Free Appendix - District Court of Delaware - Delaware

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Case 1:05-cv—OOO55-KAJ Document 47-9 Filed O1/27/2006 Page1 0f4

3 Case 1:05-cv—OOO55-KAJ Document 47-9 Filed O1/27/2006 Page 2 of 4
Robin D. Nichols v.
Bennett Detective 65- Protective Agency et aL
Valerie D. Brittinglaarn 3
january 6 2006
Hawkins Reporting Service
715 N King Street
Suite 3
VWZ1/nington, DE United States ofA1nerica -19801 _
(302) 658-6697
Original File VALER1~ 1.7X7§ 18 Pages
Mm-usmpte Fika m.·061szs997.s·
Word Index included with this Min-U-Scripte
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january 6, 2006 Bennett Detective & Protective Agency, et al.

Page 5 Page 7
pj her? [11 incident we’ve been talking about here today
¤·» MR. GERBER: I did skip over that. i [21 between Mr.Whiteman and Ms. Nichols? _
don’t think it's extremely important, so we ‘ ts] A: just what I heard here and then ‘
.., can gloss over that. I {4] the rumors that you hear around the plant,
ts; Q: Could you please just relate your ts; 0: So you never really heard anything
{sj prior work experience, how long — first off, {st other than rumors there?
m how long have you been at Allen’s? rn A: Yes, that’s correct.
[aj A: Eight years. [sj Q: Did you ever speak to Ms. Nichols
gs; Q: Eight years? rst about this occurrence?
[to] A: Yes. tw; A: Not that I recall.
mj Q: Where were you before that? my Q: You never spoke to her directly?
uz] A: Before that I was in Las Vegas. uz; A: Not that Irecall.
ps; Q: Las Vegas? ua; Q: How closely do you interact with
my A: Yes, Iwas in the [14] Bennett employees, the supervisors and the
ps] Q: What branch? [is] security guards?
us; A: U.S.Air Force. gis; A: I don’t really have much
my Q: How long were you in the Air tm interaction with them, other than to show my
pe; Force? na] I.D. as I‘m coming through the gate or if they
ps; A: Twelve years. us; have to get a product for me off the employees'
[203 Q: Twelve years.What was your rank? tram sales truck, that would be my interaction with
[21) A: Staff sergeant, E-5. {[21] them mainly.
[zz; Q: Now,Allen’s Foods, who is your im; Q: Okay. Is there a break area or
[221 supervisor? [za} some area where you would all congregate,
[aq A: Greg Miller. [241 socialize at any point?
Page 6 Page B
nj Q: And you know Robin Nichols? pj A: Just the cafeteria.
tz; A: I remember her. tz; Q: Just the cafeteria?
ta; Q: Okay.You remember her from -—— [sj A: Yes, just the cafeteria.
iq A: A1len’s. [41 Q: Do you remember what happened to
[sj Q: Allcn’s. ts] Ms. Nichols after this incident, what did you
rst So you were there the entire time ts] hear?
m she was at Allen‘s? m A: I don': remember hearing anything
ts] A: Yes. {a1 other than that there had been police there,
pt Q: Do you know her very well? You tm that was it.
no; say you remember her, did you know her? may Q: J ust from your recollection, can
my A: No, I didn’t really know her. I in 11 you just tell me as specifically as you mn, you
[121 just knew that she was a security guard there ima] just basically mentioned rumors, but what did
[ta] and we would speak and exchange pleasantries my you hear?
pq that was pretty much it. my A: 'l`hat's all I heard, rumorsffhere
us; Q: On a daily basis? ps] was an incident, the police was called, Robin
{rs] A: Whenever she was there. ns; was involved, and there was a push, that’s it. ‘
mj G: Sure. Of course. tm Q: Okay. And you knew it was
may You never worked really in close my Mr. Whiteman involved?
us; proximity with Ms. Nichols? [19] A: No,l didn‘t know that.
tai; A: No. [20] Q: You didn‘t know that?
{211 Q: You're a full—t.irne employee at [zi] A: No,] didn’t know that.
tz:} Allen’s Foods? l22] Q: Okay Did you know anything about
[za) A: Yes. [za] a suit being filed?
pq Q: Do you have any knowledge of the :[24] A: No.
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i .¢~ ifi if I V!AGétsé~Y?l¥'O5¥CV-OOO55 KAJ '
» A . .:::. . 1 l · Docume r;11.4IZ:9. ,~ » » » Flled»O1/27/2006 Page 4 of 4 l
Robin D. Nichols v. Valerie D. Brittingham
Bennett Detective & Protective Agency, et al. January 6, 2006

Page 9 Page 11
m Q: Until ·- m Ms. Nichols - sorry if I asked already you
pi A: Until Tm here today to rind that . [21 never talked to Ms. Nichols directly about this
ta] out, yes. ga] incident?
[4] Q: Now, you didn’t know why 541 A: No,I don't have any recollection
[si Ms. Nichols left? gs; of her discussing this with me.
ge; A: No,I did not. ts; Q: Did you ever talk with her
m Q: You didn't hear anything about m specihcally about Mr. Miller?
{al that? gs] A: N0.
[si A: No. ls] Q: Never about Mr. Miller?
po; Q: So you have worked with Mr. Miller [mi A: No.
my for how long? uu Q: So you never made any comment to
[12] A: Four years. [12] her that Mr. Miller was a racist?
uz; Q: Four years. na; A: No, I don't remember that.
[14] A: And I have been in the Human [14] Q: Okay.'['hat was her testimony
usp Resources Department for four years. Before [15] A: Her statement.
ns] that I was out in the plant in the QA [im Q: So you don’t remember anything
tm Department. mi like that?
pa] Q: Whats that? ua; A: No, that wasn’t me.
ps; A: Quality Assurance. ips; Q: That was not youd
tau} Q: How do you like working with iam A: That was not me.
521] M1‘.Miller? {[21] Q: S0 there wou1d.n’t have been
yzzi A: It’s okay. ‘tz21 anything even that sounded similar that would
[za] Q: Okay. Have you ever had any I {za] have been along those lines to Ms. Nichols?
[aq don't know how to term it, any run-ins with [aq A: No, not to my recollection.

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[ry anyone at Allen's Foods or any disciplinary qi) Q: Do you think Mr. Miller is racist?
m problems with anyone at Allen’s Foods? {2) MR. BREWER: I'm going to object
pi A: No. gs; to that.
pi Q: Have you ever been disciplined? :4; You can answer the question.
is; A: Just for talking too much with is; Q: You can answer.
ts] people coming to my desk; my music was too loud is] A: [have no comment.
m or something along those lines. m Q: You have no comment?
[sy Q: Minor little thing? gs; A: No.
[si A: Yes. py Q: Well, no comment.
{101 Q: Do you know how many times you [10] MR. GERBER: I think that’s all I
pu have been - were you written up for any of [11] have for you right now.
uz; those incidents? uz] THE WITNESS: Okay.
ns] A: I only heard of them when I had my ns) MR. BREWER: I don’t have any
[14] evaluation. [14] questions.
ps; Q: Okay. So you do get evaluations ns] MR. LANDON: I do.
pe; periodically? [16] BY MR. LANDON:
tm A: Yes. un Q: It’s not my intent to make you
may Q: How often? na; uncomfortable, this question is going to make
pg; A: Once a year. [19] you uncomfortable, Itl1ink.Why do you have no
[zo; Q: Have you ever had any [ani comment on that question?
{zu confrontations with Mr. Miller that you can {zi; A: It’s a personal opinion.
lazy remember, any direct confrontations with hinf [22] Q: Do you have a personal opinion?
my A: ‘No.No. [23] A: Yes.
{za; Q: Did you ever talk to [241 Q: What is it?
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