Hearing:
January 25, 2002
SUPERIOR COURT OF WASHINGTON FOR KING
COUNTY
|
LARRY PITTMAN, et al., Plaintiffs v. Defendant |
No. 99-2-52345-8KNT declaration of judith calhoun authenticating documents submitted by defendant in response to plaintiff's discovery requests regarding occurrence policy |
I, Judith Calhoun,
declare,
I reviewed Defendant’s responses to Plaintiff’s First Set of Interrogatories and Requests for Production.
Attached as exhibits are true and correct copies of documents submitted by Defendants in response to Plaintiffs' discovery requests with respect to employee discipline under the occurrence policy. These documents indicate the facts in the following summary:
Name Date Race Explanation of Occurrence
1. Curtis Hollis 12/23/98 B Absence/Tardiness
KCF01224 Curtis Explained that his hot water
heater burst and his landlord called him
home to take care of the emergency.
They gave him 1/2 occurrence for this
emergency.
2. Curtis Hollis 1/25/99 B Absence/Tardiness
KCF01229 Curtis was terminated because he
was arrested and showed up late.
3. Curtis Hollis 9/1/98 B Loafing
KCF01206 Curtis must pick up pace or he will
be demoted to packer.
4. Mike Davis 4/27/99 B Missed 2 days-sick
KCF00438-441 Last written occurrence said 4-1/2.
KC explains that they found 2-1/2
occurrences making a total of 8-1/2.
5. Larry Pittman 8/27/98 B Absence
KCF01477 On 7/6/98 Larry was at 3 occurrences.
On 8/27/98 they gave him 1-1/2
occurrences for his absence.
6. Redacted 6/20/96 W Breaking company rules.
KCF01883 No occurrence given for absence.
Not marked as an absence.
7. Redacted 12/11/00 W Breaking company rules.
KCF01876 No occurrence given for absence.
Not marked as an absence.
8. Redacted 3/2/01 W Breaking company rules.
KCF01851 No occurrence given for absence.
Not marked as an absence.
9. Redacted 1/26/01 W Breaking company rules
KCF01850 No occurrence given for absence.
Not marked as an absence.
10. Redacted 9/6/97 W Absence & Breaking company rules.
KCF01828 No occurrence was given even
though they said next absence
would result in termination.
11. Redacted 3/3/00 W Absence
KCF01723 Missed 11 days. Terminated.
Blacks terminated after 2 days.
12. Redacted 2/24 W Breaking company rules.
KCF01722 Did not come in or call.
Next time termination.
No occurrence given.
13. Redacted 10/1/98 W Other
KCF01715 Became abusive to other
employees, possibly drinking.
"Behavior will not be tolerated
again". No occurrence.
14. Redacted 12/3/97 W Breaking company rules.
KCF01712 Failed to call in. No acceptable
excuse for not reporting to work.
No occurrence.
15. Redacted 12/2/99 W Warning letter.
RCF02025 Six occurrences, normally
termination but demoted
instead and reduced pay.
The foregoing declaration and evidence are submitted under penalty of perjury under the laws of the State of Washington.
DATED this 14th day of January, 2002.
_____________________________ Judith Calhoun
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