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the development of petitioner's clinical information system.
From 1986 through 1990, Worley worked 10 to 12 hours a day for
petitioner. Worley directs the nurses petitioner employs.
Donna Stapleton (Stapleton), a registered nurse, is
petitioner's vice president of operations. Stapleton earned a
Certification in Nursing Administration in 1985 from the American
Nursing Association. She is responsible for the operational and
clinical oversight of the field staff, acts as a liaison with
State and Federal fiscal intermediaries regarding regulatory
issues, provides evaluations and advice to clients, and handles
personnel management, development, and recruitment.
Currently, petitioner has three senior consultants with
nursing backgrounds in its operations division. Each senior
consultant, along with Stapleton, supervises a team of two to
four nurses. Before the senior consultants were hired sometime
after 1990, these duties were performed under Rogers' guidance.
3. Petitioner's Management Team--General
From 1986 to 1988, petitioner's management tasks were
performed by Rogers and Worley. In late 1988, Tankersly joined,
and in late 1989, Stees joined petitioner's management team.
Rogers, Tankersly, and Worley knew petitioner's business; Rogers
had the reputation that brought the clients in and finalized the
contracts. Sometime in 1990 or 1991, a salesman began working
for petitioner out of Nashville. Rogers recruited petitioner's
executive and management staff.
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