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


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Case 1 :05-cv—00891-SLR Document 57-2 Filed 05/22/2007 Page1 0f4

Case 1 :05-cv-00891-SLR Docu ment 57-2 Filed 05/22/2007 Page 2 of 4
Blozis v. Mellon Trust of Delaware, et al.
Linda J. Blozis, Volume 2 C.A. # 05-891 (SLR) January 13, 2007
" Page 257 Page 259
G} 1 say sometimes co-workers at the time, a number of 1 would move on to speak to the supervising officer, which
2 co-workers, and perhaps Mr. Becker or Mr. Landis. 2 I think was Landls or Becker at that tlme.
3 Q. What about Mr. Gllmore? 3 Q. what time frame? _ .
4 A. I can't recollect lf I had that type of 4 A. 'l1me frame meanlng what? I don't understand.
5 conversation with hlm. 5 Q. What year? If you have a specllic date that
6 Q. Why dld you say that you would be interested in 6 would be great.
7 going down to Naples? 7 A. It would have been prior to the lift-out that
8 A. Because it was a nice place bo live and work, and 8 occurred when Mellon sold the retall and business banking
9 warm and sunny. , 9 operations to Citizens Bank.
10 Q. And you had a house down there, correct? 10 Q. 19987
11 A. I did, yes. 11 A. No. We had gone -- our group had moved fnbo Hue
12 Q. While you were employed at Mellon did you ever 12 Greenvllle office - oh, my gosh, see lf I can recollect
13 hear Brendan Gllmore make a comment about Maria Dunlop's 13 that year -- probably around 2002 to 2003, and Citizens,
14 boots? 14 or that which became Cltlzens retail was stlll operating
15 A. Specifically, I can't recollect. But there were 15 ln that office until lt can moveout.
16 comments and asldes that Gllmore had made about other 16 Q. Now, the person that you described her as a
17 employees at the time, that I worked at the Greenville 17 single mom, who was lt? i
18 office. 18 A. At this polnt I don't recollect her name, but I
19 Q. But specifically as lt relates to Maria, did you 19 could, wlth research I probably could End that out. She
20 ever hear Mr. Gllmore make any comments about her bool: 20 sat at the next desk from me. She may still be with
21 or her attire? 21 Citizens. She was an attractive girl, but a professional
22 A. Her attire, sometimes, yes. 22 worker. r _ ll
23 Q. what did you hear? 23 Q. Now, with respect to, you described what Mr.
24 A. Exact and specifically, I don't recollect at this 24 Gilmore would do I guess when he {came down to the
` Page 258 I Page 260
1 time. aut some comments that I thought might be 1 Delaware ofnce, and she would be sitting at her desk?
2 inappropriate. 2 A. Yes.
3 Q. Like what? 3 Q. Okay. Now, did you ovemear the conversations?
4 A. Perhaps -- my recollection is that perhaps, how 4 A. Several of us overheard the conversations.
S an outfit looks or posslhly fits .—· mebody. 5 Q. Did Mr. Gllmore ever make any comments to you
6 Q. when you say somebody, meaning Marla? 6 that you felt were inappropriate?
7 A. Maria, and I am also recalling when, a specific 7 A. At this point I don't recollect ln the same way
0 Incident, Instance when we shared space with the retail 8 tl1at he did to this younger employee.
9 folks, before they became Citizens, there was a sales gal 9 Q. Okay. When you say "in the same way," whether
10 who was married, and who was an auractlve single mother, 10 they were in the same way or some other way, you had
11 a responsible worker, and others ln that office -- 11 spoken eanler about me convefsatlon that you had ln his
12 because at the time Maria wasn't even on board yet - he, 12 ofhce where you felt he yelled at you, so you told me
13 Gllmore would come into the office and stop by her desk 13 about that lime. Any other times?
14 and say things and comments to her that appeared to be 14 A. I don't fully understand your comparison or the
15 unprofessional. 15 premise.
16 Q. Llke what? 16 Q. Let me just --
17 A. The exact words I don't recall. But I can bell 17 A. Would you clarify?
18 you that Miss Cindy wilson was an employee of Mellon at 18 Q. Because what I'm getting from you ls that Mr.
19 the time, myself, I'm trying to think of - Joan Rowe, 19 Gilmore made comments that you took to be of a sexual
20 who worked for Holding Companies, he just seemed to talk 20 nature concerning this woman who may or may not have been
21 in an Inappropriate manner to her, his tone of voice, an 21 a Citizens employee; is that right?
22 obvious, I think we used the berm gushing or flirting. 22 A. That'; correct. And lt was not just myself who
23 And this young lady tried to conduct herself in a 23 understood this to be that way.
24 professional manner and get on with her work, and then he 24 Q. All right. Did Mr. Gilmore ever make any
5 (Pages 257 to 260)
Wilcox & Felzer, Ltd. Professional Court Reporters (302)655-0477 V

Case 1 :05-cv—00891-SLR Document 57-2 Filed 05/22/2007 Page 3 of 4

Case 1 :05-cv—00891-SLR Document 57-2 Filed 05/22/2007 Page 4 of 4
Blozis v. Mellon Trust of Delaware, et al.
Maria F. Dunlop C.A. # 05-891 (SLR) December 21, 2006
_ Page 30 Page 32
` li 1 performance as a whole? 1 Brendan Gilmore?
' 2 A. I don't know. 2 A, Yes,
. 3 Q- A5ld¢ Wm ’/¤¤F5€lf. d¤ you know who else 3 Q. Do you remember what she said to you? .
4 received bonuses ln the Delaware office in 20027 4 A. No. I
5 A. No. » 5 Q. Do you remember what you said to her?
6 Q. Aside from yourselh do you know who else 6 A. No.
7 received bonuses ln the Delaware ofhce ln 20032 7 Q. Do you remember lf she had told you that
8 A. No. 8 Brendan Gilmore had swore at her?
9 Q. Was there ever a time when you were able to 9 A. I don't remember specifics.
10 receive assistance from unda Blozls in completing your 10 Q. You don't remember specllic words that she had
11 work load? 11 said he said to her?
12 A. Yes. 12 A. Conect. I remember —- I can't think of speclnc
13 Q. Do you remember when that was? 13 things, but I remember that he did not treat her well.
14 A. The whole time we worked together, we helped each 14 Q. And did he not treat her well on one occasion or
15 other. 15 was this something that happened dunng the course of her
16 Q. And with regard to your assignments, she was 16 employment on more than one occasion?
17 allowed to help you complete your assignments lf there 17 A. More than one occasion, yes. i
18 was more work than you had time to complete? 18 Q. How did he not treat her well?
19 A. Yes. 19 A. I can't think of specific things. ·I can't ._
20 Q. At Mellon with regard to vacation, did you have 20 remember spedficthings. I just remember in my mind
21 to request vacation? 21 that he wasn't nice to her. 1 --
22 A. Yes. 22 Q. Did you ever have any problems with
Z5 Q. And were you allotted so many days of va tion 23 Brendan Gilmore not being nice to you?
24 each year? 24 A. Again, I don't remember specific, but he -- he's
, Page 31 I Page 33
1 A. Yes. 1 not a friendly person. He makes comments that aren't
2 Q. And did you have to make any specific requests in 2 always a¤iw¤¤r1¤¤¤· His ¤¤if¤¢|¤· his d¢m¤¤¤°*’· his--·
3 advance of when and how many days you wanted to take 3 Q- $0 during tha time Y¤¤ w¤rka¤ there.
4 vacation? 4 Brendan Gilmore made Inappropriate comments?
5 A. Yes. 5 MS. WILSON: Objection to form.
6 Q. Did anyone at Mellon ever deny one of your 6 A. I can remember one specitic comment he made about
7 requests for vacation? 7 knee-high boots I wore to work once.
8 A. No. 8 Q. what did he say?
9 Q. Was there ever a point in 2003 when 9 A. He just made a comment about them. And just the
10 Brendan Gilmore had a closed-door meeting with 10 way he looked at me I d¤n't faal was ¤v¤r¤v¤*i¤¤=·
11 Linda Blozis? 11 Q. Do you remember what he said?
12 MS. WILSON: Objection to form. 12 A. I don't remember specifically, no.
13 A. I don't remember that. 13 Q. Did you feel he made a sexist comment bo you?
14 Q. Do you ever recall Brendan Gilmore shouting at 14 MS- WI|50N= 0bJ¤¢1l¤¤ tv f¤fm-
15 Linda Blozis behind closed doors? 15 A- Yas-
16 A. I don't remember. 16 Q. Do you feel that he did not treat women ln the
17 Q. Do you ever remember Brendan Gilmore using 17 ¤f¤¤a as wall as he treated the mah ln the ¤ffi¢¤?
18 profanity with Linda Blozis? 18 Ms. WILSON: objection to fonn.
19 A. I don't remember. 19 A. Yes.
20 Q. Did Linda Blozis ever tell you that 20 Q. And to the best of your knowledge, he never made
21 Brendan Gilmore had used profanity with her? 21 any inappropriate comments ta any ¤f tha man in the
22 A. I don't remember. 22 ofhce about their clo1:hing or attire?
23 Q. Do you recall Linda Blozis ever coming to you in 23 M5- W1l»$0N= 0bl¤¢¤¤¤ 170 Wm-
24 tears or upset because of a meeting she had with 24 A- I d¤¤'t Nmimber ¤¤v ¤¤¤¤m¤¤l$ m¤¤¤ W Umm-
9 (Pages 30 to 33)
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