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2. Hiring of Elizabeth "Libba" Andrews
Petitioner hired Elizabeth B. "Libba" Andrews (Andrews) as
marketing coordinator in August 1990 (the second month of the
final year in issue). She spent most of her time from August
1990 to June 30, 1991, developing an advertising program for
Alumnus. During that time she also developed new alumni
programs, participated in strategic planning, and helped manage
petitioner.
Andrews spent a negligible amount of time as petitioner's
contact person for the affinity credit card program. Brown met
with her once at petitioner's office and once at the bank. They
spoke on the phone around four times about the affinity credit
card program and six times about the sale of advertising.
Andrews sold advertising in Alumnus to PB&T for the affinity
credit card program on the same terms as applied to other
advertisers. She sent advertising contracts to Brown in February
and June 1991. Petitioner and PB&T signed the February 1991
contract.
Andrews suggested that the 1987 contract be changed to allow
petitioner to include a larger message in the monthly billing
statements.
Andrews answered some questions from alumni about the
affinity credit card. In April 1991, an alumnus complained to
petitioner about the affinity credit card program. Andrews
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