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


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Case 1 :05-cv—00891-SLR Document 53-2 Filed 05/22/2007 Page1 0f2

Case 1 :05-cv-00891-SLR Docu ment 53-2 Filed 05/22/2007 Page 2 of 2
‘ Blozis v. Mellon Trust of Delaware, et al.
Linda J. Blozis, Volume 1 C.A. # 05—891 (SLR) July 26, 2006
Page 90 Page 92 _
1 stunned and shocked that a manager would talk to a 1 Q_ who was the HR director that ygrjrg referring
2 woman in that manner. 2 to?
3 Q. So, Ms. Blozls, you believe in that dosed door 3 A. Rosemary Thomas.
4 meeting thatyou were referring to that Mr. Gilmore 4 Q. And you said you had gone to her about a sales
5 during the course of the discussion used the terms 5 officer?
6 goddamn lt and shit? 6 A. Yes.
7 A. To the best of my recollection, yes. 7 Q. When did you go to her?
8 Q. And Ithink you resulted that youre not 8 A. As I recall, it would have been in the mid to
9 certain of the exact exchange? 9 late nineties.
10 A. Yes. 10 Q. And what was the issue with the sales officer?
11 Q. Had you heard Mr. Gilmore use profanity before? 11 A. I don't recall speciically at this time. To
12 A. Regrottably, yes. · 12 my recollection, he was telling clients, he was
13 Q. The same terms? 13 telling clients Mellon would deliver on different
14 A. Yes. 14 items that were really not Mellon policy.
15 Q. And where had you heard him? 15 Q. And —
16 A. As I recall, it may have been behind l:he dosed 16 A. Prospective dieI‘l|$.
17 doors when Bill Becker was the investment officer and 17 Q. Who was the sales officer?
18 Brendan would bein with him, with Martha Fetters when 18 A. Anthony Jasienski.
19 she was an investment ofnoer and perhaps at team 19 Q. Was he working out of the Delaware facility?
20 meetings, unfortunately. 20 A. Is he working?
21 Q. During the team meetings that he would be 21 Q. At the time.
22 holding with the rest of his team? 22 A. At the time, yes.
23 A. Yes. 23 Q. And you said that you and Linda — I'm sorry ·-
24 Q. He would say goddamn it or shit during the team 24 you and Ms. Squier had gone to Rosemary to oomplaln
Page 91 . . Page 93
1 meetings? 1 about Anthony and $5 felt that lt was ln conndence
2 A. As I recall, occasionally, yes. 2 and then I guess there were other people who were
3 Q. Would he be using it as emphasis? · 3 aware of it?
4 A. I can't say at this time. I don't ruall. 4 A. Yes.
5 Q. Now, you said that you had overheard him using 5 Q. And you felt that she shouIdn't have told
6 the same terms with Becker and Fetters? 6 anybody else about lt?
7 A. Martha Fetuers. 7 A. Yes.
8 ` Q. And Becker? 8 Q. The people who were aware, were they Anthony's
9 A. Yes. 9 I guess for lack of a better word bosses or
10 Q. Now, during the periods that you overheard him 10 supervisors? ' y
11 using those terms with Bed 12 ever go to anybody to complain? 12 Q. And who was the other one?
13 A. I don't understand who you mean by "anybody." 13 A. To the best of my recollection, Brendan Gilmore
14 Q. Well, HR, for example? 14 was there, Brendan's supervisor Douglas Kloppenburg
15 A. At this time I would say I re ·¤ ll not having a 15 and the regional sales manager of Tony Jasiensld at
16 good rapport with HR. 16 tl1e time. I don't recall his name.
17 Q. At what point did you feel that you didn't have 17 Q. And why dld you feel that those individuals
18 a good rapport with HR? 18 shouldnt have been made aware of it?
19 A. Linda Squier and I and other Delaware team 19 A. Ms. Squier and I approached HR in confidence.
20 members wanted to discuss an incident years prior to 20 We were assured that it would be a confidential
21 this regarding the conduct of a sales officer. We 21 dismission between Rosemary Thomas, Linda Squier and
22 understood lt to be a confidential meeting. The HR 22 myself and Rosemary Thomas showed up with the three
23 director at that time brought in other officers that 23 oflicers, additional three officers.
24 were above Linda Squier and I besides herself. 24 Q. Did you then tell your sort of story to the
24 (Pages 90 to 93)
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