Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1:05-cv-00046-JJF Document 56-3 Filed O1/17/2006 Page 1 of 3
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Case 1 :05-cv-00046-JJF Document 56-3 Filed 01/17/2006 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
WILLIAM HANSON, III 1
Pisinttrs Z
V. Q crvn. Acrrou
: NO. 05-0046 (DF}
LOWYEDS HOME CENTERS, INC., ct el. :
Defendants.
VERIFICATION DF JUN WUODHAM
I, Jon Woodham, pursuant to 28 U.S.C. § 1746, state the following based on my
personal knowledge:
L Iam the Human Resource Assistant at SPM]. SPM} is human resources
outsourcing company which provides human resources services to DDP Holding, Inc. ("DDP"),
2. Between October 2003 and January 2004, DDP employed three individuals in the
State ofDelnware.
3. In January 2004, Jeremy Leamsn celled me and said that William Hanson had
tape recorded a conversation with a Low:-:’s employee without that ernployee’s permission in
violation of Lovve's policy and that because oi`h.is conduct, Lowc's no longer wanted Mr.
Hanson to service the Dover store.
4. Because DDP is a dedicated vendor to Lowcfs, in the event an employees
behavior is such that he is removed from his or her assigned store, DDP has to end the
employment relationship.
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Case 1:05-cv-00046-JJF Document 56-3 Filed O1/17/2006 Page 3 of 3
5. I directed Mr. Learners to terminate Plintiffs employment.
6. I did not lmow Plaintiffs race or national origin to be Asian or Korean
7. I declare under penalty of perjury that the foregoing is true and correct.
Executed on this [ Q day of January, 2006
meh weedham
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