Document 159
Filed 10/15/2007
Page 1 of 38
1 Michele Ballard Miller (SBN 104198) Janine S. Simerly (SBN 102361) 2 Lisa C. Hamasaki (SBN 197628) MILLER LAW GROUP 3 A Professional Corporation 60 E. Sir Francis Drake Blvd., Ste. 302 4 Larkspur, CA 94939 Tel. (415) 464-4300 5 Fax (415) 464-4336 6 Attorneys for Defendants CHEVRON CORPORATION (f/k/a ChevronTexaco 7 Corporation) and CHEVRON INTERNATIONAL EXPLORATION & PRODUCTION 8 (f/k/a ChevronTexaco Overseas Petroleum), a division of Chevron U.S.A. Inc. 9 10 11 12 13
A P R OF E SS I ON AL C O RP OR A T IO N L A R KSP UR , C AL IF OR NI A
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
M ILLER L AW G ROUP
14 15
KIRAN PANDE, Plaintiff,
Case No. C 04-5107 JCS DEFENDANTS' DESIGNATION OF DEPOSITION EXCERPTS OF ZUWA OMOREGIE; PLAINTIFF'S OBJECTIONS TO SAME AND THE PARTIES' COUNTER DESIGNATIONS Trial Date: Time: Place: Complaint filed: October 9, 2007 8:30 a.m. Courtroom D December 2, 2004
16 v. 17 CHEVRON CORPORATION (f/k/a 18 ChevronTexaco Corporation) and CHEVRON INTERNATIONAL EXPLORATION & 19 PRODUCTION (f/k/a ChevronTexaco Overseas Petroleum), a division of Chevron 20 U.S.A. Inc. 21 22 23 24 25 26 27 28 Defendants.
DEFENDANTS' DESIGNATION OF DEPOSITION EXCERPTS OF ZUWA OMOREGIE; PLAINTIFF'S OBJECTIONS TO SAME; AND PARTIES' COUNTER DESIGNATIONS Case No. C 04-5107 JCS
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 2 of 38
1 2 3
Enclosed please find the attached Exhibits.
Exhibit 1.
Defendants' designated excerpts of the Deposition of Zuwa Omoregie,
4 including objections made by Plaintiff Kiran Pande; 5 6 Exhibit 2. Counter-designated excerpts of the Deposition of Zuwa Omoregie,
7 made by Plaintiff Kiran Pande, including additional excerpts counter-designated by 8 Defendants for inclusion if Plaintiff's counter-designations are accepted and read into the 9 record. 10 11 12 13
A P R OF E SS I ON AL C O RP OR A T IO N L A R KSP UR , C AL IF OR NI A
Dated: October 15, 2007
MILLER LAW GROUP A Professional Corporation
M ILLER L AW G ROUP
14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
By: ____________/S/_ Lisa C. Hamasaki Attorneys for Defendants CHEVRON CORPORATION (f/k/a ChevronTexaco Corporation) and CHEVRON INTERNATIONAL EXPLORATION & PRODUCTION (f/k/a ChevronTexaco Overseas Petroleum), a division of Chevron U.S.A. Inc.
DEFENDANTS' DESIGNATION OF DEPOSITION EXCERPTS OF ZUWA OMOREGIE; PLAINTIFF'S OBJECTIONS TO SAME; AND PARTIES' COUNTER DESIGNATIONS Case No. C 04-5107 JCS
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 3 of 38
EXHIBIT 1
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 4 of 38
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
--000-
KIRAN PANDE, Plaintiff,
vs.
Case No.
04-5107 CW
CHEVRON CORPORATION(f/k/a
Chevron Texaco Corporation/, a)
Delaware corporation, et al.,
Defendants.
DEPOSITION OF ZUWA OMOREGIE
Thursday, April 6, 2006
REPORTED BY:
DENISE A. FORD, CSR 7525 (380011)
~LEGALINKe
AWORDWAVE COMPANY
LegaUnk San Francisco
575 Market Street, 11th Roor San Francisco, CA 941.05
tel (415) 357-4300 tel (800) 869-9132 fax (415) 357-4301
www.legalink.com
GLOBAL COURT REPORTING - LEGAL VIDEOGR!\PHY
TRiAL SERVICES
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 5 of 38
ZUWA OMO"REGIE April 6,2006
1
2
3
4
5
--000-
BE IT REMEMBERED that purs0ant to Notice and on
Thursday, April 6, 2006 commencing at 2:00 p m. thereof,
6
7
8
9
at the Law Offices of McGUINN, HILLSMAN & PALEFSKY, 535
Pacific Avenue, San Francisco, California 94133, before
me, Denise A,
Ford, a Certified
Sho~thand
Reporter,
personally appeared
ZUWA OMOREGIE
10
11
12
called as a witness herein,
wh~,
having been first duly
sworn, was examined and'testified as follows:
--000--
13
14
15
16
17
18
19
20
21
22
23
2~
25
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ZUWA OMOREGIE ApIi) 6, 2006
1
J.l.
1\
. Okay
Is there any reason 'dhy
T~Je
2
Q.
£orr,,~ard
cannot go'
3
\?Jith your .deposition today?
s
6
7
Q.
Have you ingested anything in the
P3S~,
say, 2.4 or 48 hours that J,lould impede or impair your
ability to recall events or testify truthfully?
8
9
No.
HQ~.---I~hy..,arl-"~Jt.,.}.e--Ftever
gotten a
"yes" anSTdcr to that
10 11
question.
Who is your current employer?
12
13
14
A.
Chevron. How long have you worked for Chevron? Since '81::
Q.
A.
Q.
15
I would like to· short-cut some things.
If
16 17 18
you can ,just give me your educational background starting 'with undergraduate,
. A.
Bachelor's, master's and Ph.D. in in Los Angeles
BAr
19
20
petroleum engineering at U.5.C, Q.
When did you receive your
BS,
what year?
21
A.
1978.
1
22
Q. A. Q.
A.
And your master s? '
23 24
25
The same year, 1978.
And your d.octorate?
1981
>
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ZUWA OMOREGIE April 6, 2006
1
Q.
And from what I can see already you went
2
3
to work immediately for Chevron?
A.
Q.
Yes, I did. And you have been with Chevron ever Slnce?
Yes.
5
6
7
-Q
That ,is unique for eny cornpan:l
knO\"
j
I
p@opls at Chsvron rna'ue around a lot
~nd
9
me at least in 'broad strokes
l..
'hat positions you have
10
held at Chevron since you started .
..f-ArZ\-."...---P:!'""'-'G-5i-t-i-ens or \Jork locations?
11
13
to include in that
Til/ork
locations,
that
IS
fine.
14
15
reser 1 Jo'ir. s11pervi serf
petrole JJTn
engin~@ring menag~rl
16
aUb5U r feG@
m~nag9r,
petroleum engineering sponsor,
sS~8t
18
leader. Q,
19
20
And what is your current job?
Team leader, petroleum engineering
21 22 23
consulting services in Chevron's Energy Technolqgy
Company.
Q.
Is that more commonly known as ETC?
Yes.
I c that ,the same group tha t at one point
24
25
A.
Q.
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ZU\VA OMOREGIE April 6, 2006
2
3
That'g cor:-@ct.
Q nnd
hOhT
long ha1 e yon been wi tb - st r
T
j ke
4
-that.
6
fear- sa I am Gonc@rnsd
j
'Jill refer to that group and
8
Fr-r----+f:;..a-t:..1 5 fi ne .
So
hOlt
9
long have y&B--WG-E-k-e4----:i-B ETC?
-I w·o r K-e-d -f..e-J.:: the m t
~Ja-5----alled
L,' ice
10
11
A--::-.--~\oJl-t-e"""--il-l;
.
S tar ted
"zith them at the time it
J2£5a@Earch Company...;... that years
Chevron Oil Field
so four
12
13
'aleS
from
'81 to 185,
Then from late 2000 to Gurrent.
14
15
Q.
And where have you been located as far as
where your job was located since 2001?
16
A.
Q. 2001 1
San Ramon. Immediately prior to coming'back to ETC
1
17
jn
18
tlhet job Ilsro you doing for Ch9 1ron?
20 21
22
'Washington, DC.
Q Ho1. ' long did you hold that position?
23
Q.
In the time
p~riod
of, say, rnid-2003, what
24
25
was your job, say, June or July?
A.
The same job.
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ZUW A OMOREGIE 'April 6, 2006
1
ETC job?
A
2
3
Yes.
Q.
A,
And as the team leader?
Yes.
5
And you held that title and that position
continuously through 2004?
A'a
6
7
Until now .
r· 5 t.- -J-+a ·VB -a F1Y -i-Fl t -e E·a c-t i-e-A-
B
QIe"_-------I~NhH-8+i--~-i-d-- y-e~- ·f· i
9
10 11
I.lith, Ki ran Pando?
I donft recall the exact year, but
p1;@
2001 'o7h@n I
\,7
6 £ first in S3n Ramon
12
13
~Q'"""r,----+-I~t--wI.]-t""'ia--?-.s..-~
to
:t'OD
first coming to San
Ramon?
Ar--.:..--~N...r..;o)""",---J;p~r~l~· y-o-f:-r-.-tt:-to1---tt:-fh+:.l~'ss---±1-dat-t:8Mt:=---lad-Ss-=sr:fi~gHn-Hmft. ce-ftAi::t----3i::-tAT-l--jEb"T~G
14 15
16
17
.
9.
Do you remember T:Jorking on a proj ect \v'ith
'90~?
Ms. Pando in the early
Not a proj e.ct together,
no.
18
Q.
~1cS.
Did you have interactions \1vith her where
19
20
Pando ',JaB \lorking on a proj cct and you !dCre
considered a customer to~t--p-re-jeet?
21
I don' t
recall.
M3j Z be
she can remind mQ
22
23
Q.
Let me see if I can holp you.
I
¥ou '.lore at' --eR-e point "'lor king in Scot 1 and
ae.l i . @~u.@?
..1 .. ,
I
24
25
7\
11
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ZUWA OMOREGIE April 6, 2006
1
You are not
"It
r~quir8d
to guea5
2 3
is
on])?
jf
yon actually remembsr
ThE WITl'JESS: No, I don' t
remember 1,Jha t
my responc:e was
5
6 7
8
~qR.
LEBOWITZ:
Q.
Do you
ha"flO
any
recollection other than she probably asked about or you
Qnd sh@ -p.r.oba-bl.y.. had -a discussion about her retu:rn-i-Rg---t-e
ETC, do you have any other details or any other
pocollection of any conversation like that?
l\. No.
..n.:nd--3-B-&t--~e
9
10
11
Q.
clea"r,
~then
you say you
~r~~~ didn'~
12 13
een't recall,
does that
mean~-y~ e~
hsppsn I
or you just don't kno\J one 'lay or another?
7\
14
I just" don't rernembert
15
16
Q,
So then we come to late 2003.
At that point there were at least two petroleum
engineer positions in ETC which were posted.
Do you recall that? Jobs in my group? Yes.
17
18
19
20
21
A.
(Whereupon
Yes".
E~-i..:t=·---1·-\Jas
22
23
24
marked for identification.)
ju~t
Q.
Mr. Ornor8gio J the Court Reporter has
·~fl·--ffi9"r-k-ed-
handed you l,·?l:}.at" deposition.
E)thibit 1 for this
25
I J·7ould like you to take a look at it and .
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ZUWA OMOREGIE April 6,2006
1
A~J-r-.----:::1T:-.:::8::-'1:C....fH+3:.£:-a-±-- &a-E-e-e-r--d-ae-de-r ~
- 23 t.g- &6, ; t i s
2
3
a multiple grade position. Q. What does that mean, multiple grade
5
.7\
You can have an eng; neo'r at different
7
-levels
8
9
the 23 to 26 pay grade can appl~{ for' this job?
~7\~ ..---Tt-th-+-ra-+-tt--:'s~---w-fra.t:
10
11
it· me a n s, yes.
~Q"'""r'----:P.n-:.lnM""ldcr--i-&-t-f:t.e.-~e tat ion
t hat the y
'va i 11
12
13
:r;ornain at the same pay grade level vJhen they' enter thi3 -job?
Not necessarily.
]4
15
16
Q.
7\
They could go up?
Yes.
Could they go do',ern?
17
18
19
20
lilt ·
7\
Yos;,
Q.
Who was on the selection committee for
this particular job?
21
A.
A number of senior petroleum engineering
22
23
managers in Chevron.
Q. A.
\~ho
were they.?
I will just tell
you the ones I remember
25 .
Q.
Okay.
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Page 12 of 38
ZUWA OMOREGIE ApIil
2006
1
.~.
Jean Carny, Bard Strong,
PeLer .Hartshorn,
2
3
4
Dave Wagner, myself, and that's who I can recall.
Q.
Were there in fact oth@rs on thQ committee
l
\Jhos@ nam@ you csn just not recall ri ght nO ,,?
5
6
7
Could be. Q.
one \laJr or another?
7\
]'OU
can' t
remember
8
No.
l\re there any documents that \;'Guld reflect
9
10
11
Q.
1.Jho T.Jas actually on this corrunittee?
A.
there.
Q
'" It.
Maybe selection record if it is still
12
13
And ','hat is a selection record?
Basically thi£ form that
\-'9£
14
7)
us@d
15
16 17 18
Q.
This form tilTed out \Jith inf\orrnation
where it is blank under cQndidet@§ listed?
1 1 ·
7\
YOb.
Q.
Do you knoT.! if there is such a docum@nt
19
20
for this position?
A.
Q.
Yes.
Do you lenD'"" ldherc . it is right nOT.J?
I
h3'>l8
21
22
23
24
3
copy in my computer.
Were you asked to produce that document or
any d.O_G..uffiO.nts. re.l.ated.
t..O
this j Qb
.G.O
par.t o.f. tb.is
25
litigation?
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ZU\;v A OMOREGIE April
2006
'A.
2
3
That's correCt
Q
Describe for me, please,
what the
selection process is,
MS. MILLER:
For this particular job? Q.
Yes.
MR
6
LEBOWITZ:
A.
The selection team rates the candidates
and then'there is a vote for
7
based on the criteria,
8
9
selectiCJn.,
Q.
And what information is used. to rate the
10
candidates?
11
A.
Their personnel knowledge of the
12
13
candidates as well as information from - feedback from
their supervisors Q.
14 15
16
17
And how is the feedback from the
supervisors solicited?
A.
The process varies.
In this case I asked
for comments on the candidates from the supervisors if I
18
19
could reach them.
Q.
And did you speak with Jack Dunn in.regard
20
to Kiran Pande's application for this job?
~~s. ~SILLER:
21 22 23
,_.2-4_., ._.. obj
I am
go~ng
to obj Get as to
":f'olevance.
I)~R. 1EBO~cJIT3:
It is not a deposition
@ction .
1gS.
1
25
~4ILLER:
Sure it is,
this \lhol@ linQ
24
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1 2
Of quogtioning.
YOt}
can anSh"er.
3
4
THE WITNESS:
Yes.
MR. LEBOWITZ: . Q.
And when did you speak
5
6
with Mr. Dunn about Kiran Pande's application?
A.
late 2003.
Sometime before the selection meeting,
so
7
8
Q.
on the phone?
Did you speak with Mr. Dunn in person or
9 10 11 12 13
A.
Q.
In person.
Where did you meet with him? In his office.
t'lnd ho'.] long did yo,;y speak abollt 1'46. Pande
A.
.. Q.
"15
A.
Q.
.A
a
I don't recall.
Wag it en
I
hOld];?
16 17 18 19
20
don't r@call
hav~
Q.
You don't
any recollection?
;·A.
Q.
A.
And what did Mr. Dunn say about Ms. Pande? Just overall feedback on her. I would like you to be as specific as
I
t>b~t(Y\:--
21 22
23
cd Nliss\bLa.
~+ ofFu-ec\ .("tn.rlYt
pro""c'ed
Q.
possible and to whatever extent your memory has of the
conversation, just relate to me what it is that Jack
Ms~
( cr-rre-n,Jl~ h2D~)
24 25
Dunn said about
Pande.
25
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ZU\VA OMOREGIE April 6.2006
t.~~ b~ e l,~'1 ~.,",
'
1
2
1 dc!n t
1
his "J'::rds,
but wha:, he sa: d
Mr.-~~<,;J,~ Ifr',,j~~~
J\o+
was
she has strcnSJ tecj'inical
[~~/P~
t~.+lJ\
\4.h
3
4
. rnove
or d.idn 1 t wan t
to rnove t:. c H 0 U s t () n
and
e nth 12 t
2
a:-n \-} -3 5
r~.A
HC)l] StC)t1 ,
k\>, 'rJ~ ~~ hQ...{,~-()
5
'lob suffereci
\I\~hen
the Houston move was
2nn()t~nced, bu~
7
:j
ITl()"V'e.
She st.ill woul·d have lJeen -- the
Ic~r.
J()D
~da5
tt;ere
in
HD.uston
bel:.
9
10
Anything else that Mr. Dvnn said about
Ms.
Pande during this convel:sati.on7
P..
11
12
No. At the time you had this conversation with
Pande was out
Q.
13
14
Mr. DDnn, did you know whether or not Ms
on a medical lea.ve?
15
A.
Q,
all?
A
I believe I did
Did you and Mr.
16
17
18 19
Dunn speak about that at
I don't recall how I heard, but 1 knew,
yes.
20
Q.
Regardless of how you first learned,
did
21
22
23
you and Mr. Dunn have any conversation that in any way referenced the fact that Ms,
A,
Pande was on medical leave?
Not that I can recall.
24
25
Q.
Did you ask Mr. Dunn for any dstail on
26
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~:"'\ \b f e <.:11\:)'" ' " "-J -------------------t---,~~I....;~~'~~
ZUWA 01v10REGIE April 6, 2006
1
suffered after
thf~
Hcrus1.:cn
rnc',"~ed
was ar;r:ounced?
2
3
P {C~J. f'c.J (\<:>-t " / pJ ~t . r-+{-J~~
(~~h~~
~p(>.r.s ....'tJ
5
~Q'1-.---Dt-+i-d
-you have an impression as t·o \Jhat he
6
7
meant by that?
No.
\~hat
I try to get from £upsruisors ;
~
9
~Q'--.---:--+D-+-:it-+d-+---+M-"+-F-;---Dunn
give you any £ort of offici3.1
10
11 12 13
14
rating,
sOInething
~Jo
~a-t--wBB-l-d-----s-}_ffiilar to
a PMP
rating~
.
E;;\re
Have YOt~ n()~'J t 01 d ITle
r'yt hi n 9 you ca n
al)c~ut
recall rr()rn YC.lur con-'.;ersation \·..; ith Jac:k Dunn
Pand : ?
Yest-;Q-.----il\"rHvh~e~n-y-e-u
l
15 16 17 18
left
I!~r.
Dunn'
5
office after that
conversation, J"hat '.Jas your impression of Ms. Pan de r s performance?
7\ .. 1.
19
20
\ei]ell, \lhat
~~r.
Dunn said "las her:
1/38
performance suffered,
I think an expression he used
21
she ',,7as one of the more least performing members of ths
22
23
team, but still
That T.J'as
c~pablG
to cto the job.
after that conversation.
~h~~
-my--:i.~sien
24
25
And did you report the contents of
conversation back to
thE~
selection
CC)1TUT.i t.tee~·~
27
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oo,~~.· Mn~~
f>("V'I1~~
rY~
1 2
A.
Q.
A.
Yes.
And how did you. do tha t? At the one meeting. We go through all the
3
4
5
~vm\.1Y)
o«t:Yed
(arY)C~'"\k
~r~,-,)
comments . Q. So is there a selection committee meeting?
Yes.
6 7
A.
Q.
And what did you tell the committee in
8
9
regard to your conversation with Jack Dunn?
A.
Q. told me?
What I just told you.
You told them everything that you have
10 11 12 13
14
I.would have . Q. doing so? A. Q.
No.
Do you have any actual recollection of
15 16
17
Tel} ffi9
~bout
th@~Q
m~@ting5,
the
cOIiurrittee meetings.
20
1\10
21
22
Q.
not e 3
0
f
~d hat
go e S }to.
G nat
C on:rrni t
toe
Oft
ID5@t j
n9~ ?
23
24
25
I
took notes
this' form.
Q
selection record?
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ZU\VA OMOREGIE April
2006
document?
2
Sometime Q
11.
For 1.7hEit
lD
the past fo;? month£; ,
3
r~ason7
\vhen I 'gJas asked to produce these
5
6
7
documents.
Q.
contacted?
And what other former supervisors were
8
9
A.
Names?
Q.
A.
Yes.
One was June Kim, another one was Dave
Carny.
10 11
12 13
Kennedy, Jean Q.
Anyone else?
Dave Kennedy. That was it.
A.
Q.
14
To your knowledge, was Rex Mitchell ever
1
15
16
contacted with regard to Kiran Pande s application? A.
Q.
No.
And Mr. Carny was also on the committee; is
17
18
19
20
that correct?
A. Yes .
fJ)QetJ ~"",.
L:
\.
I
r('~v;Je~
I
AJt~~;6k
t
()-{f.{'fJ ~
22
23
tbe rne·eting?
~2..
~~r +f~\.~ (o..Hv;w{~\1
~~e>- r:>c>,r)
Any comments that I~r: . CaiTty made rcgardi.n:;
24
25
Ms.
Fends,.
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0_·
p _____-------Z-U-W-A-OM-O-R-E-G-IE-An-·]-6-,2_0_0_6
A.
2
3
--,b\~I.-~~"" ~~~~I\,l.
~t'()'J{1~
I
don't. recall comments each mer"ber o·f :he
selection team makes a l. the rneeting.
prier to the rneeting
Conuner) t s
(\~+ ~-f{Pf{)~
~~+,,-~.~
~+hf-{VJ{)Q
I
that
t~.:am
disruptive element in his
5
when she was there.
hR'd~GJ)
don't have details on all of the details, but that was the gist of it.
Q.
When was
6
7
it, if you kno'w,
that l'1s-
Pande
8
9
worked for Mr
A.
Q.
Cnmy? I don't know. And do you know -- strike that-
10
11
Mr. Carny said- that Ms. Pande actually worked for
h irn '?
12
13
Yes.
And comments £ rom Da ve
Kenned~/ I
14
1S
wha t
hit?
re
those:
l
16 17
18 19
20
Similar 1 i.nes.
The COfTL"nent - - one comment
was that when Ms. Pande didn't get a promotion,
belie".re.f
vJhat she
I
or ma.ybe the F,rcrnotion and rarLking ,were not
e;~:pected
and that. heratti tude changed for the
worse.
Q
21
22
And did you speak with Mr. Kennedy
personally?
23
A.
Q.
Yes,
24
-25
Is this in person or on the phone?
A.
In person.
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ZUWA OMOREGIE April 6, 2006
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1
Q.
When was it? Sometime in 2003. Was it before or after your meeting with
2
A.
Q.
I~r.
3
4
Dunn?
5 6
A.
Q.
Before. And the prombtion and ranking that Mr.
7
8
Kennedy was referring to, is that something that happened when Ms. Pande actually worked for Mr. Kennedy
9
10
11
or working for somebody else? A. don't know. Q.
I
don't know.
I
assumed it was, but I
12 13
dir@ct J l'
10zith Mr
Kenned~'?
14
15 16 17 18
Q.
Did you speak with anyone else other than Dunn and Mr. Kennedy regarding Kiran
Mr.
Carny, Mr.
Panders application for the petroleum engineer position? A. performance? With respect to getting feedback on her
19
20 21
22 23
Q.
Yes.
A. Q.
No.
And other than
7
th~
co~~itt@@
members
and
th@ Qth@r indi1 idua J
&;
I
just named,
~4s.
did j,rou speak Tdith
24
25
anybody else regarding
petroloJJI:Q eng; neer
Pande' s application for the for
~n:/
po~ition
reason,
not jDst for
32
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ZUWi\ OMOREGIE April 6,.2006
1
-Q.
You dO.R' t
delete youJ;
·0
mails?
I delete some;
3
that '--s-w..h-y I am not sure.
Q.
But if you ',Jere to go bas>-: -e.n.G--F-e-turn to
you might b p
YOlJr computer and do a search,
able to fin'd
5
6
7
the email
~xch~nge?
Yes
~gR
.
LEBOtvITb:
Counsel,
I fdo111d ask that·
8
that be done.
~qs. ~1ILLER:
It has been .
And has a document been
10
~4R..
LEBOWITZ:
11
12
generated from that 8Qarch?
~1S.
P9ILLER:
I
don r t
recall off the top
14
15
t1R.
LEDOv?ITZ.
I have nev:er seen a
docum@nt that reflects anything like that, \Jhat
16
17
Mr. Omoregie has just testified to.
~1S.
MILLER:
Does
i t mstter?
&
Sho
lolas
18
19
cORsidered,
but
gur~.
I mGle3n,
if ther@ is
document,
if thero is an e mail, sure.
i'~R.
20
LEBOWITZ:
Q..
~qr.
Ornoregie,
~till
I 1.TGuld
21
22 23
j
1J
st ask that if SJJch an e meil dO 5
Qxigt
electronically, that you not destroy it. A.
So who was -- dId you.say anything at the
24 25
committee meeting regarding any personal knowledge you
34
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ZU\VA OMOREGIE ApriJ
2006
had regarding Kiran Pande?
2
A.
Those meetings, I don't recall.
It is a
3
dynamic meeting.
I am sure I would say what I knew
about everyone I knew there, but I don't recall what I
5
said specifically
Q,
regarding Ms
6
7
Old you have any personal knowledge
Pande prior to the committee meeting?
8
A,
Q A. Q.
Her reputation. What was that?
Strong technical skills.
9
10
11 12
13
And how did you come to learn that
reputation of strong technical skills?
A.
Feedback from colleagues and others who
14
15
16
have worked with her or seen her work.
(\t\lhereupon--Exhibit 2. ,Jas marked for identification.)
Q.
Mr. Ornoregie,
you have been handed what
17
18
has been marked Exhibit 2 for this deposition, which is another Summa.ry of Open Job and OpenPosi tion
19
20
Requisition Form;
Have you seen t'hese documents before?
21
22
A.
Q.
Yes.
And what is this?
It is the same as the previous one.
23
A.
Q.
cor rect?
24
25
It is for a different job; is that
35
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zuv~ A
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6~
Page 23 of 38
OMOREGIE April
2006
A.
2
3
Essentially the same job
Q.
There were two openings at the same time? Yes. Were candidates considered for both of
A
Q,
5
6
7
thes~
jobs simultaneously?
Yes, one meeting.
They were considered from the same pool
of
8
applicants?
9
10
11
A.
Q.
Yes.
So at the same meeting that you consider
people for the job that's got a job number of 50046185,"
12
13
folks were considered also for the job number
5005~160?
A.
Q.
Yes ,"
~Jo'.J
14
15
16 17 18 19
the 54160 job'has a residence located
as San Ramen or Bouston?
Yes. Q.
looked at?
A.
\~hich
j
s different than the first job ';e
Yes.
Can you expl ain to me \Jhat the di ffsr@f1cQ
20
Q.
~
21
22
23
on location \,las to el l
O\1
us; to attract a larger pool e;'
24
internal
Gandidat~~.
25
Q.
So if I understand, the point of having
36
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ZU\VA OMOREGIE April 6~ 2006
1
San Ramon or Houston as the potential
l~cation,
it ig to
2 3
4
90 more convenient for
.7\.
Q.
th~
applicants?
Yes.
So the applicant Tygo'uld 'derk or the onos
5
6
7
that got the jab Gould 'pJork from either San Ramon or
Houston=!
A.
'{es.
.b, rJ;01':
AJ1l\ ;ss lb!~
Pande on the tor;ic
{)f
.8
Q.
At any point did you learn or hear of any
teann'oiork?
T jllst
9
10
reputatic)!I regarding Ms.
!~.
Yes.
'T'hat was some of
the corrnnents
f\Q+ ~JfQ(pj
+r-A~ ~-J.h{,f\-J;~'<
of
~f'o"{ kc)
11
12
mentiohed earlier about from her formBr supervisors
Q~
So from Jean CaMy and Dave Kennedv?
Y·es·.
I\fG./-\Al
J
13
1~
A.
Q.
And how would you
chara~terize
thoSE:
15 16 17
18
COfnments rega rd~ nSf t e·arnwor k?
A~
They were poor ratings.
And did you consider
strike that
Q,
Did the committee consider teamwork to be an
j
19
20
important aspect of both of these jobs?
A. Yes.
21
22
Q.
And do you recall how Ms.
Pande was
actually rated in regards to teamwork in the selection committee process? A. Q. Below the selected candidates,
So who were the two selected candidates
23
24
25
37
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ZUWA OMOREGIE April 6,2006
1
for these jobs?
2
A.
Q.
Their names?
3
Yes.
Jalal Afifi and Graham Housenc
\a]hore pas
~qr
A.
Q
6
7
.
l\fi fi ,,;Jorking prior to
San Ramon.
8
Q.
In 1,lhat position?
9
10
A.
Ramon,
Q'
1,"3
Southern Africa business unit in San
11
Do you kno\cY 'l.Tho Mr, J1..fifi 1 S supervisor
12
13
s?
A.
Q.
Y(3~.
14
15
16
17 18
Who 'das it?
Tim MegngJ;.
~nd
h05M
abont Grabam
HOll sen)
\rJbpre
'fila s
be
hlorking prior to taking th@ pstro-:1e--Hrn-e-n.gin@er job in
~
19
20
Southern Africa business unit. Q.
,]\
Who
\laS
his 5uper . . .r isor?
21 22
23
24
,~qr
...
Chris Riccobbono.
.. Housen reported in any uay to Jack Dlinn in their
positions vJith the Southern }\.lfrica busin@££ unit?
25
A.
l'Jo.
That means they didn' t .
I don' t
JcnoTv~
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ZUWA OMOREGIE April 6, 2006
Q.
2:
lbJ3 £
5
the r8 a stu ~ll y a nume Yl SS 1 a GS '3 S SH1@nt
of
~1s.
Pando'
team\Jork done or reached by the
3
committee?
J."l)J.
It is not numeric'al f
but
',/8
rate by
5
6
7
category Q.
What kind of rating
system~
It 'dill be things like very proficient for
8
crlteria, proficient r somo1. hat profieient .and not
7
9
10 11
proficient.
Q
\J3S
l\nd do you recall le.rhat Ms
Pande I s rat j ng
on this scale in regard to team!dorJc?
~Jo
12
13
14
·
Q.
Is there any other part' of P93.
ronde'
3
.self a;SS8£srnent in ---her job application that you don' t
15
16
17
believe is accurate?
~
Do you \Jant him to read the
,c]hol@ thing?
I
don't thin)c he has read it since 2003.
~gR
18
19
~.
. LEBOWITZ.
TQkc all the time you
20
~1S
.
~4ILLER:
t~h'y
don't
'pJC
take about a
21
22
23
ten minute break or so, THE WITNESS: self ratings.
MR:, LEBOWITZ:
We didn't use the numerical
24
25
Qr
I am really asking
about the narrative more than the self-ratlngs.
46
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ZUWA OMOREGIE April 6,2006
The narrative that Ms.
2
3
Pande wrote on
th~
right-hand column under Candidate Comments, whether they
amount to a 10 or not I am not really concerned with,
4
5
but my question is, reading those comments is there anything that you learned during the selection process to coritradict or minimize or in any way negate the
comments that Ms.- Pande was making about herself?
A.:
~upervisor
6
7
8
The comments I gave you earlier,
the
9 10 11
12
feedback on Kiran negated what she wrote on
When you look in the
what we call soft skills.
selection in this OJl, the behavior organizational skills, the' criteria below that line, that's
wh~re
her
13
rating was less than of the two people selected ..
Q.
inter"vio\J Ms.
."D.. ·
14
15
16
17
Did you actually
PaRde for this job?
No .
did you or anybody
Q.
Did --y-e-H---G-±:-aA.ys-04y attempt to get fe@db3:ck
~r:···-I"-ea·ction
18
from
~qs.
Pandc"-en-
to the comments' from her
19
20
supervisors?
J..
7\
J ·
.1'Jo.
21 22 23
24
Q.
1\.
Why not?
Those
T"JCFe
comments in confidsncQ . .
Q.
-th9 comrnitt@@
So do so I understand ''''hat you 3re s3ying,
does not f@el it is important to give
opp~nity
.the
25
j--ob applicant an
to
~espond
to Gomrn@nts made
~7
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Page 28 of 38
1 2
CERTIFICATE OF REPORTER
3 4 5 6 7
8
9
I, DENISE A. FORD, a Certified Shorthand
Reporter, hereby certify that the witness in the foregoing deposition was by me duly sworn to tell the
truth, the whole truth, and nothing but the truth in the withln-entitled cause;
That said deposition was taken down in shorthand by me, a
d~sinterested
person, at the time and
10 11 12 13
14
'place therein stated, and that the testimony of the said
witness was' thereafter reduced to typewriting, by
computer, under my direction and supervision;
I further certify that I
~m
not of counselor
attorney for either or any of the parties to the said deposition, nor in any way interested in the event of this cause, and that I am not related to any of the parties thereto.
15 16
17
18 19
20
DATED:
April 18, 2006.
21 22
23
~----------_._-
DENISE A. FORD, CSR No. 7525
24
'L--
25
LegaLin~
San Francisco
(415)
357-4300
61
'
Case 3:04-cv-05107-JCS
Job No: (50054160)
Document 159
Filed 10/15/2007
Page 29 of 38
JOB TITLE: GRADE: SBU: RESIDENCE lOCATION: INCUMBENT: EXPECTED EFFECTIVE DATE: EXPECTED DURATION: REPORTS TO
Energy Technology Company Summary Of Open Job Petroleum Engineer TCl23-26 RPO/PEO Asset Eval & Ops Support San Ramon or Houston
n/a 1-Jan-04 3-4 years Team Leader NAME:Zuwa Omoregie
Direct Repor1s: 0 Tolal Nationals:-n7'"/a-------------i Total Expats: _ _ _ _ _ _ _ _ _ _...1-... n/a
_
TITLE:
HIGH LEVEL JOB SUMMARY/SCOPE: Petroleum Engineer who will provide asset evaluation and operations support to one or.more CVX upstream business units. Engineer will likely lead teams of technical staff 011 projects that support asset transaction initiatives by the business units. The focus of the work is generally to assist in framing development scenarios for oil and gas fields and generating produ~tion forecasts and reserves for them from data provided in data rooms or gathered from other external sources. Some domestic and international travel to visil data rooms will be required. For some projects. the work is done at the SBU location, which will also require travel.
Conceptual reservoir/field development planning Production/Exploration asset portfolio management Reservoir Engineering, production forecasting, & reserves· expertise for a wide range of reservoir types and depletion schemes Data room, DA & economic analysis experience
I
cor FIDE
flAL
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 30 of 38
Comments and Other Considerations as appropriate: candidate was surplus) Selection Team Members: Selected Candidate: Reason for Selection:
m CONFIDENTIAL
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 31 of 38
ChevronTexaco Open Position Requisition
ChevronTexaco
post an open position to Chevron Texaco's SAP Recruitment sys·tem and/or have an open position posted externally. complete the following form ,d email [email protected]. If you have questions regarding this form, contact your HR Employmenl Counselor directly
GENERAL INFORMATION
posmon Title
PetroleUm EngIneer
12/08/2003 _
SAP PositiDn 10
Open Date
Close Date
J 2/23/2003
50054160 ---------------------
Company Name _E_PT_C Company Code 0334
Department/Drvlsian
_RP_O_fP_E_O
_
Work Location City
Employee Group
-----------------San Ramon or H Dus10n
Category to Describe Posrtion
054 Englneenng - Petroleum CAor TX
Work Location State (or Country, if internationar)
] Exempt salaried
Pay Sca)e Group Target Fin Date
(low) 23
(high) 26
Number of Vacancies
~Ol_I_O_l/_20_0~4~~~~~~~~~~~~
CONTACT INFORMATJON AND MfSCELLANEOUS
Posilion O~ner Name
~~_a_v]_·d_~~a~gn_e_r~~~_~~
_ _~~~~~~
Position Owner Phone No.
-~--------~---
713-954-6283
Position Owner [email protected]
Alternate E-mail Address
Alternate Contact Na~e
~Z_u\_v~a~~~~~o_r~e~g~ie~~~~~_~_~_~_~
---------~~--
Alternate Contact Phone No. ....
925-842-4132
[email protected]
HR Business PartnerNa~e
Post to
~S_he_r~~~.~_a_r_sh_a_"_~~~_~~~_~_~
Employment Selection Counselor Name
_L_in_d_a_J_ohn_s_oD
lI
-
SAP Ch arge Code
Internal only Exception form required for external onJyll option
No Are you .willing to pay relocation?
TCP713J 0
Is this a safety sensitive position?
Yes
SITION DETAILS
uverview of Position: Petroleum Engineer who will provide asset evaluation and operations support to one or more CVX upstream business units. Engineer wililikety lead teams of lechnicaf staff on projects that support asset transaction initiatives by the business units. The focus of the work ;s generally to assist in framing development scenarios for oj) and gas fields and generating production forecasts and reserves for them from data provided in data rooms or gathered from other external sources. Some domestic and international travel to visit data rooms will be required. For some projects, the work is done at the SBU location, which will also require travel. Key Job Responsibilities (essential position functions):
Exploration Prospect Ev~luation Field Development Planning
Production ForecastinglReserves
Economic Analysis
Data Room Visits RecommendationslPresentations to Management
EDUCATION, CERTIFICATION, TESTING
Bachelor's degree?
[S1 ReqUired
'v1aster's degree?
D ReqUired
.0
Preferred
o Not applicable
Petroleum Engineering
o Preferred
~ Not applicable
If degree is specified. please designate majotJdiscipJine(s)
If vou will accept work experience in lieu of academic preparation, summarize minimum acceptab\e work experience
~dentify
any other academic or certificatjon requirements
Testing Requirements (eT-SA T, RBHr etc.) Please Specify
FOR EXTERNAL POSTINGS
CHEVRON/PANDE03518
Case 3:04-cv-05107-JCS
lip cDde where position is located
Document 159
Filed 10/15/2007
Page 32 of 38
_
Area code where position is located
Should the external posting show the ideal salary range? No ff yes, provide the salary range you wish to advertise (refer to salary structure tables, or coniact your counselor lor assistance). to $
Quid you like to accept employee referrals, following the guidelines ·of the program? (This means that YDU are willing to pay $1,000 from your budget to a ChevronTexaco employee who makes an eligible referral to this job tF you subsequently hire that referral.) No
f
GQ.1640 (1-03)
Please submit this completed form and the Selection Skilts Assessment (GO·1646} to [email protected]
WDrd
Eleclronic Version
m CONFIDENTIAL
CHEVRONjpANDE03519
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 33 of 38
EXHIBIT 2
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 34 of 38
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
--000--
KlRAN PANDE,
)
)
Plaintiff,
) )
vs
o'
) Case No.
04-5107 CW
CHEVRON CORPORATION(f/k/a Chevron Texaco Corporation/, a) Delaware corporation, et al.,
Defendants.
DEPOSITION OF ZUWA OMOREGIE Thursday, April 6, 2006
CERTIFIED COpy
REPORTED BY: DENISE A. FORD, CSR 7525 (380011)
III lEGALINK~
A WORDWAVE COMPANY
legaUnk San Francisco 575 Market Street, 11th Floor San Francisco, CA 94105
tel (415) 357-4300 tel (800) 869-9132 fax (415) 357-4301
www.legalink.com
GLOBAL COURT REPORTING . LEGAL VIDEOGRAPHY · TRIAL SERVICES
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 35 of 38
ZUWA OMOREGIE April 6, 2006
1
2
3
4
--000-
BE IT REMEMBERED that pursuant to Notice and on
Thursday, April 6,2006 commencing at 2:00 p.m. thereof;
at the Law Offices of McGUINN, HILLSMAN'&
PALEFS~Y,
5
6
7
535
Pacific Avenue, San Francisco, California 94133, before
me,
De~ise
8
A. Ford, a Certified Shorthand Reporter,
9
personally appeared
ZUWA OMOREGIE called as a witness herein, who, having been first duly sworn, was examined and testified as follows:
--000--
10
11
12
13
14
15 16
17
18
19
20
21
22
23
24
25
4
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ZUWA OMOREGIE April 6, 2006
1
·A.
Jean Gamy, Bard Strong, Peter Hartshorn,
my:3elf, and that'3 who I can recall.
the cOtttrllittee
2
3
4
Dave
~iagner,
Q.
~~ere there iii fact other os Oli
whose name you can just not recall right now?
'A.
5
6.
Could be. And you don't know
you can't remember
Q.
7
8
9
one way or another? A.
Q.
No. Are there any documents that would reflect
oe.J~n~,
~e\e".ANu.
10
11 12
who was actually on this committee? A. there.
Q.
..
Maybe
select~on
record if it is still
f\~q'\t
Nc:rA
~\J2.\'e=
And what is a selection record? Basically this form that was used. This form filled· out with. information
13
14 15
~r~Ns.-L1
:r-~E' 4~3
A. Q.
16
17
where it is blank under candidates listed?
A. Q. Yes. Do you know if there is such a document
C)l?J~~
18 19 20
21
for this position? A.
Q.
N\:lYf\d\\kV.e.
./
Yes. Do you know where it is right now? I have a copy in my computer.
NC),A
~f\.-t«
22 23
·24
A.
Q.
~~DN~t
Were you asked to produce that document or
'F~~4~3
any documents related to this job as part of this
litigation?
25
22
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Case 3:04-cv-05107-JCS
Case 3:04-cv-05107-JCS
Document 159
Document 157-5 Filed 10/12/2007 ZUWA OMOREGIE April 6, 2006
Filed 10/15/2007
Page 37 of 38
Page 5 of 10
1
A.
Yes.
2
MS. MILLER:
We were asked to produce
oo~("'
3
4
5
documents that were responsive to the document request. MR. LEBOWITZ: question. MS. MILLER: He did. He produced them I am asking him the
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6
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all to legal, anO'we produced the ones that are responsive to the request. MR. LEBOWITZ: Well, I will represent to
M'-\
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-ttY
That's correct. The
(:;;:VL\~
10
11
you there was no selection record produced. MS. MILLER:
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.
12
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selection is not part of this lawsuit. MR. LEBOWITZ: MS. MILLER: Well, who. said that? I believe it took place
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14
Ay\n-~.:
15
16
17
after she notified a charge about this particular selection. So no, it was not produced. MR. LEBOWITZ: We will have to make a
18
19
motion on that and bring the witness back to talk about
it.
20
This has nothing to do with you. between lawyers. Q.
It is just
21 22
23
So there is a selection - just to make an
,
l
absolutely clear record, there is a selection record for this job that exists on your computer at Chevron; is that correct?
24
25
a,..,.~hk.
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23
LegaLink. San Francisco (800) 869-9132
Case 3:04-cv-05107-JCS
Document 159
Filed 10/15/2007
Page 38 of 38
ZUWA OMOREGIE April 6, 2006
1
A.
-Q.
That's correct.
De~cribe
2
3
4
5 6
7
ror:
ute,.
please,
what the
"selectioll process is.
-HS.
~m.
~HLLER:
For thiB particular job?
LEOmn'PZ.
Q.
Yes.
A.
The selection team rates the candidates t10te for
"based on the criteria, and then there is a select; on.
.Q.
8
9
And 'lhat information is u3ed to rate the
10
11
candidates?
A.
Their personnel lmmdedge of the
feedbacl~m
12 13
14
eandidates as \,-e11 as inforffiation frofR ·their :lupervisors.
Q.
And how is the feedback: froltt Llte
15 16
17
-supervisors solicited? A. The process varies. In this
"ca~e
I
a~ked
fOT cornrnent3 on-the calldidates from the
3upervi30:r3 if I
18 19
could reach them.
Q.
And d:i4-you spealE with Jack Dunn in regard ,
20
21 22
" 23
··t--e---£f± ran Pandc's application for this job?
MS. MILLER. relevance.
HR." LEOmn'PZ.
I
dm
going to object as to
It is liot a "deposition
24 25
'ooj ection.
~1S
.
~lILLgR:
Sure it is,
this -,,'hole line
24
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