14yelling [2] 28/3 95/25Yep [5] 131/18 148/7 155/16 155/18 155/20yes [411] yesterday [5] 32/3 49/20 67/9 98/25 99/6yet [3] 83/6 139/21 154/23you [995] you'd [3] 58/3 156/5 156/6you'll [2] 92/5 142/8you're [31] 20/12 24/17 29/9 32/10 34/12 34/16 35/4 35/8 39/8 39/8 40/11 42/7 47/12 48/2 51/9 52/4 56/8 56/10 65/3 65/16 69/5 73/4 75/21 78/17 82/24 83/6 85/20 87/13 100/20 137/13 150/12you've [10] 23/1 39/3 77/16 107/17 109/9 110/21 119/19 123/16 127/3 129/8your [209] yours [2] 41/19 42/25yourself [2] 46/21 107/5yourselves [2] 63/21 118/10Yurechko [12] 49/17 49/19 50/21 54/5 92/16 94/9 94/15 119/11 120/11 121/3 122/6 137/23Yurechko's [3] 50/3 50/5 128/25YY [2] 133/16 133/17
Zzero [10] 56/6 56/21 56/24 58/9 58/21 59/1 62/22 134/3 134/18 134/19