Jared R. and Naylene M. Nield - Page 7




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               department of Spartan Showcase, and in my area we had                  
               our work tables, and then right behind us we had bins                  
               –- well, they weren’t really bins but they were wood                   
               things that had the sheets for the lights in it.  And                  
               there was not very much room between there because we                  
               had a bunch of stuff stacked in there, and he had                      
               brushed by me and did this type of thing into my breast                
               (indicating).                                                          
          In connection with Ms. Nield’s foregoing testimony during her               
          deposition, Goer’s attorney asked her the following questions, to           
          which she gave the following answers:                                       
                    Q  Talking about elbowing?                                        
                    A  Bumped his elbow right into my breast.  And I                  
               told her about that.                                                   
                    Q  What else did you tell her?                                    
                    A  The way he talked, the way he swore.  I told                   
               her everything that I have told you.                                   
                    Q  So you told her about how he broke things?                     
                    A  Yes.                                                           
                    Q  Told her about how he would scream and abuse                   
               everybody?                                                             
                    A  Yes, and the derogatory statements, harassing                  
               women.  I told her everything.                                         
                    Q  What did she say after you told her all that?                  
                    A  She said, okay, thank you, and continued her --                
                    Q  You mentioned something about the elbow in the                 
               breast.  When did that happen and what happened?                       
                    A  He just had –- he was joking with somebody over                
               down farther from me, and I don’t know what was going                  
               on.  I could just hear everybody laughing. * * * [the                  
               supervisor] was there, * * * [coworker 1] was there,                   
               and I don’t know who else was there.  But I could hear                 
               * * * [the supervisor] and * * * [coworker 1] laughing,                





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