Free Statement - District Court of Arizona - Arizona

LIST OF PLAINTIFF'S EXHIBITS Exhibit Number 1 2 3 4 5 Document Name Cigna EEO Policy Statement ("Culture" Website Printout) First Day Checklist Civil Treatment Course Objectives Cigna Diversity Program (Building an Inclusive Environment) Cigna Employee Programs Booklet (You & Cigna Employee Handbook) Cigna Hiring Instructions ("Career" Website Printout) Ed Hanway Memo (CEO Reaffirmation Statement) Guidelines for Ethical Decision Making (Wallet-Sized Card) Bates Number D0991-D0992 EEOC-CGLIC-0224 D0981 D1018,D1038 EEOC-CGLIC-01300132,0138-0140 (same as D0929) D1006-D1008 D0945 D0934-D0935

6 7 8

9 10 11 12 13 14 15

Tiffanie Dillard Deposition Sandra Gasche Deposition Heather Casey Giles Deposition Cheryl Wroten Deposition 30b6 Robert Jarvis Deposition Carmen Santa Cruz Deposition Carmen Santa Cruz Affidavit

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 REPORTED BY: WILMA A. WEINREICH, CSR, RPR Certified Court Reporter Certificate No. 50530 PREPARED FOR: (ASCII/MUS/CD) Defendants. CIGNA Healthcare of Arizona, Inc., and Connecticut General Life Insurance Company, vs. Plaintiff, UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Equal Employment ) Opportunity Commission, ) ) ) ) No. CIV-04 0627 PHX JAT ) ) ) ) ) ) ) ) ) DEPOSITION OF TIFFANIE DILLARD Phoenix, Arizona May 25, 2005 8:56 a.m.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. A. Q. A. And when did you meet? This morning. How long? Half hour. Tiffanie, when did you start working for CIGNA? I worked for Connecticut General, and I began

employment in 1999. Q. Tiffanie, when you are at a social event and

somebody asks you where you work, what do you tell them? A. Q. When they ask me where I work? Yes. If the subject of work comes up, what do

you tell them? A. Q. Typically we use the term CIGNA. And you sat in on the deposition of the

investigator, Cheryl Janes, in this case a couple days ago, didn't you? A. Q. Yes. You had a shirt on that day. Do you recall that,

that said CIGNA on it? A. Q. A. Q. A. Q. Uh-huh. Yes.

Is that a shirt you obtained from your employer? No. Where did you get it? That's a shirt I purchased. Did you purchase it through your employer?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. KRUSE: Q. So if I refer to CIGNA, I'm referring -- I'll be A. Q. CIGNA? A. Q. That is a common reference to the company. And Connecticut General Life Insurance Company is Yes. So do you generally refer to your employer as

a wholly owned subsidiary of CIGNA, isn't it? MS. CULBERTSON: THE WITNESS: Form.

That's correct.

referring to your employer as CIGNA today at the deposition, just so you understand. A. Q. A. Q. A. Okay. When did you start working for CIGNA? 1999. What was your initial position? I was hired as a trainee consultant/HR Okay?

consultant. Q. Were you working at the Phoenix Service Center at

that time? A. Q. A. Q. time? No, I was not. Where were you working at that time with CIGNA? I was working at the Black Canyon location. For what part of CIGNA were you working at that

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 would be system training, et cetera, and management training. Q. Management training of the nature you testified

to earlier? A. Q. Right. And tell me more about what you mean by technical

skill training. A. As we rolled out new systems, new processes,

across the organization, I had trainers who were responsible for conducting that training. Q. When you say systems and processes, what do you

mean by that? A. New claim processing systems, new medical Those would be a few

management software packages. examples. Q. A. Q. A. Q. A. Q. A. Q. A.

When did you become regional training director? Approximately 2000. What time of the year, do you know? I don't. Do you remember a season? I don't. When you started in 1999, when did you start? I started in August. What was your next position at CIGNA? Human resources director.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. When did you take that position? That was August of 2002. As human resources director, did you continue to

work at Connecticut General Life Insurance Company, a subsidiary of CIGNA? A. Q. Yes, I did. And as human resources director, did you support

a particular subsidiary or area within CIGNA? A. Q. A. Yes, I did. What subsidiary or area did you support? In that position I moved to the Phoenix Service

Center supporting the call and claim operation. Q. A. Q. Did you replace Heather Casey? Yes, I did. Are you still in the position of human resources

director supporting the Phoenix Service Center? A. Q. Tiffanie? A. site. Q. A. Can you tell me what your duties are? I'm responsible for the hiring process. I'm I'm the human resources lead responsible for the Yes, I am. What are your duties in your current position,

responsible for the compensation process. process.

Discipline

Basically anything involving the people in my

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. KRUSE: Q. A. Q. Do you see slide 13 D 0771? Yes. Do you see it says -- it's not a very clear copy, the middle of 2004. Q. So based on having the name Korey Hinz as service

center leader, you believe the new hire orientation was revised somehow after he left in mid-2004? A. Q. After she left, correct. You started supporting this Phoenix Service

Center in 2002; right? A. Q. Correct. Do you have any knowledge of the structure of the

Phoenix Service Center in 2001? MS. CULBERTSON: THE WITNESS: Form.

No, I don't.

but do you see it says "service operations, employee services, and call claim" and the box that's right next to the star? A. Q. A. Q. Yes, I do. And the star says Phoenix Service Center? Yes. And that box that says service operations has a Do

line up to CIGNA HealthCare, Bloomfield, Connecticut. you see that?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. KRUSE: Q. How many briefings did you have on equal BY MS. KRUSE: Q. So either a briefing or an update could occur in Q. A briefing means refreshing on information that's

already reflecting the current state of the law? MS. CULBERTSON: THE WITNESS: Form.

Right.

the manner that you -- the alternatives you described, meeting, conference call, a training session that's either web based or in person; right? MS. CULBERTSON: THE WITNESS: Form.

Right.

employment opportunity law in 1999? A. Q. I don't know. How many updates on equal employment opportunity

law did you have in 1999? A. Q. Is that the same question you are asking twice? You distinguished between briefings and updates Now I'm asking you about

so I asked you about briefings. updates. A. Q. I understand.

No, I don't know.

Do you know how many of either of those things

you had in 2000? A. I don't know the exact number.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. KRUSE: Q. Did you have a briefing or update on equal Q. A. Can you give me an estimate for 2000? That was almost five years ago so that would be I don't know.

very tough to give you an estimate. Q.

How about, can you give me an estimate on the

number of briefings and updates on equal employment opportunity law that you had in 2001? A. Q. No, I can't. Can you give me an estimate on the number of

briefings or updates on equal employment opportunity law that you had in 2002? A. Q. No, I can't. And can you give me an estimate on the number of

briefings or updates on equal employment opportunity law that you had in 2003? A. Q. No. In 2003 did you have a briefing or update on

equal employment opportunity law daily? MS. CULBERTSON: THE WITNESS: No. Form.

employment opportunity law weekly? A. No. MS. CULBERTSON: Form.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Year 2002. BY MS. KRUSE: Q. Tell me any EEO training you do recall When I use the acronym EEO, I'm referring BY MS. KRUSE: Q. Specifically? MS. CULBERTSON: THE WITNESS: Form. THE WITNESS: I can't recall. You are

asking me to dig pretty far in my memory here, three years ago. BY MS. KRUSE: Q. You don't recall any EEO training from 2002? MS. CULBERTSON: Form.

Not specifically, no, for the

specifically.

to equal employment opportunity. A. Q. Okay. What was your question again?

I'm asking you to tell me any EEO training you

remember receiving at CIGNA. A. I don't remember a specific training. We have So I

ongoing training on many topics, many, many topics. don't remember a specific session at a specific time frame. Q.

You have ongoing training on many topics outside Is that what you're saying?

of the realm of EEO. A. Yes.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. KRUSE: Q. Is there any other training you have had at CIGNA BY MS. KRUSE: Q. Correct? MS. CULBERTSON: THE WITNESS: Form. BY MS. KRUSE: Q. So far you have testified that your training on Q. Because you have already given me an estimate for

at least for 2003 to the present of how many of those were EEO; right? A. Q. Right. But you don't remember any of the EEO training

you have gotten at CIGNA specifically? A. I don't remember a specific training session at a

specific date or time. MS. CULBERTSON: Form.

equal employment opportunity issues at CIGNA comes in the form of briefings and updates that you estimate at least for 2003 and 2004 to be twice a year via a number of means including a meeting, conference call, web based or in person from fifteen minutes to two to three hours? MS. CULBERTSON: Form.

Correct.

on EEO issues other than that training you have already testified about?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 mailings. on an ongoing basis? A. Q. A. Q. A. Q. Correct. And you have since you joined CIGNA in 1999? I have for my entire career. And when did your career start? 1989 in HR. And what do you mean by legal updates? What is

the nature of the legal updates you obtained from SHRM? MS. CULBERTSON: THE WITNESS: Form. They are

They are e-mail.

They are web casts.

They are publications.

They are chat room bulletin board information sharing. Those are examples. BY MS. KRUSE: Q. A. Anything else? They are local chapter meetings and national

conferences. Q. So you define, just so I make sure I understand

you correctly, e-mail from SHRM about a legal update as training on EEO issues? A. I didn't define it as training. What I'm saying

is that's one of the ways that I stay current on EEOC issues. Q. training? So you don't consider e-mails from SHRM to be

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. It depends on what you define as training. I'm asking you what you define it as, whether you

define that as training. A. current. Q. training. A. Q. A. Q. My definition of training? Yeah. Anything that allows you to gain knowledge. When you discuss your training on EEO issues, you Let me ask you to give me your definition of It could be a component of training to stay

can be referring to an e-mail you have received; right? A. Q. Sure. How many live training sessions have you been to

with SHRM that had an EEO component since you started with CIGNA in 1999? A. Q. Can you define live? You indicated you attend local chapter meetings

and national conferences with SHRM; right? A. Q. Right. Is there any other time that you are at in-person

meetings with SHRM? A. Q. By live, you mean in-person sessions? Yes. Are there any other in-person sessions that

you have besides local chapter meetings and national

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 training sessions. A. Q. Right. Have you testified as to all the training that You indicated you facilitated those?

was provided to the managers at the Phoenix Service Center? A. I have given you specific recent training that I

have clear recollection of that was in-person instructor-led training. We provide other types of training as well. That's the instructor led that I recall. Q. Tell me then about the other training that's

provided to managers at the Phoenix Service Center on EEO issues. A. Managers are required to attend -- we have a

process in place for managers to attend a course that's called Civil Treatment, and it's a requirement for all CIGNA managers. It is a two day session devoted to EEO issues basically civil treatment, equal treatment of all employees. Q. training? A. Q. Yes. And that includes the managers at the Phoenix And all CIGNA managers are required to take that

Service Center?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. managers. Q. How soon after they become managers are they Yes. How often do they take the training? They are required to take it as they become

required to take the civil treatment? A. Our goal is within the first three to six months

of becoming a manager, if not sooner, depending on when sessions are offered. Q. Occasionally do the work schedules -- is it

necessary that -- do some managers take the training after six months? A. Q. A. Q. And some take it before. But some take it after six months? That's possible. What does the civil treatment class cover? What

are the topics? A. Everything from racial discrimination, sex

harassment, again, ADA accommodation, pregnancy discrimination, gender discrimination, inappropriate behavior in the workplace and how to manage those. Q. When you say "inappropriate behavior," what do

you mean by that? A. I mean things that may not reach the level of

illegal but still not behaviors that we want to have occur

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the Center or in our operation. Q. A. Can you give me an example? There's one case study or one example in civil

treatment that is inappropriate workplace banter that may not be discriminatory or harassing, but clearly we don't want managers approaching behavior that could become illegal at some point. So we are teaching managers where to draw the line between having an environment that you can be friendly and open and crossing the line. Q. Does civil treatment cover any topics other than

what you have already listed? A. Q. A. Also coverage of wrongful termination. Anything else? And then also there is a section on hiring

practices. Q. A. Q. A. Q. A. Q. Anything else? I'm sorry? Promotions or failure to promote? That is addressed. Anything else? Those are the major topics I can remember. Do you track the attendance of the Phoenix That is a piece, yes. Promotions?

Service Center for the civil treatment course? A. Yes, we do.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 etc. training on EEO issues or orientation on EEO issues? A. Q. A. The in-person session is one hour. Solely on EEO issues? Equal treatment, the workplace, the environment, Approximately one hour. The web-based piece can be

approximately one hour, depending on how fast somebody -or slow because it's self-paced. Managers also receive interview training on how to appropriately interview and select new hires, and managers go through that training prior to interviewing for us. Q. A. Q. training? A. It's woven throughout the entire session. The And does that have an EEO component? Absolutely. How long is the EEO component of interview

session is a full day. Q. Are there other topics other than EEO components

to interview training? A. Sure. How to make the best match for the job in

terms of skill set, interviewing techniques, behavioral interviewing, style, practice, etc. the entire session. Q. A. It's an eight hour one-day session? Yes. It's woven throughout

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 asking. BY MS. KRUSE: Q. You indicated managers obtain interview training Q. A. Q. When do managers obtain interview training? Before they are allowed to interview for us. Do they go through once or more than once? MS. CULBERTSON: THE WITNESS: Form.

I'm not sure what you're

that have an EEO component before they are allowed to conduct interviews at CIGNA; right? A. Q. Yes. And do they take that manager training that one

occasion or is it repeated? A. That piece is repeated prior to our interview

season for the managers who are going to be interviewing -- our hiring is very seasonal so we will select a group of managers for that hiring season and we will have refresher training for them prior to participating in the interviewing and hiring process. Q. When you say we "select a group of managers," are

you talking about the Phoenix Service Center? A. Right. Myself and the senior directors in the

operation. Q. So a portion of the managers go through the

training again prior to interview season every year?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. KRUSE: Q. Did I understand you correctly that new employee MS. CULBERTSON: THE WITNESS: Form.

Correct.

orientation on EEO issues is provided to both managers and non-managers? A. Q. Right. Is there any other training provided to managers

of the Phoenix Service Center on EEO issues other than what you have already discussed? A. There is also the just-in-time training, as they

have questions, as we work employee relations issues, and that's a large portion of the work I do. Q. Does that involve answering questions about how

to handle things like terminations? A. Q. A. Yes. Why do you describe that as training? Because it's giving managers knowledge to do

their jobs and it's consulting with me as the HR professional to make the right decisions. that is a component of training. Q. So I believe

On-the-job training.

Any other training given to managers on EEO

issues as you define training? A. Again, if I define training as giving managers

knowledge to do their jobs, there are multiple resources

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for our managers. There are reference guides on our intranet. There is the employee relations department that's available for consult. There are posters throughout our building specifying our policy and how to address concerns. Q. A. Q. Anything else? Those are the ones that come to mind. Is there any other training of non-managers at

the Phoenix Service Center on equal employment opportunity issues beside the employee orientation that has an EEO component to it? MS. CULBERTSON: THE WITNESS: Form.

Again, if I define training as

giving people knowledge, it would be also -BY MS. KRUSE: Q. Let me stop you because I want to define training

first again as live education instructor lecturing. A. The instructor lecturing provided to non-managers

is mainly at orientation when they first become employed. Q. And is that the orientation as you previously

testified to that's given to managers? A. Q. Correct. So it involves a live component of maybe an hour

and a web-based component that's self-paced but could

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 website. possibly take an hour? A. Q. A. Correct. Anything else? If you define training as instructor led, that

would be the main instructor-led piece. Q. You say it's the main. Is there any other

instructor-led EEO training to non-managers at the Phoenix Service Center? A. The way you define training, that would be the

training that I would reference. Q. And in the broader definition of training of

providing information to employees, what else is provided to employees regarding EEO issues to non-managers at the Phoenix Service Center? MS. CULBERTSON: THE WITNESS: Form. It

There are multiple venues.

begins when they first apply for the job. policy and our stance. It's on the application. It's in the employee handbook.

This is our EEO

It's on our It's in the

documents they receive as a new hired employee before they even show up for Day One. Again, it's at the orientation. in our building. It's throughout our website. It's posted There is

an annual reaffirmation statement from the CEO of the

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 company. There is the annual performance objective that all employees and managers are held to regarding the work environment. It's called The People Expectation. Or

if you're a manager, it's called The Manager Expectation. So employees are held -- we hold every employee accountable to that expectation of treating employees fairly. BY MS. KRUSE: Q. And you define that as equal employment

opportunity training? A. I believe that when you have a performance

evaluation that covers that topic being an expectation for all employees when you spend time on that one on one with your employee twice a year, that would be part of a training curriculum. Q. A. You spend time on it twice a year. How so?

When I have my performance evaluation with my

boss and I walk through all of my performance objectives and one of those performance objectives is how did I treat folks fairly and insure that we have a discrimination-free, harassment-free work environment, and have a chance to be evaluated and measured on those, I think that is to make sure that everyone in the environment knows what that is and knows that they are

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. It's got the required documents that we have to

post in the building. Q. What's the equal employment opportunity component

of the Five-In-One posting? A. I think -- I have not looked at that recently to

be able to recite what's on it. Q. A. Q. A. Q. Center? A. Q. A. Q. That Five-In-One is in the lunch room. Anywhere else? No. Are there any other postings of the Phoenix But it does have some? Yes, it does. Do you know -- what do you mean by Five-In-One? It's five posters on one document. Where is that posting at at the Phoenix Service

Service Center regarding equal employment opportunity? A. There's the reaffirmation statement in the lunch

room next to the Five-In-One as well as outside of human resources. Q. When you say outside human resources, do you mean

like on a door as you enter the human resources area? A. Q. It's on the wall outside of my office. Are there any other postings on equal employment

opportunity at CIGNA Phoenix Service Center at the present

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1 2 3 4 5 6 7 8 9 10 11 12 13 96 14 15 97 16 17 18 19 20 21 100 22 23 101 24 25 Internal CIGNA web page publications 128 Excerpted information from the Phoenix Service Center Management Training Reference. 128 99 98 Interoffice Memo to All CIGNA Employees from Ed Hanway re Reaffirmation of Equal Employment Opportunity dated January 3, 2005 Document titled Honest Interviewing for Rational Employment Document titled Civil Treatment for Managers Course Objectives 121 Document titled Doing Things the Right Way, An Employee Guide to CIGNA Policies & Ethics 127 NUMBER 95 E X H I B I T S DESCRIPTION CIGNA card titled Guidelines for Ethical Decision Making PAGE: 127 WITNESS: TIFFANIE DILLARD Examination by Ms. Kruse Examination by Ms. Culbertson Further Examination by Ms. Kruse 72 155 156 I N D E X PAGE:

128

128

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1 2 3 4 103 5 6 7 105 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 106 107 108 Defendants' Fifth Supplemental Disclosure Statement Salary History re Tara Ball Salary History re Celina Ramirez Salary History re Heather Dunn 149 104 Document titled Consider a Company In The Business of Caring Document titled Building An Inclusive Environment 128 NUMBER 102 E X H I B I T S (Cont'd) DESCRIPTION CIGNA Internal web page publications PAGE: 128

129

71 71 71

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CIGNA web page. BY MS. KRUSE: Q. When you say the CIGNA web page, do you mean the at that time. 101 and 102 are recent 2005 prints from the that would have been used in 2001. MS. CULBERTSON: exhibits are mixed up, I think. along. THE WITNESS: 98. 98 is D0946. Okay. Okay. I'm sorry. My

So I'm just trying to follow

MS. CULBERTSON: THE WITNESS:

Exhibit 99 is one page of the

civil treatment training package that managers would have gone through at that time. And Exhibit 100 also would have been available

web page accessible to employees -A. Q. A. Q. A. Q. A. Yes. -- or to the public? Yes. Internal web page.

Internal web pages? Uh-huh. Okay. Exhibit 103 is our employment application. It also

would have been available at the time. MS. CULBERTSON: That was 103?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: Right. I don't

And 104 would have been available.

know if every manager would have had this accessible, but it would have been available in that time frame. Not every

manager would have gone through this training at that time, but the majority probably had. BY MS. KRUSE: Q. Okay. Let's go back then to the ones that were Tell me what this

available in 2001, starting with 95. document is. A.

This is a job aid given to all employees, so All employees are

managers and front line employees.

required -- by employees, I mean managers and non-managers, are required to go through an ethics training program. And

this is the job aid -- wallet sized card that you can keep with you at your desk or in your -- in your wallet. you guidelines for ethical decision making. So the first page is the front of the card. The second page is the back of the card. That gives you some It gives

places to go to get help if you're faced with an ethical dilemma, including the CIGNA Ethics Help Line. Q. A. When do employees receive ethics training at CIGNA. Employees receive ethics training during new hire

orientation. Q. And is that when they receive this Exhibit 95?

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 D0961, What to Avoid. You'll see another

reference to EEO related questions in the middle of the page. D0963, we expound on that, legally defensible EEO related questions. That's where we give some examples of

questions to ask and not to ask. And then near the end of the manual, D0976, as we're talking about evaluating the candidate, one of the items on that page, avoiding stereotyping based on sex, race, ethnic background, age, et cetera. And then the appendix that we already referenced, D0980. Q. Moving -- and how -- how are you aware that this

honest interviewing was offered at the Phoenix Service Center in 2001, that this course for which this is the manual? A. Because Korena Carlyon, who is in my HR team, was

in the department at that time and has that firsthand knowledge. Q. A. Q. She told you? She's passed it on to me, uh-huh. And how are you aware that Exhibits 95 and 96 were

available in the Phoenix Service Center in 2001? A. Based on my previous role before I came to the

service center, I was the regional training director for the southwest region which encompassed some of the Phoenix Service Center -- or encompassed the Phoenix Service Center,

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and I was responsible for rolling this training out across the region. Q. So you did -- conducted training at the Phoenix

Service Center, the ethics training? A. In 2001, I was not the person to have conducted However, when I got to the center in 2002, I

this training.

did verify that all managers had already gone through it. Otherwise I would have facilitated it again, had it occurred on site. Q. Go ahead and turn to 99, which is D0981. It says, So this is

"Civil Treatment for Managers Course Objective."

a one-page document that's part of course material? A. Q. Correct. And this course was offered in 2001 at the Phoenix

Service Center -- or to managers at the Phoenix Service Center? A. sure. I can't tell you that it was offered in 2001 for I know that this is the course all managers are

required to go through once they become a manager for CIGNA. So we may have had this course in 1999 or 2000. I don't know

for sure if we needed it in 2001 since we may have had all of our managers already trained. Q. A. Q. But this course existed -Yes, it did. -- in 2001?

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