Noted for
LARRY E. PITTMAN and
SYLVESTER )
PITTMAN,
MICHAEL PITTMAN, ) No. 99-2-52345-8 KNT
TERRANCE A. DAVIS, KEITH
KERN, )
YOLANDA
ESKRIDGE, MICHAEL ) DECLARATION OF
ROGER W.
DAVIS, GREGORY CODY, DAVID )
KNIGHT
IN OPPOSITION TO
LISTIOWEL ABRUQUAH, ARTHUR ) DEFENDANT’S
MOTION FOR
JOSEPH A. DONKOR, DARREL
CODY, ) AFTER ACQUIRED EVIDENCE
MARY COLEMAN, ERIC ARHIN, )
SHABAE DIQUAN, SIDNEY
LANIER, )
RE-LASHIA SEARLES, JAMES
GOODE, )
CURTIS HOLLIS,
and BENJAMIN )
BARNES, individually, )
)
plaintiffs, )
v. )
)
a
defendant. )
____________________________________)
I,
ROGER W. KNIGHT, declare that:
I work in the Law Office Paul H.
King, performing those tasks that do not require a bar license. I have personal knowledge of the facts of
this case.
Previously, I was employed by
The
Boeing Company as an Engineer, Boeing Paycode 4, a member of the Professional Bargaining Unit of the Seattle
Professional Engineering Employees Association.
My dates of employment are from
During my time there,
Boeing had a
procedure for voluntary layoff. What
happens is that if an employee wishes to leave the company under amicable
conditions, the company can offer to place him or her on a voluntary lay off. The employee is not selected for lay off during
a reduction in force exercise, or the employee volunteers to be laid off out of
turn during such exercise, thereby reducing the number of involuntary lay offs
by one. In such circumstances, it is an
act of compassion and generosity on the part of the employee volunteering to be
laid off. The deal is that Boeing agrees
not to contest the employee’s application for unemployment compensation,
it is treated like any other lay off.
Sometimes, particularly if the employee volunteered to be laid off out of
turn during a reduction in force exercise, the employee is eligible for recall
from lay off under whichever collective bargaining agreement applies to that
employee.
Therefore,
if such employee lists on his or her application for another company that he or
she was laid off from The Boeing Company, it is not a false statement of fact.
I
certify under penalty of perjury under the laws of the State of
Dated this 5th day of February, 2002 in
____________________________________
Roger
W. Knight for
Law Office of Paul H. King
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