Miller, Graves and Klein

Memorandum
To: Vanessa Graves, Esq.
From: Erin Goecke
Date: February 2, 2018
RE: Private Deposition Preparation

This memorandum is to help in preparation of the deposition of Ms. Alice Bennett

in the Bennett v. Rikards-Hayley case. The first section consists of questions to ask the
plaintiff. The second list is the documents that need to be reviewed. Lastly, I included
questions that the Plaintiff’s attorney may ask.

Questions to Ask:

1. How long did you work at Rikards-Hayley?

2. What were your responsibilities at Rikards-Hayley?
3. Did you receive employee reviews?
a. How often were they?
4. Did your employers ever suggest that you were disrespectful to other
employees?
a. Did you change your perspective and treatment of others?
5. Why do you think were you a good fit for the managing position?
6. Was it explained to you that the hiring board did not find you could fulfill
the requirements due to your experience being limited?
7. You believe you were discriminated against because of your sex, was the
person hired a male or female?
a. What is their name?
8. Did you have any issues with this person after they were hired?
a. What was the issue?
9. Did you know Ms. Yardly before she was hired?
10. Do you know anything about Ms. Yardly’s work history or work ethic?
11. Were you mad that Ms. Yardley was hired for the position?
a. Why?
12. Why did you not take the position in another department when it was
offered?
13. Did you receive a severance package when you left Rikards-Hayley?
14. What symptoms are you experiencing from your physical and emotional
suffering?
 15. Have you seen a doctor or psychologist since you were terminated from
Rikards-Hayley?
16. Which doctor(s) are you seeing?
17. How many jobs have you submitted an application to since you were
terminated?
18. How many interviews have you secured from these applications?
19. Do these companies give you feedback on your interview or explain why
they are not hiring you?

Documents to Review:

1. Demand letter from Plaintiff’s Attorney

2. Interview Transcript of Darren Blackwood
3. Interoffice Memo from Rhees Bradley
4. 42 U.S.C §2000

Questions the Plaintiff May Ask:

1. Why did Rikards-Hayley hire Ms. Yardly?

2. What were her qualifications?
3. Why did Ms. Bennett only qualify to get a six-month severance, when
others have gotten more?
4. How are severance packages valued?
5. Are employee records kept on location, or are the stored electronically?
6. Are there records of Ms. Yardly’s reviews of Ms. Bennett?
7. Are there records of comments about Ms. Bennett’s weight or appearance?
8. Is it acceptable at Rikards-Hayley for a man to be uncomfortable with a
woman supervisor?
9. If Ms. Bennett was doing so well in her department, what reasons was she
not promoted?
10. Who else supervised Ms. Bennett?
11. Who is on the hiring board?
12. How did the employees in Ms. Bennett’s department enjoyed having her as
their supervisor?
13. Was their opinion ever considered in the hiring of Ms. Bennett?