Document gaZ6NopJo0Ko077j7jqy6XkkG

Marcella Duncan 7-22-04.txt 19 MR. PARKER: OKAY. THIS IS NOW THE FOURTH TIME 20 I'VE ASKED YOU TO START THE DEPOSITION. 21 MR. FISHBACK: I KNOW WHAT YOU'RE ASKING, 22 COUNSEL. AND, AGAIN, I'LL STATE -- MAKE MY RECORD IN 23 POINTING OUT THE INACCURACIES THAT WERE BEING POINTED OUT 24 TO THE COURT. 25 MR. PARKER: NO. I DISAGREE THAT THERE HAVE 0014 1 BEEN ANY INACCURACIES. THIS IS NOW THE FIFTH TIME, YOU 2 WANT TO START THE DEPOSITION? 3 I'M PREPARED TO MEET AND CONFER WITH YOU AFTER 4 THE DEPOSITION ABOUT THESE SUBJECTS. AT THIS POINT, IF 5 YOU WANT TO START YOUR DEPOSITION, THIS IS THE TIME. 6 MR. FISHBACK: CALIFORNIA CODE AND CASE LAW 7 REQUIRES ME TO MEET AND CONFER DURING THE PENDENCY OF THE 8 DEPOSITION IF YOU HAVE ANY DISPUTES ARISING. I'M MERELY 9 POINTING OUT WHAT I SEE IS AN INACCURACY AND CONCERNS 10 THAT I HAVE WITH THIS DEPOSITION GOING FORWARD AS I'M 11 REQUIRED TO DO. 12 Q. MISS DUNCAN -13 MR. PARKER: THAT'S AN INACCURATE STATEMENT OF 14 CALIFORNIA LAW BECAUSE WHAT YOU HAVE TO MEET AND CONFER 15 ABOUT IS IF THE DISPUTE CONCERNS QUESTIONS AND YOU NEED 16 TO SEEK A PROTECTIVE ORDER. NONE OF THAT HAS HAPPENED. 17 AGAIN, PLEASE START THE DEPOSITION. 18 MR. FISHBACK: AGAIN, IT'S -- OKAY. 19 Q. MISS DUNCAN? 20 A. YES, SIR. 21 Q. NOW I WANT TO TALK A LITTLE BIT ABOUT YOUR 22 HISTORY WITH DANA CORPORATION. I DON'T HAVE A GOOD FEEL 23 FOR ALL OF YOUR EXPERIENCE LEADING UP TO THE PRESENT 24 TIME. 25 LET ME JUST FIRST ASK YOU ABOUT YOUR EDUCATION. 0015 1 DID YOU GRADUATE FROM HIGH SCHOOL? 2 A. YES, I DID. 3 Q. WHERE WAS THAT? 4 A. COLUMBUS CITY, INDIANA, IN 1968. 5 Q. DID YOU SEEK ANY SECONDARY EDUCATION? 6 A. YES, I HAVE. 7 Q. WHEN DID YOU DO THAT? 8 A. I ATTENDED SOME COURSES AT ST. FRANCIS COLLEGE 9 IN FORT WAYNE, AND I.U.P.U.I. IN FORT WAYNE IN THE EARLY 10 1970'S. AND I ALSO ATTENDED FOUR YEARS OF INSTITUTE FOR 11 MANAGEMENT AT ILLINOIS BENEDICTINE COLLEGE IN LISLE IN 12 THE 1990'S. 13 Q. HAVE YOU --DO YOU HAVE A DEGREE? 14 A. NO. 15 Q. COLLEGE DEGREE? 16 A. NO. 17 Q. ARE YOU JUST -- HAVE YOU BEEN WORKING TOWARDS 18 PARTICULAR DEGREE? 19 A. YES. 20 Q. WHAT DEGREE ARE YOU WORKING TOWARD? 21 A. BUSINESS MANAGEMENT. 22 Q. HOW CLOSE ARE YOU TO THAT? 23 A. ABOUT THREE CREDITS AWAY. 24 Q. CLOSE. OKAY. 25 A. UH-HUH. 0016 1 Q. HAVE YOU EVER ATTEND THE DANA CORPORATION 2 COLLEGE UNIVERSITY? 3 A. YES, I HAVE; SEVERAL TIMES. Page 7