Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 1 of 78

In The Matter Of: LISA T JACKSON v. PAULA DEEN, et al.

PRiSCILLA SUMERLIN February 26, 2013

WHEELER REPORTING
Court Reporting m, Video Litigation Support 404351 .4577 ieoo Norhskie Drive (Tax) 404.251.3484 Suite 250 wwwVTheelerReporting.com Atlanta, GA 30318

EXHIBIT

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 2 of 78

LISA T. JACKSON V. PAULA DEEN, et al.
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Defendants.
Val

PRISCILLA SUMERLIN February 26, 2013

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APPEARANCES OF COUNSEL: On Behalf of the Plaintiff: S. WESLEY WOOLF, ESQUIRE S. Wesley Woolf, P.C. 408 East Bay Street Savannah, Georgia 31401 Phone: 912-201-3696 Fax: 912-236-1884 Email: [email protected] On Behalf of the Defendants: WILLIAM J. HUNTER, ESQUIRE OliverManer, LLP 218 West State Street Savannah, Georgia 31412 Phone: 912-236-3311 Fax: 912-236-8725 Email: [email protected] THOMAS A. WITHERS, ESQUIRE Gillen, Withers & Lake, LLC 8 East Liberty Street Savannah, Georgia 31401 Phone: 912-447-8400 Fax: 912-629-6347 Email: twitharsgwllawfirm.com ALSO PRESENT: BUBBA HIERS MELLISA MCCURRY

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA

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LISA T. JACKSON, Plaintiff, }CIVIL ACTION FILE )NO. 412-CV-00139-wrM-ORS

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PAULA DEEN, at al.,

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WHEELER REPORTING COMPANY, INC 1600 Northeide Drive, N.W. Suite 250 Atlanta, Georgia 30318 (404) 351-4577 The videotaped deposition of PRISCILLA StJMRNLIN r taken on behalf of the Defendants, pursuant to the stipulations set forth herein, before Carla J. Hopson, RPR, Certified Shorthand Reporter, at 3490 Piedmont Road, N.E., Suite 1050, Atlanta, Georgia, on the 26th day of February, 2013, onmalencing at approximately 10:00 a.m.

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VIDEO: Ervin Parkas

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EXAMINATIONS Cross Examination (By Mr. Withers) Cress Examination (By Mr. Hunter) ReDress Examination (By Mr. Withers) Recross Examination (By Mt. Hunter) 165 5 155 20 141 13 5 6
EXHIBITS

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INDEX

(For the Defendants)

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Line 14 9 19 14 21. 1 6

Exhibit No. 1 Exhibit No. 2 Exhibit No. 3 Exhibit No. 4 Exhibit No. 5 Exhibit No. 6 Exhibit No. 7

THE VIDEOGRAPHER: This will be the videotape deposition of Priscilla Sumerlin in the matter of 4 Jackson Lisa (Sic) versus Paula Deen and others. Today's date is February 26th, 2013, and 5 6 the time is 10:03 a.m. 7 Would counsel please identify yourselves a and state whom you represent. MR. WITHERS: Tom Withers. I represent the 10 Hiers defendants in this case, Bubba Hiers ii individually and Uncle Bubba's Seafood & Oyster 12 House, Inc. 13 Mr. Hunter, who represents the Paula Deen 14 defendants, is not present but will be here 15 shortly. 16 MR. WOOLF: My name's Wesley Woolf. I 17 represent the plaintiff, Lisa Jackson. 18 (Oath administered.) 19 MR. WITHERS: And, Wes, I should have said 20 the same stipulations from the prior depositions. 21 MR. WOOLF: That's fine. 22 MR. WITHERS: And read and sign? 23 MR. WOOLF: Yes. 24 MR. WITHERS: All right. 25 THE WITNESS: I think so.
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.'1=[

... .

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LISA T. JACKSON v. PAULA DEEN, et al.
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PRISCILLA SUMERLIN February 26, 2013

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MR. WITHERS: Okay. THEREUPON, PRISCILLA SUMERLIN, 3 4 having been first duly sworn, was examined and 5 testified upon her oath as follows: 6 CROSS EXAMINATION 7 0. (By Mr. Withers) Ma'am, my name is Tom a Withers. We've just met. I'm going to be asking you 9 some questions about your background, circumstances of 10 this lawsuit, and Lisa Jackson. ii If at any time you don't understand a 12 question or would like for me to repeat it or clarify 13 it, please ask me to do so and I'll be happy to comply 14 with that request. Okay? is A. Okay. 16 Q. A couple of ground rules as well. You have 17 to give us a verbal response as opposed to a nod of the 18 head because this will be taken down by the court 19 reporter and sometimes it's difficult to define what 20 the nod of the head actually means. 21 A. Okay. 22 Q. Now, would you state your full name for the 23 record, please, ma'am? 24 A. Priscilla Antonia Sumerlin. 25 Q. Miss Sumerlin, as I'm asking you questions
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0. And then after St. Vincent's what did do you? 3 A. I went to Wesleyan College in Macon, 4 Georgia. s 0. And did you get a degree from Wesleyan? s A. I have two bachelor's of arts degrees, one 7 in psychology and one in studio art. 8 Q. And when did you obtain those degrees? 9 A. I graduated in 2002. 10 Q. And then after you graduated from Wesleyan 11 in Macon what did you do? 12 A. I went to Vanderbilt University in 13 Nashville. 14 Q. And what did you study there? 15 A. I studied acute care nurse practitioner. 16 Q. And how long was that program? 17 A. Twenty-four months. 18 Q. And then I take it you got a graduate 19 degree in nursing? 20 A. I'm an acute care nurse practitioner. 21 Q. Okay. Was that a-22 A. It's a master's degree. 23 Q. -- degree program? 24 Master's -- that's what I'm trying to find 25 out.
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a. unless you ask me to repeat it or clarify it, I'm going 2 to assume that you are giving a fair response and 3 answer to a fair question. 4 Is that a good ground rule for us to 5 proceed upon? 6 A. That's a ground rule. 7 Q. All right. And as well, if you need to B take a break at any time I'm happy to do so. But if 9 there's a pending question we'll want that question 10 answered. ii. A. Okay. 12 Q. It's not an endurance contest, in other 13 words. 14 You're not under the influence of any 15 medications that would make it difficult for you to 16 hear and answer our questions here today, are you? 17 A. I am not. 18 Q. All right. Let's talk about your 19 background for a little bit. Where did you grow up? 20 A. Savannah, Georgia. 21 Q. And what high school did you go to? 22 A. St. Vincent's Academy. 23 Q. And when did you graduate from St. 24 Vincent's? 25 A. 1998.

All right. And -- and that would have been when? In 2004? 3 A. Correct. 4 Q. And then after 2004 what did you do? 5 A. I moved back to Savannah. 6 Q. And what did you do in Savannah? 7 A. I started working at Memorial Hospital. 8 Q. And what did you do at Memorial? 9 A. My first position? 10 Q. Sure. ii A. I was a bedside nurse in the trauma center. 12 Q. Who was your supervisor when you first 13 started? 14 A. Immediate supervisor? 15 Q. Yes. 16 A. It was Karen Boyer. 17 Q. And how long was Miss Boyer your 18 supervisor? 19 A. Three years, I believe. 20 Q. And you were an acute care nurse in the 21 trauma center. How long did you continue in that 22 capacity? 23 A. Three years-24 Q. And then -25 A. Approximately.
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LISA T. JACKSON v. PAULA iniii" et ai.
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PRISCILLA SUMERLIN February 26, 2013

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Q. Okay. And then what did you do? A. I became the nursing supervisor of the 3 hospital. 4 Q. And how long were you the nursing s supervisor? 6 A. About two years. 7 0. And who did you report to as the nursing 8 supervisor? s A. The CEO and the COO, Maggie Watts. I mean, ic Maggie Gill. Sorry. ii Q. And then did your job change after nursing 12 supervisor? 13 A. Yes, I took the manager of the trauma 14 program. 15 0. And is that nursing manager or just manager 16 generally? 17 A. It's more of a program manager than it is is a -- necessarily a nursing manager. ig Q. Okay. And how long were you manager of the 20 trauma center? 21 A. Two years. 22 0. And where does that take us to? 23 A. Here. 24 Q. All right. And "here meaning Atlanta? 25 A. Correct.
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i to make millions of dollars in filing a lawsuit against 2 Uncle Bubba's Seafood? 3 A. That's the same question, but no. 4 Q. Actually, it was a little different. s Tell me where your parents live. 6 A. They have a few homes. 7 Q. All right. And tell me where those are. 8 A. They have a few in Richmond Hill, Georgia, 9 and they have a farm in Sylvania, Georgia. 10 Q. And your father, what kind of work does he 11 do? 12 A. He owns his own businesses. 13 Q. And what are those businesses? 14 A. Industrial supply businesses. 15 Q. What are the names of those businesses? 16 A. He just sold the biggest one, Industrial 17 Rubber and Supply to Lewis & Goetz Company. ie Q. And where was that industrial supply? is A. There were a few locations, but they worked 20 primarily out of the Savannah location. It was in 21 Garden City. 22 Q. How many employees does that business have? 23 A. I have no idea. 24 Q. All right. And you mentioned other 25 businesses that he had.
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1 A. Industrial Conveyor Belt. i Q. All right. And when you were manager of 2 Q. And where is that located? 2 the trauma center at Memorial who was your supervisor 3 A. Garden City as well. 3 then? 4 Q. All right. 4 A. Maggie Gill. s A. Those are the only two that come to mind. 5 Q. How many folks did you supervise in the 6 I'm sure there's more, but I don't know all of his 6 trauma center? 7 business. 7 A. Well, 1 had four immediate employees, but a Q. All right. Does your -- your mother is 8 it was more of the program, the trauma program that I 9 was a manager of, not necessarily nurses or doctors per s still with us? 10 se. 10 A. She is. ii Q. I see. All right. Did you ever tell 11 0. And her name? 12 A. Diane Sumerlin. 12 Maggie Gill that Lisa Jackson was going to be filing 13 suit against Uncle Bubba and Uncle Bubba's Seafood? 13 0. And does Diane work? 14 A. No, she does not. 14 A. Not that I recall. 15 Q. Did you ever tell Maggie Gill that Lisa is Q. And your fathers name? 16 Jackson was going to do make millions of dollars in a 16 A. Cyrus Anthony Sumerlin. 17 lawsuit against Uncle Bubba or Uncle Bubba's Seafood? 17 Q. Does he go by Bubba as well? 18 A, No, I did not. 18 A. Yes. 19 Q. Did you ever tell anyone who was an is Q. And how long have they lived in the 20 employee at Memorial that Lisa Jackson was going to be 20 Richmond Hill area? 21 filing a lawsuit against Uncle Bubba's? 21 A. Since 1970. 22 A. Not that I recall. I didn't have personal 22 0. All right. Well, I thought you told me you 23 relationships with them. 23 grew up in Savannah? 24 0. All right. Did you ever tell anyone what 24 A. Savannah, Richmond Hill. 25 was an employee at Memorial that Lisa Jackson was going 25 Q. Okay.

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YAULPL

LISA T. JACKSON v. et at.

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PRISCiLLA SUMERLIN enruary 4O,hU1

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i A. I mean, I went to school in Savannah, so -Q. All right. 3 A. My home resided in Richmond Hill, but I 4 spent all of my time in Savannah. 5 Q. All right. What's the residence address for your parents? A. Currently their primary location is their 7 farm in Sylvania, Georgia. I don't know the physical 8 address. 10 Q. What was - what was their most recent 11 residence address in Richmond Hill? 12 A. They've sold quite a few houses and they've 13 moved a lot in the last few years, but I think the last 14 one was Jericho Way. I don't know the number. 15 Q. All right. And brothers and sisters, do 16 you have brother or sisters? 17 A. I have one sister. 18 Q. And her name? ig A. Ashley. 20 0. And where does Ashley live? 21 A. That's a good question. I don't know. 22 Q. Do you know what town Ashley lives in? 23 A. I know the last town she was known to live 24 in, but I doubt she's still there. It was Boone, North 25 Carolina.
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A. She called my phone pretending not to be herself about three months ago perhaps. 3 Q. And did you speak with her? 4 A. I said "hello. 5 Q. Did she say "hello" back? 6 A. She said, "I have the wrong number.' And I 7 said, "Ashley?" And she hung up the phone. She had s blocked the number. and then she proceeded to text 9 me 10 Q. And -11 A. -- so I knew it was her. 12 Q. And what did she text you? 13 A. Forget that I called, or that was a mistake 14 or something to that effect. 15 Q. Do you know what name she uses as her last 16 name now? 17 A. No clue. is Q. When was the last time you saw Ashton, 19 Cyrus orAdrianna? 20 A. I caught a glimpse of them in May of last 21 year, two of them, Cyrus and Adrianna. And that was 22 for a -- a court case and -- but I did not see Ashton. 23 So the last time I saw Ashton was probably five years 24 ago, the last time I talked to my sister -25 Q. All right.
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Q. What's Ashley last name? i A. - had any conversation with her. A. Another good question. I have no idea. 2 Q. When was - do you correspond with Ashton, 3 Cyrus or Adrianna? 3 Q. You don't know her last name to be 4 Martinez? 4 A. No, I have no way to correspond with them. 5 A. That was her deceased husband's name, but 5 Q. I'm sorry? 6 she's been remarried about three times since then. 6 A. I have no way to correspond with them. 7 Q. All right. Does Ashley have children? 7 Q. Within the last five years other than the 8 A. She does. 8 glimpse you caught of OM and AIJIL0 have you Q. And what are her children's names and ages? 9 spoken with or had any kind of a relationship with 10 C 10 A. AdIft JSft --he just turned 14. orAS1L.orA? ii C4ow A _Lis 12, and A&WwoM E1J is ten. ii A. No. 12 And they all go by the last name M111101111111111110 12 Q. That's a no? 13 Q. All right. Well, as you sit here today you 3.3 A. That is a no. 14 don't know where Ashley resides? 14 Q. All right. Over the last five years has 15 A. I do not. 15 either A, A4111111IMMor C4ft lived with you? 16 Q. When was the last time you spoke with 16 A. Yes. Well, they stayed with me frequently. 17 Ashley? 17 Q. And when did they stay with you? 18 A. An interactive conversation? 18 A. Over the last five years. 19 Q. Yes. 19 Q. Yes, ma'am. 20 A. Probably about five years ago. 20 A. Oh, no, not in the last five years. Prior 21 0. Well, I'm not sure what "interactive 21 to that. 22 conversation" means, so let's break that down. When 22 Q. All right. And is-- let's just try and 23 was the last time you spoke words with her? 23 get to the heart of this. Are you and Ashley estranged 24 A. With her? 24 in some fashion now? 25 Q. Yes. 25 A. We don't speak. I don't -2

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LISA T. JACKSON v. PAULA DEEN, et at.
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PRiSCILLA SUMERLIN February 26, 2013

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Q. And what's the reason for that estrangement, if that's a fair word? A. There's multiple reasons. She's on drugs. She's certifiable. Q. And certifiable what? A. Crazy. Q. Okay. And I take it then that she moves from place to place without you being able to follow her or find her? A. Correct. Q. And that she moves her children with her from place to place so that you're unable to maintain a relationship with her children for-A. Correct. Q. -- the last five years. Is that fair to say? A. Correct. 0. Now, going back prior to that, you had indicated that at some point in time those kids had stayed with you from time to time. A. Most of the time. Q. And when was that? A. From the time 2004 that I moved back to Savannah until she left Q. And so if this is February of 2013, backing
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A. They didn't have custody, but he resided with them full time. They took him to school, c 3 and AlIjl_. tayed with me, I would say, probably 4 80 percent of the time. And they were with their s mom -- after thaw father was killed they started s staying with me. 7 Q. So just to pinpoint the time frame, it 8 would be after Willie Martinez was killed that they 9 started staying with you? 10 A. Correct. I --he was killed the year that ii I moved back to Savannah in 2004. 12 Q. All right. Where was Mr. Martinez from? 13 A. Dade City, Florida. Well, that's where he 14 resided when he died, so -is Q. Okay? 16 A. -- I'm not sure where he's from. 17 0. Do you know -18 A. Puerto Rico. That's where he was born, if 19 that's what you're looking for. 20 Q. And would you describe Mr. Martinez as 21 black, Hispanic or Caucasian? 22 A. He's Hispanic, Latino. 23 Q. Now, the time frame that Cand A 24 were staying with you, did any of that time frame 25 overlap when you and Miss Jackson were living together
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five years would be February of '08. When would she have left? 3 A. I don't recall the exact date that she 4 left. 5 0. Would it have been about then February of 6 '08? Is that fair to say? 7 A. Again, I don't recall the exact date. And 8 I don't know -- I know that the last time that I -- I 9 know the month was May. So we may be looking at four 10 yearst-l-knovi w4tere I lived and I know the last time I ii saw A.J., so so perhaps it wasJir years. 12 0. And has Miss Jackson maintainsda 13 relationship with AJ who I assume you call A.J.? 14 A. A.J. 15 Q. -- CorAwithinthelastfour 16 years? 17 A. No. is Q. She simply hasn't been able to because 19 they've been moved by your sister Ashley? 20 A. Correct. 21 Q. All right. When A.J., Cand A*J....._ 22 lived with you how long did they live with you? 23 A. I wouldn't say -- A400 resided with my 24 parents full time. 25 0, Okay.
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or residing together? A. Yes. Q. And how long would that have been? A. 2007, 2008. 0. To whenever Ashley took them away in 2008? A. Correct. Q. All right. And again, it would be fair to say that since -- I think yousaid it was ty that she left with them -A. *Yes. Q. of2008 you all haven't had any meaningful relationship with those children? A. Not really, no. Q. No email, no phone? A. I mean, we've reached out tc them, but we have had no response. Q. Okay. And just to make -- make that thought process complete, since May of '08 you haven't had any email communication with the -- Ashley's children; is that correct? A. Again, I've reached out to them, but I have had no response. Q. And that's what I -A. Yeah. Q. Any meaningful communication.

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LISA T. JACKSON v. PAULA DEEN, et at.
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PRISCILLA SUMERLIN February 26, 2013

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A. No. Q. And you haven't been Facebook friends with 3 them on a regular basis? 4 A. No, they're not on Facebook -5 Q. All right. 6 A. -- that I'm aware of. 7 Q. Okay. And haven't had any meaningful phone 8 conversations then in the last four and a half years? 9 A. No. io 0. Do you have any other nieces and nephews? ii A. Nope. That's it. I think. As far as I 12 know. 13 0. Okay. 14 A. A lot could happen in five years. is 0. Now, did your parents ever go to Uncle 16 Bubba's Seafood? 17 A. Once or twice, I believe. 18 Q. And when would that have been? 19 A. I had them come on Lisa's birthday one year 20 and my nephews and niece came. And if they went 21 another time it was not with me that I recall. If they 22 went any other times it was not with me. 23 Q. I'm sorry. You kind of faded off there. 24 A. If they-- if they went any other times, 1 25 don't believe it was with me that I can recall.
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A. Yeah. Q. And was Mr. Hiers present? 3 A. No, he was not. 4 Q. All right. Do you recall what year that s was that you all had Lisa's birthday party at Uncle 6 Bubba's? 7 A. I believe it was '08. 8 Q. Okay. Did -- on how many occasions have you been to Uncle Bubba's? 10 A. I don't have an exact number. I have no ii idea. 12 Q. Would it be more like five, 15 or 50 over 13 the years? 14 A. Twenty maybe. is Q. Okay. It was not unusual for you to go to 16 Uncle Bubba's, right? 17 A. It was selective. 18 Q. All right. And do you recall any other 19 specific occasions when you went to Uncle Bubba's? 20 A. No. 21 Q. Nothing stands out as you sit here? 22 A. (Nodding.) 23 0. And again, you have to answer verbally -24 A. No, I don't. 25 Q. --opposed to a shake of this head.
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0. So that would have been on a couple of occasions then to the best of your recollection that your parents came to Uncle Bubba's restaurant? 3 4 A. To the best of my recollection, I mean, the 5 only time I remember was Lisa's birthday -6 Q. All right. 7 A. -- for certain. 0. All right. And let's talk for a second 9 then about that birthday party. That was a birthday 10 party that you threw for Lisa at Uncle Bubba's. Is ii that -- does that seem right? 12 A. Yeah, it wasn't necessarily a party. 1 13 mean, it was just dinner. 1.4 0. Right. I mean, in other words, where you is chose to celebrate Lisa's birthday was at Uncle 16 Bubba's; right? 17 A. Yes. 18 Q. And you had dinner there? 19 A. We did. 20 Q. You had family with you? 21 A. I did. 22 0. Friends with you? 23 A. It was just family. 24 Q. All right. And you all had a pleasant time 25 at Uncle Bubba's that evening, I trust?
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All right. At any occasion when you were at Uncle Bubba's on those 20 occasions or so did you 3 ever hear Mr. Hers use the N word? 4 A. Typically I was never there when Mr. Hiers 5 was there. 6 Q. All right. 7 A. I think I recall one time that I -- he was s there that I was there. 9 Q. All right. And is that just happenstance 10 that you happened to be present and he would not be . ii present? 12 A. I was -- from Lisa I was told that he said 13 I was not welcome there. 14 Q. And so it was intentional then that you is would be present when he was not present? 16 A. Correct. 17 0. And would she call you and tell you or text 18 you and tell you he's not here, drop on by, or words to 19 that effect, or how did that work? 20 A. Well, due to the amount of hours that she 21 worked if I had time I would go eat dinner if I was off 22 of work and he wasn't there. 23 Q. But only -- you would only eat dinner if he 24 was not present? 25 A. Correct.
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LISA T. JACKSON v. AIJLA LJLLIN, et al.
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PRISCILLA SUMERLIN February 26, 2013

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Q. On -- and on how many occasions that you went there did you actually see Mr. Hiers present? 3 A. I only recall one. 4 Q. All right. Is there anything distinctive 5 about that one occasion that you can recall? 6 A. I believe that was the day of the Big Wit 7 incident. a Q. All right. 9 A. Wil Frazier, 10 Q. And what do you recall about that? 11 A. I know that Lisa was off that day and she 12 got called up to address some issue, and I just waited 13 for her and they both left. Mr. Hiers and Lisa left 14 and went to the kitchen and I just waited. 15 Q. Okay. Did you hear any fracas, raised 16 voices or anything of that sort? 17 A. No. 18 0. Did anybody tell you what had occurred with 19 respect to -- I think you've call it the Big Wil 20 incident? 21 A. I mean, yeah. Yes. 22 Q. And who was that? 23 A. Lisa did, a few of the kitchen staff 24 members that we were friends with, 25 Q. And who was that?
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i you? A. Nope. 3 Q. You mentioned having spoken to some other 4 people that you characterized as friends. Who else s would you have spoken to? 6 A. I mean, I -- I think that -- I don't recall 7 that exact-- I mean, you know, exactly how many people 8 came Out, but a few of them came out at the one time. 9 So, I mean, I remember that Tameka was io there. I think Delphine Jones was there. I don't know ii who all was outside of the office. Maybe Tony Cole. I 12 mean, I'm just guessing. 13 Q. Well, don't -- again, don't guess. 14 A. Yeah, so -is Q. Mr. -- Mr. Woolf may have told you that, is you know, it's -- if you don't remember it's okay for 17 YOU to-is A. Okay. Yeah, that's -iLR Q. -- not -- to say you don't remember. 20 A. Tameka and Big Wit and Delphine. 21 Q. All right. Other-- did you speak with 22 Delphine? 23 A. She kind of came out at the same time that 24 Tameka did. 25 Q. Yes. Were you speaking to Tameka and
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A. I know that Big Wit came out from the kitchen and I was still waiting on Lisa, and then 3 everybody kind of followed. I think Tameka came out. 4 I don't recall everybody that was there that day. s Q. Did you speak with Big Wil? 6 A. We didn't have much interaction. The 7 only -- I mean, I didn't know him that well. The 8 only - I know he had asked for some medical help prior 9 to that. But other that that, I wasn't really on a, 10 you know, friendly basis with him. 11 Q. Okay. So the answer would be, you really 12 didn't speak with Big Wit that day? 13 A. Not necessarily, no. 14 Q. All right. Did you speak with Tameka that 15 day about what had happened? 15 A. Yes. 17 Q. And what did Tameka tell you? 18 A. She said that, you know, there was an 19 interaction or ruckus, whatever you want to call it, 20 regarding Wit saying that he wanted to plead the fifth 21 regarding whatever they were talking about and that 22 Bubba got really angry and shook him and Wit walked 23 out. And then Bubba said he didn't have any civil 24 rights or something to that effect. 25 0. All right. Anything else that Tameka told
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Delphine at the same time? A. Correct. 3 0. And do you recall Delphine saying anything 4 in particular? s A. They were both discussing the story at the s same time. 7 Q. Did they tell you what had kind of 8 initiated the -- what you call interaction or ruckus? 9 A. I believe it was somebody getting fired for 10 calling somebody else a lewd name, if I remember ii correctly. 12 Q. Okay. Did they talk with you about that as 13 well? 14 A. They did. 15 Q. Did you speak with anyone other than 16 Delphine and Tameka? 17 A. No. Lisa. 18 Q. All right. And what did Lisa Jackson tell 19 you? 20 A. When it was time to leave she was just very 21 upset and she said that Mr. Hiers was very angry -22 Q. Yes. 23 A. -- and got in Wil's face and I guess shook 24 him, told him that he didn't have any civil rights 25 whenever Wil said that he wanted to plead the fifth and
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that that - that was a civil right. And that's all I recall. 3 Q. All right. And what else did -- do you 4 recall anything else her saying about that incident? 5 A. No. 6 Q. All right. Has she-- has Miss Jackson 7 told you that she has sued Mr. Hiers and Uncle Bubba's 8 and others about that incident? 9 A. I'm aware, yeah. 10 Q. All right. Have you read the lawsuit? ii A. I have. 12 Q. All right. You mentioned other friends who 13 had come out, and I -- I trust that by that you mean 14 Delphine and Tameka in answer to my earlier question is about who you spoke with. You said some friends. 16 A. Uh-hmm. 17 Q. Yes? 18 A. Yes. 19 Q. All right. Did you have other African 20 American friends at Uncle Bubba's Seafood? 21 A. Yeah, I knew most of the people in the kitchen, so yes. 23 0. Did you ever have-- share meals with any 24 of the folks who worked in the kitchen? 25 A. Yes.
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A. Yes. Q. And tell me who that was and when that was. 3 A. I know Scrap. I don't remember his real 4 name. Scrap came over one time to help us move. Tony s Cole came over, April. They came for --well, 6 sometimes they came just to like have dinner. Another 7 time they came for - to help us move, like we would s pay them to do things at our house. 9 Q. Anybody other than Scrap, Tony Cole and 10 April? ii. A. Tanya was there before. Tanya, Tony Cole. 12 Delphine's been there. That's all I can remember. 13 0. Okay. With -- backing up to Hungary for a 14 second. Do you know Hungary's actual name? 15 A. I don't. 16 Q. All right. When was the last time you saw ii Hungary? 18 A. About three months ago. 19 Q. All right. And what was that at Mary 20 Mac's? 21 A. It was at his apartment. 22 Q. All right. And tell me the circumstances 23 of you going to Hungary's apartment? 24 A. He needed a ride somewhere in town. 25 Q. All right. How many other occasions have
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Q. And who would that have been? A. Like at our house or there at work? 3 Q. Well, let's talk about both. First let's 4 talk about work. Who did you have meals with from s the Uncle Bubba's folks? 6 A. I mean, we wouldn't come separately, but 7 if-- I mean, if they were eating and I was there at 8 the same time, then we would eat. 0. All right. And who would that have been? 10 A. April -- you're only speak about African ii American people? 12 Q. Yes, at this point in time. 13 A. Delphine, Hungary, Tony Cole. I'm having 14 trouble remembering names. Tanya. 15 Q. Anybody else? 16 A. Did I say Delphine? 17 Q. You did. is A. Okay. I think that's -- I think that's it. 19 Q. All right. And that would have people that 20 you just associated with while you were there at Uncle 21 Bubbas? 22 A. Correct. 23 Q. All right. Did you ever invite any of the 24 African American staff at Uncle Bubba's to your 25 residence for any purpose?
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i you spoken to or seen Hungary in the last few months? A. That's about it. 3 0. Has Hungary been to your residence here in 4 Atlanta? 5 A. in Atlanta? No. s Q. Had Hungary been to your residence in 7 Savannah? a A. Yes. 9 Q. And for what occasions? io A. He -- I know he did yard work one time at ii one of our residences in Savannah. In the second 12 residence I know that he and Lisa went to go get some 13 furniture or something from what I remember, went to go 14 pick up -- he had a pick-up truck. I think they went is to go pick it up. 16 And then he was there when I got off work. 17 Q. All right. So just looking back at this 18 list, then, Scrap has done work at your house in terms 19 of helping you all move and whatnot; is that right? 20 A. Yes. 21 Q. Tony Cole has done yard work and other work 22 at your house; is that right? 23 A. Painted, yeah. 24 Q. All right. April, what was the reason for 25 her coming over to your residence?
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A. She was with Tony Cole. They were a couple, so if he came she typically came. 3 Q. And she would give him a hand with respect 4 to -5 A. She just would hang out. 6 Q. All right. So she's not throwing in a 7 laboring oar into the water and helping him do -- do a stuff? A. No. 10 Q. Tanya, what was the reason she came to the ii residence? 12 A. I don't remember. Maybe dinner. I -- I 13 don't remember. 14 Q. Delphine, what was the reason she came to 15 the residence? 16 A. Dinner. ii Q. All right. How many occasions did Delphine 18 have dinner at your residence? 19 A. Two that I remember. 20 0. Who else was present when Deiphine was 21 there? 22 A. One occasion -- one occasion she and -- I 23 want to say -- I think she, April and Tanya all came 24 together, and I think it was just dinner. And then a 25 second occasion it was about Miss Dora.
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Q. That's -- that's what I understand. You told me that Dora was there for the purpose of taking . 3 pictures; correct? 4 A. Yeah, Dora and Delphine came one time s together. 6 Q. All right. 7 A. And then the second time Deiphine was there a she was there with Tanya and April. 9 Q. All right. Do I have this right that both io of those incidences occurred after Lisa Jackson had ii left Uncle Bubba's? 12 A. No. 13 Q. All right. The Delphine, April and Tanya 14 instance, that was after Lisa Jackson left-is A. Before. 16 Q. Before. 17 A. Yes. 18 Q. The Dora and Deiphine instance, was that 19 before or after Lisa Jackson -20 A. After. 21 Q. All right. Do you recall about when the 22 Delphine, April and Tanya meeting over at your house 23 would have been? 24 A. It was at our previous residence which was 25 on 48th Street. We moved from there 1 2 Page 36

Q. Was that after Lisa had left the employment of Uncle Bubba's that they came over? 3 A. I believe so, yes. 4 Q. All right. One of the reasons for that s dinner or for that get-together was to discuss a 6 lawsuit or the situations at Uncle Bubba's and Lady and 7 Son (sic). Fair? a A. No. 9 0. Was that discussed at that - that io get-together? ii A. No. I mean, they ate inside. I was 12 outside most of the time. Miss Dora wanted me to take 13 some pictures of some food she had cooked, so I did 14 that. 15 Q. Well, were you present while they were is eating or meeting or whatever? 17 A. I was in and out, yeah. is Q. All right. Do you recall any discussion 19 with respect to a lawsuit or a pending lawsuit? 20 A. At the time, no. No, at that -- I mean, 21 that specific day, no, it was about me taking pictures 22 for Dora. 23 Q. All right. I'm talking about with respect 24 to EDeiphine, April and Tanya. 25 A. Those are two separate incidents.
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i Q. Okay. A. -- in 2008, I believe, so -3 0. So that would have been in the 2008 time 4 frame then; is that right? s A. 1 think so, yeah. 6 Q. Has Lisa Jackson ever had a get-together at 7 your residence in Savannah for the purpose of meeting 8 with folks at Uncle Bubba's to talk about suing Uncle 9 Bubba or Lady and Son? io A. At our residence? 11 Q. Yes. 12 A. No. 13 0. Well, 1 was talking about other than your 14 residence. Anywhere else? is A. No, not that I'm aware of. 16 Q. Would -- did you all have meetings - or, 17 strike that. Did you all have dinner or get-togethers is with folks who were not African American at your 19 residence who were employees at Uncle Bubba's? 20 A. Yes. 21 0. And on how many Occasions? 22 A. A few perhaps. I mean, are you talking 23 about before, after, while she was employed? 24 0. While she -25 A. A few.
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Q. And do you recall who came over? A. I know there was a baby shower -- this -3 we weren't living together at the time. It was Lisa's 4 residence, not mine when she lived on Bay Street. 5 There was a baby shower. 6 Q. Is that the baby shower for Miss McCurry? 7 A. I think so, yeah. It was -- I had not 8 really -- I didn't know everybody that well at that 9 point. But I was there. 1 was present. 10 Q. All right. Do you recall who was present? ii A. I know Mellisa was, Sarah Copeland maybe, 12 Lindsey, Lisa and myself. That's all that I remember 13 off the top of my head. 14 Q. All right. Who else did you all have is get-togethers with who worked at Uncle Bubbas? 16 A. Lindsey, she would come over for dinner and 17 her now husband. Stephanie Strong would could over 18 before for -- her dog would play with our dog. Dinner. 19 We had -- my friend from high school, her mother worked 20 there, so she --she had been over to our house before. 21 Q. And who is that friend from high school? 22 A. Jamie McCoy, 23 Q. Her mother's name is Terry; is that right? 24 A. Terry Mooney. 25 0. Where does Terry Mooney work at this point
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Q. Tell me who you can recall talking about Bubba showing up intoxicated. 3 A. Mellisa, Sandra, Lindsey, all the managers. 4 They changed over the course of her employment, so -5 0. All right. Tell me who you can recall 6 talking about inappropriate conversations. Sexual 7 comments, 1 think you said. a A. Lindsey, Stephanie, Terry, Sandra. 9 0. And emails, porn you mentioned. ic A. The same people. Mellisa as well. ii. Q. The racial issues that you mentioned. 12 A. More Lindsey, Sandra. 13 Q. With respect to the racial issues you 14 mentioned the kitchen versus the front staff. Anything is else that was mentioned with respect to the racial 16 issues? 17 A. I mean, the N word being used frequently. 18 The despairment (sic) of treatment between the back of 19 the house and the front of the house. The comments, 20 you know, being made by Mr. Hiers. 21 Q. Such as hat? What kind of comments? 22 A. The few that I remember, there were -23 think, some of them were jokes or meant to be jokes 24 about putting the ends on the boat back to Africa, 25 referring to all the people in the kitchen.
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in time? A. I have no idea. Q. Anybody else that you recall? 4 A. Not off of the top of my head, no. 5 Q. All right. At any of those get-togethers 6 was the topic of suing Uncle Bubba's or Lady and Son 7 brought up to the best of your recollection? a A. No. 9 Q. At any of those get-togethers were the io horrid work conditions at Uncle Bubba's talked about i1 amongst any of the employees? 12 A. Yes. 13 Q. And tell me about that. 14 A. They would talk about the things that would is happen in the office, the way that Bubba would -- if he 16 showed up intoxicated. Ernails, you know, that were 17 sent, I guess porn on the computers. 18 Q. And tell me everything that you can recall 19 about that, what those folks said. 20 A. There were inappropriate conversations, I 21 guess, you know, sexual comments. 22 0. Anything else? 23 A. I know that, you know, they discussed prior 24 to -- racial issues, I guess, from the kitchen versus 25 the front of the house staff. I think that's about it.
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Q. Who made that comment? A. Mr. Hiers. 3 0. No, who related to you 4 A. Oh. s Q. -- let me - let me strike that. Did you 6 hear Mr. Hiers make that comment? 7 A. I did not. a Q. Who related to you that Mr. Hiers made that 9 comment? 10 A. I believe Tony Cole. ii Q. Okay. Anything -- any other inappropriate 12 racial comments? 13 A. Something about coons, talking about 14 racoons referring to black people. 15 Q. Who told -- did you hear Mr. Hiers make 16 that comment? 17 A. No, I was not there. is 0. Who told you that Mr. Hiers made that 19 comment? 20 A. 1 believe it was Tanya. 21 Q. Anything else? Any other comments, racial 22 in nature? 23 A. No. 24 Q. All right. On how many occasions were 25 you personally around Bubba Hiers? You said you saw
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i him once in the restaurant that you can recall; is that right? 3 A. Uh-hmm. Yes. 4 Q. Yes. How many other occasions were you 5 ever around Bubba Hiers? 6 A. He came to our house one time. 7 Q. All right. Is that-- so just two 8 occasions then; is that correct? 9 A. Yes. 10 Q. All right. ii A. That I recall. 12 Q. And when did he come to your house? 13 A. Lisa had been hospitalized. It was after 14 she came home from the hospital. I was having to take 15 care ofher. 16 Q. And did Mr. Hiers come by himself? 17 A. He did. 18 Q. Who else was present? 19 A. Myself and Lisa. 20 Q. AU right. Did anybody else show up? 21 A. No. 22 Q. And what did Mr. Hiers do or say on that 23 occasion? 24 A. He came on the pretences of taking me-25 for taking care of Lisa while she was sick because she
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Q. Right. One of the -- one of the pain relievers in that class? 3 A. Correct. 4 Q. It would have been a Schedule 2 drug? 5 A. Yeah, no doubt. G Q. And so what you're describing -- and you 7 were a nurse at the time; is that right? sA. lam. 9 Q. You were a nurse manager at that time, ic right? ii. A. Iwasa -- yes. 12 0. Okay. 13 A. A manager of the trauma program. 14 Q. Right. And what you are describing to me, 15 ma'am, is someone taking a pain medication which would 16 have been a Schedule 2 drug and unlawfully taking out 17 of that bottle a -- one of those prescription pain is medications; right? 19 A. That is. 20 Q. What did you do as a result of that? 21 A. Nothing. 22 Q. You have a duty as a nurse to make sure 23 that pain medications are not misapplied, do you not? 24 A. Not in my home. That is not my duty in my 25 own home.
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was hospitalized for about a month and said that he wanted to cook dinner. 1 had never really spoken with 3 him prior to that, so it was a little odd. 4 He showed up and told me to get Lisa well s so she could go back to work. 6 0. Anything else that he said? 7 A. He took her pain pills, shooted up a actually. 9 0. I'm sorry. Say that again? 10 A. Shoot up her pain pill. And I asked him -11 because I -- it was time for her medicine. She had -12 her stomach was open down to the fascia, it was wide 13 open, and she had a wound vac on. She was still very 14 ill, and it was time -- when he came it was time for is her medicine and she had not eaten. 16 So I got her medicine, her pain pills out 17 to give it to her, and he took the bottle from me and is took one out and started chewing it up. And I said, 19 are you in pain? And he said, yeah, this restaurant is 20 a pain in my ass. 21 I said, "Okay." 22 Q. So he took a -- what was that pain 23 medication, by the way? 24 A. I don't recall exactly what she was taking 25 at the time. It was Lortab or Lorcet.
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Q. You didn't think that you had any kind of a duty I mean, what you're describing to me the best I 3 can tell would be a felony. That is the unlawful 4 taking of a prescription pain medication as a S Schedule 2 narcotic controlled substance, true? 6 A. If you want to consider one pill a felony, 7 then okay. a Q. Well, you would certainly-- if that 9 occurred at work, somebody walked up and took a 10 Schedule 2 narcotic controlled substance out of the ii inventory of Memorial Hospital, what would you do in 12 that occasion? 13 A. I would report it. 14 0. All right. And -- and you have an is obligation to report it, right? 16 A. Yeah, while I'm at work. 17 0. But what you're telling me is that because is of this unlawful taking of a narcotic controlled 19 substance, prescription Oout of the prescription bottle 20 that because it-21 A. It was out of my hand actually. 22 0. Out of your hand? 23 A. Uh-hmm. 24 Q. - that you didn't have any duty to do 25 anything about that?
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A. Nope. Q. Didn't notify the nursing board? 3 A. No. 4 Q. Didn't notify the doctor who prescribed 5 that pain medication? 6 A. No. 7 Q. Didn't notify your employer? 8 A. No. 9 Q. All right. Anything else that he did on 10 that occasion? ii A. He came drinking. He had a cup in his 12 hand. That's about it. Said he was coming to cook, 13 but I ended up cooking, so -14 0. So he didn't cook? is A. No, I put the steaks on the grill. 16 Q. Did he bring steaks? 17 A. He did. 18 0. What else did he do? 19 A. That was it. 20 0. Was Julian de Fontaine there? 21 A. I think he did show up later actually, 22 yeah. 23 Q. Was Julian de Fontaine there when Bubba was 24 there? 25 A. The time overlapped, but he was not
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Q. And how do you recall that it was in March of '07? 3 A. 1 just recall it was March of '07. 4 Q. All right. Where did you meet her? s A. In the trauma unit at Memorial. 6 Q. And what was her purpose for being in the 7 trauma unit? a A. Her shift got hit by a car. 9 Q. Her shift, that would be Ambrose Harrison? 10 A. Correct. Ili Q. And if - if that incident with 12 Mr. Harrison took place in August of '07 would you 13 accept that it was August as opposed to March of '07 9 14 A. It was March of '07. I'm confident. 15 0. Okay. And on how many occasions? 16 A. March 25th actually. 17 Q. And how many occasions did you see Mr. -18 or strike that. On how many occasions did you see Miss 19 Jackson visiting Mr. Ambrose Harrison? 20 A. Maybe -- he was -- he was there for 21 about - in my unit for about a month. So she came a 22 couple of times a week from what I remember. 23 Q. And did she tell you why she was visiting 24 him couple times a week? 25 A. No, I mean, other than he was a co-worker.
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i there -- they did not arrive at the same time that I recall. 0. Did Julian -- was Julian de Fontaine there 4 when Mr. Hiers took this prescription medication -5 A. Nope. Lisa -6 Q. -- out of your-7 A. No, Lisa was sitting at the island, kitchen 8 island. She couldn't walk. She had a wound vac on her s shoulder. I was standing in the corner where the io prescription was in the cabinet and he walked over to 11 me. It was just the three of us. 12 Q. One thing, you've got to let me finish my 13 question. I know that sometimes I'll go slow and you 14 can anticipate what I'm going to say, but to make it 15 all make sense -16 A. Okay. 17 Q. -- at the later point in time, you've got 18 to be patient and let me finish that question. Okay? 19 A. Okay. 20 Q. What did Mr. de Fontaine do that evening? 21 A. I don't remember actually. I think he was 22 coming just to see Lisa. He had visited her in the 23 hospital. 24 Q. When did you first meet Lisa Jackson? 25 A. In March of '07.
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Q. Well, did you understand that she was visiting them because they had a romantic relationship as opposed to simpler -- a simple co-worker relationship? A. No. 0. She never told -- Miss Jack -- Lisa Jackson never told you that she had a romantic relationship with Mr. Ambrose Harrison? A. No. 0. And -- and so she was visiting him on -- a couple of times a week while he was incarcerated in the -- incarcerated - while he was -- and it's almost incarceration. A. May as well be, yeah. Q. -- while he was present in the trauma unit; is that right? A. Yeah, he was dying. Q. All right. And Mr. Harrison was ultimately transferred to a facility in Atlanta, I think? A. I have no idea. Q. She didn't tell you that he had -A. I have no idea. Q. All right. A. I know that he went to a rehab facility at Memorial --

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0. Okay. A. -- following his discharge from the main 3 hospital. 4 Q. Did Miss Jackson continue to follow him at 5 that rehab facility? 6 A. Ihave -- ntthatl -- Ihavertoidea. 7 Q. All right. And how long was it before you s all became romantically involved? 9 A. I don't have an actual date. I'm not sure. 10 Q. Okay. Within a few weeks? ii A. A few weeks? No. 12 Q. All right. Before Mr. Harrison left the 13 trauma unit. 14 A. No. is Q. Back to the two occasions that you have 16 personally been around Mr. Hiers, on either of those 17 occasions did he use any racially discriminatory 18 language? 19 A. No, not in front of me. 20 0. On either of those occasions did he say 21 anything sexually inappropriate? 22 A. Not that I recall. 23 Q. On either of those occasions was he 24 intoxicated? 25 A. I believe both of those occasions he was
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A. 1 have not. 0. What was your role with respect to 3 Mr. Ambrose Harrison's care and treatment? Was he 4 simply a patient in that unit, or were you a nurse for 5 Mr. Harrison? 6 A. Both. I mean, he was there for a long 7 time, so I had -- sometimes I functioned as his nurse, 8 sometimes I was simply working at the same time he was 9 there. io Q. Okay. Now, when you started going out 11 with -- dating, whatever the term you want to use, Miss 12 Jackson, tell me everything that she told you about her 13 employment at that time with Uncle Bubba's Seafood. 14 A. ln respect to? is Q. Well, what did she tell you about racial 16 discrimination when you all were beginning your ii relationship in, let's say, the spring of 2007? 18 A. Our relationship didn't begin in The spring
1 2 19 20 21 22 23 24 25

of 2007.
Q. All right. Well, then tell me this: When did your relationship with Miss Jackson begin on a romantic level? A. Again, I don't know an exact date, but it was not in the spring. I would say it was probably closer to the end of summer, maybe beginning of the
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i intoxicated. 2 Q. All right. And what do you have base that 3 on? 4 A. Odor, alcohol order, behavior. 5 0. All right. On either of those occasions 6 did he engage in any kind of sexually offensive conduct 7 or language? e A. Not in my presence, no. 9 Q. Did you ever go to Uncle Bubba's for dinner io with your sister? ii A, Not that I remember. 12 Q. Backing up real quickly, what were the 13 circumstances of Willie Martinez's death? 14 A. He was hit by a car. is Q. And did you -- where did you tell me that 16 occurred? In Dade City, Florida? 17 A. I'm not sure where the accident occurred. is He was living in Dade City, Florida, at the time. 19 Q. Was Ashley living with him at that point in 20 time? 21 A. No. 22 Q. You don't have any children, do you? 23 A. Ido not, no, 24 Q. All right. And you've never been married, 25 have you?

fall. 0, Okay. So later in 2007 when you and Miss 3 Jackson began a relationship -- and I'm not trying to 4 try you down on any particular date, I'm just trying to s get a general time frame. Do you understand that? 6 A. Uh-hmm. 7 Q. That's a yes? B A. Yes. 9 0. What did she tell you with respect to the io issue of racial discrimination occurring in Uncle ii. Bubba's? 12 A. I don't recall any particular conversation 13 at that time -14 Q. All right. I didn't mean to interrupt you. is I'm sorry. Were you finished of? 3.5 A. -- frame, time frame. I don't recall any. 17 Q. All right. When you all started your 18 relationship -- and is that a fair characterization? 19 I'm not trying to be tricky or offensive or anything. 20 1 just want to make sure I capture that correctly. Is 21 that a fair characterization of your -22 A. You can call it whatever you like. 23 Q. All right. Well, I'm trying to be fair 24 with, Is that a fair characterization? 25 MR. WOOLF: Let's -- can I object? Confusing
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i question. MR. WITHERS: All right. 3 Q. (By Mr. Withers) Is romantic relationship a 4 fair characterization of your relationship with Miss 5 Jackson? 6 A. We have a relationship. i Q. All right. All right, When you began your a relationship with Miss Jackson then, I want you to describe for me what she told you with respect to io racial discrimination in the workplace. 11 A. We didn't have those conversations. 12 Q. All right. When -- during the initial 13 periods of your relationship with Miss Jackson was she 14 describing to you any violence in the workplace at 15 Uncle Bubba's? 16 A. I remember conversations of it being 17 hostile but... 18 Q. And what did she tell you about that? 19 A. Mainly Mr. Hiers being intoxicated at work. 20 Q. Anything else? 21 A. She was fearful of him finding out about 22 our relationship. 23 Q. Why is that? 24 A. I'm not sure. 25 Q. Anything else that she said about that?
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0. All right. A. That she asked numerous times to leave 3 and, 1 mean, 1 was present for a lot of those 4 conversations to both Karl Schumacher as well as Jim s Gerard based on Bubbas behavior. She would have 6 rather worked either at the corporate office or Lady 7 and Sons, but it wasn't an option. They frequently referred to the Lady and a 9 Sons as 'the boys club," clearly she would not fit in. io No -- 1 mean, there were conversations 11 about her-- no black people being -- I guess she hired 12 or somebody hired an African American hostess, and 13 Bubba requested that they be tired, which there were no 14 African American front of house staff except for is bussers, but 1 guess that's technically back of house 16 staff. 17 Frequent conversations about --just 18 inappropriate comments made by Mr. Hiers, the same ig thing over and over, porn over the email, multiple 20 discriminatory remarks regarding sex, sexual 21 orientation, race, gender. 22 Q. Anything else? 23 A. Nope. That about sums it up. 24 Q. Okay. Do you recall when her conversation 25 with Mr. Schumacher would have taken place regarding
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A. I mean, if we we're only talking about those beginning months, that's all I had recall. 3 Q. All right. And at some point in time did 4 she begin to tell you, talk to you about her workplace s conditions, the conditions in her workplace with 6 respect to sexual and racial discrimination? 7 A. Yes. 8 Q. When would that have been? 9 A. 1 don't have an exact date or necessarily a 10 time frame. It just progressed overtime. 11 Q. Well, as you sit here today I want you to 12 describe for me what she told you. 13 A. Regarding.... 14 0. Let me be more specific. is A. Please. 16 0. What did Miss Jackson tell you about sexual 17 discrimination in the workplace at Uncle Bubba's is Seafood? 19 A. That Mr. Karl -- I don't remember his last 20 name. There was a large pay discrimination apparently 21 between her and Dustin Walls per Karl Shoe-- oh, 22 Schumacher. 23 0. Yes. 24 A. Apparently I guess he shared that 25 information with her.
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i. the discrimination in pay between her and Dustin Walls? A. It was a constant communication with her 3 and Karl about fair pay. I mean, I can remember it 4 being as early as maybe fall of 2007, and it went s through the end of her employment. 6 Q. And that would have been -- what you've 7 described as "it' went through the end of her a employment would have been the difference in pay 9 between her and Dustin Walls and her complaints about ic that? 11 A. Correct, and her benefits, the discrepancy 12 in benefits, promises that he had made that he didn't 13 follow through with, bonuses, base salary, 401k, things 14 of that nature. is Q. And that would have been Mr. Schumacher was 16 telling her of those discrepancies. Do I have that 17 right? le A. Correct. 19 Q. All right. And -- and you had said that 20 promises of benefits. Who making those promises, 21 Mr. Hiers or Mr. Schumacher? 22 A. Mr. Schumacher. 23 Q. All right. You mentioned Lisa Jackson 24 asking to leave and that that conversation would have 25 occurred both with Karl Schumacher and Mr. Gerard,
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i correct? 2 A. Correct. 3 0. That would have been much later in her 4 tenure through the 2010 time frame. Does that seem s right? 6 A. I know that the discussions started in 7 probably late 2008 when things had gotten -- I think B it -- from what I remember it -- things got worse after 9 he found out about her relationship, so I'm not sure, 10 it was after some cruise. I believe his ex-wife told 11 him. So whenever that was, 12 Q. So -- you threw a lot of things into that 13 answer. You said that - you said that things got 14 worse. You mean things got worse at the workplace for is Lisa Jackson. 16 A. Correct. 17 Q. And that was after Mr. Hiers found out 18 about your relationship with Lisa Jackson? 19 A. Correct. 20 Q. And that would have been after some cruise? 21 A. The Paula Deen cruise. I don't know what 22 year it was or what month it was. 23 Q. Right. 24 A. 1 know that that's whenever he found out. 25 Q. And how do you know that's when he found
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after Mr. Hiers found out about your romantic involvement with Miss Jackson, then things got worse 3 for Lisa Jackson at Uncle Bubba's. Is that accurate? 4 A. That's what she says, yes. s Q. All right. And you mentioned that she had 6 asked Mr. Gerard to leave as well. 7 A. Yes. a Q. And tell me -- you said that you were s present for some of those conversations. io A. I was only on one of-- obviously one side ii of it because they were all via the phone. 12 Q. Okay. And that was going to be my 13 question, then. So you're listening to a phone 14 conversation between Lisa Jackson and Jim Gerard to the 15 best of your recollection? 16 A. He was on speaker. So, I mean -17 Q. And she's communicating at home on a cell 18 phone? 19 A. Or in the car, 20 Q. All right. 21 A. Yeah. 22 Q. On how many occasions do you recall 23 Mr. Gerard being on the phone with Lisa Jackson talking 24 about her opportunities to move to the main office I 25 think you said.
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i out? A. Two ways. Brandon Branch called Lisa and 3 told her as soon as I think they docked that Bubba 4 knew. And then Bubba pulled her out on the dock is my s understanding of the story and they had a discussion 6 about it once he got back. 7 0. Pulled her out on the dock at Uncle 8 Bubba's? 9 A. Correct. io Q. And what did he say to Lisa Jackson when he ii got back from that cruise out on the dock? 12 A. Her lifestyle was not welcome there. 13 Q. I'm sorry. Say that another again? 14 A. Her lifestyle was not welcome there. is Q. And did he specify what he meant by her 16 Lifestyle? 17 A. I'm not sure. I think there was a is discussion - my memory of it is that there was a 19 discussion about his ex-wife Leaving him for another 20 women perhaps. I'm not-- I wasn't there, so that's 21 what I remember of it. 22 Q. Okay. Anything else that you can recall 23 about that discussion relayed to you by Lisa Jackson? 24 A. No. 25 0. You mentioned that-- or strike that. So
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i A. I can't really quantify. Q. Well, did it happen once or did it 3 happen -4 A. No. 5 Q. -- five times? 6 A. More than once. More that five times. 7 Q. Okay. So did it happen as many as 15 B times? 9 A. Perhaps. 10 Q. More than five and you're not able to put a ii number on it? 12 A. No. 13 Q. What I said it accurate; is that right? 14 MR. WOOLF: Objection. is Q. (By Mr. Withers) More than five times that is Lisa Jackson spoke to Jim Gerard but you're not able 17 to-18 A. Too numerable for me to count. 19 Q. You've got to let me finish. I'm sorry. 20 A. Okay. 21 Q. More than five times that Lisa Jackson 22 spoke with Jim Gerard complaining that she wanted to 23 move to the main office. Is that accurate? 24 THE WITNESS: Objection. Characterizing the 25 testimony.
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Q. (By Mr. Withers) Go ahead, Too numerable for me to count and to remember. MR. WITHERS: Are you doing okay on time? 3 THE VIDEOGRAPHER: Yes. 4 MR, WITHERS: All right. 5 6 Q. (By Mr. Withers) You mentioned that she 7 wasn't able to go to the Lady and Son because it was 8 the boys club. Was that something that she related to you or who -- how -- how did you hear that term? 10 A. I believe Karl. ii Q. All right. 12 A. in the conversation they had. 13 Q. That's what Karl had told her? 14 A. Yeah. 15 Q. As related to you by Lisa Jackson. 16 A. From what I recall, yes. 17 Q. Were you ever on the phone or on 18 speakerphone when Lisa Jackson was speaking to Karl 3.9 Schumacher? 20 A. Yes. 21 Q. On how many occasions? 22 A. Five to ten maybe. 23 Q. All right. And tell me what you recall 24 with respect to those phone conversations. 25 A. Most of the time it was about Bubba's
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A. Yes. There was an emergent call. Q. That's not my question. 3 A. Okay. 4 0. You knew that your deposition had been s scheduled for that Friday, February 15; correct? 6 A. Yes. 7 0. And Mr. Woolf had told you, had he not, 8 that we were to take your deposition here in Atlanta; 9 correct? '0 A. Yes. ii 0. And -- and just so there's no mistake, 12 there wasn't some misunderstanding about whether you 13 were supposed to be here or not, you just had a work 14 emergency. Do I have that right? 15 A. Correct. 16 Q. All right. And tell me what that work 17 emergency was. 18 A. We had six brain dead donors in Atlanta. 19 Q. All right. And tell me how that manifests 20 itself into an emergency with respect to your duties. 21 A. I was fourth call, so I typically would not 22 go out on a Friday. But due to the high volume and 23 there has to be something there to medically manage the 24 donor, so -25 Q. And where did you go?
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behavior and Karl saying that he would take care of it 1 A. Kennestone Hospital. with Paula or to call Jim Gerard if there was problem 2 Q. And-3 A. Marietta, 3 more than he can handle or that he would take care of 4 Q. --who was the doctor in charge of that 4 it. s Q. Okay. Anything else that you recall s donor? 6 Mr. Schumacher saying? 6 A. I am in charge of that donor. A. Nope. 7 Q. All right. There's not a physician in a 0. All right. When Mr. Gerard was on the 8 charge? 9 phone what do you recall Mr. Gerard saying? 9 A. No. 10 A. The few times that I recall it was that 10 Q. And what was that donor's name, do you 11 Bubba didn't need to be in the business, that he was 11 recall? a liability for the business, that Paula knew that and 12 12 A. I don't recall. 13 Paula needed to pay him out and he needed to get out of 13 Q. Your office would have those documents? 14 the business. 14 A. Yeah. 15 Q. Anything else that you can recall is Q. Do you have a supervisor at your office? 16 Mr. Gerard saying? 16 A. Multiple. 17 A. No. 17 Q. Who would be your supervisor over your call 18 Q. By the way, what is the reason that you did 18 Friday, February 15th? 19 not appear on Friday, February 15th for your originally 19 A. The one that I called about that case was 20 scheduled deposition? 20 Allison Reese. 21 A. I take call and 1 was not -- there was an 21 Q. Excuse me. How do you spell Allison's last 22 emergent case. I do organ donors now. 22 name? 23 Q. Okay. So you knew that your deposition had 1 23 A. R F E S E. 24 been scheduled for that Friday, February 15th then; 24 Q. And how long did that call take you? 25 correct? 25 A. I usually work 30 hours straight, so I was
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1 those two and a half years, tell me -- tell me the i finished -- I got home Saturday around noon or 2 nature of those get-togethers that you're having with 1:00 P.M. 2 3 Lindsey, Mellisa, Sandra, and Stephanie that they start 3 0. And started when, at what time? 4 divulging these things to you. 4 A. Friday 10:00 am.? MR. WOOLF: Objection to extent it's been s 5 Q. You mentioned in terms of things that Lisa asked and answered. 6 6 Jackson had informed you about, the African American But you can go ahead. 7 7 hostess who had been hired. And did that come to you MR. WITHERS: They were just talking and I 8 a just through Miss Jackson? was present, so -9 9 A. No. 10 Q. (By Mr. Withers) Anything that you can give io 0. Who told you that? 11 me in terms of a circumstance beyond that? ii A. Miss Jackson did, but I mean, the other 12 A. Nope. 12 people they had talked about it, the other managers. 13 Q. I didn't think so. 13 Q. And who is that? 14 In 2007 -14 A. Mellisa, Sandra, people in the office, MR. WOOLF: And I'm going to object to that 15 15 Lindsey. 16 comment by counsel. 16 Q. When did you talk to Mellisa McCurry about 17 Q. (By Mr. Withers) In 2007 when you began 17 that? is dating Miss Jackson did she tell you that she had been 18 A. I don't have an exact date. 19 subjected to sexual harassment nearly every single day 19 Q. When did you talk to Mellisa McCurry about 20 the issue of Bubba being intoxicated at the workplace? 20 she came to work over the prior two and a half years? MR. WOOLF: Objection. Answered. 21 21 A. They were never direct. I mean, it was You may go ahead. 22 22 casual conversation, so I don't have a -THE WITNESS: It was discussed inappropriate 23 23 Q. When did you talk to Mellisa about improper 24 comments made by Mr. Hiers, 24 sexual comments by Mr. Hiers? 25 Q. (By Mr. Withers) That's not my question. 25 A. Again, it was casual conversation. Page 66 1 Page 68

i I'm -- my question was: Did he tell you that she was Q. When did you talk to Mellisa about subjected to racial harassment -- excuse me -- sexual 2 inappropriate racial comments made by Mr. Hiers? 2 harassment nearly every single day that she came to 3 3 A. Again, the same answer. work for the previous two and a half years? 4 4 Q. All right. And so you've named the s A. No. s managers as follows: Mellisa, Sandra, Lindsey and 0. All right. Did she tell you that she was 6 Stephanie -subjected to racial harassing harassment nearly every 7 7 A. Lindsey wasn't a manager. I'm sorry to a single day she came to work over the prior two and a a interrupt. Lindsey was not a manager. half years? 9 Q. Lindsey was an office manager. Does that io A. Not that I recall. 10 seem right? ii Q. Did you ever ask her, by the way, how it is ii A. I guess. 12 that she is able to manifest a claim for racial 12 Q. All right. 13 harassment in this case? 13 A. I wasn't sure that washer title. MR. WOOLF: I'm going to object to that, 14 14 Q. All right. So if you would, do me the 15 favor, though, of letting me finish my question before is calls for a legal conclusion and it's 16 argumentative with the witness. 16 an interruption, please. 17 0. (By Mr. Withers) You can go ahead and You've named Mellisa, Sandra, Lindsey, 17 18 Stephanie as people who have spoken to you about is answer. 19 A. No. 19 inappropriate sexual and racial comments made by 20 Q. Okay. Did - did you get to know Lisa 20 Mr. Hiers. True? 21 Jackson's birth parents? 21 A. True. 22 A. I knew them. 22 Q. And so tell me how that comes up. If 23 Q. Did you see-23 you're never there at Uncle Bubba's when Bubba is there 24 A. Not parents. Mother. 24 except on one occasion and that you're therefor 25 Q. Mother. Did you ever meet her father? 25 approximately 20 occasions over those five -- no, over

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A. No. Q. Did you ever see a photograph of her 3 father? 4 A. Yes. 5 Q. And on how many occasions? 6 A. We have numerous photos of him. 7 Q. Okay. All right. And describe those 8 photographs for me, if you would, please, ma'am. A. In what respect? 10 Q. I mean, give me a description. If you were ii describing him to the police, you know, how would you 12 describe him? 13 A. Dark skinned male, dark hair, dark eyes. 14 Q. Oka y . Anything else? is A. No. 16 Q. I'm sorry? 17 A. No. 18 Q. All right. Did Lisa Jackson tell you in 19 2007 that Bubba Hiers was showing her pornography in 20 his office? 21 A, Yes. 22 Q. And what did she tell you about that? 23 A. It wasn't that he -- She walked in was my 24 understanding while he was looking at it. It was under 25 the circumstances that she had to get the computers
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Q. Did she ever tell you, that is Lisa Jackson, did Lisa Jackson ever tell you that -- that 3 Bubba Hiers was asking her to come in and watch 4 pornography with him? s A. Not that I recall, 6 Q. All right. 7 A. May I have a rest room break? 8 Q. Absolutely. s A. I'm sorry. 10 THE VIDEOGRAPHER: We can go off video. 11 11:24 am, off video record. 12 (Recess.) 13 THE VIDEOGRAPHER: 11:39 am. back on video 14 record. 15 MR. WOOLF: Thank you. 15 Q. (By Mr. Withers) Ma'am, when we left off we 17 were talking about some of the things that had been 18 relayed to you or related to you by Miss Jackson 19 regarding Uncle Bubba's Seafood and Bubba Hiers 20 himself. I want to kind of pick back up on that. And I'd ask you about the African American 23. 22 hostess that had been fired and you had told me that 23 you had heard that from Miss Jackson and others. Is 24 that right? 25 A. Yes.
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cleaned oft because there were viruses from the pornography that he was watching. 3 Q. And what do you recall she walked in on to 4 the best of your recollection? s A. The subject matter was not discussed. 6 Q. Just that it was pornography? 7 A. Correct, e Q. And what did she do when she walked in? A. I have no idea. 10 Q. Did she walk out? ii A. 1 have no idea. 3.2 Q. Did she sit down and say, goodness 13 gracious, what's this? 14 A. I have no idea. 15 0. On how many occasions did she walk in on 16 Mr. Hiers when pornography was up on the computer 17 screen? 18 A. I'm not sure of an exact number. 1 Q. Do you know whether it happened more than 20 once? 21 A. It did. 22 Q. You don't know whether it happened five, 15 23 or 50 times, you're not able to put a number on that. 24 Is that accurate? 25 A. That is accurate.
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i. Q. And you don't remember specifically who the 2 others were, although you talked about that being 3 related - relayed to you by managers. 4 MR. WOOLF: Objection. Asked and answered. 5 Q. (By Mr. Withers) Do I have that right? 6 A. Yes. 7 Q. All right. Inappropriate racial comments 8 made by Mr. Hiers, with respect to what Miss Jackson 9 said about that tell me what you recall about that 10 specifically. ii A. The different jokes that we've already 12 discussed? Is that what you're asking me? 13 0. Well, that's -- that's my question. Is 14 that what she told you about inappropriate racial is comments was different jokes. 16 A. Discussions they had in the office. 11 Q. And "they" being whom? 18 A. Her and Mr. Hiers. 19 0. And those discussions being what? 20 A. Him using -- referring to them as the N 21 word. 22 Q. All right. Anything else that you recall 23 with respect to inappropriate racial comments by 24 Mr. Hiers? 25 A. No. No.

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Q. All right. And now, you talked about porn as well and you mentioned something about an email. 3 What did Miss Jackson tell you about that? 4 A. The email was something -- it was printed off. My understanding is it came from his cousin or a 6 family member. It was - I don't recall the time i frame, but why gay marriage should be legalized, and it B was -- apparently he printed it out and brought it to a 9 managers meeting, and it was women having sex with io women apparently. ii Q. All right. And anything else that you 12 recall about porn in the workplace as related to you by 13 or relayed to you by Miss Jackson? MR. WOOLF: I object to the extent it's been 14 is asked and answered. MR. WITHERS: Multiple emails that, you know, 16 17 he would share apparently with her in addition to 18 the live video streaming, I guess. 19 Q. (By Mr. Withers) All right. And we've about 20 the watching porn -21 A. Correct. 22 Q. -- issues? 23 A. Yeah. 24 Q. And you just mentioned live video 25 streaming. Is that what-1 Page 74

Q. All right. And you remarked about comments about sexual orientation and gender. Tell me what you 3 recall Mr. Hiers saying about that. 4 A. He referred to dykes and faggots frequently s apparently. 6 Q. That's -- that's what she related to you? 7 A. Yes. 8 Q. That Mr. Hiers said. 9 A. Yes. 'a Q. Anything else in that respect? ii A. Conversations apparently about his ex-wife. 12 Jill, I guess, is her name. 13 0. And tell me about those conversations with 14 his ex-wife. is A. That she left him for another woman. 16 Q. All right. How many occasions did 17 Mr. Hiers as relayed to you by Miss Jackson make 18 inappropriate comments about sexual orientation or 19 gender? 20 A. I can't place a number on that. I'm not 21 sure. 22 Q. All right. Well, would it have been in the 23 range of five or fifty, or do you recall? And if you 24 don't recall, that's fair. 25 A. I don't recall.
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A. Yeah, the -Q. We're talking about the same thing there. 3 A. And then emails -4 0. All right. And what other emails do you s recall Mr. Hiers receiving that he told Miss Jackson 6 about? 7 A. I mean, she would come home and discuss -8 I mean, having said that his -- 1 think it was his 9 cousin or -- I'm not sure of the person's name that 10 set -- and I don't recall all the subject matter. ii. Q. All right. So as you sit here today you 12 don't recall any specific instance with respect to 13 email except for that one about why gay marriage should 14 be illegal (sic): is that right? is A. There were other racial ones but I don't 3.6 recall the exact title or the exact content, but -- I 17 mean, that she came home and discussed. 18 Q. And on how many occasions did they occur 19 when she discussed with you racial emails that he had 20 shared with her? 21. A. Maybe three. 22 Q. And on how many occasions do you recall 23 sexual emails that he had received that he had shared 24 with her? 25 A. Too numerable to count.
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Q. All right. Now, are you personally offended by the use and display of pornography? 3 A. Yeah. 4 Q. Do you ever watch pornography? s A. No. 6 Q. And I'm not trying to be offensive to you, 7 but it's part of what the allegations are in this case. 8 And what about Miss Jackson? Has Miss Jackson ever to s your knowledge watched pornography? io A. No. ii Q. All right. Do you have a cable provider 12 here in Atlanta at your address in Atlanta? 13 A. We do. 14 Q. And who is that? 15 A. U-verse, AT&T U-verse. 16 Q. And when you lived in Savannah who was your 17 cable provider in Savannah? is A. I think your only option there -- I think 19 it's Conicast I think was our only option, I believe. 20 Q. Was that-- tell me the different locations 21 you and Miss Jackson lived at in Savannah. 22 A. She first resided at Bay Street -- well, 23 first she lived in The Landings and then she lived on 24 Bay Street. I lived at -- I forget the number. It was 25 on 48th Street. And then we moved together-- I rented
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out my house. I owned that home and we rented a house on 49th Street and then we renovated the 48th Street 3 house, moved back to it, and then bought our house on 4 Southbridge. s Q. All right. So her residences would have 6 gone from Bay Street first then to 48th Street, 49th Street and Southbridge. Do 1 have that accurate? e A. Bay Street, 49th -9 Q. Okay? io A. - 48th, Southbridge. ii. 0. All right. Fair enough. Thank you. And with respect to your cable providers at 12 13 those various locations, they would have been - it 14 would have been Corncast? is A. Yes, as far as I remember, yes. 16 Q. And where do you all live here in Atlanta? 17 A. Are you asking for my physical address? is Q. Yes, ma'am. 19 A. 2896 McCaw Street, Northwest. 20 0. All right. And do I have it right that you 21 and Miss Jackson reside together at that address? 22 A. That's correct. 23 0. When did Uncle Bubba's give your sister a 24 job? s A. I'm not sure.
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i A. Go ahead. Q. Not some coincidence that she ended up 3 getting a job at Uncle Bubba's. That position came 4 through Miss Jackson through you: right? s A. She knew that they were hiring. 6 Q. And she knew that either from you or Miss 7 Jackson; correct? 8 A. I'm sure, yes. 9 Q. All right. And at that point in time Miss 10 Jackson had been working at Uncle Bubba's for a period 11 of two and a half years or more; right? 12 A. I'm not aware of her start date, but -13 Q. Well, if it was in mid 2005 you would 14 accept that? 15 A. Yes. 16 Q. All right. And you had been seeing Miss 17 Jackson for several months by October of 2007? 18 MR. WOOLF: Objection. Asked and answered. 19 Q. (By Mr. Withers) You can go ahead. MR. WOOLF: You're trying to trick the 20 21 witness. THE WITNESS: No, I'm not saying -23 don't - again, I don't have a specific date 24 as25 0. (By Mr. Withers) By the way, your mother did
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Q. Do you -- if the records reflect that it was in October of 2007, would that seem to be right or 3 would you have a quarrel with that? 4 A. I don't have a quarrel with that. s 0. All right. At -- at the point in time that 6 Ashley -- and that's your sister, Ashley Martinez, 7 correct? 8 A. At the time I think that's what she went 9 by. 10 Q. All right. At that point in time in ii October of 2007 you and Miss Jackson were in a 12 relationship together; right? 13 A. Yes. 14 Q. And the reason that Ashley got a job at is Uncle Bubba's Seafood was through you through Miss 16 Jackson. ls that fair to say? 17 A. I don't believe Lisa interviewed her, no. 18 Q. Well, who -- 1 mean, you and Lisa Jackson 19 had something to do with Ashley Martinez getting a job 20 at Uncle Bubba's. It's not just some great-21 A. She knew that they were hiring. 22 Q. -- coincidence. You've got to let me 23 finish my questions. 24 A. I'm sorry. 25 Q. Please, ma'am.
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some -- some work for Lisa Jackson on behalf of either Uncle Bubba's or Paula Deen Enterprises at a period of 3 time, did she not? 4 A. She did not. s Q. Your mother never worked either at the 6 Paula Deen Enterprises home offices there in Thunder 7 Bolt? 8 A. No. 9 Q. All right. Back to your sister, did -- of io course -- or strike that. ii. You were comfortable having your sister go 12 to work at Uncle Bubba's, were you not? That's fair to
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S3Y.

A. My sister and I were not that close. I is didn't have an impact on where she worked. 16 0. Are you the older sister or younger sister? 17 A. The youngest. 18 Q. All right. You certainly wouldn't put your 19 sister at risk to either racial abuse or sexual abuse, 20 would you? 21 A. Again, I don't really have that kind of 22 relationship with my sister. 23 0. Well, you wouldn't put anybody at risk for 24 abusive racial harassment, would you? You're not that 25 kind of person, are you?

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MR. WOOLF: Objection. THE WITNESS: I'm not sure what you're 3 asking. MR. WOOLF: Argumentative. 4 5 Q. (By Mr. Withers) Simple question. If you 6 knew that a place was a workplace where abusive racial 7 harassment occurred on a daily basis, you're not to B kind of person that would allow a friend to go work at s that place, are you? MR. WOOLF: Objection. Its hypothetical. 10 MR. WITHERS: Again, I'm not understanding ii iz your direct question. 13 Q. (By Mr. Withers) 1 can't make it any more 14 simple. If you knew that sexual harassment was 15 occurring on a near daily basis somewhere would you 16 have your sister go to work at that place? You 17 wouldn't, would you? MR. WOOLF: Objection. It assumes she has 18 19 some control over where her sister goes to work. THE WITNESS: I don't. I've stated I -- my 20 21 sister and I did not have that relationship. We 22 did not discuss what kind job she had, where it 23 was. The relationship did not exist. 24 0. (By Mr. Withers) You knew that she went to 25 work at Uncle Bubbas, didn't you?
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Q. And you know that part of this lawsuit is that that allegation is that sexual harassment occurred 3 on a near daily basis. You know that, do you know? 4 A. Ido. s Q. You know that this lawsuit says that racial 6 harassment occurred on a near daily basis. You know 7 that, do you know? 8 A. Ido. 9 Q. Now, knowing those facts when your sister 10 went to work in October of 2007 did you say, goodness 11 gracious, Ashley, you know what? Racial harassment is 12 occurring at that place on a near daily basis. Did you 13 say that to your sister Ashley? 14 A. No, I think we discussed earlier that at 3.5 that point in our relationship not much of the 16 environment that Lisa worked in had been discussed ii between us. So it was not a topic of conversation. 18 0. Did you discuss with your sister before the 19 - she went to work at Uncle Bubbas that racial 20 harassment was occurring on a near daily basis? 21 A. I was not aware of that at that point. 22 Q. All right. Did you discuss with your 23 sister when she went to work at Uncle Bubba's that 24 sexual harassment was occurring there on a near daily 25 basis?
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1 A. Again, I was not aware at that point. A. Oh, 1 knew that she worked there, yes. 2 0. And you certainly -- and let's get back to Q. All right. Now, knowing that you wouldn't 3 have your sister go work at some place where there is 3 this earlier point. If you had known that you 4 sexual harassment on a near daily basis. You wouldn't 4 certainly would not have put your sister into the s position of going to that place where no reasonable 5 expose your sister or anyone else to that? 6 person could be expected to work under those 6 A. I'm asking-7 MR. WOOLF: The same objection. 7 conditions. You wouldn't do that to your sister, would 8 THE WITNESS: No, that's not true. 8 you? MR. WOOLF: Objection. It assumes the 9 9 Q. (By Mr. Withers) It's not true that you io wouldn't expose your sister to that. So if you knew - io witness has some control over where her ii for instance, the allegation in this case, ma'am -- and 11 witness -- where her sister works. 12 THE WITNESS: If I could -- if I knew about 12 I want you to assume that -- is that no reasonable 13 it and 1 could tell her, I would advise her 13 person could be expected to work under those conditions 14 against it. 14 of sexual and racial harassment. Okay? You've read this lawsuit, true? is Q. (By Mr. Withers) All right. Let me ask you is 16 this then, and this gets back to one of my earlier 16 A. Uh-huh. 17 Q. You need to said yes or no. 17 questions that you were having difficulty 18 A. True. It was swallowing. True. 18 understanding. You know the difference between -19 0. All right. And so that you know that 19 MR. WOOLF: I'm going to object to that. 20 your -- that Lisa Jackson has made the allegation that 20 You're harassing the witness. 21 racial and sexual harassment were so intolerable that 21 MR. WITHERS: I'm not harassing the witness. 22 no reasonable person could be expected to work under 22 THE WITNESS: This is comical. 23 those conditions. You know that that's part of this 23 0. (By Mr. Withers) You know the difference 24 between right and wrong, don't you? 24 lawsuit; correct? s A. Ido. 25 A. It's all debatable.

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MR. WOOLF: Objection. It has been asked and i MR. WOOLF: Objection. 2 answered. Q. (By Mr. Withers) Oh, it is? 3 Q. (By Mr. Withers) Go ahead. 3 A. Oh, it is. 4 A. Over the course of the last, I mean, five 4 Q. Okay. Well, would it be the wrong thing to 5 years. s let anybody go to work at a place where the condition 6 Q. All right. And so my question, ma'am, is 6 was such that no reasonable person could be expected to 7 if you didn't know it in October of 2007 when did you 7 work at that condition? 8 come to know it? MR. WOOLF: Objection. It assumes that she 8 MR. WOOLF: Objection. Asked and answered. 9 9 has some authority to control whoever is going to THE WITNESS: It was an accumulation of 3.0 10 work at that place. 11 knowledge. It wasn't anything that was --the ii Q. (By Mr. Withers) Simple question. 12 light got turned on one day. 12 A. Not necessarily. 13 0. (By Mr. Withers) By October of 2007 you had 13 Q. What do you mean not necessarily? 14 known Lisa Jackson since March 25 of 2007; correct? 14 A. You asked if it would be the wrong thing. is A. We had been acquainted by March 25th. is Not necessarily. I don't think its a black and white 16 Q. Exactly. That was the date of the Ambrose 16 answer. ii Harrison incident. That was the date that you first 17 0. Okay. So if-- if racial harassment is 18 met Lisa Jackson, correct? is occurring at a place on a daily basis you'd be okay is recommending somebody to go work at that place? 19 A. I actually met her on the 26th. 20 0. Okay. She was there the next day after his 20 A. I didn't say that. 21 accident; correct? 21 Q. Well, you said it wouldn't necessarily be 22 A. Correct. 22 the wrong thing. It means that maybe it's not necessarily a bad thing to have somebody go to work 23 Q. So by October of 2007 you had known Lisa 23 24 Jackson at least since March 26th of 2007; correct? 24 under those conditions. A. That's correct. I knew her. MR. WOOLF: Objection to what it means or 25 25 i
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what it doesn't mean. THE WITNESS: I mean, you're assigning 3 personal actions here. I didn't say anything 4 about my personal actions. 5 Q. (By Mr. Withers) No. s A. I just said it not -- not necessarily is 7 wrong for whomever. It's not my place to judge. 8 Q. And I'm not asking about anybody but Priscilla Sumerlin. This is all about what Priscilla lo Sumerlin knows and did, right? ii MR. WOOLF: Objection to the question on the 12 table. 13 Q. (By Mr. Withers) I'm not asking you for 14 anything but your personal knowledge and what you would 15 do under the circumstances. 16 MR. WOOLF: Objection. Is there a question 17 on the table? 18 Q. (By Mr. Withers) Do you understand that? is A. I understand. My personal knowledge was 20 limited at the time. 21 0. All right. And when did your personal 22 knowledge become manifest such that you have described 23 it to us here this morning? When did you learn those 24 things? If not by October of 2007 when did you learn 25 those things?
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i Q. And just so the record is clear, by October 2 of 2007 you weren't aware of sexual harassment in the 3 workplace, were you? 4 MR. WOOLF: Objection. Asked and answered. THE WITNESS: I don't know how long -- again, 5 I told you I don't know how long -- when our 7 relationship began. So for a large period of a that time it was strictly a family member 9 employee work relationship. 3.0 So, no, none of those things would be ii discussed. 12 0. (By Mr. Withers) Did you go to the 13 bachelorette part, I think you mentioned about earlier, 14 with respect to this young lady here, Mellisa McCurry? 3.5 A. Bachelorette? j.6 Q. Was it -- were you at a party where Mellisa 17 McCurry-is A. It was a baby shower. 19 Q. Baby shower. I'm sorry. It's been 20 described to others as a bachelorette party. And you 21 remember Lindsey being there? 22 A. Ido. 23 Q. All right. I think you mentioned Sarah 24 Copeland? 25 A. Yep.

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i Q. When was the last time you spoke with 2 Lindsey McCoy? 3 A. I couldn't tell you. 4 Q. What was the relationship that Lindsey 5 McCoy had with Jamie? MR. WOOLF: Objection. Jamie who? 6 7 Q. (By Mr. Withers) Jamie McCoy. e A. They were friends. 9 Q. And Jamie is the daughter of Terry Mooney? lo A. She is. ii Q. By the way, your cousins with Nick 12 Greenwood? 13 A. Nicholas, yes. 14 Q. Yeah. Talked with him about this case? 15 A. Okay. 16 Q. Yes? 17 A. Have I? 18 Q. Yes, have you talked with him about this 19 case? 20 A. No, I have not. 21 Q. has Lisa talked with him about this case? 22 A. Not that I'm aware of. 23 Q. You've never talked with Nicholas Greenwood 24 about this case? 25 MR. WOOLF: Objection. Asked and answered
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i Q. All right. You've described to us that as you got to know Lisa Jackson she would tell you more 3 and more about the difficulties at her workplace. Is 4 that a fair characterization? 5 A. Yes. 6 Q. Now, as a nurse did you become concerned 7 about the abusive nature of the workplace that Miss 8 Jackson was in at Uncle Bubba's Seafood? 9 A, I don't know that I would associate it with 10 me being a nurse. I think on a personal level I became 11 concerned. 12 Q. All right, And tell me all of the steps 13 you took to try and get your partner out of that 14 abusive environment? is MR. WOOLF: Objection, assumes facts in 16 evidence that she took some steps. 17 THE WITNESS: I didn't take any steps. 18 Q. (By Mr. Withers) Very good. 19 You know Karl Schumacher, do you not? 20 A. Ido. 21 Q. How many occasions did you meet 22 Mr. Schumacher? 23 A. I've never actually met him in person. 24 Q. Okay. You've just heard Miss Jackson 25 speaking with him on the phone, though?
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THE WITNESS: No, I have not. Q. (By Mr. Withers) All right. Now, when you 3 were at the bridal shower, whatever it was, that took 4 place on Bay Street, the East Bay Street address? MR, WOOLF: Objection to the characterization 5 6 of the event. 7 THE WITNESS: Yes. 8 Q. (By Mr. Withers) You remember it was a 9 shower of some sort. 10 A. From what I remember. ii Q. All right. Did all of those folks that 12 were present that night talk about what an 13 inappropriate boss Bubba Hiers was? 14 A. I didn't really partake in that 15 conversation. I stayed in the kitchen most of time. 16 Q. Okay. Did you ever play the dirty 17 Pictionary game that was brought to that party? is MR. WOOLF: Objection whether it was or not. 19 THE WITNESS: There was no dirty Pictionary 20 at that party. 21 Q. (By Mr. Withers) All right. You didn't 22 bring a dirty Pictionary game? 23 A. Negative. No. 24 Q. Have you ever played dirty Pictionary? 25 A. I can't say that I have.
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i A. He has a relationship with my parents. Q. Karl Schumacher does. 3 A. He does. 4 Q. All right. And tell me about that if you 5 would, please. 6 A. I can't really qualify. It's not my 7 relationship other than I know it's been longstanding. s 0. And which of your parents does 9 Mr. Schumacher know or have a relationship with? 10 A. Both of my parents. ii Q. And is it professional or social? 12 A. Both. 13 0. And has he been to your house? 14 A. I'm not sure. 15 Q. Nicholas Greenwood has been to your house, 16 right? 17 A. Here? 18 Q. In Savannah? 19 A. No. 20 0. Or Richmond Hill rather. 21 A. I didn't have a house in Richmond Hill. 22 Q. Your parents' house. 23 A. My parents' house. I have not lived with 24 my parents since I have 17, so-25 0. All right. To your knowledge has Nick
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Greenwood ever been to your parents house in Richmond Hill, Georgia? A. I'm sure that he has at some point. 4 Q. To your name has Nick Greenwood ever been 5 to your parents' farm in -- Where did you tell rrie it 6 was? i A. Sylvania. 8 Q. Sylvania, Georgia. s A. Yes, he has. 10 Q. And on how many occasions? ii A. Maybe ten. 12 Q. You all have gotten together on different 13 occasions at that farm in Sylvania for family 14 occasions; is that right? is A. He's been present, I think, twice at the 16 time that lwas. 17 Q. Back to Mr. Schumacher. Mr. Schumacher has 18 been to your parents' residence? 19 A. I told you, I don't know. MR. WOOLF: Objection asked and answered. 20 21 0. (By Mr. Withers) You're not aware? 22 A. I don't know. 23 0. I couldn't hear you because counsel here -24 by the way, does Mr. Woolf represent you? 25 A. He does not.
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A. Not that I'm aware of. Q. Did Lisa Jackson ever meet with Mr. Woolf inJuneof2010? A. Not that I'm aware of. Q. How long did Uncle Bubba's pay for your cellular phone service? MR. WOOLF: Objection. It assumes facts in evidence assumes that she did get it paid for. MR. WITHERS: My personal cell phone? Q. (By Mr. Withers) Yes. A. I'm not aware that they did. Q. Did you pay for your personal cell phone plan in --when you were living in Savannah? A. It came out of our checking account. Q. Did you ever draft a check to pay for your personal cell phone when you and Lisa Jackson were partners together from 2008 through 2010? A. Did I ever draft a check? Q. Yes. Did you ever pay for it? A. Yeah, bill pay every month. Q. And who was that for? A. At the time? 0. Yeah. A. T-Mobile. Q. All right. And so it's your testimony that
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0. Has Mr. Woolf ever signed an engagement letter with you for the purpose of representing you in 3 any capacity? 4 A. No, he has not. 5 0. When did you first meet with Mr. Woolf 6 related to this case? 7 A. I've never met with Mr. Woolf. a Q. When did your partner first meet with s Mr. Woolf related to this case? io A. I'm assuming you're talking about Lisa ii Jackson? 12 Q. Yes. 13 A. I don't have an exact date. 14 Q. Well, do you have an approximate date then? is A. I knew it was August of '10, August of 16 2010. 17 0. All right. And do you know when it was in 18 August of 2010? is A. I don't. 20 Q. And when did Lisa Jackson tell you that she 21 was going to be filing a lawsuit against Uncle Bubba's? 22 A. August of 2010. 23 0. Did Miss Jackson ever meet with Mr. Woolf 24 prior to her leaving Uncle Bubba's on August 19th, 25 2010?
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i bill pay -- that you did electronic payment of your T-Mobile cellular phone bill; right? 3 A. Yes. 4 Q. And that you would have done that s personally? 6 A. I did do that personally. 7 Q. Okay. Do you recall how much that cost? 8 A. Nope. 9 0. Have your parents ever been to -- out on 10 social occasions with Mr. Schumacher? ii A. Yes. 12 0, On how many occasions? 13 A. I'm not sure. 14 Q. Where? is A. They're the presidents of a charity and I 16 know that he goes to that. He attends it. 17 Q. Tell me everything that you know about your 18 parents' relationship with Mr. Schumacher. 19 A. I know that they -- he handles their o finances in some manner. That's the extent of my 21 knowledge. 22 Q. All right. 23 A. And that it's been a long standing 24 relationship and that he attends that every year. 25 Q. He attends to that every year did you say?
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1 it. A. Attends that gala every year. 2 Q. Anything else? Q. That -- a charity function. 3 A. No. 3 A. Correct. 4 Q. All right. Did she tell you or-- or 4 Q. Do you know whether they share meals 5 strike that. Did Miss Jackson ever go to any Buddhist s together? 6 services, temples, what have you, when she lived in 6 A. Idonot. 7 Savannah? 7 Q. Are you aware of any other social occasion 8 A. There was one associated with the -B that they get together other than the charity function? Yes. Yes. 9 A. I'm not aware of any. 9 Q. All right. And what - let's stop there. 10 10 Q. Has he ever been to the family farm up in ii I think I've gotten the signal that we're almost out of ii Sylvania? tape. And let's take a break and come back. 12 12 A. I have no idea. MR. WITHERS: So we can go off the record. 13 13 Q. What did Miss Jackson tell you about Karl THE VIDEOGRAPHER: Going off video. This 14 14 Schumacher and any sexually inappropriate comments he is marks the end of Videotape Number One in the 15 may have made? deposition of Priscilla Sumerliri. The time is 16 16 A. None that I recall. 12:13 p.m. and we are now off the record. 17 17 0. All right. What did Lisa Jackson tell you 18 (Lunch recess.) 18 about what her relationship was with Mr. Schumacher? THE VlDEO3RAPHER: We're back on the record 19 19 A. That he was -- the relationship appeared to at 1:16 p.m. and this marks the beginning of Tape 20 20 be like her go-to person at work, like her immediate Number 2 in the deposition of Priscilla Sumerlin. 21 21 go-to higher up. Please proceed. 22 22 Q. And what did she tell you about that 23 Q. (By Mr. Withers) Miss Sumerlin, you 23 relationship is the question. I'm not asking for the 24 understand that you're still under oath. 24 conclusions that you drew, but what did she tell you 25 A. Ido. 25 about her relationship with Mr. Schumacher? 2 Page 100

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A. In relation to? I'm not understanding what you're 3 Q. Well, you said that she never complained 4 about anything with respect to Mr. Schumacher making S inappropriate sexual comments. Did she ever complain 6 to you about Mr. Schumacher making any appropriate -I any inappropriate racial comments? 8 A. No. 9 Q. Did she ever complain to you about anything 10 with respect to Mr. Schumacher and his work performance ii or lack therefore at Uncle Bubbas? 12 A. Mostly it was personal, religious judgment 13 passed on employees and Lisa. 14 Q. And what did she tell you about that? 15 A. He wouldn't allow certain servers if they 16 were drinkers to serve him. I know there was a topic 17 of conversation about living with someone before you're 18 married. I believe Lindsey was pregnant before she got 19 married. All these things were deemed immoral by him. 20 Clearly homosexuality would be immoral. 21 0. Did she tell you that's what he said? 22 A. He(sic)did. 23 Q. All right. 24 A. He referred to Brandon Branch as a 25 nymphomaniac faggot. That was the way that I recall
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Q. Do you recall when Lisa Jackson went on a medical leave of absence for a couple of months from, 3 I think, November of 2009 through January of 2010? 4 A. Ido. s Q. And during that period of time she was paid while she was having her medical issues attended to; 7 correct? B A. Correct. s Q. And that is during the period of time that 10 you described Mr. Hiers coming over with the steaks on ii that one occasion; correct? 12 A. Correct. 13 Q. I was -- following up with where we left 14 off with respect to Lisa Jackson and attending is Buddhist -- I'm not sure what the right term is -16 temple, ceremonies, what have you, where did she do 17 that in Savannah? 18 A. It's on Liberty right there at Troup 19 Square. 20 Q. And do you know what the name of that 21 gathering was? 22 A. There have services every Sunday. 23 Q. Do you know what the name was? 24 A. No, I don't. 25 Q. Did you ever go to any of those services
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with her? A. No, I did not. 3 Q. And when did she join that Buddhist group? MR. WOOLF: Objection, assumes facts not in 4 5 evidence about "joined." It's not "joining." 6 Q. (By Mr. Withers) You can go ahead. 7 A. I'm not sure. 8 Q. By the way, how many times have you seen 9 Karl Schumacher? MR. WOOLF: I objection. Asked and answered, 10 MR. WITHERS: I've never met him in person. 11 I've only seen him in passing. Like I've never 12 13 been introduced to him. 14 0. (By Mr. Withers) Let me hand you what's been is marked as Defendant's Exhibit 1. This is a letter 16 that's been previously identified, and that will be 17 marked as Defendant's Exhibit 1 to this deposition. Take a second and tell me if you recognize is 19 that letter, please. 20 A. I do. 21 Q. And tell me what that is, please, ma'am. 22 A. It was a letter that Lisa had me write. 23 Q. And who actually - well, tell me how 24 that took place in terms of Lisa having you write it. 25 Are these your words or are these Lisa's words?
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i fairly represent what her thoughts were concerning Paula Deen at the time? 3 A. Yes. 4 Q. All right. In other words, she didn't s draft this letter as a big lie to Paula Deen, did she? 6 A. No. 7 0. I'm sorry? 8 A. No. 9 Q. And in the second paragraph, the last io sentence of the second paragraph it says, "As you will 11 know, people appreciate and you respect you as a person 12 and the personal struggles and stories you have to 13 tell." 14 That's language that you and Lisa Jackson is came up with together; is that right? 16 A. Yes. 17 Q. And it expressed Lisa Jackson's heart felt is belief at the time, is that accurate? MR, WOOLF: I object what she -- what her 19 20 heartfelt belief is. 21 THE WITNESS: I believe so. 22 Q. (By Mr. Withers) Continuing on to the next 23 paragraph. I think it's the third sentence. "At 24 Section at 15 homeless without parents and with a young 25 child my life was headed in a direction no one could
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A. They are her thought processes. I just put

them into sentences. 0, Okay. Was she talking to you -- I mean, that's a collaborative effort, then? She's kind of telling you what to say and you're actually crafting the words and the sentence? A. Formulating it into a -Q. All right. But it's -- it's her thoughts that are going into this letter. Is that fair to say? A. Yeah, her thoughts are behind it, yeah. Q. Okay. And is -- is that a fair representation, this Defendant's Exhibit 1, a fair representation of what Lisa Jackson was telling you with respect to her thoughts concerning Paula Deen at the time? A. If you will give me a second. I haven't actually read this letter in a long time, so -MR. WOOLF: Take your time to read it. THE WITNESS: (Reading.) Having written it, I mean, I -- I know that at the time it was a last ditch effort as --to stay with the company because she obviously wanted to remain employed but get out of the current situation at Uncle Bubba's. Q. (By Mr. Withers) My question was, does that

i ever assume positive." Do you see that? 3 A. I do see that. 4 Q. That's words that you and Lisa Jackson put s together collaboratively; correct? 6 A. Correct. 7 Q. Now, what had Miss Jackson told you about 8 her being homeless and without parents at age 15? 9 A. In regards to... 10 Q. What has she told you about it? ii A. Exactly that. 12 Q. Did she tell you where she was homeless? 13 A. Here in Atlanta or actually Conyers. 14 0. All right. And did she tell you why she is was homeless? 16 A. Bad fostering is my understanding. 17 Q. Did you ever meet her adoptive parents, Mr. is and Mrs. Still, S T I L L? 19 A. No, I have not. 20 Q. Have you ever spoken with Lisa Jackson's 21 adoptive parent? I think her adoptive father is 22 deceased now, But her adoptive mother, have you ever 23 spoken with her? 24 A. No. 25 0. What did Miss Jackson tell you occasioned
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her having to be homeless if she was being raised by adoptive parents? 3 A. Intolerable living. 4 Q. And what was intolerable about her living s circumstances? 6 A. it was abusive. 7 0. And how was it abusive? 8 A. Physically, emotionally. 9 0. What kind of physical abuse? 10 A. We never got in depth about it. ii Q. What did she tell you about the emotional 12 abuse? 13 A. Just that it was very emotionally abusive. 14 0. Did she ever tell or has Miss Jackson ever 15 told you about her adoptive sister? 16 A. Donna? 17 Q. Yes. 18 A. 1 know about Donna. 19 0. And what did she tell you about her 20 relationship with Donna? 21 A. It was strained at times, but overall it 22 was okay, I mean, as far as I know. 23 Q. And what do you understand Lisa Jackson's 24 relationship is with her adoptive mother, Miss Still, 25 at this point in time?
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A. She's received counseling. Q. My question was more specific than that. 3 To your knowledge did Miss Jackson receiver has Miss 4 Jackson received counseling as a result of being raped 5 on multiple occasions? 6 A. Again, she's received counseling. I don't 7 know what specifically was discussed in her counselling a sessions. 9 0. The next line Miss Jackson and you write, 10 "I did what I had to do to survive." 11 What do you understand that to mean? 12 A. I understand that to mean work multiple 13 jobs. 14 Q. Anything else? is A. No. 16 Q. No? 17 A. No. 18 Q. All right. Continuing three sentences 19 below that you all wrote, "When I started working for 20 Bubba he gave me an opportunity that allowed me over 21 time a freedom I have never experienced." 22 Is that a fair expression of the manner in 23 which Miss Jackson viewed Bubba Hiers in May of 2010? 24 A. I don't think the relationship is 25 necessarily here that that should be appreciated to
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A. Non existent from what I understand. 0. The young child that she references here, 3 who is the father of that child to your understanding? 4 A. I have no idea. s Q. Did Mr. Jackson ever tell you that she was 6 raped at the age of 14? 7 A. I know there were multiple occasions, but I a don't know the exact ages. 0. All right. And how many times do you io understand Miss Jackson has been raped? 11 A. Three or four to my knowledge. 12 Q. And when did those rapes take place? 13 A. I -- I'm not sure. 14 Q. By whom did those rapes take place? 15 A. I don't have names or the relationships for 16 that matter. 17 Q. In terms of the actual geographic location is do you know geographically where those rapes took 19 place? 20 A. I do not. 21 Q. Do you know the ages of Miss Jackson at the 22 time of those different rapes? 23 A. I do not. 24 Q. Has Miss Jackson ever received counseling 25 as a result of those multiple rapes?
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i Bubba Hiers but that she did feel a certain freedom 2 with that position and her salary and her ability to 3 take care of herself. I wouldn't associate the 4 relationship with Bubba Hiers. 5 0. All right. Well, she talks about when I 6 started working for Bubba, does she not? 7 A. She does. 8 Q. All right. The next sentence, "He allowed 9 me for once in my life to take care of myself and for 10 once have faith in myself as a person and as a woman to ii know that I could do it on my own. You all were my 12 Aunt Peggy." 13 Does that statement accurately reflect Miss 14 Jackson's view with respect to Mr. Hiers in May of 15 2010? 16 A. No, I don't believe so. 17 Q. Oka y. So that -- that sentence then would 18 be false, is this what you're saying? 19 A. I'm just saying, again, that the 20 relationship, I don't feel like it was appropriate 21 attributing it to Bubba Hiers. 22 Q. All right. Well, she writes here and -23 and maybe we're ships passing in the night. She 24 writes, you wrote, "He allowed me for once in my life 25 to take care of myself." Correct?

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i about Uncle Bubba's Seafood becoming kind of a A. Yes, I'm reading -2 destination event type place as opposed to a Q, Yes? 3 restaurant; correct? 3 A. I'm reading it. 4 A. Correct. 4 Q. All right. And for once have faith in 5 Q. Who did you understand she had vetted that S myself as a person; correct? 6 or spoken with about that for the purpose of putting 6 A. That's correct. 7 Defendants Exhibit 1 into words? 7 Q. Does that -- those two clauses, that he a A. I believe that she had spoken to both Karl a allowed her to take care of herself and to have faith 9 and Brandon Branch. 9 in herself as a person, does that fairly represent what 10 she was communicating to you about Mr. Hiers in May of 10 Q. And had they both endorsed that idea? ii A. Yeah. ii 2010? 12 Q. And what did she tell you Karl told her 12 A. No, I think it was about the position. 13 about that? 13 Q. All right. 'And as a women, to know that I 14 A. I don't remember discussing it. 14 call do it on my own. You all were my Aunt Peggy." 15 0. Fair enough. Fair enough. I didn't mean 15 Who is Aunt Peggy? 16 to interrupt you. Were you finished? 16 A. I think Bubba and Paula's aunt. 1 17 A. Yes. 17 Q. And what --what is meant by you all were la my Aunt Peggy? What did you understand that to mean? 18 Q. All right. Did Miss Jackson when you first 19 came to know her in 2007, did she come into an iMac iq A. My understanding was at that Peggy gave 20 computer that had purchased for Uncle Bubba's? Paula a chance in the past. 20 A. Karl told her to go buy it was my 21 21 Q. Okay. And that Bubba and Paula were Lisa 22 understanding. Sorry. 22 Jackson's Aunt Peggy; correct? 23 Q. All right. And -- I'm sorry. I didn't 23 A. Correct. mean to interrupt you. Were you finished? 24 24 Q. In other words, the idea of being an Aunt A. No, I was apologizing for-- I didn't mean 25 25 Peggy was something that was positive as opposed to
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i to interrupt you. something that was negative. Is that fair to say? A. She was given a chance, yes. 2 Q. And what happened with that iMac computer? 3 Q. All right. 'And since then," reading on, 3 Where did it stay? 4 A. He told her to keep it. 4 "I've become the independent woman I have always wanted s Q. And how do you know that? 5 to be." Is that what she wrote? 6 A. Yep. 6 A. There was multiple conversations about it. 7 Q. And how do you know that? 7 Q. That's what you all collaborated with? a A. I overheard them. a A. Correct. 9 Q. And how did you overhear them? 9 Q. Does that fairly represent how Lisa Jackson A. She was on the phone. 10 was feeling in May of 2010? 1 ii A. An independent woman, yes. 11 Q. On the speaker phone again with Mr. 12 Schumacher? 12 0. "And that I have been given opportunities 13 that I never thought possible all because of you and 13 A. Whether it be on the speaker or-- yeah, I 14 mean, sitting next to me. 14 Bubba.' Is that what you all wrote? is 0. All right. And what did you understand she 15 A. Correct. 16 Q. And does that fairly reflect how she 16 had been told by Mr. Schumacher with respect to that 17 thought about Paula Deen and Bubba at the time? 1.7 computer? 18 A. Yes. 18 A. It needed to be a Mac because there needed 19 Q. Did Lisa Jackson discuss with you her idea 19 to be like graphic design programs on it. It couldn't 20 about this new concept she was having with respect to zo be put on a PC and that it would be broken in the 21 Uncle Bubba's Seafood? Well, let me ask it a different 21 office. 22 way, She obviously discussed with you what you all put 22 Q. And so she would maintain it at her home? 23 A. Correct. 23 into words here in Defendant's Exhibit 1; correct? 24 A. Correct. 24 Q. And that computer made its way from 25 Q. All right. So she had talked with you then 25 Savannah to Atlanta, did it not?

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A. It did. Q. And how did that come to be? 3 A. It's still in her possession. 4 Q. Right. And is it still at you all's 5 residence today -6 A. Yes. 7 Q. -- on McCaw Street? 8 A. McCaw, yes. 9 Q. McCaw Street. Sorry. And still in use, I trust? 10 ii A. Yes, it's been rebuilt. But, yes. 12 Q. And when was it rebuilt? 13 A. I think it-- I believe it was purchased in 14 '07 and it was struck by lightening in '08 and we paid is to have it rebuilt. 16 Q. How much was that? 17 A. I can't recall. is Q. You're computer literate. I trust? 19 A. Pretty much. 20 0. All right. So you all moved up to Atlanta 21 from Savannah in January of-- December of 2010, 22 January of 2011 time frame; is that right? 23 A. That's correct. 24 Q. And has that computer been operational at 25 you all's address on McCaw Street since then?
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i when it was purchased, do you remember? A. I didn't purchase it, so, no, I don't know. 3 Q. And -4 A. I mean, I -- I know what they go for, but I 5 don't know what she paid for it. 6 Q. What do they go for? 7 A. An iMac? a 0. Yeah. 9 A. About $2,100. ic Q. And the amount that you paid for the ii rebuild was what? Do you recall? 12 A. I do not. 13 Q. Does $283.50 ring a bell? 14 A. It doesn't. 15 Q. The fact is that you had the hard drive 16 replaced, and if that's what the records reflect the 17 cost was that was paid for by you, you wouldn't dispute 18 that, would you? 19 A. Whatever the -20 MR. WOOLF: Objection. Asked and answered. 21 THE WITNESS: Whatever the receipt says. 22 Q. (By Mr. Withers) Okay. Now, so it the 23 records showed 280 some odd dollars and some change, 24 that's the only -- and you took it back to that same 25 place there near Best Buy; correct?
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1 A. Correct, i A. Yes, after we had it rebuilt, yes. 2 Q. Yes? That's the only time you took it to Q. But you had it rebuilt down in Savannah or 3 that facility; correct? 3 up here? 4 A. I believe so. 4 A. Down in Savannah. 5 Q. All right. And then how was it that you 5 Q. Okay. So it's been -- in other words, 6 all ended upbringing the computer from Savannah to 6 since January of 2011 you all have been using it here ' Atlanta and not returning it to Uncle Bubba's? 7 in Atlanta. Fair to say? 8 A. Yes. 8 A. I'm not sure. 9 Q. All right. Let's talk about the -- you 9 Q. Not just sitting in a package stored away io somewhere; right? io remember the three-tiered plate stand that you all ii A. No. 11 have? 12 Q. With respect to the rebuild, that-- you 12 A. We don't have. 13 Q. You used to have a three-tiered plate 13 all took that computer to the place that's out there 14 near Best Buy and that FedEx store; right? 14 stand, right? 15 A. She purchased it for work, yeah. 15 A. Correct. 16 Q. As I understand it, you took the computer 16 Q. And that stayed at your house for a lengthy 17 period of time, did it not? 17 in; correct? 18 A. We actually both were there that day. 18 A. It went back and forth between that storage 19 trailer, if you want to call it that, in the back of is Q. All right. And you ended up paying for the 20 repairs, did you not? 20 Uncle Bubbas and our house. 21 A. I did. 21 Q. Okay. You've been to that storage trailer, 22 Q. Repairs that took -- how long did that 22 I trust? 23 rebuild take? 23 A. In it? No. 24 A. I can't remember. 24 Q. Been to it? 25 Q. How much did that computer originally cost J25 A. No. 2

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Q. All right. So you never went back there to -A. I've seen it. 0. You've really got to let me finish these questions. You never went back to retrieve anything from the storage trailer? A. No. Q. All right. And what did Lisa Jackson ultimately end up doing with that three-tiered plate stand? A. I believe it was broken at an event. Q. At an Uncle Bubba's event? A. That's my understanding. Q. Is this what Lisa Jackson told you? A. Yes. 0. Do you know when that took place? A. I do not. Q. Would it have been after May of2ol0? A. I don't know. Q. All right. What about the Nikon camera? Did Lisa Jackson take the Nikon camera that was purchased by Uncle Bubba's Seafood to you all's residence? A. Its been returned. We did not use it.
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Q. All right. Was it after Dr. Abdi's deposition to your knowledge? 3 A. I'm not sure when his deposition was. 4 Q. Has Lisa Jackson ever told you that she had 5 been raped by a former employer? 6 A. Former employer? 7 0. Yes. 8 A. No. 9 Q. Are you aware of any doctor that Lisa 10 Jackson has made a complaint to at the medical board? ii A. Dr. Abdi. 12 Q. All right. And how did you become aware of 13 that? 14 A. She told me. is Q. And when did she tell you that? 16 A. Ithink it was May of 2011. 17 Q. Are you aware of any other complaints made 18 by Lisa Jackson against any medical practitioners? '9 A. No. 20 Q. How many husbands do you understand Lisa 21 Jackson has previously had? 22 A. Legally? I think two, three? 23 0. And who do you understand they --what are 24 the names of those former husbands? 25 A. Jay Jackson was one. I don't know the
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Q. All right. That stayed at you all's residence for a lengthy period of time; correct? 3 A. Yes. 4 0. All right. By the way, with respect to the s iMac, is that the computer that you worked on for the 6 purpose of helping prepare the employee handbook? 7 A. No. s Q. What computer did you do that on? s A. I have a Macbook. 10 Q. Yes? 11 A. I have a Macbook. 12 Q. Okay. 13 A. So no. 14 Q. All right. What doctors has Lisa Jackson 15 seen here in Atlanta to your knowledge? is A. Excuse me. Dr. Shirley Chancey, Dr. Abdi 17 and Dr. -- the most recent one I can't remember her 18 name. 19 0. Who is the most recent one? 20 MR. WOOLF: Asked and answered. 21 THE WITNESS: I cant remember her name. 22 Q. (By Mr. Withers) All right. Well, let me -23 let me ask it a better way. When did she go see the 24 most recent one? 25 A. About a month ago.
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i names of the other others. Q. Okay. And do you know whether it's two, 3 three or four? 4 A. It's either two or -5 MR. WOOLF: Objection. THE WITNESS: Oh, sorry. 6 7 MR. WOOLF: Objection. Asked and answered. 8 Q. (By Mr. Withers) Go ahead. 9 A. I don't know. io Q. All right. Have you ever filed a complaint 11 against a medical practitioner? 12 A. No. 13 Q. Pardon me? 14 A. No. is 0. Have you ever filed a lawsuit against is anybody? 17 A. I was involved in one for a car accident. 18 Q. And when was that? 19 A. I don't recall the year. 20 Q. And where was that? 21 A. Where was -- It wasn't a lawsuit. I don't 22 know if it was a lawsuit, if it would constitute as a 23 lawsuit. 24 Q. Did you have an attorney? 25 A. I did.
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you get a settlement? A. Yes. 3 Q. Do you know whether suit was prior -- was. 4 filed prior to settJement? s A. I have no idea. 6 Q. Fair enough. Do you remember who your 7 attorney was? 8 A. Yes. 9 Q. And what was that attorney's name? 10 A. 1 think it was Mr. Waters out of Brunswick, ii Georgia. 12 Q. Was that the location of the car accident 13 in Brunswick? 14 A. No, their location was in -- on 1-75 near 15 Atlanta. 16 Q. How many jobs has Lisa Jackson had here in 17 Atlanta since you all moved here two years ago? 18 A. Two different restaurants, and then as an 19 independent contractor. So three, I guess. 20 Q. And what were the names-- or what are the 21 names of the restaurants? 22 A. Cafe Intermezzo and then an independent 23 contractor, so she worked at a few different places 24 doing that. And then now she's at Mary Mac's. 25 Q. And her at Cafe Intermezzo was what?
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_ 1 Q. Did

i A. Multiple -- I mean, there's -- I have a few different people that she worked with that I've spoken 3 with. 4 Q. And what were those people's names? 5 A. Mike was one of their names. He lived in 6 our neighborhood. And then I forget -- I don't know 7 the rest of their names. a 0. Okay. I'm going to show you what's been 9 marked as Defendant's Exhibit 2. That's a screen shot 10 from your Facebook page, and the date of that 11 photograph or Facebook, I guess, post was March of 12 2010, I believe. Do you recognize that Facebook post? 13 14 A. I do. is Q. And point out to me, if you would, please, 16 ma'am, the iMac computer? 17 A. It's right there. 18 Q. And circle that with that blue pen, if you 19 would, please. 20 Thank you. That's the iMac computer that 21 still is in use at your residence today; correct? 22 A. Yes. 23 Q. When was the Canon camera returned? 24 MR. WOOLF: Objection, facts not in evidence. MR. HUNTER: You mean Nikon? 25
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A. General manager. Q. And why did she leave Cafe intermezzo? 3 A. Mainly, I believe, the hours. 4 Q. Any other reason? s A. There was inappropriate behavior, my 6 understanding, with other staff members, but I don't 7 believe it was directed towards her. B Q. What was the appropriate behavior? 9 A. They had a history of sexually ic inappropriate relationships. I guess you could say. ii Q. Define what that means for me. What 12 physically happened, in other words? 13 A. My understanding was that either the owner 14 or a manager witnessed a very intoxicated employee is being forced into intercourse with multiple people. 16 Q. And where did that intercourse allegedly 17 take place? 18 A. I'm not sure. 19 Q. Is this something that Lisa Jackson told 20 you about at the time? 21 A. She did, multiple-- I mean, another 22 manager that worked there. 23 Q. Another manager told you about it as well? 24 A. Yeah. 25 0. And who was that?
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i Q. (By Mr. Withers) Nikon. Excuse me. Hand that to him. 3 A. We tried to return it before we left 4 Savannah. But I believe she called Sandra to return s multiple items but was never successful. 6 Q. By the way, what kind of car did Lisa 7 Jackson drive when you first came to know her? a A. Ford Expedition. 9 Q. What kind of car did she drive when you all io moved up here to Atlanta? ii A. Mercedes. 12 Q. And what kind of mere did? 13 A. CLK 320. 14 Q. And when did she purchase that? is A. I don't recall the year. 16 Q. And does she still drive that Mercedes. 17 A. She does. 18 Q. I'm going to hand you what's been marked as 19 Defendant's Exhibit Number 3. And again, this is a -20 a screen shot from your Facebook page, is it not? 21 A. It is. 22 Q. I didn't look at the date on that prior to 23 handing it to you. Is that May of 2010? 24 A. That's just when it was uploaded. I don't 25 believe that's when it was taken.
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Q. Okay. They-- that is - that depicts, does it not, the three-tiered plate stand that belonged 3 to Uncle Bubbas; correct? 4 A. It does. s Q. And if you would, circle that three-tiered 6 place stand for me, please, ma'am. 7 A. Do you want this back? a Q. And you've placed a circle around that 9 plate stand? 10 A. I did. ii Q. Okay. Thank you. 12 Now, as I understand it when you left 13 Savannah you did not place your Southbridge home on the 14 market, did you? 15 A. We attempted to, yes. 16 Q. Well, tell me about that. What does that 17 mean, that you attempted to? 18 A. When she left there was no income coming in 19 clearly other than mine. So we tried to -- I think we 20 had it -- I'm not -- I can't remember if we had 21 appraised or not, and we listed it for a short period 22 of time. 23 0. Who did-- I'm sorry. I didn't mean to 24 interrupt you. 25 A. I think it was Tracy Hammock, I believe.
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i Q, Yes. A. Yeah. 3 Q. All right. And could she on occasion be 4 profane in that respect? s A. By saying that word? 6 Q. Yes. 7 A. She's said the word. 8 Q. All right. And has -- have you ever heard 9 her use profanity at the workplace? 10 A. No. ii 0. Did you ever speak with Brandon Branch? 12 A. Yes. 13 Q. On how many occasions? 14 MR. WOOLF: I'm going to object. I think 15 she's asked and answered that. THE WITNESS: Maybe five. 3.6 17 Q. (By Mr. Withers) And if I did ask you, I 18 don't recall that frankly. But tell me what the nature 19 of those occasions were that you spoke with Brandon? 20 A. I believe we went out to lunch a few times. 21 I think that's it. 22 Q. During those meetings with Brandon was 23 anything any discussed with respect to Bubba Hiers or 24 Uncle Bubba's Seafood? 25 A. I don't recall.
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Q. And how long did you list the residence 1 Q. Since the filing of this lawsuit in March 2 of 2012 what employees of Uncle Bubba's have you with Tracy Hammock? 3 communicated with in some fashion or another? A. It got rented fairly quickly, so I don't -I can't remember how tong it was. 4 A. Deiphine Jones would be the only one. s Q. So if you had listed it with Tracy Hammock s 0. And what has your communication with 6 there will be all real estate contract that Miss 6 Delphine been? 7 A. Just if she needed anything -- she has 7 Hammock has; correct? a family here in Atlanta -- she can call. a A. Yes. 9 Q. And ultimately when -- what happened is you 9 Q. And who is that that is her family here in 10 all just ended up giving that home back to the bank; io Atlanta? ii. right? 11 A. I'm not sure. I know they live in 12 A. Yes. 12 Stockbridge, I believe. 13 Q. All right. And at the time that you gave 13 0. And how many times have you spoken with 14 it back to the bank it was not listed with a real 14 Delphine? is estate agent, was it? 15 A. Once, I think. 16 A. It was rented. 16 Q. And have you us the nature of that 17 0. At the time you gave it back to the bank it 17 communication with her? ia was not listed with a real estate agent, was it? 18 A. It was relating to her family. She was 19 A. No, it had been prior to when we rented it, is meeting her family for a trip at Six Flags. 20 50-20 Q. All right. Anything else with respect to 21 It was occupied. 21 Delphine in terms of communication? 22 Q. Did you ever hear Miss Jackson use 22 A. No. 23 language that would be -- generally considered to be 23 0. Text, Facebook, Pinterest, anything like 24 offensive such as the -- what I will term as a F word? 24 that? 25 A. Has she said it? 25 A. No.
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Q. Are you Facebook or social media friends with any of the witnesses in this case to you 3 knowledge? MR. WOOLF: Objection. That. 4 s Q. (By Mr. Withers) That's fair. To your 6 knowledge anybody that's a witness are you Facebook 7 friends? 8 A. I'm not sure who all is witnesses, so 1 9 can't really say. 10 Q. All right. Prior to the lawsuit being i. filed in March of last year from the time Lisa Jackson 12 left until -- and which would have been in August of 13 2010 until March of 2012, on how many occasions have 14 you communicated with a current or former employee of is Uncle Bubba's? 16 A. Me personally? 17 Q. Yes. is A. None. 19 Q. Pardon me? 20 A. None. 21 Q. Did you ever-- or strike that. Were you 22 aware of Lisa Jackson ever contacting Al Sharpton or a 23 representative of Al Sharpton with respect to this 24 case? 25 A. I know that one of her former employees
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Lisa Jackson attending four EEOC mediations that had been filed --from claims that had been filed against 3 Uncle Bubba's? 4 A. Vaguely. s Q. Do you recall Lisa Jackson complaining that 6 those women were making allegations about her? 7 A. No. 8 Q. Did she ever talk to you that the EE -9 those four EEOC claimants were accusing Miss Jackson of ic age discrimination and retaliation? 11 A. No. 12 Q. Did she ever tell you that she and Elaine 13 Thomas who was a manager at the time had had a falling 14 out that ended with Lisa Jackson telling Miss Thomas to 15 get the F out of the restaurant? 16 A. I know that there was an exchange, but I 17 was not aware of what was said. 18 Q. Did -- You understand that Lisa Jackson has 19 file suit in this case again Paula Deen, do you not? 20 A. Uh-huh. 21 Q. That's ayes? 22 A. Yes. I'm sorry. 23 Q. And did Miss Jackson ever complain to you 24 about any activities related to Paula Deen, that is, 25 racial or sexual harassment or discrimination by Paula
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1 Deen? worked for him or with him. That's all I know of that. 2 A. Just overt sexual natured topics of Q. Did you ever send after text message to my 3 conversation, I guess. 3 current or former employment of Uncle Bubba's? 4 Q. Such as what? 4 A. Ever? s A. 1 don't have any off the top of my head, s Q. Since August of 2010 have you send any text 6 but those were the complaints that she made. 6 messages to any current or former employees of Uncle 7 Q. Did she ever show you any video clips of 7 Bubba's? 8 any comments of Paula Deen that she thought were s A. I think Deiphirie would be the only one, and 9 inappropriate in some fashion or another? 9 again, it was related to that trip. io A. Yes. 10 0. Did Lisa Jackson ever complain to you talk 11 to you about Bubba Fliers and any trips to strip clubs? ii 0. And when did that occur? 12 A. I when they were taping, I guess, 12 A. Yes. 13 Paula's Party or whatever it was called. 13 Q. And what did she say about that? 14 0. And when was that? 14 A. That he frequently and put it on his, 1 is guess, card that the company paid for. is A. 2008, maybe. 16 0. And what was said? 16 Q. Okay. Anything else? 17 A. I don't know. I can't remember what was 17 A. Big 3 took him and Big D said that he 18 said. ia brought the strippers back to his house. 19 Q. Okay. Anything else? 19 Q. All right. I think my question was 20 A. That's all 1 had remember. 20 addressed to inappropriate sexual comments. Did she, 21 Lisa Jackson, ever make any complaints to you about 21 Q. When you were at Uncle Bubba's did you ever 22 see any African American employees enter the business 22 Paula Deen making inappropriate racial comments? 23 A. Yes. 23 through the front door? 24 A. No. 24 Q. And what did -- what did she say? 25 Q. Do you recall in the early spring of 2009 25 A. The one that I remember was about Bubba's 2

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i wedding. 0. Okay. And what was that? 3 A. She wanted, I guess, African American 4 people to dress up as -- little ends on a plantation 5 was the way that it was described to me. 6 Q. And what did Miss Jackson tell you? That 7 she had heard that, that somebody had related that to 8 her? What was the nature? 9 A. She was there when Paula said it. 10 0. All right. What was the last day that Lisa ii Jackson worked at Uncle Bubba's Seafood? 12 A. I'm not sure of the date. 13 Q. I'm going to hand you what's been marked as 14 Defendant's Exhibit 4. Do you recognize that? 15 A. Yes. 16 Q. That's an email that you were forwarding ri from Lisa Jackson to Karl Schumacher; correct? 18 A. Correct. 19 Q, And it forwards a copy of the Uncle Bubba's 20 operational handbook, does it not? 2]. A. Correct. 22 Q. Had you worked on that handbook? 23 A. I made that handbook. 24 Q. All right. And the date of-- by the way, 25 of that email is what date?
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A. Correct. Q. And it talks about using the corrections 3 from both you and Jim; right? 4 A. Yes. s Q. And it's signed, thanks, Silla; correct? 6 A. Correct. 7 0. And then up at the - if you go up that B email then is apparently forwarded from your GMail 9 address to your Memorial address; correct? 10 A. Correct. ii 0. All right. And --and that is what took 12 place in August of 2010; right? 13 A. Correct. 14 Q. All right. So your forward of the -- and I is would represent to you this is the attachment, and 16 Mr. Woolf can correct me if I'm wrong, but I believe 17 I'm correct about that, is -MR. WOOLF: Well, I -- I'll object because I 18 19 don't know and I'm not sure if she does. 20 Q. (By Mr. Withers) All right. Well, it-21 this is - Exhibit Number 5, that I've handed to you, 22 ma'am, is the Uncle Bubba's House -- Oyster House 23 Operational Handbook, is it not? 24 A. It is -- I don't know if it's the one that 25 was emailed this specific day. There were about 15
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i A. That is August 6th, 2010. 2 0. I think if you scroll down or go down to s the forward message -- see where it says from Lisa 4 Jackson, date, Wednesday, May 19, 2010? 5 A. Yes. 6 Q. That email then from you to Karl is dated 7 Wednesday, May 19, 2010, is it not? 8 A. Yeah. Q. It's an email string, in other words, isn't io it? ii A. I never sent it directly from my email to 12 Karl's email, 13 Q. Right. So let's just - I mean, I don't 14 want to belabor the point here, but at the bottom of 15 that page, Defendant's Exhibit 4, there is a forwarded 16 message from Lisa Jackson's email to Karl Schumacher; 17 correct? is A. Correct. 19 Q. It's dated May 19, 2010; correct? 20 A. Correct. 21 Q. The subject line is Operational Handbook; 22 correct? 23 A. Correct. 24 Q. And then it says, "Hey, Karl" -- or, "Hi, 25 Karl, this is Silla sending for Lisa." Correct?

versions, so I'm not sure which one was emailed that specific day. 3 Q. There were 15 versions emailed back and 4 forth? s A. They were all done as individual pages 6 initially, and then I had to put them together. So, I 7 mean, however many pages that is. 8 Q. Okay. Does that look familiar to you? I 9 mean, does that look like your handy work, in other 10 words? You said you're the one that put it together? ii A. I did. It does. 12 Q. Okay. And how long did that task take you? 13 A. Months. I don't -- I can't give you an 14 exact time. I did it on my time off, so -15 Q. Okay. Tell me the name, if you would, 16 please, ma'am, of every medical practitioner who you 17 understand treated Lisa Jackson while she was in 18 Savannah for anything related to her employment at 19 Uncle Bubba's. 20 A. She saw Karen Dunston, Dr. Lord, Doku 21 (phonetic) -- I believe - I think that was it. 22 Q. All right. What did you understand she saw 23 Dr. Doku for? 24 A. She was having a panic attack at work was 25 my understanding.
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i at Uncle Bubba's Seafood? Q. And when would that have been? 2 A. I mean, she still has diverticulitis, I A. I don't recall the date. 3 mean, which is induced by and worsened with stress. So 3 Q. Why did she see Dr. Lord? I'm taking these 4 the surgery and continued, I guess, issues from that. in reverse order? 4 5 Anxiety now. Depression. A. She had diverticulitis and became 5 6 Q. Anything else? obstructed, so she had to have a sigmoidectomy. 6 7 A. (Nodding.) 7 0. Is that what kept her out of work for so B 0. No? a long in the winter of 2009, 2010? 9 A. No. 9 A. Correct. Q. And what medications does she take now for 10 'a Q. And then Dr. Dunston? ii any of those three things that you described, ii A. That was her primary physician. diverticulitis, anxiety and depression? 12 12 Q. Primary care? A. I'm not aware of all of her medications. 13 13 A. Uh-hmm. Yes. I'm sorry. Q. All right. Where did she apply for a job 14 14 Q. And what -- and I have already asked you when she was in Savannah following her leaving Uncle 15 about who she's seen her in Atlanta, and you related to 15 16 Bubba's in August of 2010? 16 me Dr. Chancey, Abdi, and some other physician here 17 A. I can't remember all the places. 17 recently. is Q. Do you know of anywhere that she applied 18 A. It's a new primary care physician. 19 forajob? 19 Q. All right. When did you and Lisa Jackson 20 decide that you all were going to be moving to Atlanta? 20 A. Yeah, C sent out all the applications. 21 Q. All right. Tell me who -- who you recall 21 A. We didn't really discuss it. She applied 22 her making application to? 22 for multiple jobs after she left and financially we 23 couldn't afford that house anymore, so we had to have a 23 A. I know U.S. Foods, Cisco. I can't remember 24 any other specifics. I know that there were multiples. 24 Plan B. So I think I applied for my first job -- the 25 0. Did she ever get an employment interview in 25 only job I think I applied for was at LifeLink where I
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currently work, and I believe I applied in October, I 2 think,of2010. 3 Q. '10? 4 A. Yes. s Q. And then I think - I had either assumed or 6 you told me that you all moved up here in December 7 or January -- December of 2010 or January of 2011. a A. Yes. 9 Q. Do you recall what the move date was? 10 A. Well, we moved out of our house and it was ii rented before we found a place here. So we moved out 12 of our house in December 4th, 1 think maybe, and then 13 finally moved up here -- I don't -- I think it was 14 maybe the second or third week. is Q. All right. When did you start 16 Mr. LifeLirik? 17 A. January -- it was the year of that snow 18 storm, so my hire got delayed, but it was -- it was 19 supposed to be January 1st but it was January, 1 think, 20 16th. 21 0. 0f2011? 22 A. Correct. 23 Q. All right. What conditions do you 24 understand Miss Jackson suffers from now, medical, 25 mental, emotional, that she attributes to having worked
i.

i the Savannah, Chatham County area? A. No. 3 Q. Do you know anybody at U.S. Foods? 4 A. I knew Julian de Fontaine. s Q. How many times did you see Mr. de Fontaine? 6 A. Maybe ten. 7 Q. Was Mr. de Fontaine ever present at the 8 same time at Uncle Bubba's that Bubba Hiers was 9 present? 10 A. And that I was present or just them two ii together? 12 Q. Well, did you ever personally observe them? 13 I'm sorry. 14 A. No, not that I'm aware of. 15 Q. All right. Tell me what happened with 16 respect to Miss Jackson's application with U.S. Foods? 17 A. She -- my understanding was that she had 18 talked to -- I'm not sure of Julian's boss's name. 19 1 -- I can't remember his name, but that it would be -20 he stated that he would lose his business with Uncle 21 Bubba's and Lady and Sons if he moved forward with 22 that. 23 Q. And that was related to you by Miss 24 Jackson, I trust? 23 A. Yes.
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Q. All right. MR. WITHERS: Mr. Hunter, I think that's all 3 the questions I've got. MR. HUNTER: Can we take a --just a 4 s two-minute bathroom break? MR. WITHERS: Yeah, lets -7 MR. HUNTER: I'm not going to be very long. THE VIDEOGRAPHER: Going off video. 2:13 a 9 p.m., off video record. (Recess.) 10 THE V1DEOGRAPHER: 2:23 p.m. Back on video ii 12 record. 13 CROSS EXAMINATION 14 0. (By Mr. Hunter) Miss Sumerlin, my name is 15 Bill Hunter and I represent Paula Deen and the Deen 16 defendants in this case, and I'm here to ask you some 17 additional questions. You're still under oath. Do you understand is 19 that? 20 A. ldo. 21 Q. Have you ever spoken with a gentleman named 22 Matt Billups? 23 A. I have not. 24 Q. Have you ever been interviewed by anyone 25 with regard to this case?
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i 0. Okay. Would it be important to you to know what he had to say about the Big Wil incident? 3 A. Not necessarily. 4 Q. Okay. Now, Lisa Jackson believed at all 5 times that Paula Deen was a -- a good lady, did she 6 not? MR. WOOLF: Excuse me? What the question 7 a again? 9 Q. (By Mr. Hunter) Lisa Jackson all the times 10 that you talked to her or been around her believed that ii. Paula Deen was a good lady, didn't she? 12 A. I think that's fair to say. 13 0. Okay. And she believed she was fair, 14 didn't she? is A. Not -- we never had that specific 16 conversation. 17 Q. Well, you did have a conversation that -is on May 27th, 2010 where she believed -- Lisa Jackson 19 expressed to you that Paula Deen was a role model for 20 women, wasn't she? 21 A. Shewas -- yes. 22 Q. And especially for those women who had 23 started out in a place in life that would be less than 24 fortunate, isn't that true? 25 A. That's true.
2 Page 144

A. No. Q. You've told Mr. Billips, Mr. Woolf or 3 anyone from their office what you knew about this case, 4 the allegations or anything of that nature; is that s true? 6 A. I've never been interviewed by them, no. 7 Q. Okay, What I said is correct? a A. That is correct. 9 Q. Okay. Now, you did review the complaint in 10 this case; correct? ii A. I did. 12 Q. And why did you do that? 13 A. I have a relationship with Lisa. 14 0. Okay. is A. 1 mean, outside of that .... 16 Q. Did you review anything else? 17 A. Such as? lB 0. Such as anything, any other documents that 19 have been generated as a result of this case, any other 20 depositions, any other things of that nature? 21 A. No. 22 Q. Okay. Have you ever -- other than -23 strike that. You have not read Big Wil's deposition 24 for instance, have you? 25 A. No, I have not.
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Q. Okay. Now, she respected Paula Deen, didn't she? 3 A. I can't really say that. 4 Q. Okay. When -- you related to s Mr. Withers-- and I'm going to jump around, so I'm not 6 covering the same ground. Okay? And get us out of 7 here quick -- more quickly. a When Mr. -- when you related to Mr. Withers 9 that in 2008 Lisa told you, I believe you said, that io Paula Deen had used some sort of sexually suggestive ii or sexual nature type language -12 Is that correct? Did I hear your testimony 13 correctly? 14 A. You did. is 0. Okay. She didn't complain that she was 16 offended by that, did she? 17 A. I don't know that complained is a --you 18 know, she wasn't -- it's not the way that she would 19 talk nor is it a conversation that she would typically 20 have or necessarily approve of. 21 Q. Okay. But you don't recall her actually 22 making - or strike that. You don't recall her 23 actually saying that she was offended by the language, 24 do you? 25 A. I can't recall.
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not? A. He was. 3 some racist language about Bubba's wedding, did she say 3 Q. But he didn't during that night at least 4 when he was drinking and on pain pills make any 4 that she was offended by that? 5 comments that you believe to be racist or sexually 5 A. She did. 6 suggestive, true? 6 Q. And when did that conversation that she 7 overheard or heard Paula say that word, when did that 7 A. True. 8 Q. Okay. You claim to have overheard Jim e occur? 9 Gerard, a lawyer at Oliver Maner, my firm, speaking 9 A. The date, I'm not sure. It was at the -10 they were planning -- my understanding is they were io with Lisa on one more than -- at least more than five ii occasions. True? ii planning for the rehearsal dinner or maybe the 12 A. True, 12 reception. 13 MR. WOOLF: Asked and answered. 13 Q. Okay. And what year was that? 14 A. I don't recall. 14 MR. HUNTER: I'm just -- that is not a proper is form objection. Okay? We -- ft sure that we're 15 Q. Okay. Was it in 2009? 16 operating under the rules that we're going to 16 A. I don't recall, 17 Q. Was it before May 27, 2010? reserve all objections except as to form and 17 18 responsiveness. 18 MR. WOOLF: Asked and answered. 19 So if you have a form objection, please is THE WITNESS: I don't recall the date. 20 state it, but asked and answered is not a proper 20 Q. (By Mr. Hunter) Okay. When Mr. Withers 21 objection. 21 asked you and you related some information about 22 MR. WOOLF: Well, I'm going to state my 22 Mr. Hiers bringing steaks over and chewing on a pain 23 objection if you're asking her the same question 23 pill, did you pick-- strike that. You told him you 24 didn't know the exact type of pain medicine Lisa was 24 over and over. He's done it. 25 25 taking during that period of time? Is that correct? MR. HUNTER: Okay.
2

i Q. And this stuff you mentioned about the that she told you she was there when Paula Deen used

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MR. WOOLF: Asked and answered. THE WITNESS: I don't recall. 3 Q. (By Mr. Hunter) Okay. Now, do you recall 4 whether or not you picked up that -- that prescription 5 from the pharmacy? 6 A. I'm sure that I did. 7 Q. Okay. Do you recall showing them your ID B at the pharmacy when you picked up that controlled s substance? 10 A. No. ii Q. Do you recall signing your name to a piece 12 of paper when you picked up that controlled substance? 13 A. I don't recall, but I'm sure that I did. 14 Q. Did you read what that piece of paper said? is A. Nope. 16 Q. Do you know what duties and 17 responsibilities you had as the person who picked up 18 that controlled substance? 19 A. I do. 20 Q. Okay. And you're aware of those duties and 21 responsibilities because you're a nurse by trade; 22 correct? 23 A. I'm a nurse practitioner by trade, correct. 24 0. All right. And Mr. Hiers ate that pain 25 pill and on that same night he was drinking, was he
1 2

MR. WOOLF: Bill's done it, I've done it, it's been an accepted practice in these 3 depositions. 4 MR. HUNTER: Well, it's not a proper -MR. WOOLF: I'll try not to interrupt you, s 6 Bill. 7 Q. (By Mr. Hunter) What type of -- strike that. 8 When you -- when you overheard these conversations 9 where were you? ic A. Usually in the car. ii Q. Who kind of car? 12 A. I don't recall. 13 Q. Well, how did the speakerphone work in that 14 car? is A. They work on the phones. 16 Q. Oh, so it's a speakerphone on the phone 17 itself, not -- not a bluetooth system in a car or 18 something like that? 19 A. No. 20 Q. Okay. What type of phone was it? 21 A. I don't recall at the time. 22 Q. Okay. What-- do you recall Mr. Gerard's 23 voice? 24 A. I think so. 25 Q. Was it a very deep voice? i
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A. I cant really classify it at this point in time. It's been a while since I've heard it. 3 Q. Well, was it a-- well, describe his voice 4 for me. 5 A. lt wasn't very deep. 6 Q. Okay. 7 A. Somewhat soft -8 0. Okay. s A. -- from what I remember. 10 Q. Did you have -- strike that. Do you 11 remember any specific words that Mr. Gerard said during 12 any of these conversations? 13 A. Individual words? 14 Q. Yes, any words. 15 A. Yeah. Yes. 16 Q. What did he -- what did he say? 17 A. Bubba is a liability. 18 0. What else? 19 A. It's never going to change. Paula is 20 aware. 21 Q. Okay. 22 A. I've been to Paula to this numerous times, 23 I'll take care of it. 24 Q. Okay. What else? 25 A. That's about it.
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Q. Okay. Tell me every phone number you've used in the last five years, cell phone number? 3 A. The last five years? 4 Q. Yeah. 5 A. 912-441-3090. 6 Q. Okay, 7 A. And 404-989-9022. a Q. And who are the providers on those phones? 9 A. T-Mobile and Verizon. 10 Q. And I guess the T-Mobile is the 912 and the 11 Verizon is 404? 12 A. The 912 switched over to Verizori at one 13 point -- at some point. 14 Q. Right. Okay. And do you -- we talked 15 about Facebook. Do you also do anything like MySpace 16 or Twitter or anything of that nature? 17 A. 1 have a Twitter, yes. 16 Q. You have a Twitter account? 19 A. I do. 20 Q. And what is your Twitter address? 21 A. Silla Surnerlin. 22 Q. Okay. Does Lisa have a Twitter account?
1 2 23 24 25

A. No.
Q. Does she ever use yours? A. No, she doesn't know how to use Twitter.
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Q. And was it the same words each time that they talked? 3 A. No. 4 Q. Okay. When did this -- when did these 5 conversations take place specifically? 6 A. I don't have an exact date. 7 Q. Well, approximately when? a A. I can't even tell you approximately. 9 Q. You don't know what year? lo A. 2008. ii Q. But it was before May 27th, 2010. True? 12 A. True. 13 Q. Okay. You have never spoken with Jim 14 Gerard on the phone; correct? 15 A. No, I have not. 'a Q. Did he know you were listening when you -17 did you make your presence known? 1 18 A. She may have. I did not personally, no. 19 0. Well, do you recall Jim saying, hey, Silla, 20 how you doing, anything like that? 21 A. Nope. 22 0. Now, when -- and you've never spoken 23 directly with Karl Schumacher on the phone; is that 24 correct? 25 A. That is correct.
1 2

Q. Okay. Would it be fair to say that Karl Schumacher was Lisa's confidante in the workplace? 3 A. Not necessarily confidante. 4 0. And you described earlier as a -- as he was s her go-to person? 6 A. Yeah, I think she saw him as her boss. 7 0. Okay. And you related to Mr. Withers some a complaints that he -- that she had about Karl in terms 9 of sort of being religiously judgmental and things of 10 that nature? ii A. Correct. 1 12 Q. Did Lisa ever tell you that Karl Schumacher 13 called her names or harassed her, discriminated against 14 her in any way? is A. No. 16 Q. Okay. Mr. Withers -- and I know it's a 17 difficult subject to talk about -- but asked you about 18 Miss Jackson's history in relation to you, that history 19 of being raped. And he asked you, you know, how old 20 was she when this happened. 21 Is it your understanding that all these 22 occurred when she was either in her childhood or at 23 least sort in a teenager-24 A. I don't have any idea. 25 Q. Okay. Were you aware at any time of Al
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Sharpton being in Savannah, Georgia about Lisa's case? A. No. 3 Q. Did Lisa tell you that she was trying to 4 gather up other Uncle Bubba's employees to go meet with 5 Al Sharpton? 6 A. No. 7 Q. You're not aware of that ever happening? e A. No. 9 Q. Would that surprise you? 10 A. No. ii Q. Okay. MR. WOOLF: What did you say? 12 THE WITNESS: No. 13 14 Q. (By Mr. Hunter) Did Lisa express to you that 15 she was scared to go to - to go to work, she was 16 fearful to go to work at Uncle Bubba's? 17 A. Yes. 18 Q. Did she believe it to be and did she do 1.9 that - did she express those feelings in 2008 and 20 2009? 21 A. Yes. 22 Q. And did she fear-- did she feel like the 23 place was a -- a place where most employees, at least 24 the women and the employees who were not white should 25 have been or had the same feelings that she had?
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Q. Okay. Tell me where in that letter it says that she wants to escape Uncle Bubba's? 3 A. It doesn't. 4 Q. In fact, it says that she envisioned Uncle s Bubba's as a perfect place for these special events, 6 does it not? 7 A. It does. s 0. And it also says that she has been given 9 all the opportunity she ever thought possible because ig of Paula and Bubba; correct? ii A. It does. 12 Q. And that was May 27th, 2010; correct? 13 A. It is. 14 Q. That was true when you and Lisa wrote it; is correct? is A. Yes. 17 MR. HUNTER: Okay. No further questions. 18 MR. WITHERS: I've got some brief follow-up. i Can you pick me up? 20 RECROSS EXAMINATION 21 Q. (By Mr. Withers) Ma'am, you were served with 22 a subpoena Sunday evening for the purpose of being here 23 today, were you not? 24 A. Yes. 25 0. Thatsubpoenahadattachedtoit -- and
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A. No, not necessarily. I think she took the brunt of it. 3 Q. Okay. Do you recall given that -- given 4 her feelings while she -- when she was developing her 5 new plan or the things set forth in the May 27th, 2010 6 letter you all decided that Uncle Bubba's was the 7 perfect place for these events and this new plan? 8 A. As I stated to Mr. Withers, it was in an 9 effort to create a new position for her so that she io could remain with the company but escape the daily ii behavior by Mr. Hiers. 12 Q. Well, where does it say -- I'm going to 13 show what's been -- what I'm going to mark -- or strike 14 that. MR. HUNTER: Where are the exhibits? 15 16 MR. WOOLF: They're right behind you. 17 MR. HUNTER: I just need that letter. 18 Q. (By Mr. Hunter) Yeah. I'm going to show you 19 what's been marked again as Defendant's Exhibit 1 to 20 your deposition. 21 A. Uh-hmrri. 22 Q. Tell me where in that -- in that letter of 23 May 27, 2010, it says that she wants to escape from 24 Mr. Hiers? 25 A. It doesn't.
1 2

I'll mark this as Defendant's Exhibit 6 - documents that you were commanded to produce for the purposes of 3 this deposition. Does that look like a copy of the 4 subpoena you were delivered? 5 A. It does. 6 Q. That's marked as Defendant's Exhibit 7; 7 correct? a A. Correct. 9 Q. Excuse me. 10 A. Oh, 6 ii Q. 6? 12 A. - actually. 13 Q. Do you have any document that comply with 14 that subpoena? 15 A. My understanding is that they were already 16 in evidence. 17 Q. Did you bring with you any emails or 18 correspondence sent by you to a prospective employer or 19 employment agency from January 1, 2010 to December 31, 20 2010? Did you bring any such documents today? 21 A. Idid not. 22 Q. Are there any such documents? 23 A. "To any prospective employer or 24 employment -2 (Reading.) 25 There should just be the ones to LifeLink
1 2

1ihitScrip

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which you all already have a copy of. Q. Any other documents? 3 A. No. 4 Q. Did you bring with you the documents called 5 for in Paragraph 2 which is text messages, social media 6 messages, emails or other communications, and It goes 7 on, did you bring any of those documents with you? s A. They've already been provided to Lisa's s attorney. io 0, Did you bring any of those documents with 11 you here today? 12 A. 1 did not. 13 Q. Did you make any search for those documents 14 after receiving the subpoena? is A. No. 16 Q. All right. So you've arrived at this 17 deposition without having complied with a search for 18 any of the records that you were requested to produce 19 pursuant to the subpoena? 20 MR. WOOLF; I'll object to that to the extent 21 it calls for a legal conclusion. 22 THE WITNESS: Do I still answer? 23 Q. (By Mr. Withers) Yes. 24 A. I mean, I received this via email last 25 week. I looked last week, but I did not look any
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0. Simple question: You made no effort to locate any of those documents called for in that 3 subpoena. True? 4 A. They have already been provided. 5 Q. In response to that subpoena did you make 6 any effort to locate any document, yes or no? 7 A. Yes. 8 0. You did? s A. They were provided to Mr. Woolf. 10 Q. When did you provide those to Mr. Woolf? ii A. I've emailed him in the past week. 12 Q. All right. And when did that take place? 13 A. In the past week. 14 Q. With respect to Paragraph 1 did you email 15 documents to Mr. Woolf in the last week regarding those 16 documents? 17 A. No. 18 Q. With respect to Paragraph 2 did you -19 email documents to Mr. Woolf with respect to those 20 documents? 21 A. Yes. 22 0. And as we sit here today, the fact is you 23 don't have in your possession any documents that 24 respond to either of those paragraphs in that subpoena, 25 do you; correct?
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further. 0. Okay. Well, you received that same 3 subpoena prior to your last scheduled deposition on 4 February 15, didn't you? 5 A. No, I was not served a subpoena. 6 Q. Mr. Woolf forwarded that subpoena to you -7 A. Correct, 8 Q. --last week? 9 A. 1 believe so. 10 Q. What day did you receive it? ii A. I can't recall. 12 Q. All right. And you were served that 13 personally on Sunday, were you not? 14 A. Sunday night about 9 o'clock. 15 Q. All right. And so you knew that we wanted 16 those documents last week; right? 17 A. Correct. 18 Q. And you knew as of Sunday you'd been 19 personally served; right? 20 A. Correct. 21 0. And you made no effort to bring - to 22 locate or bring any of those documents with you today; 23 correct? 24 A. Mr. Woolf stated he already had everything 25 that we needed.
1 2

A. Correct. Q. All right. Now, earlier this month did you 3 take a computer over to Blue Hill Group Computer 4 Services for the purpose of obtaining a recorded 5 conversation from -- made by Miss Jackson of Karl 6 Schumacher? 7 A. Yes, I did. e Q. And where did you-- when did you take that 9 to Blue Hill Group? 10 A. I don't have the exact date. ii Q. Were you the one that took that computer to 12 Blue Hill Group and not Mrs.-- Miss Jackson? 13 A. l took itfor her. 14 0. All right. Have you ever listened to the 15 conversation that was recorded by Miss Jackson of Karl 16 Schumacher in July of 2010? 17 A. Yes. 18 0. And when did you listen to that? 19 A. The same day it occurred. 20 0. Okay. How was it that Miss Jackson 21 recorded Mr. Schumacher? 22 A. I believe on her phone. 23 Q. And why did she -- did she tell Mr. 24 Schumacher to your knowledge that she was recording 25 him?
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A. I have no idea. i A. Okay. Q. Did she give Mr. Schumacher a copy of that 2 Q. --for asking. 3 A. You're welcome. 3 recording? 4 Q. I learned that a few years ago. 4 A. I have no idea. s A. That's good. s Q. But she did bring it home and play it for s Q. And the two computers then are which 6 you that night or that evening? 7 computers? 7 A. Correct. e A. The iMac and the Macbook Pro. 8 Q. And what is that -- give me the nature and s substance of that conversation, if you would, please. s Q. Voila. Voila then. If I want to get Uncle 10 Bubba's computer back I can find it at Blue Hill Group? 10 A. The gist of this conversation was that 11 my understanding is that Bubba was stealing cash money ii A. Perhaps. 12 Q. I will, right? 12 from the bottom line of the restaurant that would 13 A. Yeah. 13 therefore impact her bonuses and salary. 14 0. You Just told me it was there. 14 Q. Anything else? is Outstanding. 15 A. That's all I remember. 16 Let me ask you this as well. That document 16 Q. All right. Do you know what the status of that work order with Blue Hill Group is at this point 17 asked for you to bring with you various social media. 17 18 in time? is Were you aware that Lisa Jackson was using your social is media accounts for the purpose of contacting Uncle 19 A. It's still open. 20 Q. Pardon me? 20 Bubba's current and former employees? 21 A. I didn't know at the time. I know it now, 21 A. Its still open. 22 Q. What does that mean? 22 yeah. 23 A. They're still doing data recovery. 23 Q. All right. And so you have the ability 24 then to get those communications that she's been making 24 Q. When was the last time you spoke to someone 25 through your social media accounts, right? 25 at Blue Hill Group?
2 Page 162 Page 164

A. Sunday. Q. Who did you speak with? 3 A. Musha (phonetic). 4 Q. And is that what he told you, that it's S still open, they're still trying to recover that data? 6 A. Correct. 7 Q. What computer is that? a A. The -- they have two computers. s 0. What computer did you take to them that you 10 and Miss Jackson had? ii A. They have two computers. 12 0. Okay. So it was on two computers? 13 A. Correct. 14 Q. Okay. Neither of which are recoverable at 15 this point in time? 16 A. Yes, they're recoverable. 17 Q. They are recoverable. 18 A. Yes, as long as the disk is not rewritten 19 or overwritten it's recoverable. 20 0. Because they still haven't been able to 21 recover it as today's date? 22 A. Well, it's about two Terabytes of data, so 23 I'm not sure if you're familiar. 24 Q. I actually do know what a Terabyte IS. 25 Thank you very much -1 2

I 1

A. If they're still available. I don't know that they were, 3 0. How many people did she contact through 4 your accounts? 5 A. I have no idea. 6 Q. You don't know whether it's two or ten? 7 A. No earthly idea. 8 0. All right. When did she tell you that she s had been surreptitiously using your social media 10 accounts for the purposes of contacting Uncle Bubba's ii folks? 12 MR. WOOLF: Objection to the 13 characterization. 14 THE WITNESS: I don't know that it was 15 surreptitious in behavior, but she frequently 16 just my Facebook, so I don't know. I have no 17 idea. 18 Q. (By Mr. Withers) Did she use your text as 19 well? 20 A. My text messages? 21 Q. Send and receive texts on your phone. 22 A. No. 23 Q. So it would just be your social media 24 account that she was using for the purpose of 25 communicating with Uncle Bubba's?
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PRISCILLA SUMERLIN February 26, 2013

Page 167 3. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page Line should read:
I, the undersigned, PRISCILLA SURLIN, do hereby certify that I have read the foregoing deposition and that to the beat of my knowledge said deposition is true and accurate (with the exception of the following corrections listed below)

A. Correct. Q. All right. MR. WITHERS: I think that's all the 3 4 questions I've got. Mr. Hunter? MR. HUNTER: One more question. 5 s RECROSS EXAMINATION 7 0. (By Mr. Hunter) Did -- Miss Surnerlin, did 8 you have any contact with Musha about the subpoena he 9 received? 10 A. He called me about it, and I told him that 11 he needed to call Wes. 12 Q. Okay. Do you -- did you have any -- did 13 you give him any instruction about whether he should 14 show up for his deposition on Friday? is A. No. 16 Q. And I asked you earlier if you had been 17 interviewed or things of that nature. Other than the 18 emails that you sent to Mr. Woolf, have you 19 communicated in writing with Mr. Woolf or Mr. Billips 20 or anyone in their office other that sending him these 21 documents as a result of the subpoena? 22 A. No. MR. HUNTER: No further questions. Thank you 23 24 very much. MR. WITHERS: Woolf. Woolf. 25
1 2 Page 166

ERRATA SHEET Pursuant to Rule 30)a) of the Federal Rules of Civil Procedure and/or Official Code of Georgia Annotated 9-11-30(e), any changes in form or substance which you desire to make to your deposition testimony shall be entered upon the deposition with a statement of the reasons given for making them.

To assist you in making any such corrections, please use the form below. If supplemental or additional pages are necessary, please furnish aeue and attach them to this errata sheet.

Reason for change: Page _Line_should read: Reason for change: Page _Lineshould read, Reason for change: Page ___Line should reed: Reason for change: Page Line should read: Reason for change: _____ PagaLine_should read:_ Page 166 Reason for change:

Mr. Woolf, let's --we can go off the video record. THE VIDEOGRAPHER: Nothing further? 3 MR. WITHERS: Nothing further. 4 THE VIDEOGRAPHER: This concludes today's 5 6 deposition of Priscilla Sumerlin consisting of 7 two tapes. We are off the record at 2:52 p.m. s MR. WITHERS: I want to stay on the record 9 for just a moment. If you would attach all of the exhibits to lo 11 the transcript. 12 And Mr. Woolf, I would like to receive if 13 she did -- in fact send you documents responsive 14 to the subpoena, I'd like to receive those. MR. WOOLF: Yes, you will. 15 16 MR. WITHERS: All right. 17 MR. WOOLF: I haven't checked that email in 18 the last week, but I believe the witness 19 incorrect, but you're entitled to them you will 20 receive them if I have them. MR, WITHERS: Thank you very much. 21 (Deposition concluded.) 22 i
2 23 24 25

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Page

Line

should read:

Reason for change:_________ Page Line should read:

Reason for change: Page Line should read, ______

Reason for change: Page _Line

should read:

Reason for change: Page Line should read; Reason for change: Page _Line_shou1d read: Reason for change:___________ PageLine_should read: Reason for change: _________ Page Line should read: Reason for change:

PRISCILLA SUMERLIN

Sworn to and subscribed before me this day of 1 2013. NotaryPublic; My Cosoission

1i

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1 DISCLOSURE STATE OF GEORGIA COUNTY OF FULTON DEPONENT PR3SCILLA SU14RLTN

PRISCILLA SUMERLIN February 26. 2013

3
4

Pursuant to Article 10.5 of the Rules and Regulations of the Board of Court Reporting of the udicial Council of Georgia, I make the following Judicial disclosure.

6 I em a Georgia Certified Court Reporter. I am here as an independent contractor for Wheeler Reporting Company, Inc. Wheeler Reporting Company, Inc B was contacted by the offices of Thomas A. Withers, Esguire, to provide court reporting services for this 9 deposition. Wheeler Reporting Company, Inc. will not be taking this deposition under any contract that is 10 prohibited by O.C.G.A 9-11-28 (c).

11 12 13 14 15 16 17 18
19

Wheeler Reporting Company, Inc. has no contract/agreement to provide reporting cervices with any part to the case, any counsel in the case, or any reporter or reporting agency from whom a referral might have been made to cover this deposition. Wheeler Reporting Company, Inc. will charge its usual and customary rates to all parties in the case, and a financial discount will not be given to any party to this litigation.

CARLA J. HOPSON, CCR# B-1816 March 14, 2013,

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4
STATE OF GEORGIA COUNTY OF FULTON CERTIFICATE

5
6

1 hereby certify that the foregoing deposition was

taken dawn, as stated in the caption, and the

7 colloquies, questions and answers were reduced to B typewriting under my direction that the foregoing 9 transcript is a true and correct record of the evidence

10
11

given. The above certification is expressly withdrawn and denied upon the disassembly or photocopying of the foregoing transcript, unless said disassembly or photocopying is done under the auspices of Wheeler Reporting Company, Inc., Certified Court Reporters, and
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12 13 14 15
17

16 the signature and original seal

I

attached thereto.

further certify that I am not a relative or employee

18 or attorney of any party, nor am I financially

19 20 2]. 22 23 24 25

interested in the outcome of the action. This, the 13th day of March, 2013.

CARLA J. HOPSON, RPR Certified Shorthand Reporter 5-1815

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LISA T. JACKSON V. PAULA DEEN, et al. $ $2,100(l)

PRISCILLA SUMERLIN February 26, 2013 22; 164:24

accounts (4) address (12)

115:9
$283.50(1)

163:19, 25; 164:4,10

accumulation (1)

115:13 A
Abdi (3)

87:10
accurate (7)

118:16; 119:11; 137:16

Abdi's (1)

119:1
ability (2)

59:3; 60:13, 23; 70:24, 25;77:7; 103:18

accurately (1)

13:5,9, 11; 25:12; 76:12; 77:17, 21;90:4; 113:25; 135:9,9; 151:20

addressed (1)

81:11; 84:1; 88:5; 107:6; 108:19; 112:11; 124:19; 130:9; 131:19; 143:8; 154:19
against (11)

153:5
alcohol (1)

50:4
allegation (3)

82:11, 20;83:2
allegations (3)

76:7; 131:6; 142:4

allegedly (1)

132:20
administered (1)

122:16
Allison (1)

4:18
adoptive (7)

108:2; 16323
able (8)

108:13
accusing (1)

131:9
acquainted (1)

17:8; 18:18; 60:10, 16;61:7; 68:12; 70:23; 162:20

absence (1)

104:17, 21,21, 22; 105:2, 15,24

Adrianna(11)

87:15
actions (2)

86:3,4
activities (1)

100:2
Absolutely (1)

131:24 actual (3) 31:14; 49:9; 106:17

actually (19)

14:11; 15:19, 21;16:3, 8,10,15; 18:15, 21;19:3, 23

advise (1)

10:13, 17,21; 11:1; 84:14; 94:21; 119:18; 120:11, 15; 131:2; 152:13
age (3)

64:20
Allison's (1)

64:21 allow (2) 81:8; 98:15

allowed (4)

107:20; 108:8, 24;109:8

all's (4)

104:8; 106:6; 131:10

agency (1)

156:19
agent (2)

113:4, 25; 117:23; 118:1

almost (2)

71:8
abuse (4)

84:13
afford (1)

80:19, 19; 105:9,12

abusive (7)

80:24; 81:6; 91:7,14; 105:6,7, 13

Academy (1)

6:22
accept (2)

47:13; 79:14
accepted (1)

148:2
accident (4)

50:17; 87:21; 120:17; 121:12

account (4)

5:20; 11:4; 25:2; 42:8; 44:21; 45:21; 46:21; 47:16; 87:19; 91:23; 101:23; 102:5, 17; 104:13; 114:18; 144:21, 23; 156:12; 162:24
acute (3)

126:15, 18
ages (3)

48:12; 99:11
although (1)

137:23 Africa (1) 39:24

African (10)

14:9; 106:8,21
ago (7)

72:2
always (1)

110:4
Ambrose (5)

29:19; 30:10, 24; 36:18; 55:12, 14;65:6; 71:21; 130:22; 133:3

Again (23)

14:20; 15:2,24; 31:18; 118:25; 121:17; 163:4

ahead (9)

18:7; 20:7,21; 23:23; 27:13;

42:9;

61:1; 67:7,22; 68:17; 79:1,19; 87:3; 101:6; 120:8

AJ (4)

47:9, 19;48:8; 51:3; 87:16 American (10) 29:20; 30:11, 24; 36:18; 55:12, 14;65:6; 71:21; 130:22;
133:3 amongst (1)

7:15, 20;8:20
addition (1)

95:14; 151:18,

73:17
additional (1)

141:17

51:23; 58:13; 65:25; 66:3; 79:23; 80:21;

18:11, 13,1421
Al (4)

38:11
amount (2)

129:22, 23; 152:25;

24:20; 115:10
angry (2)

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(171) $2,100 - angry

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 46 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 26:22; 28:21
answered (20)

PRISCILLA SUMERLIN February 26, 2013 2425; 138:1; 139:18

apply (1)

6:10; 67:6,21; 72:4; 73:15; 79:18; 87:2,9; 88:4; 89:25; 93:20; 101:10; 115:20; 118:20; 120:7; 127:15; 145:18; 146:1; 147:13, 20
Anthony (1)

139:14
appraised (1)

125:21
appreciate (1)

103:11
appreciated (1)

107:25
appropriate (3)

14:17, 14,17; 15:7; 16:15, 23; 18:19; 20:5; 50:19; 78:6,6, 14,19; 83:11,13
Ashley's (1)

98:6; 108:20; 122:8

approve (1)

20:19
Ashton (9)

144:20
approximate (1)

94:14
Approximately (4)

14:10; 15:18, 22,23; 16:2,10; 18:11, 13,23

ass (1)

76:12, 12; 77:16; 104:13; 112:25; 113:20; 114:7; 116:7; 118:15; 121:15, 17; 124:10; 128:8, 10; 137:15, 20
attach (1)

139:16
Aunt (7)

108:12; 109:14, 15,16, 18,22,24

authority (1)

85:9
available (1)

164:1
aware (26)

166:10
attached (1)

155:25
attachment (1)

12:16
anticipate (1)

8:25; 66:25; 150:7,8

April (9)

42:20
assigning (1)

135:15
attack (1)

86:2
associate (2)

136:24
attempted (2)

46:14
Antonia (1)

5:24
Antonio (1)

14:11
Anxiety (2)

139:5, 12
anymore (1)

30:10; 31:5,10; 32:24; 33:23; 34:24; 35:8,13, 22

area (2)

91:9; 108:3
associated (2)

125:15, 17
attended (1)

30:20; 99:8
assume (4)

100:6
attending (2)

137:23
apartment (2)

12:20; 140:1
argumentative (2)

6:2; 18:13; 82:12; 104:1

assumed (1)

31:21, 23
apologizing (1)

68:16; 81:4
around (7)

100:14; 131:1 attends (4) 96:16, 24,25; 97:1

attorney (3)

21:6; 29:9; 36:15; 79:12; 83:21; 84:1; 88:2; 89:22; 93:21; 95:1,4, 11;97:7, 9;119:9, 12,17; 129:22; 131:17; 139:13; 140:14; 146:20; 149:20; 152:25; 153:7; 163:18
away (2)

20:5; 114:9 B
baby (5)

111:25
apparently (8)

54:20, 24;73:8, 10,17; 75:5,11; 135:8

appear (1)

40:25; 41:5; 49:16; 65:1; 125:8; 143:10; 144:5

arrive (1)

138:5 assumes (7) 81:18; 84:9; 85:8; 91:15; 95:7,8; 101:4

assuming (1)

120:24; 121:7; 157:9

attorneys (1)

121:9
attributes (1)

37:2,5, 6;88:18, 19
bachelorette (3)

138:25
attributing (1)

62:19
appeared (1)

46:1
arrived (1)

97:19
application (2)

157:16
art (1)

139:22; 140:16
applications (1)

7:7
arts (1)

94:10 AT&T (1) 76:15 ate (2) 34:11; 146:24

Atlanta (22)

108:21
August (12)

88:13, 15,20
bachelors (1)

7:6
Ashley (19)

139:20
applied (5)

137:21,

13:19, 20,22;

9:24; 32:4,5; 48:19; 63:8,18;

47:12, 13 94:15, 15,18, 22,24; 129:12; 130:5; 134:1; 135:12;

7:6
back (35)

8:5; 15:5; 17:18, 23; 19:11; 32:17; 39:18, (172) answered - back

Wheeler Reporting Company www.wheelerreporting.com

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 47 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 24;42:5; 49:15; 55:15; 58:6,11; 71:13, 20;77:3; 80:9; 84:2,16; 93:17; 99:12, 19; 115:24; 116:18, 19; 117:1,6; 125:7; 126:10, 14,17; 130:18; 136:3; 141:11; 163:10
background (2)

PRISCILLA SUMERLIN February 26, 2013 9:2; 49:8; 91:10; 137:5

become (4)

44:2; 59:15; 70:4; 114:14; 115:25

better (1)

bluetooth(1)

127:11
Brandon (6)

148:17
board (2)

45:2; 119:10
boat (1)

86:22; 91:6; 110:4; 119:12

becoming (1)

118:23
beyond (1)

39:24
Bolt (1)

58:2; 98:24; 111:9; 127:11, 19,22

break (5)

67:11
Big (11)

80:7
bonuses (2)

111:1
bedside (1)

8:11
began (4)
1

52:3; 53:7; 67:17; 86:7

begin (3)

25:6, 19;26:1, 5,12; 27:20; 103:5; 130:17, 17; 142:23; 143:2

biggest (1)

56:13; 161:13
Boone (1)

6:8; 14:22; 71:7; 99:12; 141:5

bridal (1)

13:24
born (1)

19:18
boss (2)

90:3 brief (1) 155:18

bring (11)

90:13; 152:6
boss's (1)

51:18, 21;54:4
beginning (4)

11:16
bill (5)

140:18
both (14)

5:9; 6:19
backing (3)

51:16, 25;54:2; 99:20

behalf (1)

95:20; 96:1,2; 141:15; 148:6

Billips (2)

17:25; 31:13; 50:12

bad (2)

80:1
behavior (7)

85:23; 104:16
bank(3)

126:10, 14,17
base (2)

50:4; 55:5; 62:1; 122:5,8; 154:11; 164:15

behind (2)

142:2; 165:19 Bill's (1) 148:1

Billups (1)

141:22
birth (1)

68:21
birthday (6) 21:19;

50:2; 56:13
based (1)

102:10; 154:16
belabor (1)

25:13; 28:5; 30:3; 35:9; 49:25; 51:6; 55:4; 56:25; 92:10, 12; 111:8, 10; 114:18; 135:3
bottle (3)

45:16; 90:22; 156:17, 20; 157:4,7, 10; 158:21, 22; 161:5; 163:17
bringing (2)

116:6; 145:22
broken (2)

112:20; 117:12
brother(1)

13:16
brothers (1)

134:14
belief (2)

55:5
basis (11)

22:5,9, 9,15; 23:5

bit (1)

42:17; 43:17; 44:19

bottom (2)

13:15
brought (4)

21:3; 26:10; 81:7,15; 82:4; 83:3,6,

12,20,

103:18, 20
bell (1)

6:19
black (4)

134:14; 161:12
bought (1)

38:7; 73:8; 90:17; 130:18

Brunswick (2)

115:13
belonged (1)

125:2
below (1)

19:21; 40:14; 55:11; 85:15

blocked (1)

77:3
Boyer (2)

121:10,
13 brunt(1)

8:16,17
boys (2)

25;85:18
bathroom (1)

107:19
Belt (1)

154:2
Bubba (38)

141:5
Bay (7)

12:1
benefits (3)

37:4; 76:22, 24;77:6, 8;90:4,4

became (4)

56:11, 12,20
best (8)

22:2,4; 38:7;

15:8 blue (7) 123:18; 160:3,9, 12; 161:17, 25; 163:10

55:9; 61:8
brain (1)

63:18
Branch (4)

58:2; 98:24; 111:9;

4:10; 10:13, 17; 12:17; 26:22, 23;36:9; 38:15; (173) background - Bubba

Wheeler Reporting Company

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 48 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 39:2; 40:25; 41:5; 45:23; 55:13; 58:3,4; 62:11; 65:20; 66:23; 69:19; 71:3,19; 90:13; 107:20, 23; 108:1,4, 6,21; 109:16, 21; 110:14, 17; 127:23; 130:11; 140:8; 149:17; 155:10; 161:11
Bubba's(89)

PRISCILLA SUIrERLIN February 26, 2013 78:15, 20;79:3, 10;80:2, 12; 81:25; 83:19, 23;91:8; 94:21, 24;95:5; 98:11; 102:24; 110:21; 111:1, 20; 116:7, 20; 117:13, 23; 125:3; 127:24: 128:2; 129:15; 130:3,7, 21; 131:3; 132:25; 133:11, 19; 135:22; 136:19; 139:1, 16; 140:8, 21; 145:3; 153:4, 16; 154:6; 155:2,5; 163:10, 20; 164:10, 25
Buddhist (3)

13,14, 15,25
bussers(1)

55:15
buy (3)

111:21; 114:14; 115:25 C

cabinet (1)

46:10
cable (3)

76:11, 17;77:12
Cafe (3)

121:22, 25;122:2
call (16)

4:11; 10:13, 17,21; 11:2; 21:16; 22:3,10, 16,25; 23:6,9, 16,19; 24:2; 29:7,20; 30:5,21, 24;34:2, 6;35:11; 36:8,19; 37:15; 38:6,10; 50:9: 51:13; 52:11; 53:15; 54:17; 55:5; 58:8; 59:3; 61:25; 66:23; 71:19; 77:23;

18:13; 24:17; 25:19; 26:19; 28:8; 5222 62:2,21; 63:1,21; 64:17, 24; 109:14; 116:19; 128:8; 165:11
called (11)

23;31:4, 5,5,6,7; 33:2,2, 10,14, 23:34:2; 35:4; 37:1; 41:6,14, 24; 42:14; 45:11; 47:21; 67:20; 68:3,8; 73:5; 74:17; 79:3; 95:14; 103:15; 111:19; 124:7
camera (3)

52:20
car (11)

47:8; 50:14: 59:19; 120:17; 121:12; 124:6,9; 148:10, 11,14,17

card (1)

130:15
care (15)

117:21, 22; 123:23

can (28)

7:15, 20;8:20; 41:15, 25;51:3; 62:1,3; 108:3,9, 25; 109:8; 137:12, 18; 149:23
Carolina (1)

13:25
case (22)

21:25; 25:5; 31:12; 38:18; 39:15; 41:1; 44:3; 46:14; 52:22, 25:56:3; 58:22; 62:3,15; 67:7,10; 68:17; 71:10; 79:19; 99:13; 101:6; 128:8; 135:16: 141:4; 155:19; 163:10; 166:1
Canon (1)

99:5; 100:15; 101:3

business (7)

151, 13; 25:12; 58:2; 64:19; 124:4; 132:13; 152:13; 157:4; 159:2; 165:10
calling (1)

28:10
calls (2)

4:10; 15:22; 62:22; 64:19; 68:13; 76:7; 82:11; 89:14, 19,21, 24;94:6, 9:129:2, 24; 131:19; 141:16, 25; 142:3, 10,19; 153:1 cash (1) 161:11
casual (2)

11:22; 12:7; 62:11, 12,14; 130:22; 140:20

businesses (5)

68:15; 157:21
came (36)

65:22, 25
Caucasian (1)

11:12,

21:20; 22:3, 26:1,3: 2788 27:88

123:23
capacity (2)

19:21
caught (2)

8:22; 94:3
capture (1)

15:20; 16:8
celebrate (1)

Wheeler Reporting Company www.wheelerreporting.com

(174) Bubba's - celebrate

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 49 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 22:15 cell (5) 59:17; 95:9,12, 16;151:2
cellular (2)

PRISCILLA SUM]RLIN February 26, 2013 140:1

check (2) clarify (2) comical (1)

95:15, 18
checked (1)

5:12; 6:1
class (1)

84:22
coming (5)

131:23: 144:15
complained (2)

43:2
classify (1)

166:17
checking (1)

95:6; 96:2
center (5)

149:1
clauses (1)

95:14
chewing (2)

32:25; 45:12; 46:22; 100:10; 125:18

commanded (1)

98:3; 144:17
complaining (2)

60:22; 131:5
complaint (3)

109:7
cleaned (1)

8:11, 21;9:20; 10:2,6 CEO (1) 9:9

ceremonies (1)

42:18; 145:22
child (3)

156:2
comment (6)

70:1
clear (1)

103:25; 106:2,3
childhood (1)

88:1
clearly (3)

40:1,6, 9,16,19; 67:16

comments (23)

119:10; 120:10; 142:9

complaints (5)

100:16
certain (3)

152:22
children (6)

22:7: 98:15; 108:1

certainly (4)

44:8; 80:18; 84:2,4

certifiable (2)

14:7; 17:11, 13; 20:12, 20;50:22

children's (1)

55:9; 98:20; 125:19 clips (1) 132:7

CLK (1)

38:21; 39:7,19, 21; 40:12,

21;

56:9; 119:17; 132:6, 21;152:8

complete (1)

20:18
complied (1)

124:13
close (1)

80:14
closer (1)

14:9
chose (1)

51:25
club (2)

17:4,5
chance (2)

22:15
circle (3)

109:20; 110:2
Chancey (2)

123:18: 125:5,8
circumstance (1)

55:9; 61:8
clubs (1)

130:11
clue (1)

118:16; 137:16
change (3)

67:11
circumstances (6)

15:17
coincidence (2)

55:18; 65:24; 66:2,19; 67:24; 72:7,15, 23;75:1, 18; 97:14; 98:5,7; 132:8, 20,22; 147:5
communicated (3)

157:17
comply (2)

5:13; 156:13
computer (21)

9:11; 115:23; 149:19

changed (1)

39:4 52:18, 21,24; 53:4; 90:5; 91:4; 164:13

characterized (1)

5:9; 31:22; 50:13; 69:25; 86:15; 105:5 139:23

City (5)

78:22; 79:2
Cole (8)

128:3; 129:14; 165:19

communicating (3)

characterization (7) Cisco (1)

27:11; 30:13; 31:5,9, 11;

32:21;

59:17; 109:10; 164:25

communication (6)

70:16; 111:20; 112:2, 17,24; 113:18, 24; 114:13, i 16,25; 116:6; 118:5,8; 123:16, 20; 160:3,3, 11; 162:7,9; 163:10
computers (7)

11:21; 12:3; 19:13; 50:16,18

civil (3)

33:1; 40:10
collaborated (1)

110:7
collaborative (1)

20:19, 25;56:2; 128:5, 17,21

communications (2)

27:4
Characterizing (1)

60:24
charge (3)

26:23; 28:24; 29:1

claim (2)

102:4
collaboratively (1)

157:6; 163:24
Company (4)

38:17; 69:25; 162:8, 11,12; 163:6,7

concept (1)

104:5
College (1)

110:20
concerned (2)

64:4,6, 8
charity (3)

68:12; 147:8
claimants (1)

7:3
Comcast (2)

96:15; 97:2,8
Chatham (1)

131:9
claims (1)

131:2

76:19; 77:14 comfortable (1) 80:11

11:17; 102:22; 130:15; 154:10

complain (5)

91:6,11
concerning (2)

102:14; 103:1
concluded (1)

98:5,9; 130:10;

166:22 (175) ccli- concluded

Wheeler Reporting Company

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 50 of 78

LISA T. JACKSON v. PAULA DEEN, et al.
concludes (1)

PRISCILLA SUMERLIN February 26, 2013 121:19, 23

control (3) cooked (1)

100:2
course (3)

166:5
conclusion (2)

34:13
cooking (1)

19:13; 50:16,18
daily (10)

68:15; 157:21
conclusions (1)

81:19; 84:10; 85:9

controlled (6)

45:13
coons (1)

39:4; 80:10; 87:4

court (2)

40:13
Copeland (2)

97:24
condition (2)

85:5,7 conditions (8) 38:10; 54:5,5; 82:13, 23;84:7; 85:24; 138:23 conduct (1) 50:6
confidante (2)

44:5, 10,18; 146:8, 1218

conversation (22)

37:11; 88:24
copy (4)

5:18; 15:22
cousin (2)

152:2,3
confident (1)

47:14
Confusing (1)

52:25
consider (1)

44:6 considered (1) 126:23

consisting (1)

166:6
constant (1)

56:2
constitute (1)

14:18, 22;16:1; 52:12; 55:24; 56:24; 59:14; 61:12; 65:22, 25; 83:17; 90:15; 98:17; 132:3; 143:16, 17; 144:19; 145:6; 160:5, 15; 161:9,10
conversations (16)

133:19; 156:3; 157:1; 161:2

corner (1)

73:5; 74:9
cousins (1)

81:7, 15:82:4; 83:3,6, 12,20, 24; 85:18; 154:10

dark (3)

89:11
covering (1)

69:13, 13,13
data (3)

144:6
co-worker (2)

46:9
corporate (1)

161:23; 162:5,22
date (27)

55:6
corrections (1)

47:25; 48:3
crafting (1)

135:2
correctly (3)

102:5
Crazy (1)

28:11; 52:20; 144:13

correspond (3)

17:6
create (1)

154:9
CROSS (2)

16:2,4, 6 156:18
cost (3)

5:6; 141:13 57:10, 20,21: 58:11

cup (1)

correspondence (1) cruise (4)

96:7; 114:25; 115:17

counsel (3)

45:11
current (5)

120:22
contact (2)

164:3; 165:8
contacting (3)

129:22; 163:19; 164:10

content (1)

74:16
contest (1)

6:12
continue (2)

8:21; 49:4
continued (1)

21:8; 38:20; 39:6; 53:11, 16;55:4, 10,17; 59:9; 61:24; 75:11, 13; 112:6; 148:8; 149:12; 150:5
Conveyor (1)

4:7; 67:16; 93:23

counseling (4)

102:24; 129:14; 130:3,6; 163:20

Currently (2)

106:24; 107:1,4, 6
counselling (1)

13:7; 138:1
custody (1)

4:5; 18:3,7; 49:9; 51:23; 52:4; 54:9; 65:18; 79:12, 23; 87:16, 17; 94:13, 14; 123:10; 124:22; 133:12, 24,25; 134:4; 137:2; 138:9; 145:9, 19; 150:6; 160:10; 162:21
dated (2)

107:7
count (3)

19:1
Cyrus (12)

60:18; 61:2; 74:25

County (1)

12:1
Conyers (1)

140:1
couple (7)

139:4
Continuing (2)

103:22; 107:18
contract (1)

104:13 coo (1) 9:9

cook (3)

126:6
contractor (2)

42:2; 45:12,14

5:16; 22:1; 33:2; 47:22, 24; 48:11;

12:16; 14:11; 15:19, 21;16:3, 8,10,15; 18:15, 21;19:2, 23

0

134:6, 19
dating (2)

51:11; 67:18
daughter (1)

89:9
day (17)

25:6, 11;26:4, 12,15; 34:21; 67:19; (176) concludes - day

Wheeler Reporting Company www.wheelerreporting.com

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 51 of 78

LISA T. JACKSON v. PAULA DEEN, et at. 68:3,8; 87:12, 20; 114:18; 133:10; 135:25; 136:2; 158:10; 160:19 de (7) 45:20, 23;46:3, 20; 140:4,5, 7
dead (1)

PRISCILLA SUMERLIN February 26, 2013 410, 14; 141:16

Defendant's (12)

101:15, 17; 102:12; 110:23; 111:7; 123:9; 124:19; 133:14; 134:15; 154:19; 156:1,6
define (2)

142:23; 154:20; 156:3; 157:17; 158:3; 165:14; 166:6,22

depositions (3)

72:11, 15; 76:20; 93:12; 106:22; 110:21; 121:18, 23;123:2

difficult (3)

131:10, 25
discriminatory (2)

49:17; 55:20
discuss (7)

34:5; 74:7;
81:22;

4:20; 142:20; 148:3

Depression (2)

5:19; 6:15; 152:17

difficulties (1)

139:5, 12
depth (1)

83:18, 22; 110:19; 137:21

discussed (13)

91:3
difficulty (1)

105:10
describe (6)

84:17
dinner (16)

63:18
death (1)

5:19; 122:11
degree (4)

50:13
debatable (1)

84:25
deceased (2)

7:5,19, 22,23
degrees (2)

19:20; 53:9; 54:12; 69:7,12; 149:3

described (8)

14:5; 104:22
December (5)

7:6,8
delayed (1)

138:18
delivered (1)

113:21; 138:6,7, 12; 156:19 decide (1) 137:20 decided (1) 154:6
deemed (1)

156:4
Deiphine (23)

98:19
Deen (22)

4:4,13; 57:21; 80:2,6; 102:14; 103:2,5; 110:17; 131:19, 24; 132:18, 22;
141:15,

27:10, 20,22; 28:1,3, 16; 29:14; 30:13, 16; 33:14, 17,20; 34:24; 35:4,7, 13,18, 22; 128:4,6, 14,21; 130:8
Delphine's (1)

56:7; 86:22; 88:20; 911; 100:10; 133:5; 139:11; 152:4

describing (5)

22:13, 18; 24:21, 23;31:6; 33:12, 1618, 24;34:5; 36:17; 37:16, 18;42:2; 50:9; 145:11
direct (2)

34:9; 38:23; 67:23; 70:5; 72:12; 74:17, 19; 83:14, 16; 88:11; 107:7; 110:22; 127:23
discussing (2)

28:5; 111:14
discussion (5)

65:21; 81:12
directed (1)

43:6, 14;44:2; 53:14; 69:11

description (1)

122:7
direction (1)

34:18; 58:5,18, 19,23

discussions (3)

103:25
directly (2)

57:6; 72:16,19
disk (1)

69:10
design (1)

134:11; 150:23
dirty (4)

162:18
display (1)

112:19
despairment(1)

39:18
destination (1)

90:16, 19,22,24
discharge (1)

76:2
dispute (1)

115:17
distinctive (1)

111:2
developing (1)

49:2
discrepancies (1)

25:4
ditch (1)

31:12
depicts (1)

154:4
Diane (2)

56:16
discrepancy (1)

102:21
diverticulitis (3)

4:3; 62:20, 23;63:4, deep (2) 8;99:16, 21; 148:25; 149:5 101:17; [defendants (119:23; Mi-t .S j

15; 143:5, 11,19; 144:1, 10;145:2

125:1
deposition (18)

12:12, 13
died (1)

56:11
discriminated (1)

152:13
discrimination (9)

137:5; 139:2,12
divulging (1)

19:14
difference (3)

56:8; 84:18,23
different (10)

11:4;

51:16; 52:10; 53:10; 54:6,17, 20;56:1;

67:4
dock (3)

58:4,7, 11
docked (1)

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(177) de - docked

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 52 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 58:3
doctor (3) Dora (6) during (7) effort (6)

PRISCILLA SUMERLIN February 26, 2013 33:25; 34:12, 22;35:2, 418

doubt (2)

45:4; 64:4; 119:9

doctors (2)

10:9; 118:14
document (3)

13:24; 43:5
down (9)

53:12; 100:5,9; 127:22; 145:25; 147:3; 149:11

Dustin (3)

102:4, 21: 154:9; 158:21; 159:1,6

either (15)

156:13; 159:6; 163:16

documents (20)

64:13; 142:18; 156:1, 20,22; 157:2,4, 7,10,13; 158:16, 22; 159:2, 1516, 19,20, 23; 165:21; 166:13
dog (2)

5:18; 14:22; 42:12; 52:4; 70:12; 114:2,4; 134:2,2

Dr (10)

54:21; 56:1,9
duties (3)

63:20; 146:16, 20
duty (4)

118:16, 16,17; 119:1, 11; 136:20, 23; 137:3, 10,16

draft (3)

43:22, 24;44:2, 24
dying (1)

48:17
dykes (1)

16:15; 49:16, 20,23; 50:5; 55:6; 79:6; 80:1,5, 19; 120:4; 122:13; 138:5; 152:22; 159:24
Elaine (1)

139:6; 142:16; 149:18, 24; 161:14 email (18) 20:14, 19; 55:19; 73:24; 74:13; 133:16, 25; 134:6,9, 11,12, 16; 135:8; 157:24; 159:14, 19; 166:17
emailed(4)

75:4 E
earlier (8)

131:12
electronic (1)

96:1
Elizabeth (1)

135:25; 136:1,3; 159:11

Emails (10)

95:15, 18;103:5
dress (1)

37:18, 18
Doku(2)

133:4
drew (1)

136:20, 23
dollars (3)

97:24
drinkers (1)

29:14; 83:14; 84:3,16; 88:13; 152:4; 160:2; 165:16

early (2)

14:11
else (39)

98:16
drinking (3)

10:16; 11:1; 115:23 done (7) 32:18, 21;96:4; 136:5; 147:24; 148:1,1
Donna (3)

45:11; 146:25; 147:4

drive (4)

56:4; 130.25
earthly (1)

164:7
East (1)

115:15; 124:7,9, 16
drop (1)

90:4
eat (3)

24:21, 23;30:8
eaten (1)

24:18
drug (2)

105:16, 18,20
donor (3)

42:15
eating (2)

43:4,16
drugs (1)

63:24; 64:5,6
donors (2)

17:3
due (2)

62:22; 63:18
donor's (1)

24:20; 63:22 duly (1) 5:4

Dunston (2)

30:7; 34.16 EE (1) 131:8

EEOC (2)

131:1,9
effect (3)

64:10
door (1)

130:23

136:20; 137:10

15:14: 2419; 26:24

26:25; 27:4; 28:10; 29:3,4; 30:15; 33:20; 36:14; 37:14; 38:3,22: 39:15; 40:21; 41:18, 20;42:6; 45:9,18; 53:20, 25; 55:22; 58:22; 62:5,15; 69:14; 72:22; 73:11; 75:10; 82:5; 99:2; 107:14; 128:20; 130:16, 19;

38:16; 39:9; 73:16; 74:3,4, 19,23; 156:17; 157:6; 165:18

emergency (3)

63:14, 17,20
emergent (2)

62:22; 631
emotional (2)

105:11; 138:25
emotionally (2)

105:8, 13
employed (2)

36:23; 102:23
employee (6)

10:20, 25;88:9; 118:6; 122:14; 129:14

employees (13)

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(178) doctor - employees

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 53 of 78

LISA T. JACKSON V. PAULA DEEN, et al. 10:7; 11:22; 36:19; 38:11; 98:13; 128:2; 129:25; 130:6, 22; 153:4, 23,24; 163:20
employer (5) Enterprises (2)

PRISCILLA SUMERLIN February 26, 2013 80:2,6

entitled (1)

166:19
environment (2)

106:8; 136:14; 145:24; 150:6; 160:10

exactly (4)

124:8
experienced (1)

98:25
faggots (1)

107:21
expose (2)

75:4
fair (31)

82:5,10
express (2)

83:16; 91:14
envisioned (1)

155:4
escape (3)

27:7; 42:24; 87:16; 104:11

EXAMINATION (4)

153:14, 19
expressed (2)

154:10, 23;155:2
especially (1)

103:17; 143:19
expression (1)

45:7; 119:5,6; 156:18, 23

employment (10)

143:22
estate (3)

5:6; 141:13; 155:20; 165:6

examined (1)

107:22
extent (4)

126:6, 15,18
estranged (1)

5:4
except (4)

67:5; 73:14; 96:20; 157:20

ex-wife(4)

34:1; 39:4; 51:13; 56:5,8; 130:3; 136:18; 139:25; 156:19, 24

end (5)

16:23
estrangement (1)

17:2
even (1)

55:14; 66:24; 74:13; 147:17

exchange(1)

57:10; 58:19; 75:11,14

eyes(1)

150:8
evening (4)

131:16
Excuse(6)

69:13 F face (1) 28:23

Facebook (11)

22:25; 46:20; 155:22; 161:6

event (4)

51:25; 56:5,7; 99:15; 117:10

ended(6)

90:6; 111:2; 117:12, 13

events (2)

64:21; 68:2; 118:16; 124:1; 143:7; 156:9

Exhibit (13)

6:2,3; 17:2,15; 18:6; 20:7; 34:7; 52:18, 21,23, 24;53:4; 56:3; 75:24; 77:11; 78:16; 80:12; 91:4; 102:9, 11,12; 107:22; 110:1; 111:15, 15; 114:7; 121:6; 129:5; 143:12, 13;152:1
fairly (5)

45:13; 79:2; 114:19; 116:6; 126:10; 131:14

endorsed (1)

154:7; 155:5
everybody (3)

26:3,4; 37:8
evidence (5)

111:10
ends (2)

39:24; 133:4
endurance (1)

91:16; 95:8; 101:5; 123:24; 156:16

exact (16)

101:15, 17; 102:12; 110:23; 111:7; 123:9; 124:19; 133:14; 134:15; 135:21; 154:19; 156:1,6
exhibits (2)

21:2,4; 123:10, 11,13; 124:20; 128:23; 129:1,6; 151:15; 164:16

facility (4)

103:1; 109:9; 110:9, 16;126:3

faith (3)

108:10; 109:4,8
fall (2)

48:19, 24:49:5; 116:3

fact (4)

52:1; 56:4 failing (1) 131:13

false (1)

6:12
engage()

50:6
engagement (1)

94:1
enough (4)

77:11; 111:15, 15;121:6

enter (1)

130:22

18:3,7; 23:10; 27:7; 51:23; 54:9; 65:18; 70:18; 74:16, 16; 94:13;

154:15; 166:10
exist (1)

115:15; 155:4; 159:22; 166:13

facts (5)

108:18
familiar (2)

136:8; 162:23
family (10)

81:23
existent (1)

106:1
expected (4)

82:13, 22;84:6; 85:6

Expedition (1)

83:9; 91:15; 95:7; 101:4; 123:24

faded (1)

22:20, 23;73:6; 88:8; 93:13; 97:10;

128:8,9,

21:23
faggot (1)

18,19
far (3)

Wheeler Reporting Company www.wheelerreporting.com

(179) employer - far

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 54 of 78

LISA T. JACKSON v. PAULA DEEN, et al, 21:11; 77:15; 105:22
farm (5)

PRISCILLA SUMERLIN February 26, 2013 13:12, 13; 25:23; 27:8; 32:1; 36:22, 25; 39:22; 49:10, 11; 62:10; 121:23; 123:1; 127:20; 163:4
fifth (2)

65:1; 111:16, 24
fired (3)

follow (3)

forwarded (3)

17:8; 49:4; 56:13

followed (1)

134:15; 135:8; 158:6

forwarding (1)

11:9; 13:8; 93:5,13; 97:10 fascia (1) 42:12

fashion (3)

28:9; 55:13; 71:22

firm (1)

26:3
following (3)

133:16
forwards (1)

147:9
first (14)

49:2; 100:13; 139:15

follows (2)

133:19
fostering (1)

104:16
found (6)

16:24; 128:3; 132:9 father (6) 11:10; 19:5; 68:25;

69:3;

26:20; 28:25
fifty (1)

104:21; 106:3
father's (1)

75:23
file (1)

5:4; 8:9,12; 30:3; 46:24; 76:22, 23;77:6; 87:17; 94:5,8; 111:18; 124:7; 137:24
fit (1)

5:5; 66:5
follow-up (1)

155:18
Fontaine (7)

57:9, 17,24, 25;59:1; 138:11

four (9)

45:20, 23;46:3, 20; 140:4,5, 7

food (1)

131:19
filed (6)

10:7; 18:9,11, 15;21:8; 106:11; 120:3; 131:1,9

fourth (1)

12:15
favor (1)

55:9
five (24)

34:13
Foods (3)

66:15 fear (1) 153:22

fearful (2)

120:10, 15; 121:4; 129:11; 131:2,2

filing (5)

63:21
fracas (1)

53:21; 153:16
February (9)

4:5; 17:25; 18:1,5; 62:19, 24;63:5; 64:18; 158:4

FedEx (1)

10:12, 21;11:1; 94:21; 128:1

finally (1)

138:13
finances (1)

96:20
financially (1)

137:22
find (3)

114:14
feel (3)

108:1, 20; 153:22

feeling (1)

7:24; 17:9; 163:10

finding (1)

14:20; 15:23; 16:7,14, 18,20; 17:15; 18:1; 21:14; 23:12; 60:5,6, 10,15, 21; 61:22; 66:25; 70:22; 75:23; 87:4; 127:16; 147:10; 151:2,3
Flags (1)

139:23; 140:3,16
forced (1)

25:15
frame (11)

122:15
Ford (1)

124:8
Forget(3)

15:13; 76:24; 123:6 form (3) 147:15, 17,19

former (8)

19:7, 23,24; 36:4; 52:5,16, 16; 54:10; 57:4; 73:7; 113:22 frankly (1) 127:18
Frazier (1)

119:5, 6,24; 129:14, 25; 130:3,6; 163:20

Formulating (1)

25:9
freedom (2)

107:21; 108:1
Frequent (1)

53:21
fine (I)

128:19
Florida (3)

55:17
frequently (6)

110:10
feelings (3)

102:7
forth (3)

4:21
finish (6)

153:19, 25;154:4
felony (2)

19:13; 50:16,18
folks (8)

44:3,6
felt (1)

103:17
few (18)

11:6,8, 19;

46:12, 18; 60:19; 66:15; 78:23; 117:4 finished (4) 52:15;

10:5; 29:24; 30:5; 36:8,18; 38:19; 90:11; 164:11

116:18; 136:4; 154:5

fortunate (1)

143:24
forward (3)

134:3; 135:14; 140:21

16:16; 39:17; 55:8; 75:4; 130:14; 164:15 (7) Friday 1 62:19, 24;63:5, 22; (180) farm - Friday

Wheeler Reporting Company www.wheelerreporting.com

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 55 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 64:18; 65:4; 165:14
friend (3)

PRISCILLA SUMERLIN February 26, 2013 109:19; 126:13, 17

gay (2)

10:4,12, 15 gist ( 1 ) 161:10

given (5)

45:15
ground (4)

37:19, 21;81:8
friendly (1)

73:7; 74:13
gender (3)

5:16; 6:4,6; 144:6

group (7)

124:1, 18; 133:13

handbook (6)

118:6;
133:20,

110:2,
12;

26:10
friends (10)

55:21; 75:2,19
general (2)

154:3,3; 155:8
giving (2)

21:2; 22:22; 25:24; 27:4; 29:12, 15,20; 89:8; 129:1,7

front (6)

52:5; 122:1
generally (2)

6:2; 126:10
glimpse (2)

101:3; 160:3,9, 12; 161:17, 25; 163:10

grow (1)

22,23; 134:21; 135:23

handed (1)

135:21
handing (1)

124:23
handle (1)

9:16; 126:23
generated (1)

15:20; 16:8
GMail (1)

6:19
guess (20)

62:3
handles (1)

142:19
gentleman (1)

135:8
goes (3)

38:25; 39:14, 19; 49:19; 55:14; 130:23

full (3)

141:21
geographic (1)

106:17
geographically (1)

81:19; 96:16; 157:6

Goetz (1)

106:18
Georgia (9)

11:17
good (7)

5:22; 18:24; 19:2

function (2)

97:2,8
functioned (1)

6:20; 7:4; 11:8,9; 13:8; 93:2,8; 121:11; 153:1

Gerard (14)

6:4; 13:21; 14:2; 91:18; 143:5, 11;163:5

goodness (2)

51:7 furniture (1) 32:13

further (5)

155:17; 158:1; 165:23; 166:3,4 G

gala (1)

55:5; 56:25; 59:6,14, 23; 60:16, 22;62:2, 8,9,16; 147:9; 149:11; 150:14
Gerard's (1)

70:12; 83:10
go-to (3)

27:13; 28:23; 38:17, 21,24; 54:24; 55:11, 15; 66:11; 73:18; 75:12; 121:19; 122:10; 123:11; 130:15; 132:3, 12; 133:3; 139:4; 151:10
guessing (1)

96:19
handy (1)

136:9
hang (1)

33:5
happen (5)

21:14; 38:15; 60:2,3,7

happened (9)

97:20, 21;152:5
gracious (2)

24:10; 26:15; 70:19, 22; 112:2; 122:12; 126:9; 140:15; 152:20

happening (1)

27:12
II hair (1)

153:7
happenstance (1)

70:13; 83:11
graduate (2)

24:9
happy (2)

6:23; 7:18
graduated (2)

69.13
half (6)

5:13;
6:8 harassed (1)

97:1
game (2)

148:22
gets (1)

7:9,10
graphic (1)

90.17, 22
Garden (2)

84:16
get-together (3)

112:19
great (1)

21:8; 67:1,20; 68:4,9; 79:11

Hammock (4)

152:13
harassing (3)

11:21; 12:3
gather (1)

34:5, 10;36:6
get-togethers (5)

78:20
Greenwood (5)

153:4 gathering (1) 100:21

gave (4)

36:17; 37:15; 38:5,9; 67:2

Gill (4)

89:12, 23; 92:15; 93:1,4

grew (1)

125:25; 126:2,5, 7
hand (8)

68:7; 84:20,21
harassment (19)

107:20;

12:23
grill (1)

9:10;

33:3; 44:21, 22; 45:12; 101:14;

67:19; 68:2,3 7,13; 80:24 81:7,14; 82:414, 2183:2 6,11,20, (181) friend - harassment

Wheeler Reporting Company www.wheelerreporting.com

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 56 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 24; 85:17; 88:2; 131:25
hard (1) herself (4)

PRISCILLA SUMERLIN February 26, 2013 97:21

Hill (14)

98:20
horrid (1)

15:2; 108:3; 109:8,9

Hey (2)

115:15
Harrison (8)

47:9, 12,19; 48:8,18; 49:12; 51:5; 87:17

Harrison's (1)

134:24; 150:19 Hi (1) 134:24

Hiers (56)

51:3
hat (1)

39:21
head (6)

5:18, 20; 23:25; 37:13; 38:4; 132:5

headed (1)

103:25 hear (9) 6:16; 24:3; 25:15; 40:6,15; 61:9; 93:23; 126:22; 144:12
heard (6)

71:23; 91:24; 127:8; 133:7; 145:7; 149:2

heart (2)

16:23; 103:17
heartfelt (1)

103:20
hello (2)

15:4,5
help (3)

26:8; 31:4,7
helping (3)

4:10, 10;23:2; 24:3,4; 25:2,13; 28:21; 29:7; 39:20; 40:2,6, 8,15,18, 25;41:5, 16,22; 46:4; 49:16; 53:19; 55:18; 56:21; 57:17; 59:1; 65:24; 66:2,20; 67:24; 69:19; 70:16; 71:3,19; 72:8,18, 24;74:5; 75:3,8, 17; 90:13; 100:10; 107:23; 108:1,4, 14,21; 109:10; 127:23; 130:11; 140:8; 145:22; 146:24; 154:11, 24
high (4)

11:8; 12:20, 24;13:3, 11; 92:20, 21;93:2; 160:3,9, 12; 161:17, 25; 163:10
himself (2)

38:10
Hospital (7)

30:13; 31:13, 17;32:1, 3,6

Hungary's (2)

8:7; 9:3; 41:14; 44:11; 46:23; 49:3; 64:1

hospitalized (2)

31:14, 23
Hunter (23)

41:13; 42:1
hostess (3)

41:16; 71:20
hire (1)

138:18
hired (3)

55:12; 65:7; 71:22

hostile (1)

55:11, 12;65:7
hiring (2)

53:17
hours (3)

78:21; 79:5
Hispanic (2)

24:20; 64:25; 122:3

House (32)

4:13; 123:25; 141:2,4, 7,14,15; 143:9; 145:20; 146:3; 147:14, 25; 148:4,7; 153:14; 154:15, 17,18; 155:17; 165:4,5, 7,23
husband (1)

19:21, 22
history (3)

122:9; 152:18, 18 hit (2) 47:8; 50:14

home (14)

13:3; 41:14; 43:24, 25; 59:17; 65:1; 74:7,17; 77:1; 80:6; 112:22; 125:13; 126:10; 161:5
homeless (5)

32:19; 33:7; 118:6

6:21; 37:19, 21;63:22

higher (1)

103:24; 104:8, 12,15; 105:1

homes (1)

4:12; 30:2; 31:8; 32:18, 22; 35:22; 37:20; 38:25; 39:19, 19;41:6, 12; 55:14, 15;77:1, 1,3,3; 92:13, 15,21, 22,23; 93:1; 116:16, 20; 130:18; 135:22, 22; 137:23; 138:10, 12
houses (1)

37:17
husbands (2)

119:20, 24
husband's (1)

14:5
hypothetical (1)

81:10

175 (1)

121:14 ID (1) 146:7

idea (22)

13:12
hung (1)

11:6
homosexuality (1)

15:7
Hungary (6)

11:23; 14:2; 23:11; 38:2; 48:20, 22;49:6; 70:9,11, 14; 97:12; 1064 109:24; 110:19; 111:10; 121:5; 152:24; (182) hard - idea

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 57 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 161:1,4; 164:5,7, 17
identified (1)

PRISCILLA SUMERLIN February 26, 2013 48:13

incidences (1) intentional (1)

44:11
invite (1)

24:14
interaction (3)

35:10
incident (7)

30:23
involved (2)

101:16
identify (1)

4:7
ill (1)

42:14
illegal (1)

25:7, 20;29:4, 8;47:11; 87:17; 143:2

incidents (1)

26:6, 19;28:8
interactive (2)

49:8; 120:17
involvement (1)

14:18, 21
intercourse (2)

59:2
island (2)

74:14 Mac (7) 111:19; 112:2; 115:7; 118:5; 123:16, 20;163:8

Immediate (3)

34:25
income (1)

122:15, 16
Intermezzo (3)

46:7,8
issue (3)

125:18
incorrect (1)

121:22, 25;122:2
interrupt (7)

25:12; 52:10; 65:20

issues (7)

60:16, 21; 61:15, 18;65:6, 8,11; 67:18; 69:18; 71:2,2, 18,23; 72:8; 73:3,13; 74:5; 75:17; 76:8,8,
21;
1

166:19
independent (4)

8:14; 10:7; 97:20

immoral (2)

110:4, 11; 121:19, 22

indicated (1)

17:19
individual (2)

52:14; 66:8; 111:16, 24; 112:1; 125:24; 148:5

interruption (1)

38:24; 39:11, 13,16; 73:22; 100:6; 139:4

items (1)

124:5

98:19, 20
impact (2)

136:5; 149:13
individually (1)

66:16
interview (1)

139:25
interviewed (4)

80:15; 161:13 important (1) 143:1 improper (1) 65:23

inappropriate (21)

4:11 i nduced (1) 139:3

Industrial (4)

Jack (1)

11:14, 16,18; 12:1

influence (1)

38:20; 39:6; 40:11; 49:21; 55:18; 66:2,19; 67:23; 72:7,14, 23; 75:18; 90:13; 97:14; 98:5,7; 122:5, 10; 132:9, 20,22 Inc (1) 4:12
incarcerated (2)

6:14
information (2)

54:25; 145:21
informed (1)

78:17; 141:24; 142:6; 165:17 into (11) 33:7; 57:12; 63:20; 84:4: 102:2,7, 9; 110:23; 111:7, 19; 122:15
intolerable (3)

48: 6
Jackson (139)

65:6
initial (1)

53:12
initially (1)

136:6
initiated (1)

82:21; 105:3,4
intoxicated (7)

28:8
inside (1)

34:11
instance (5)

48:11, 12
incarceration (1)

35:14, 18; 74:12; 82:11; 142:24

instruction (1)

38:16; 39:2; 49:24; 50:1; 53:19; 65:20; 122:14

introduced (1)

101:13
inventory (1)

165:13

44,17 5:10; 10:12, 16:20, 25, 18:12; 19:25; 28:18; 29:6; 35:10, 14,19; 36:6; 46:24; 47:19; 48.6; 49:4; 51:12, 21:52:3; 53:5,8, 13; 54:16; 56:23; 57:15, 18 58:10, 23;59:2, 3,14,23;

77:21; 78:11, 16,18; 79:4,7, 10,17; 80:1; 82:20; 87:14, 18,24; 91:2,8, 24; 94:11, 20,23; 95:2,16; 97:13, 17;99:5; 100:1, 14; 102:13; 103:14; 104:4,7, 25; 105:14; 106:5, 10,21, 24; 107:3,4, 9,23; 110:9, 19; 111:18; 117:9, 15,22; 118:14; 119:4, 10,18, 21,25; 121:16; 122:19; 124:7; 126:22;

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(183) identified - Jackson

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 58 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 129:11, 22: 130:10; 131:1,5, 9,14,18, 23; 132:21; 133:6, 11,17; 134:4; 136:17; 137:19; 138:24; 140:24; 143:4,9,
18;

PRISCILLA SUMERLIN February 26, 2013 22:62:2; 135:3; 147:8; 150:13, 19

job (10) Karl (27)

9:11; 77:24; 78:14, 19:79:3; 81:22; 137:24, 25; 139:14, 19

jobs (3)

160:5, 12,15, 20: 162:10; 163:18

Jackson's (9)

107:13; 121:16; 137:22 join (1) 101:3

joined (1)

54:19, 21;55:4; 56:3,25; 61:10, 1318; 62:1; 91:19: 92:2; 97:13; 101:9; 111:8, 12,21; 133:17; 134:6, 16,24, 25; 150:23; 152:1,8, 12; 160:5,15
Karl's (1)

23;26:2; 29:22, 24; 38:24; 39:14, 25:46:7; 90:15

knew (22)

98:11
Lady (10)

68:21; 103:17; 104:20; 105:23; 108:14: 109:22; 134:16; 140:16; 152:18

Jamie (5)

101:5
joining (1)

134:12
keep (1)

101:5
jokes (4)

112:4
Kennestone (1)

15:11; 29:21; 58:4; 62:12, 23:63: 4 ; 68:22; 78:21; 79:5,6; 81:6,14, 24;82:1, 10; 84:12; 87:25; 94:15; 140:4; 142:3; 158:15, 18
knowing (2)

34:6; 36:9; 38:6; 55:6,8; 61:7; 88:14; 140:21; 143:5,11

Landings (1)

76:23
language (7)

49:18: 50:7; 103:14; 126:23; 144:11, 23;145:3

large (2)

54:20; 88:7
last (42)

39:23, 23; 72:11,15

Jones (2)

64:1
kept (1)

137:7
kids (1)

82:2; 83:9
knowledge (14)

27:10; 128:4
judge (1)

17:19
killed (3)

37:22; 89:5,6, 7,9

January (10)

86:7
judgment (1)

19:5,8, 10
kind (21)

98:12
judgmental (1)

100:3; 113:21, 22; 114:6; 138:7,7, 17,19,

19;

152:9
Julian (5)

45:20, 23:46:3, 3;140:4

Julian's(l)

156:19
Javier (1)

14:10
Jay (1)

119:25
Jericho (1)

140:18 July (1) 160:16 jump (1) 144:5

June (1)

13:14 Jill (1) 75:12

Jim (9)

95:3 K Karen (2) 8:16; 136:20

55:4; 59:14; 60:16,

11:10; 16:9; 21:23; 26:3; 27:23; 28:7; 39:21; 44:1; 50:6; 71:20; 80:21, 25:81:8, 22; 102:4; 105:9; 111:1; 124:6,9, 12; 148:11
kitchen (10)

76:9; 86:14, 19,22; 87:11; 92:25; 96:21; 106:11; 107:3; 118:15; 119:2; 129:3,6; 160:24
known (5)

13:23; 84:3; 87:14, 23; 150:17

knows (1)

86:10 L
laboring (1)

33:7
lack (1)

25:14,

13:13, 13,23; 14:1,3, 12,16, 23; 15:15, 18,20, 2324; 16:7,14, 18,20; 17:15; 18:8,10, 15;21:8; 31:16: 32:1; 54:19; 64:21; 87:4; 89:1; 102:21; 103:9; 129:11; 133:10; 151:2,3; 157:24, 25; 158:3,8, 16; 159:15; 161:24; 166:18 late (1) 57:7 (184) Jackson's - late

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 59 of 78

LISA T. JACKSON v. PAULA DEEN, et al.
later (4)

PRISCILLA SUMERLIN February 26, 2013 75:15; 100:13; 124:3; 125:12, 18; 129:12; 137:22
legal (2)

14,16
light (1)

45:21; 46:17; 52:2; 57:3

Latino (1)

87:12
lightening (1)

113:14
limited (1)

19:22
lawsuit (19)

86:20
Lindsey (16)

5:10; 10:17, 21;11:1; 29:10; 34:6,19, 19; 82:15, 24:811, 5;94:21; 120:15, 21,22, 23; 128:1; 129:10 lawyer (1) 147:9
learn (2)

68:15; 157:21
legalized (1)

73:7
Legally (1)

119:22
lengthy (2)

116:16; 118:2
less (1)

143:23
letter (11)

86:23, 24
learned (1)

163:4
least (5)

94:2; 101:15, 19,22; 102:9, 17; 103:5; 154:6, 17,22; 155:1

letting (1)

37:12, 16;39:3, 8,12; 65:15; 66:5,7, 8,9,17; 67:3; 88:21: 89:2,4; 98:18 line (3) 107:9; 134:21; 161:12
Lisa (117)

87:24; 147:3, 10; 152:23; 153:23

leave (6)

66:15 level (2) 51:22; 91:10

lewd (1)

28:10
Lewis (1)

28:20; 55:2; 56:24; 59:6: 100:2; 122:2

leaving (3)

11:17
liability (2)

62:12; 149:17
Liberty (1)

100:18
lie (1)

58:19; 94:24; 139:15 left (18) 17:24; 18:2,4; 20:9; 25:13, 13:34:1; 35:11, 14; 49:12; 71:16;

103:5
life (4)

103:25; 108:9, 24; 143:23 LifeLink(3) 137:25; 138:16; 156:25

lifestyle (3)

58:12,

4:4,17; 5:10; 10:12, 15,20, 25; 22:10: 24:12; 25:11, 13,23; 26:2; 28:17, 18; 32:12: 34:1; 35:10, 14,19; 36:6; 37:12; 41:13, 19,25; 42:4; 46:5,7, 22,24; 48:6; 56:23; 57:15, 18;58:2, 10,23; 59:3,14, 23; 60:16, 21; 61:15,

718;65:5;, 68:20; 69:18; 71:1,2; 78:17, 18;80:1; 82:20; 83:16; 87:14, 1823; 89:21; 91:2; 94:10, 20:95:2, 16; 97:17; 98:13; 100:1, 14; 101:22, 24; 102:13; 103:14, 17; 104:4, 20; 105:23; 109:21; 110:9, 19: 117:9, 15,22; 118:14; 119:4,9, 18,20; 121:16; 122:19; 124:6; 129:11, 22; 130:10; 131:1,5, 14,18; 132:21; 133:10, 17; 134:3, 16,25; 136:17; 137:19; 142:13; 143:4,9, 18; 144:9; 145:24; 147:10;

151:22; 152:12; 153:3, 14; 155:14; 163:18

Lisa's (9)

21:19; 22:5,15; 23:5; 37:3; 101:25; 152:2; 153:1; 157:8

list (2)

32:18; 126:1
listed (4)

125:21; 126:5, 1 14,18

listen (1)

160:18 listened (1) 160:14

listening (2)

59:13; 150:16
literate (1)

113:18
little (4)

6:19; 11:4; 42:3; 133:4

live (8)

11:5; 13:20, 23; 18:22; 73:18, 24; 77:16; 128:11

lived (13)

12:19; 16:15; 18:10, 22;37:4; 76:16, 21,23, 23,24; 92:23; 99:6; 123:5 (185) later - lived

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 60 of 78

LISA T. JACKSON v. PAULA DEEN, et at.
lives (1)

PRISCILLA SUMERLIN February 26, 2013 19:19; 32:17; 69:24

Lorcet (1)

60:23
Mainly (2)

13:22
living (8)

19:25; 37:3; 50:18, 19; 95:13; 98:17; 105:3,4

locate (3)

53:19; 122:3
maintain (2)

42:25
Lord (2)

136:20; 137:3
Lortab(1)

17:12; 112:22
maintained (1)

18:12
making (8)

42:25
lose (1)

158:22; 159:2,6
located (1)

140:20
lot (4)

12:2
location (5)

11:20; 13:7; 106:17; 121:12, 14

locations (3)

13:13; 21:14; 55:3; 57:12

Lunch (2)

56:20; 98:4,6; 131:6; 132:22; 139:22; 144:22; 163:24

male (1)

99:18; 127:20
M

69:13
manage (1)

63:23
manager (18) Ma'am (16)

11:19; 76:20; 77:13

long (23)

7:16; 8:17,21; 9:4,19; 12:19; 18:22; 20:3; 49:7; 51:6; 64:24; 88:5,6; 95:5; 96:23: 102:17; 114:22; 126:1,4; 136:12; 137:8; 141:7; 162:18
longstanding (1)

5:7,23; 16.19, 43.15, 69:8: 71:16; 77:18; 78:25; 82:11; 87:6; 101:21; 123:16; 125:6; 135:22; 136:16; 155:21
Mac (1)

9:13, 15,15, 17,18, 19;10:1, 9;43:9, 13;66:7, 8,9; 122:1, 14,22, 23; 131:13
managers (5)

33:17; 36:21; 40:24; 41:4; 47:15, 17,18; 59:22; 60:7; 61:21; 69:5; 70:15; 74:18, 22; 75:16; 91:21; 93:10; 96:12; 101:8; 106:9; 119:20; 121:16; 127:13; 128:13; 129:13; 136:7; 140:5; 164:3
March (13)

marriage (2)

73:7; 74:13
married (3)

50:24; 98:18,19
Martinez (7)

14:4, 12;19:8, 12,20; 78:6,19

Martinez's (1)

50:13
Mary (2)

31:19; 121:24
master's (2)

7:22,24
Matt (1)

141:22
matter (4)

4:3; 70:5; 74:10; 106:16

May (27)

15:20;
18:9,9;

39:3; 65:12; 66:5; 72:3; 73:9

Maner(1)

46:25; 47:1,3, 13,14, 16; 87:14, 15,24; 123:11; 128:1; 129:11, 13

Marietta (1)

112:18
Macbook (3)

64:3
mark (2)

147:9
manifest (2)

1189, 11:163:8
Macon (2)

68:12; 86:22
manifests (1)

154:13; 156:1
marked (7)

7:3,11
Mac's (2)

63:19
manner (2)

92:7
look (5)

124:22; 136:8,9; 156:3; 157:25

looked (1)

31:20; 121:24
Maggie (5)

96:20; 107:22
many (34)

9:9,10; 10:4,12, 15
main (3)

157:25
looking (4)

18:9;

49:2; 59:24;

10:5; 11:22; 23:8; 25:1; 27:7: 31:25;

101:15, 17; 123:9; 124:18; 133:13; 154:19; 156:6

market (1)

j 20:8,18; 27:15; 48:14; 67:22; 71:7; 97:15; 107:23; 108:14; 109:10; 110:10; 117:19; 119:16; 124:23; 134:4,7, 19; 143:18; 145:17; 150:11, 18; 154:5, 23; 155:12
maybe (18)

125:14
marks (2)

99:15, 20

23:14; 27:11; 33:12; 37:11; 47:20; (186) lives - maybe

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 61 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 51:25; 56:4; 61:22; 74:21; 85:22; 93:11; 108:23; 127:16; 132:15; 138:12, 14; 140:6; 145:11
McCaw (5)

PRISCILLA SUMERLIN February 26, 2013 69:10; 74:78, 17; 78:18; 85:13; 86:1,2; 87:4; 102:3, 20; 105:22; 107:11, 12; 109:18; 111:15, 24,25; 112:14; 115:4; 122:21; 123:1, 25; 125:17, 23; 134:13; 136:7,9; 139:2,3; 142:15; 157:24; 161:22
meaning (1)

120:11; 136:16; 138:24

medically (1)

63:23
medication (5)

10:2,20, 25; 44:11; 47:5; 48:25; 135:9

memory (1)

43:23
Miss (75)

42:23; 43:15; 44:4; 45:5; 46:4

medications (5)

58:18
mental (1)

138:25
mentioned (17)

77:19; 113:7,8, 9,25

McCoy (4)

6:15; 43:18, 23; 139:10, 13

medicine (4)

37:22; 89:2,5,7
McCurry (5)

42:11, 15,16; 145:24

meet (10)

37:6; 65:16, 19: 88:14,17

meals (3)

29:23; 30:4; 97:4

mean (64) 9:9;

9:24
meaningful (3)

46:24; 47:4; 68:25; 91:21; 94:5,8, 23;95:2; 104:17; 153:4

meeting (5)

11:24; 27:3; 29:12; 39:9,11, 14,15; 56:23; 58:25; 59:5; 61:6; 65:5; 73:2,24; 88:13, 23;145:1
Mercedes (2)

124:11, 16
mere (1)

124:12
message (3)

13:1; 20:15; 22:4,13, 14; 25:21; 26:7; 27:6,7, 9,12; 29:13; 30:6,7; 34:11, 20;
36:22;

20:12, 25;21:7
means (5)

5:20; 14:22; 85:22, 25; 12211

meant (3)

34:16; 35:22; 36:7; 73:9; 128:19 meetings (2) 36:16; 127:22

Mellisa (13)

130:2; 134:3,16
messages (4)

130:6; 157:5,6; 164:20

met (6)

39:23; 58:15; 109:17

media (7)

39:17; 44:2; 47:25; 51:6; 52:14; 54:1; 55:3,10; 56:3; 57:14; 59:16; 65:11, 21;

129:1; 157:5; 163:17, 19,25; 164:9,23

mediations (1)

37:11; 39:3,10; 65:14, 16,19, 23;66:1, 5,17; 67:3; 88:14,16

member (2)

5:8; 87:18, 19; 91:23; 94:7; 101:11 mid (1) 79:13 Mike (1) 123:5
millions (2)

131:1
medical (8)

73:6; 88:8
members (2)

10:16; 11:1
mind (1)

12:5
mine (2)

26:8; 100:2,6; 119:10, 18;

25:24; 122:6
Memorial (9)

37:4; 125:19
misapplied (1)

8:7,8;

5:25; 8:17; 18:12; 19:25; 29:6; 33:25; 34:12; 37:6; 47:18; 48:6; 49:4; 51:11, 21:52:2; 53:4,8, 13; 54:16; 59:2; 65:8,11; 67:18; 71:18, 23;72:8; 73:3,13; 74:5; 75:17; 76:8,8, 21; 77:21; 78:11, 15;79:4, 6,9,16; 91:7,24; 94:23; 97:13; 99:5,23; 104:7, 25; 105:14, 24; 106:10, 21,24; 107:3,3, 9,23; 108:13; 111:18; 126:6, 22; 131:9, 14,23; 133:6; 138:24; 140:16, 23; 141:14; 152:18; (187) McCaw - Miss

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 62 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 160:5, 12,15, 20; 162:10; 165:7
mistake (2) morning (1)

PRISCILLA SUMERLIN February 26, 2013 86:23

most (10)

15:13; 63:11
misunderstanding (1)

63:12
model (1)

143:19 mom (1) 19:5

moment (1)

13:10; 17:21; 29:21; 34:12; 61:25; 90:15; 118:17, 19,24; 153:23

Mostly (1)

26:6; 57:3; 83:15; 96:7; 113:16, 19; 114:25; 162:25; 165:24; 166:21
multiple (14)

98:12
mother (8)

166:9
money (1)

161:11
month (7)

18:9; 42:1; 47:21; 57:22; 95:20; 118:25; 160:2

months (8)

12:8; 37:19; 68:24, 25; 79:25; 80:5; 104:22; 105:24

mother's (1)

37:23
move (6)

17:3; 55:19; 64:16; 73:16; 106:7, 25; 107:5, 12; 112:6; 122:15, 21; 123:1; 124:5; 137:22
multiples (1)

[ 75:12; 93:4; 100:20, 23; 118:18, 21; 121:9; 136:15; 140:18, 19; 141:14; 146:11
named (3)

24; 114:14; 115:25; 121:14

nearly (3)

67:19; 683,7
necessarily (16)

66:4, 17; 141:21

names (12)

7:17; 15:2; 31:18; 32:1; 54:2; 79:17; 100:2; 136:13

Mooney (3)

31:4,7; 32:19; 59:24; 60:23; 138:9

moved (16)

139:24
Musha (2)

11:15; 14:9; 30:14; 106:15; 119:24; 120:1; 121:20, 21; 123:4,5, 7;152:13
name's (1)

9:18; 10:9; 22:12; 26:13; 54:9; 85:12, 13,15, 21,23; 86:6; 107:25; 143:3; 144:20; 152:3; 154:1
need (4)

6:7; 62:11; 82:17; 154:17

needed (8)

162:3; 165:8
myself (6)

4:16
narcotic (3)

37:24, 25;89:9
more (22)

9:17; 10:8; 12:6; 23:12; 39:12; 54:14; 60:6,6, 10,15, 21;62:3; 70:19; 79:11; 81:13; 91:2,3; 107:2; 144:7; 147:10, 10;165:5

8:5; 13:13; 17:23; 18:19; 19:11; 35:25; 76:25; 77:3; 113:20; 121:17; 124:10; 138:6, 10,11, 13; 140:21
moves (2)

37:12; 41:19; 108:9, 10,25; 109:5

MySpace(1)

44:5, 10,16
Nashville (1)

7:13
nature (14)

151:15
N

name (31)

17:7,11
moving (1)

137:20
Mrs (1)

104:18
Mrs- (1)

160:12
much (10)

5:7,22; 12:11, 15, 13:18; 14:1,3, 5,12; 15:15, 16; 28:10; 31:4,14; 37:23; 54:20; 64:10, 22;74:9;

40:22; 56:14; 67:2; 91:7; 127:18; 128:16; 133:8; 142:4, 20; 144:11; 151:16; 152:10; 161:8; 165:17 natured (1) 132:2
near (10)

31:24; 62:13, 13; 112:18, 18; 128:7; 158:25; 165:11

Negative (2)

90:23; 110:1
neighborhood (1)

123:6
Neither (1)

162:14
nephews (2)

21:10, 20
new (5)

110:20; 137:18; 154:5,7, 9

next (5)

81:15; 82:4; 83:3,6, 12,20,

87:20; 103:22; 107:9; 108:8; (188) mistake - next

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 63 of 78

LISA T. JACKSON v. PAULA DEEN, et al 112:14
Nicholas (3) 89:13,

PRISCILLA SUMERLIN February 26, 2013 45:2,4, 7

November (1) object (9)

23;92:15
Nick (3)

100:3
nt (1)

89:11; 92:25; 93:4

niece (1)

49:6
number (15)

21:20
nieces (1)

21:10
night (6)

90:12; 108:23; 146:25; 147:3; 158:14;

161:6

Nikon (4)

13:14; 15:6,8; 23:10; 60:11; 70:18, 23; 75:20; 76:24; 99:15, 21; 124:19; 135:21; 151:1,2
numerable (3)

52:25; 67:15; 68:14; 73:14; 54:19; 103:19; 127:14; 135:18; 157:20

Objection (38)

25:5; 33:22, 22,25; 41:23; 44:12; 45:10; 66:24; 97:7; 100:11; 127:3
occasioned (1)

35:10; 44:9; 50:16, 17; 56:25; 81:7; 83:2,6; 152:22; 160:19

occurring (6)

117:21, 22; 123:25; 124:1

nod (2)

60:18; 61:1; 74:25

numerous (3)

5:17,20
Nodding (2)

23:22; 139:7
Non (1)

55:2; 69:6; 149:22

nurse (13)

106:1
none (4)

88:10; 97:16; 129:18, 20

noon (1)

7:15, 20;8:11, 20;43:7, 9,22; 51:4,7; 91:6, 10; 146:21, 23

nurses (1)

65:1
Nope (10)

60:14, 24;67:5, 21:72:4; 79:15; 81:1,10, 18;82:7; 54:9; 85:1,8, 25; 86:11, 16;87:1, 9:88:4; 89:6,25; 90:5,18; 91:15; 93:20; 95:7; 101:4, 10; 115:20; 120:5,7; 123:24; 129:4; 147:15, 19,21, 23; 164:12
objections (1)

104:25
occasions (41)

10:9
nursing (8)

21:11; 27:2; 45:1; 46:5; 55:23; 62:7; 67:12; 96:8; 146:15; 150:21
nor (1)

147:17
obligation (1)

7:19; 9:2,4,7, 11,15, 18;45:2

nymphomaniac (1)

44:15
observe (1)

140:12
obstructed (1)

98:25
El oar (1)

137:6
obtain (1)

7:8
obtaining (1)

22:2; 23:8,19; 24:2; 25:1; 31:25; 32:9; 33:17; 36:21; 40:24; 41:4,8; 47:15, 17,18; 49:15, 17,20, 23,25; 50:5; 59:22; 61:21; 66:25; 69:5; 70:15; 74:18, 22; 75:16; 91:21; 93:10, 13,14; 96:10, 12; 106:7; 107:5; 127:13, 19; 129:13; 147:11
occupied (1)

52:10; 81.15; 83:12, 20,24; 85:18

o'clock (1)

158:14
October (10)

78:2, 11; 79:17; 83:10; 86:24; 87:7,13, 23;88:1; 138:1

odd (2)

42:3; 115:23
Odor (1)

50:4
off (21)

21:23; 24:21; 25:11; 32:16; 37:13; 38:4; 70:1; 71:10, 11,16; 73:5; 99:13, 14,17; 100:14; 132:5; 136:14; 141:8,9: 166:1,7
offended (4)

144:19 North (1) 13:24

Northwest (1)

33:7
Oath (4)

160:4
obviously (3)

126:21
occur (3)

77:19
notify (3)

4:18; 5:5; 99:24; 141:18

59:10; 102:22; 110:22

occasion (12)

74:18; 132:11; 145:8

occurred (11)

76:2; 144:16, 23;145:4

offensive (4)

24:1;

25:18;

50:6; 52:19; (189) Nicholas - offensive

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 64 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 76:6; 126:24
office (14)

PRISCILLA SUMERLIN February 26, 2013 10; 64:19; 66:24; 74:13; 84:16; 87:12; 99:8,15; 100:11; 103:25; 118:17, 19,24; 119:25; 120:17; 123:5; 128:4; 129:25; 130:8; 132:25; 135:24; 136:1, 10; 147:10; 151:12; 160:11; 165:5
ones (2)

135:23
opportunities (2)

27:11; 38:15; 55:6; 59:24; 60:23; 64:13, 15; 65:14; 66:9; 69:20; 72:16; 112:21; 142:3; 165:20
offices (1)

59:24; 110:12
opportunity (2)

107:20; 155:9
opposed (6)

5:17; 23:25; 47:13; 48:3; 109:25; 111:2

option (3)

55:7; 76:18,19
order (3)

80:6
old (1)

152:19 older (1) 80:16

Oliver (1)

50:4; 137:4; 161:17

organ (1)

62:22
orientation (3)

147:9
Once (11)

55:21; 75:2,18
originally (2)

21:17; 41:1; 58:6; 60:2,6; 70:20; 108:9, 10,24; 109:4; 128:15

one (52)

74:15; 156:25
only (18)

57:917, 24;58:1, 47,11; 59:1; 62:13, 13; 63:22; 70:10; 73:8; 77:1; 91:13; 95:14; 96:9; 99:11; 102:23; 114:13; 121:10; 123:15; 127:20; 131:14, 15; 137:7; 138:10, 11; 139:20; 143:23; 144:6
outside (3)

100:10; 107:20; 145:22; 147:24, 24; 151:12; 160:3

overall (1)

105:21
overhear(1)

112:9
overheard (4)

112:8; 145:7; 147:8; 148:8

overlap (1)

19:25
overlapped (1)

45:25
overt (1)

132:2
overwritten (1)

162:19
own (4)

62:19; 114:25
others (6)

7:6,7; 11:16; 13:14, 17; 21:19; 24:7; 25:35; 27:8; 31:4; 32:10, 11; 33:22, 22;34:4; 35:4; 41:6; 42:18; 43:1,1, 17;44:6; 46:12;

12:5; 22:5; 24:23, 23:25:3; 26:7,8; 30:10; 54:1; 59:10; 76:18, 19; 101:12; 115:24; 116:2; 128:4; 130:8; 137:25 open (5) 42:12, 13; 161:19, 21;162:5
operating (1)

4:4; 29:8; 71:23; 72:2: 88:20; 120:1

out(54)

27:11; 34:12; 142:15

Outstanding (1)

11:12; 43:25; 108:11; 109:14 owned (1) 77:1

owner (1)

163:15
Over (33)

122:13
owns (1)

147:16
operational (4)

113:24; 133:20; 134:21;

7:25; 11:20; 20:15, 21; 23:21; 26:13, 23;27:8, 8,23; 29:13; 33:5; 34:17; 42:16, 18; 43:16; 44:10, 2122; 46:6; 51:10; 53:21;

16:14, 18; 23:12; 31:4,5; 32:25; 34:2; 35:22; 37:1,16, 17,20; 39:4; 46:10; 54:10; 55:19, 19,19; 64:17; 66:25, 25; 67:20; 68:8; 81:19; 84:10; 84;

11:12
Oyster (2)

4:11; 135:22 F
package (1)

114:9
page (3)

123:10; 124:20; 134:15

pages (2)

136:5,7
paid (7)

95:8; 1005 113:14; 115:5, 10,17; 13015 (190) office - paid

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 65 of 78

LISA T. JACKSON v. PAULA DEEN, et at.
pain (16) partake (1) Paula's (2) perhaps (6)

PRISCILLA SUMERLIN
February 26, 2013 phone (27)

42:7, 10,16, 19,20, 22;43:1, 15,17, 23;44:4; 45:5; 145:22, 24; 146:24; 147:4
Painted (1)

90:14
particular (3)

109:16; 132:13
pay (12)

28:4; 52:4,12
partner (2)

91:13; 94:8
partners (1)

95:17
party (9)

31:8; 54:20; 56:1,3, 8;62:13; 95:512, 15,19, 20;96:1

paying (1)

15:2; 18:11; 36:22; 58:20; 60:9; 163:11

period (9)

32:23
panic (1)

136:24
paper (2)

146:12, 14
paragraph (6)

22:9, 10,12; 23:5; 88:16, 20; 90:17, 20; 132:13

passed (1)

114:19
payment (1)

96:1
PC (1)

79:10; 80:2; 88:7; 100:5,9; 116:17; 118:2; 125:21; 145:25

periods (1)

112:20
Peggy (7)

53:13
person (15)

103:9, 10,23; 157:5; 159:14, 18

paragraphs (1)

98:13
passing (2)

101:12; 108:23
past (3)

108:12; 109:14, 15,18, 19,22,25 pen (1) 123:18

pending (2)

159:24
Pardon (3)

109:20; 159:11,
13 patient (2)

6:9; 34:19
people (17)

120:13; 129:19; 161:20 parent (1) 104:21

parents (16)

46:18; 51:4
Paula (31)

11:5; 13:6; 18:24; 21:15; 22:3; 68:21, 24;92:1, 8,10,24; 96:9; 103:24; 104:8, 17;105:2
parents (6)

92:22, 23;93:1, 5,18; 96:18

part (4)

76:7; 82:23; 83:1;

4:4,13; 57:21; 62:2,12, 13;80:2, 6; 102:14; 103:2,5; 109:20, 21; 110:17; 131:19, 24,25; 132:8, 22; 133:9; 141:15; 143:5, 11,19; 144:1, 10; 145:2,7; 149:19, 22; 155:10

27:4,7; 29:21; 30:11, 19; 39:10, 25; 40:14; 55:11; 65:12, 14; 66:18; 103:11; 122:15; 123:2; 133:4; 164:3
people's (1)

80:25; 81:8; 82:13, 22;84:6; 85:6; 91:23; 97:20; 101:11; 103:11; 108:10; 109:5,9; 146:17; 152:5
personal (12)

15:17; 20:14; 21:7; 59:11, 1318, 23; 61:17, 24;62:9; 91:25; 95:6,9, 12,16; 96:2; 112:10, 11; 148:16, 20; 150:14, 23; 151:1,2; 160:22; 164:21
phones (2)

14815; 151:8
phonetic (2)

136:21; 162:3
photograph (2)

69:2; 123:11
photographs (1)

69:8
photos (1)

10:22; 86:3,4, 14,19, 21; 91:10; 95:9,12, 16; 98:12; 103:12

personally (10)

69:6
physical (3)

13:8; 77:17; 105:9

Physically (2)

105:8; 122:12
physician (4)

123:4
per (2)

10:9; 54:21
percent (1)

19:4
perfect (2)

40:25; 49:16; 76:1; 96:5,6; 129:16; 140:12; 150:18; 158:13, 19

64:7; 137:11, 16,18

pick (5)

32:14, 15; 71:20; 145:23; 155:19

1

154:7; 155:5
performance (1)

1 person's (1) 74:9 pharmacy (2) I

picked (4)

146:4, 8,12,17
pick-up '1)__ (191) pain - pick-up

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 66 of 78

LISA T. JACKSON v. PAULA DEEN, et at. 32:14
Pictionary (4)

PRISCILLA SUMERLIN February 26, 2013 125:8

places (2)

90:17, 19,22,24
pictures (3)

121:23; 139:17
plaintiff (1)

34:13, 21;35:3
piece (2)

4:17
plan (4)

146:11, 14
pill (4)

95:13; 137:24; 154:5,7

planning (2)

42:10; 44:6; 145:23; 146:25

pills (3)

145:10, 11
plantation (1)

133:4
plate (5)

42:7, 16;147:4
pinpoint (1)

19:7
Pinterest (1)

116:10, 13; 117:10; 125:2,9

play (3)

30:12; 37:9,25; 46:17; 50:19; 54:3; 78:5,10; 79:9; 83:15, 21;84:1, 3:93:3; 105:25; 123:15; 134:14; 149:1; 151:13, 13: 161:17; 162:15
police (1)

136:16; 146:23
practitioners (1)

12,18
printed (2)

73:4,8
prior (15)

119:18
pregnant (1)

98:18
prepare (1)

118:6
prescribed (1)

45:4
prescription (7)

43:17; 44:4,19, 19;46:4, 10;146:4

presence (2)

50:8; 150:17
present (22)

4:20; 16:20; 17:18; 26:8; 38:23; 42:3; 67:20; 68:8; 94:24; 121:3,4; 124:22; 126:19; 129:10; 158:3
Priscilla (8)

69:11
porn (6)

128:23
place (39)

17:8,8, 12,12; 47:12; 55:25; 75:20; 81:6,9, 16:82:3; 83:12; 84:5; 85:5,10, 18,19; 86:7; 90:4; 101:24; 106:12, 14,19; 111:2; 114:13; 115:25; 117:17; 122:17; 125:6, 13; 135:12; 138:11; 143:23; 150:5; 153:23, 23; 154:7; 155:5; 159:12 placed (1)

37:18; 90:16; 161:5

played (1)

90:24
plead (2)

38:17; 39:9; 55:19; 73:1,12, 20

pornography (8)

26:20; 28:25
pleasant (1)

22:24
please (17)

69:19; 70:2,6, 16:71:4; 76:2,4,9

position (6)

4:7; 5:13,23; 54:15; 66:16; 69:8: 78:25; 92:5; 99:22; 101:19, 21; 123:15, 19; 125:6; 136:16; 147:19; 161:9
pm (6)

8:9; 79:3; 64:5; 108:2; 109:12; 154:9

positive (2)

4:14; 23:2; 24:10, 11,15, 15,24; 25:2; 33:20; 34:15; 37:9,10; 41:18; 48:15; 55:3; 59:9; 67:9; 90:12; 93:15; 140:7,9, 10
presidents (1)

4:3; 5:3,24; 86:9,9; 99:16, 21;166:6 Pro (1) 163:8

Probably (5)

14:20; 15:23; 19:3; 51:24; 57:7

problem (1)

62:2
proceed (2)

6:5; 99:22
proceeded (1)

96:15
pretences (1)

15:8
process (1)

104:1; 109:25
possession (2)

41:24
pretending (1)

20:18
processes (1)

113:3; 159:23
possible (2)

15:1 Pretty (1) 113:19

previous (2)

102:1
produce (2)

110:13; 155:9
post (2)

156:2; 157:18
profane (1)

35:24; 68:4
previously (2)

127:4
profanity (1)

65:2; 99:17, 20; 141:9, 11;166:7

point (23)

123:11, 13
practice (1)

101:16; 119:21
primarily (1)

127:9
professional (1)

148:2
practitioner (5)

92:11
program (7)

11:20
primary (4)

17:19;

7:15, 20; 120:11;

13:7; 137:11,

7:16, 23:9:14, 17;10:8, (192) Pictionary - program

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 67 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 8:43:13
programs (1)

PRISCILLA SUMERLIN February 26, 2013 157:19

put (13)

112:19
progressed (1)

54:10
promises (3)

56:12, 20,20
proper (3)

147:14, 20;148:4
prospective (2)

156:18, 23 provide (1) 159:10

provided (3)

45:15; 60:10; 70:23; 80:18, 23;84:4; 102:1; 104:4; 110:22; 112:20; 130:14; 136:610
putting (2)

82:14, 21;83:5, 11,19; 85:17; 98:7; 131:25; 132:22

racially (1)

49:17
racist (2)

145:3; 147:5
racoons(1)

22;37:8; 42:2; 60:1; 80:21; 90:14; 92:6; 117:4; 129:9; 137:21; 144:3; 149:1
reason (7)

40:14
raised (2)

39:24; 111:6
Q qualify (1)

25:15; 105:1
range (1)

157:8; 159:4,9
provider (2)

75:23 92:6
quantify (1) raped (5)

17:1; 32:24; 33:10, 14; 62:18; 78:14; 122:4

reasonable (4)

76:11, 17
providers (2)

60:1
quarrel (2)

77:12; 151:8
psychology (1)

783,4
quick (1)

7:7
Puerto (1)

144.7
quickly(3)

19:18
pulled (2)

58:4,7
purchase (2)

50:12; 126:3; 144:7

quite (1)

106:6, 10; 107:4; 119:5; 152:19 rapes (5) 106:12, 14,18, 22,25
rather (2)

82:12, 22;84:5; 85:6

reasons (2)

17:3; 34:4
rebuild (3)

114:12, 23; 115:11

rebuilt (5)

115:2; 124:14
purchased (5)

13:12 R
race(1)

55:6; 92:20
reached (2)

20:15, 21
read (7)

113:11, 12,15; 114:1,2

recall (94)

111:20; 113:13; 115:1; 116:15; 117:23

purpose (11)

5521
racial (32)

30:25; 35:2; 36:7; 47:6; 94:2; 111:6; 118:6; 155:22; 160:4; 163:19; 164:24
purposes (2)

156:2; 164:10
pursuant (1)

3824 39:11 1315: 4012' 21; 51:15. 52:10' 5310' 54:6. 66219' 68:27 12727 1423: ' 74:15' 19 8019 2481.6'

4:22; 29:10; 82:15; 102:17, 18; 142:23;

Reading (5)

102:19; 109:1,3; 110:3; 156:24

real (5)

31:3; 50:12; 126:6, 14,18

really (15)

20:13; 26:9,11,

10:14, 22;18:3, 7;21:21, 25;23:4, 18;24:7; 25:3,5, 10;26:4; 27:6; 28:3; 29:2,4; 34:18; 35:21; 37:1,10; 38:3,18; 39:1,5; 41:1,11; 42:24; 46:2; 47:1,3; 49:22; 52:12,

16;54:2; 55:24; 58:22; 59:22; 61:16, 23;62:5, 9,10,15; 64:11, 12; 68:10; 70:3; 71:5; 72:9,22; 73:6,12; 74:5,10, 12,16, 22;75:3, 23,24, 25;96:7; 97:16; 98:25; 100:1; 113:17; 115:11; 120:19; 124:15; 127:18, 25; 130:25; 131:5; 137:2; 138:9; 139:21; 144:21, 22,25; 145:14, 16,19; 146:2,3, 7,11,13; 148:12, 21,22; 150:19; 154:3; 158:11
receipt (1)

115:21
receive (5)

158:10; 164:21; 166:12, 14,20

received (8)

74:23; 106:24; 107:1,4, 6; (193) programs - received

'1

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 68 of 78

LISA T. JACKSON v, PAULA DEEN, et al. 157:24; 158:2; 165:9
receiver (1)

PIUSCILLA SUMERLIN February 26, 2013 162:14, 16,17,19 recovery (1) 161:23
RECROSS (2)

140:23; 144:4,8; 145:21; 152:7

relating (1)

152:9
remain (2)

rented (6)

102:23; 154:10
remarked (1)

107:3
receiving (2)

74:5; 157:14
recent (4)

155:20; 165:6 Reese (1) 64:20

references (1)

128:18
relation (2)

75:1
remarks (1)

76:25; 77:1; 126:3, 16,19; 138:11

repairs (2)

98:1; 152:18
relationship (43)

55:20
remarried (1)

114:20, 22
repeat (2)

13:10; 118:17, 19,24

recently (1)

14:6
remember (45)

106:2
referred (3)

137:17
reception (1)

55:8; 75:4; 98:24

referring (3)

145:12
Recess(3)

71:12; 99:15; 141:10

recognize (3)

39:25; 40:14; 72:20

reflect (4)

101:18; 123:13; 133:14

recollection (5)

78:1; 108:13; 110:16; 115:16

regard (1)

22:2,4; 38:7; 59:15; 70:4

recommending (1)

141:25
regarding (7)

85:19
record (12)

5:23; 71:11, 14;88:1; 99:13, 17,19; 141:9, 12; 166:2,7, 8

recorded (3)

26:20, 21; 54:13; 55:20, 25; 71:19; 159:15

regards (1)

104:9
regular (1)

21:3
rehab (2)

48:24; 49:5
rehearsal (1)

16:9; 17:13; 18:13; 20:12; 48:2,4, 7;51:17, 18,21; 52:3,18; 53:3,4, 6,8,13, 22;57:9, 18; 75:12; 80:22; 81:21, 23; 83:15; 88:7,9; 89:4; 92:1,7, 9;96:18, 24; 97:18, 19,23, 25; 105:20, 24; 107:24; 108:4, 20; 142:13
relationships (3)

160:4, 15,21
recording (2)

145:11
related (20)

160:24; 161:3
records (4)

78:1; 115:16, 23; 157:18

recover (2)

162:5, 21
recoverable (4)
-=r

40:3,8; 61:8,15; 71:18; 72:3; 73:12; 75:6; 94:6,9; 130:9; 131:24; 133:7; 136:18; 137:15;

10:23; 106:15; 122:10

relayed (5)

58:23; 71:18; 72:3; 73:13; 75:17

relievers (1)

22:5; 27:9,16, 19; 28:10; 31:3,12; 32:13; 33:12, 13,19; 37:12; 39:22; 46:21; 47:22; 50:11; 53:16; 54:19; 56:3; 57:5; 58:21; 61:2; 72:1; 77:15; 88:21; 90:8,10; 111:14; 114:24; 115:1; 116:10; 118:17, 21; 121:6; 125:20; 126:4; 130:20; 132:17, 25; 139:17, 23; 140:19; 149:9, 11; 161:15
remembering (1)

5:12; 6:1
replaced (1)

115:16
report (3)

9:7; 44:13,15
reporter (1)

5:19
represent (9)

4:8,9, 17; 93:24; 103:1; 109:9; 110:9; 135:15; 141:15

representation (2)

102:12, 13
representative (1)

129:23
representing (1)

94:2
represents (1)

4:13
request (1)

5:14
requested (2)

55:13; 157:18
reserve (1)

147:17
reside (1)

77:21
resided (5)

13:3; 18:23; 19:1,14; 76:22

residence (22)

43:2
religious (1)

30:14
renovated (1)

98:12
religiously (1)

77:2

13:5, 11; 30:25; 32:3,6, (194) receiver - residence

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 69 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 12,25; 33:11, 15,18; 35:24; 36:7,10, 14,19; 37:4; 93:18; 113:5; 117:24; 118:2; 123:21; 126:1
residences (2) respond (1)

PRISCILLA SUMERLIN February 26, 2013 159:24

response (5)

92:20, 21;93:1
Rico (1)

5:17; 6:2; 20:16, 22;159:5

responsibilities (2)

19:18
ride (1)

31:24
right (266)

146:17, 21
responsive (1)

166:13
responsiveness (1)

147:18
rest (2)

32:11; 77:5
resides (1)

71:7; 123:7
restaurant (6)

14:14 residing (1) 20:1

respect (38)

25:19; 33:3; 34:19, 23; 39:13, 15;51:2, 14:52:9; 53:9; 54:6; 61:24; 63:20; 69:9; 72:8,23; 74:12; 75:10; 77:12;
88:14;

22:3; 41:1; 42:19; 111:3; 131:15; 161:12

restaurants (2)

121:18, 21
result (6)

43:20; 106:25; 107:4; 142:19; 165:21

retaliation (1)

131:10
retrieve (1)

117:6
return (2)

98:4,10; 100:14; 102:14; 103:11; 108:14; 110:20; 112:16; 114:12; 118:4; 127:4, 23; 128:20; 129:23; 140:16; 159:14, 18,19
respected (1)

124:3,4
returned (2)

117:25; 123:23
returning (1)

116:7
reverse (1)

137:4
review (2)

142:9, 16 rewritten (1) 162:18

Richmond (8)

144:1

11:8; 12:20, 24:13:3, 11;

4:24; 6:7,18; 8:1; 9:24; 10:1,11, 24;11:7, 24;12:4, 8,22; 13:2,5, 15;14:7, 13; 15:25; 16:14, 22; 18:21; 1912; 20:7; 21:5; 22:6,8, 11,14, 16,24; 23:4,16, 18;24:'l, 6,9; 25:4,8; 26:14, 25; 27:21; 28:18; 29:1,3, 6,10,12, 19:30:9, 19,23; 31:16, 19,22, 25; 32:17, 19,22, 24:33:6, 17;34:4, 18,23; 35:69, 9,13,21; 36:4; 37:10, 14,23; 38:5; 39:5; 40:24;

41:2,7, 10,20; 43:1,7, 10,14, 18; 44:14, 15;45:9; 47:4; 48:16, 18,23; 49:7,12; 50:2,5, 24; 51:20; 52:14, 17,23; 53:2,7, 7,12; 54:3; 55:1; 56:17, 19,23; 57:5,23; 59:5,20; 60:13; 61:5,11, 23:62:8; 63:14, 16,19; 64:7; 66:4,10, 12,14; 68:6; 69:7,18; 71:6,24; 72:5,7, 22;73:1, 11,19; 74:4,11, 14:75:1, 16,22; 76:1,11; 77:5,11, 20,20; 78:2,5, 10,12; 79:4,9, 11,16: 80:9,18; 82:2,19; 83:22; 84:15, 24; 86:10, 21;87:6; 88:23;

90:2,11, 21;91:1, 12;92:4, 16,25; 93:14; 94:17; 95:25; 96:2,22; 97:17; 98:23; 99:4,10; 100:15, 18; 102:8; 103:4, 15; 104:14; 106:9; 107:18; 108:5,8, 22; 109:4, 13; 110:3, 25; 111:18, 23; 112:15; 113:4, 20,22; 114:10, 14,19; 116:5,9, 14; 117:1,9, 21; 118:1,4, 14,22; 119:1, 12; 120:10; 123:17; 126:11, 13; 127:3,8; 128:20; 129:10; 132:19; 133:10, 24; 134:13; 135:3, 11,12, 14,20; 136:22; 137:19; (195) residences - right

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 70 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 138:15, 23; 139:14, 21; 140:15; 141:1; 146:24; 151:14; 154:16; 157:16; 158:12, 15,16, 19; 159:12; 160:2, 14; 161:16; 163:12, 23,25; 164:8; 165:2; 166:16
rights (2)

PRISCILLA SUMERLIN February 26, 2013 56:13; 108:2; 161:13

same (22)

26:24; 28:24 ring (1) 115:13

risk (2)

4:20; 11:3; 27:23; 28:1,6; 30:8; 39:10; 46:1; 51:8; 55:18; 66:3; 74:2; 82:7; 115:24; 140:8; 144:6; 146:25; 147:23; 150:1; 153:25; 158:2; 160:19
Sandra (8)

116:6; 124:4; 125:13; 136:18; 139:15; 140:1; 153:1

saw (8)

15:18, 23; 18:11; 31:16; 40:25; 136:20, 22:152:6

saying (14)

18; 97:14, 18,25; 98:4,6, 10; 101:9; 112:12, 16; 133:17; 134:16; 150:23; 152:2, 12; 160:6, 16,21, 24;161:2
Scrap (4)

10; 138:14
Section (1)

103:24
seeing (1)

79:16
seem (4)

22:11; 57:4; 66:10; 78:2

selective (1)

23:17
send (4)

80:19, 23
role (2)

51:2; 143:19 romantic (5) 48:2,7; 51:22; 53:3; 59:1

romantically (1)

39:3,8, 12; 65:14; 66:5,17; 67:3; 124:4

Sarah (2)

26:20; 28:3; 29:4; 62:1,6, 9,16; 75:3; 79:22; 108:18, 19; 127:5; 144:23; 150:19 scared (1) 153:15
Schedule (4)

31:3,4, 9;32:18
screen (3)

130:2, 5; 164:21; 166:13

sending (2)

70:17; 123:9; 124:20

scroll (1)

134:25; 165:20
sense (1)

46:15
sent (5)

134:2 se (1) 10:10

Seafood (17)

37:11; 88:23
Saturday (1)

43:4, 16;44:5, 10
scheduled (4)

65:1
Savannah (31)

62:20, 24;63:5; 158:3

school (5)

49:8
room (1)

71:7
Rubber (1)

11:17
ruckus (2)

26:19; 28:8
rule (2)

6:4,6
rules (2)

5:16; 147:16

salary (3)

6:20; 8:5,6; 11:20; 12:23, 24;13:1, 4;17:24; 19:11; 32:7,11; 36:7; 76:16, 17,21; 92:18; 95:13; 99:7; 100:17; 112:25; 113:21; 114:2,4;

6:21; 13:1; 19:2; 37:19,21

Schumacher (36)

4:11; 10:13, 17;11:2; 21:16; 29:20; 51:13; 54:18; 71:19; 78:15; 91:8; 110:21; 111:1; 117:23; 127:24; 133:11; 139:1
search (2)

38:17; 134:11; 139:20; 156:18; 165:18

sentence (5)

102:6; 103:10, 23; 108:8,17

sentences (2)

102:2; 107:18
separate (1)

34:25
separately (1)

30:6
serve (1)

98:16
served (4)

54:22; 55:4,25; 56:15, 21,22, 25; 61:19; 62:6; 91:19, 22;92:2, 9;93:17, 17; 96:10,

157:13, 17
second (10)

155:21; 158:5, 12,19

servers (1)

22:8; 31:14; 32:11; 33:25; 35:7; 101:18; 102:16; 103:9,

98:15 service (1) 95:6

services (4)

99:6; 100:22, 25;160:4

sessions (1)

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(196) rights - sessions

Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 71 of 78

LISA T. JACKSON v. PAULA DEEN, et at. 107:8
set (2) Shirley (1)

PRISCILLA SUMERLIN February 26, 2013 99:11

signed (2)

114:9
situation (1)

140:21
soon (1)

74:10: 154:5
settlement (2)

118:16 Shoe (1) 54:21

shook (2)

94:1; 135:5
signing (1)

102:24
situations (1)

58:3
Sorry (21)

34:6
six (2)

121:1,4
several (1)

26:22; 28:23
Shoot (1)

146:11
Silla(4)

79:17
sex (2)

42:10
shooted (1)

55:20; 73:9
sexual (25)

42:7
short (1)

38:21; 39:6; 54:6,16; 55:20; 65:24; 66:19; 67:19; 68:2; 74:23: 75:2,18; 80:19; 81:14; 82:4,14, 21;83:2, 24:88:2; 98:5;
131:25;

125:21
shortly (1)

4:15
shot (2)

134:25; 135:5; 150:19; 151:21 simple (5) 48:3; 81:5,14; 85:11; 159:1
simpler (1)

63:18; 128:19
skinned (1)

69:13
slow (1)

46:13
snow (1)

138:17
social (10)

123:9; 124:20
shoulder (1)

48:3
simply (3)

46:9
show (7)

18:18; 51:4,8
single (3)

41:20; 45:21; 123:8; 132:7; 154:13, 18; 165:14

showed (3)

67:19; 68:3,8
sister (27)

92:11; 96:10; 97:7; 129:1; 157:5; 163:17, 18,25; 164:9,23 soft (1) 149:7
sold (2)

9:10; 16:5; 21:23; 42:9; 52:15; 58:13; 60:19; 66:7; 69:16: 71:9; 78:24; 88:19; 103:7; 111:22, 23; 113:9; 120:6; 125:23; 131:22; 137:13; 140:13
sort (5)

132:2, 20; 144:11

sexually (6)

38:16; 42:4; 115:23

shower (7)

49:21; 50:6; 97:14; 122:9; 144:10; 147:5

shake (1)

37:2,5, 6;88:18, 19:90:3, 9

showing (3)

23:25
share (3)

39:2; 69:19; 146:7

sic (5)

29:23; 73:17; 97:4

shared (3)

54:24; 74:20,23
Sharpton (4)

4:4; 34:7; 39:18; 74:14; 98:22 sick (1) 41:25

side (1)

13:17; 15:24; 18:19; 50:10; 77:23; 78:6; 80:9,11, 14,16, 16,19, 22; 81:16, 19,21; 82:3,5, 10;83:9, 13,18, 23;84:4, 7,11; 105:15
sisters (2)

11:16; 13:12
somebody (7)

28:9, 10:44:9; 55:12; 85:19, 23;133:7

someone (3)

25:16; 90:9; 144:10; 152:9,23

Southbridge (4)

77:4,7, 10; 12513

speak (10)

43:15; 98:17; 161:24

sometimes (5)

5:19; 31:6; 46:13; 51:7,8

Somewhat (1)

15:3; 16:25; 26:5,12, 14; 27:21; 28:15; 30:10; 127:11; 162:2

speaker (3)

129:22, 23; 153:1,5

shift (2)

59:10
sigmoidectomy(1)

137:6
sign (1)

13:15, 16 sit (6) 14:13; 23:21; 54:11; 70:12; 74:11; 159:22

sitting (3)

149:7
somewhere (3)

31:24; 81:15; 114:10

Son (4)

59:16; 112:11, 13
speakerphone (3)

47:8,9
ships (1)

34:7; 36:9; 38:6; 61:7

Sons(3)

61:18; 148:13, 16
speaking (4)

4:22
signal (1)

108:23 IiLI,

46:7; 112:14;

55:7,9;

27:25; 61:18; 91:25; (197) set - speaking

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 72 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 147:9
special (1)

PRISCILLA SUMERLIN February 26, 2013 6:22, 23;7:1

staff (7)

155:5
specific (10)

23:19; 34:21; 54:14; 74:12; 79:23; 107:2; 135:25; 136:2; 143:15; 149:11
specifically (4)

25:23; 30:24; 38:25; 39:14; 55:14, 16;122:6

stand (6)

17:20; 19:3; 90:15; 116:16; 118:1

staying (3)

114:9
stories (1)

7:15
studio (1)

103:12
storm (1)

7:7
study (1)

138:18
story (2)

7:14
stuff (2)

19:6,9, 24
steaks (4)

28:5; 58:5
straight (1)

33:8; 145:1
subject (4)

116:10, 14; 117:11; 125:2,6, 9

standing (2)

45:15, 16; 100:10; 145:22

stealing (1)

64:25
strained (1)

105:21
streaming (2)

70:5; 74:10; 134:21; 152:17

subjected (3)

161:11
Stephanie (5)

73:18, 25
Street (17)

72:1, 10; 107:7; 150:5

specifics (1)

67:19; 68:2,7
subpoena (15)

46:9; 96:23
stands (1)

23:21
start (3)

37:17; 39:8; 66:6,18; 67:3

steps (3)

139:24
specify (1)

58:15 spell (1) 64:21

spent (1)

67:3; 79:12; 138:15

started (12)

91:12, 16,17
still (22)

13:4
spoke (8)

14:16, 23; 29:15; 60:16, 22;89:1; 127:19; 161:24

spoken (15)

8:7,13; 19:5,9; 42:18; 51:10; 52:17; 57:6; 65:3; 107:19; 108:6; 143:23
state (4)

16:9; 27:3,5; 32:1; 42:2; 66:18; 104:20, 23; 111:6,8; 123:2; 128:13; 141:21; 150:13, 22
spring (4)

4:8; 5:22; 147:20, 22

stated (4)

81:20; 140:20; 154:8; 158:24

statement (1)

12:9; 13:24; 26:2; 42:13; 99:24; 104:18; 105:24; 113:3,4, 10; 123:21; 124:16; 139:2; 141:18; 157:22; 161:19, 21,23; 162:5,5, 20;164:1
stipulations (1)

35:25; 37:4; 76:22, 24,25; 77:2,2, 6,6,7,8, 19;90:4, 4;113:7, 9,25 stress (1) 139:3
strictly (1)

88:8
strike (13)

155:22, 25; 156:4, 14; 157:14, 19; 158:3,5, 6;159:3, 5,24; 165:8, 21; 166:14
substance (7)

4:20
Stockbridge (1)

128:12
stomach (1)

108:13
status (1)

36:17; 40:5; 47:18; 58:25; 80:10; 99:5: 129:21; 142:23; 144:22; 145:23; 148:7; 149:10; 154:13 string (1) 134:9 strip (1) 130:11
strippers (1)

44:5, 10,19; 146:9, 12,18; 161:9

successful (1)

124:5
sued (1)

29:7
suffers (1)

138:24
suggestive (2)

144:10; 147:6
suing (2)

36:8; 38:6
suit (3)

42:12
stop (1)

161:16
stay (4)

130:18
Strong (1)

51:17, 18,24; 130:25

Square (1)

100:19
St (3)

16:17; 102:22; 112:3; 166:8 stayed (6) 16:16;

99:10 storage (3) 116:18, 21;117:7

store (1)

37:17
struck (1)

10:13; 121:3; 131:19

Sumerlin (15)

113:14
struggles (1)

114:14
stored (1)

103:12
studied (1)

4:3; 5:3,24, 25; 12:12, (198) special - Sumerlin

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 73 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 16;86:9, 10; 99:16, 21,23; 141:14; 151:21; 165:7; 166:6
summer (1)

PRISCILLA SUMERIAN February 26, 2013 106:13; 116:8; 119:3; 122:18; 128:11; 129:8; 133:12; 135:19; 136:1; 140:18; 145:9; 146:6, 13; 147:15; 162:23
surgery (1)

116:9; 130:10; 131:8; 144:19; 152:17

talked (14)

166:7
taping (1)

164:21
thanks (1)

132:12 task (1) 136:12

technically (1)

135:5
therefore (2)

98:11; 161:13
THEREUPON (1)

51:25
sums (1)

55:23
Sunday (6)

100:22; 155:22; 158:13, 14,18; 162:1

supervise (1)

139:4
surprise (1)

153:9
surreptitious (1)

15:24; 38:10; 65:12; 72:2; 73:1; 89:14, 18,2 1, 23; 110:25; 140:18; 143:10; 150:2; 151:14
talking (14)

55:15
teenager (1)

5:2
third (2)

152:23
telling (5)

44:17; 56:16; 102:5, 13; 131:14

temple (1)

103:23; 138:14
Thomas (2)

131:13, 14
though (2)

100:16
temples (1)

66:15; 91:25
thought (7)

99:6
ten (5)

10:5
supervisor (10)

164:15
surreptitiously (1) 164:9 survive (1)

8:12, 14,18; 9:2,5,8, 12:10:2; 64:15,17

supply (3)

107:10
swallowing (1)

82:18
switched (1) 151:12 sworn (1)

11:14, 17,18
supposed (2)

63:13; 138:19
Sure (38)

5:4
Sylvania (6)

26:2 1; 34:23; 36:13, 22;39:1, 6;40:13; 54:1; 59:23; 67:8; 71:17; 74:2; 94:10; 102:3
talks (2)

14:11; 61:22; 93:11; 140:6; 164:6

tenure (1)

12:22; 20:18; 102:1; 110:13, 17; 132:8; 155:9

thoughts (4)

57:4
Terabyte (1)

162:24
Terabytes (1)

102:8, 10,14; 103:1

Three (13)

162:22
term (4)

8:10; 12:6; 14:21; 19:16; 43:22; 49:9; 50:17; 52:20; 53:24; 57:9; 58:17; 66:13; 70:18; 74:9; 75:2 1; 77:25; 79:8; 81:2; 92:14; 93:3; 96:13; 100:15; 101:7;

11:9; 13:8; 93:7,8, 13;97:11 system (1) 148:17 T

table (2)

108:5; 135:2
Tameka (10)

86:12, 17
talk (18)

26:3, 14,17, 25;27:9, 20,24, 25; 28:16; 29:14

Tanya (10)

51:11; 61:9; 100:15; 126:24 terms (7) 32:18; 65:5; 67:11; 101:24; 106:17; 128:21; 152:8
Terry (5)

8:19, 23;14:6; 15:2; 31:18; 46:11; 74:21; 106:11; 107:18; 119:22; 120:3; 121:19; 139:11
three-tiered (5)

6:18; 22:8; 28:12; 30:3,4; 36:8; 38:14; 54:4; 65:16, 19,23; 66:1; 90:12;

30:14; 31:11, 11; 33:10, 23; 34:24; 35:8,13, 22;40:20

tape (2)

37:23, 24,25; 39:8; 89:9

testified ('1)

116:10, 13; 117:10; 125:2,5

threw (2)

22:10; 57:12
throwing (1)

5:5
testimony (3)

33:6
Thunder (1)

99:12, 20
tapes (1)

60:25; 95:25; 144:12 texts (1)

80:6
times (23)

14:6; (199) summer - times

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 74 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 21:22, 24; 47:22, 24; 48:11: 55:2; 60:5,6, 8,15,21; 62:10; 70:23; 101:8; 105:21; 106:9; 127:20; 128:13; 140:5; 143:59; 149:22
title (2)

PRISCILLA SUMERLIN February 26, 2013 10; 140:11

told (45) took (26)

66:13; 74:16
T-Mobile (4)

95:24; 96:2; 151:9.10

today (11)

6:16; 14:13; 54:11; 74:11; 113:5; 123:21; 155:23; 156:20; 157:11; 158:22; 159:22
Today's (3)

4:5; 162:2 1; 166:5

together (17)

19:25; 20:1; 33:24; 35:5; 37:3; 76:25; 77:21; 78:12; 93:12; 95:17; 97:5,8; 103:15; 104:5; 136:6,

12:22; 24:12: 26:25; 27:15; 28:24; 29:7; 35:2; 40:15, 18;42:4; 48:6,7; 51:12; 53:9; 54:12; 57:10; 58:3; 61:13; 63:7; 65:10; 71:22; 72:14; 74:5; 88:6; 93:19; 104:7, 10; 105:15; 111:12, 21; 112:4, 16; 117:15; 119:4, 14; 122:19, 23; 138:6; 142:2; 144:9; 145:2, 23; 162:4; 163:14; 165:10
Tom (2)

9:13; 19:2; 20:5; 42:7,17, 18,22; 44:9; 46:4; 47:12; 90:3; 91:13, 16; 101:24; 106:18; 114:13, 16,22; 115:24; 116:2; 117:17; 130:17; 135:11; 154:1; 160:11, 13
top (3)

6,8; 43:13; 47:5,7; 48:15; 49:13

treated (1)

136:17
treatment (2)

7:24; 52:3,4, 19,23; 76:6; 79:20; 153:3; 162:5

turned (2)

39:18; 51:3 trick (1) 79:20

tricky (1)

14:10; 87:12
Twenty (1)

23:14
Twenty-four (1)

52:19
tried (2)

7:17
twice (2)

124:3; 125:19
trip (2)

21:17; 93:15
Twitter (6)

128:19; 130:9
trips (1)

151:16, 17,18, 20,22,25

two (29)

130:11
trouble (I)

30:14
Troup (1)

37:13; 38:4; 132:5

topic (3)

100:18
truck (1)

32:14
true (19)

38:6; 83:17; 98:16

topics (1)

132:2
towards (1)

122:7
town (3)

13:22, 23;31:24
Tracy (3)

125:25; 126:2,5
trade (2)

44:5; 66:20, 21;82:8, 915,18, 18; 142:5; 143:24, 25; 147:6,7, 11,12; 150:11, 12; 155:14; 159:3
trust (6)

146:21, 23
trailer (3)

4:9;5:7
Tony (8)

116:19, 21;117:7
transcript (1)

27:11; 30:13; 31:4,9, 11; 32:21; 33:1; 40:10

166:11
transferred (1)

48:19
trauma (12)

8:11, 21;9:13, 20; 10:2,

22:25; 29:13; 113:10, 18; 116:22; 140:24 try (4) 16:22; 52:4; 91:13; 148:5
trying (9)

7:6; 9:6,21; 12:5; 15:21; 33:19; 34:25; 41:7; 49:15; 58:2; 67:1,20; 68:48; 79:11; 109:7; 119:22; 120:2,4; 121:17, 18; 140: 10; 162:8, 11,12, 22; 163:6; 164:6; 166:7
two-minute (1)

141:5
type (5)

111:2; 144:11; 145:24; 148:7,20

Typically (4) 24:4;

33:2; (200) title- Typically

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 75 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 63:21; 144:19
U

PRISCILLA SUMERLIN February 26, 2013 24;95:5; 98:11; 102:24; 110:21; 111:1, 20; 116:7, 20; 117:13, 23; 125:3; 127:24; 128:2; 129:15; 130:3,6, 21; 131:3; 133:11, 19; 135:22; 136:19; 139:1, 15; 140:8, 20; 153:4, 16; 154:6; 155:2,4; 163:9, 19; 164:10, 25
under (10)

6:1
unusual (1)

23:15
up (48)

Uh-hmm

29:16: 41:3; 44:23; 52:6; 137:13: 154:21

ultimately (3)

48:18; 117:10; 126:9

unable (1)

17:12
Uncle (88)

4:11; 10:13, 13,17, 17,21; 11:2; 21:15; 22:3,10, 15,25; 23:5,9, 16,19; 24:2; 29:7,20; 30:5,20, 24;34:2, 6;35:11; 36:8,8, 19; 37:15; 38:6,10; 50:9; 51:13; 52:10; 53:15; 54:17; 58:7; 59:3; 66:23; 71:19; 77:23; 78:15, 20;79:3, 10:80:2, 12; 81:25; 83:19, 23;91:8; 94:21,

6:14; 69:24; 82:13, 22:84:6; 85:24; 86:15; 99:24 141:18; 147:16

unit (6)

47:5,7, 21; 48:15; 49:13; 51:4

University (1)

6:19; 12:23; 15:7; 18:1; 25:12; 31:13; 32:14, 15;38:7, 16:39:2; 41:20; 42:47, 10,18; 44:9; 45:13, 21; 50:12; 55:23; 66:22; 70:16; 71:20; 79:2; 97:10, 21; 100:13: 103:15; 113:20; 114:3, 19; 116:6; 117:10; 124:10; 126:10; 133:4; 135:7,7; 138:6, 13; 146:4,8, 12,17; 153:4; 155:19; 165:14
uploaded (1)

113:10; 117:25; 123:21; 126:22; 127:9; 151:24, 25; 164:18

used (5)

via (2)

59:11; 157:24
video (11)

39:17; 116:13: 144:10; 145:2; 151:2 uses (1) 15:15

using (6)

71:10, 11,13; 73:18, 24: 99:14; 132:7; 141:8,9, 11:166:1

VIDEOGRAPHER(1O)

72:20; 114:6; 135:2; 163:18; 164:924

usually (2)

4:2; 61:4; 7110, 13; 99:14, 19; 141:8, 11; 166:3,5

videotape (2)

64:25; 148:10
Uverse(2)

4:2; 99:15
view (1)

76:15, 15
V

108:14
viewed (1)

107:23
Vincent's (3) vac (2)

42:13; 46:8
Vaguely (1)

6:22, 24;7:1
violence (1)

53:14
viruses (1)

131:4
Vanderbilt (1)

70:1
visited (1)

7:12
various (2)

46:22
visiting (4)

77:13; 163:17 verbal (1) 5:17 verbally (1) 23:23

Verizon (3)

47:19, 23;48:2, 10
voice (3)

148:23, 25;149:3
voices (1)

124:24
upon (2)

151:9, 11,12
versions (2)

25:16
Voila (2)

5:5;6:5
upset (1)

136:1,3
versus (3)

163:9,9
volume (1)

7:12
unlawful (2)

28:21
use (12)

44:3,18
unlawfully (1)

43:16
unless (1)

24:3; 49:17; 51:11; 76:2;

44 38:24; 39:14
vetted (1)

63:22 W waited (2)

111:5

25:12, (201) Uh-hmm - waited

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 76 of 78

LISA T. JACKSON v. PAULA DEEN, et al. 14
waiting (1)

PRISCILLA SUMERLIN February 26, 2013 133:1; 145:3

Wednesday (2) wide (1)

42:12
Wil (11)

26:2
walk (3)

134:4,7
week (12)

46:8; 70:10,15
walked (6)

26:22; 44:9; 46:10; 69:23; 70:3,8

Walls (3)

54:21; 56:1,9
wants (2)

47:22, 24; 48:11; 138:14; 157:25, 25; 158:8, 16; 159:11, 13,15; 166:18
weeks (2)

25:6,9, 19;26:1, 5,12,20, 22; 27:20; 28:25; 143:2

Willie (2)

19:8; 50:13
Wil's (2)

28:23; 142:23
winter (1)

154:23; 155:2
watch (2)

49:10, 11
welcome (4)

137:8
WITHERS (82)

71:3; 76:4
watched (1)

76:9
watching (2)

24:13; 58:12, 14;163:3

weren't (2)

70:2; 73:20
water (1)

37:3; 88:2
Wes (2)

33:7
Waters (1)

4:19; 165:11
Wesley (1)

121:10
Watts (1)

4:16
Wesleyan (3)

9:9
Way (21)

13:14; 16:4,6; 38:15; 42:23; 62:18; 68:11; 79:25; 89:11; 93:24; 98:25; 101:8; 110:22; 112:24; 118:4, 23; 124:6; 133:5, 24; 144:18; 152:14 ways (1) 58:2
wedding (2)

7:3,5, 10
whatnot (1) 32:19 What's (10)

13:5; 14:1; 17:1; 70:13; 101:14; 123:8; 124:18; 133:13; 154:13, 19

whenever (4)

20:5; 28:25; 57:11,24

white (2)

85:15; 153:24
whomever (1)

86:7

4:9,9, 19,22, 24;5:1, 7,8; 53:2,3; 60:15; 61 -.1,3, 5,6; 67:8,10, 17,25; 68:17; 71:16; 72:5; 73:16, 19; 79:19, 25;81:5, 11,13, 24;82:9; 84:15, 21,23; 85:2,11; 86:5,13, 18;87:3, 13; 88:12; 89:7; 90:2,8, 21; 91:18; 93:21; 95:9,10; 99:13, 23; 101:6, 11,14; 102:25;

103:22; 115:22; 118:22; 120:8; 124:1; 127:17; 129:5; 135:20; 141:2,6; 144:5,8; 145:20; 152:7, 16; 154:8; 155:18, 21; 157:23; 164:18; 165:3, 25; 166:4,8, 16,21
Within (3)

146:2; 153:13; 157:22; 164:14; 166:18

witnessed (1)

122:14
witnesses (2)

129:2,8
woman (4)

75:15; 108:10; 110:4,11

women (8)

58:20; 73:9, 10; 109:13; 131:6; 143:20, 22; 153:24

WOOLF (85)

16:7; 18:15; 49:10

without (4)

17:8; 103:24; 104:8; 157:17

WITNESS (35)

4:25; 60:24; 67:23; 68:16; 79:21, 22;81:2. 20:82:8; 84:10, 11,12, 20,21, 22;86:2; 87:10; 88:5; 90:1,7, 19; 91:17; 102:19; 103:21; 115:21; 118:2 1; 120:6; 127:16; 129:6; 145:19;

4:16, 16,21, 23; 27:15; 52:25; 60:14; 63:7; 67:5,15, 21; 68:14; 71:15; 72:4; 73:14; 79:18, 20:81:1, 4,10,18; 82:7; 84:9,19; 85:1,8, 25; 86:11, 16; 87: 1, 9:88:4; 89:6,25; 90:5,18; 91:15; 93:20, 24;94:1, 5,7,9, 23:95:2, 7;101:4, 10; 102:18; 103:19; (202) waiting - WOOLF

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 77 of 78

LISA T. JACKSON v. PAULA DEEN. et al. 115:20; 118:20; 120:57; 123:24; 127:14; 129:4; 135:16, 18; 142:2; 143:7; 145:18; 146:1; 147:13, 22; 148:1,5; 153:12; 154:16; 157:20; 158:6, 24; 159:9, 10,15, 19; 164:12: 165:18, 19,25, 25; 166:1, 12,15,17 word (8) 17:2; 24:3; 39:17; 72:21; 126:24; 127:5,7; 145:7 words (20) 6:13; 14:23; 22:14; 24:18; 101:25, 25; 102:6; 103:4; 104:4; 109:24; 110:23; 111:7; 114:5; 122:12; 134:9; 136:10; 149:11, 150:1 work (55) 11:10; 12:13; 24:19, 22;30:2, 4;32:10, 16,18, 21,21; 37:25; 38:10; 42:5; 44:9,16; 53:19; 63:13, 16; 64:25; 67:20; 68:4,8; 80:1,12; 81:8,16, 19,25; 82:3,13, 22; 83:10, 19,23; 84:6; 85:5,7, 10,19, 23;88:9; 97:20; 98:10; 107:12; 116:15; 136:9, 24; 137:7; 138:1; 148:13, 15; 153:15, 16; 161:17 worked (1 B) 11:19: 24:21; 29:24; 37:15, 19:55:6; 80:5,15; 82:1; 83:16; 118:5; 121:23; 122:22; 130:1; 133:11, 22; 138:25 working (5) 8:7; 51:8; 79:10; 107:19; 108:6 workplace (14) 53:10, 14;54:4, 5,17; 57:14; 65:20; 73:12; 81:6: 88:3; 91:3,7; 127:9; 152:2 works (1) 84:11 worse (4) 57:8, 14,14; 59:2 worsened (1) 139:3 wound (2) 42:13; 46:8 write (3) 101:22, 24;107:9 writes (2) 108:22, 24 writing (1) 165:19 written (1) 102:20 wrong (7) 15:6; 84:24; 85:4,14, 22:86:7; 135:16 wrote (5) 107:19; 108:24; 110:5, 14; 155:14
Y

PRISCILLA SIJMERLIN February 26, 2013 46:25; 47:2,3, 12,13, 14; 113:14 08 (5) 18:1,6; 20:18; 23:7; 113:14 Oout (1) 44:19

yard (2) 32:10, 21 year (14) 15:21; 19:10; 21:19; 23:4; 57:22; 96:24, 25:97:1; 120:19; 124:15; 129:11; 138:17; 145:13; 150:9 years (29) 8:19, 23;9:6, 21; 13:13: 14:20; 15:23; 16:7,14, 18,20; 17:15; 181,10, 11,16; 21:8,14; 23:13; 67:1,20; 68:4,9; 79:11; 87:5; 121:17; 151:2,3: 163:4 Yep (2) 88:25; 110:6 young (3) 88:14; 103:24; 106:2 younger (1) 80:16 youngest (1) 80:17

07 (7)

1(8) 101:15, 17; 102:12; 110:23; 1117; 154:19; 156:19: 159:14 100(1) 65:2 1:16 (1) 99:20 10 (2) 94:15; 138:3 10:00(1) 65:4 10:03(1) 4:6 11:24 (1) 71:11 1139 (1) 71:13 12(l) 14:11 12:13 (1) 99:17 14(2) 14:10; 1066 15(9) 23:12; 60:7; 63:5; 70:22; 103:24; 104:8; 135:25; 136 : 3 ; 158:4 (203) word- 15

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Case 4:12-cv-00139-WTM-GRS Document 146-4 Filed 04/17/13 Page 78 of 78

LISA T. JACKSON v. PAULA DE1N, et al. 15th (3) PRISCILLA SUMERLIN

February 26, 2013 83:10; 86:24; 87:7,13, 14,23, 24;88:2; 111:19

2008(11)

62:19, 24;64:l8
16th (1)

119:16; 138:7,21
2012 (2)

49th (3)

77:2,6, 8
4th (1)

138:20
17(1) 92:24 19 (3)

128:2; 129:13
2013 (2)

138:12

134:4, 7,19
1970(l)

12:21
1998 (1)

6:25
19th (1)

20:4,5, 11;36:2, 3;57:7; 95:17; 132:15; 144:9; 150:10; 153:19

2009 (5)

4:5; 17:25
25(l)

5(1)

87:14
25th (2)

135:21
50 (2)

47:16; 87:15
26th (3)

23:12; 70:23

94:24 1st (1) 138:19

4:5; 87:19,24
27 (2)

100:3; 130:25; 137:8; 145:15; 153:20

2010 (36)

6 (3)

145:17; 154:23
27th (4)

156:1, 10,11
6th (1)

2 (8)

43:4, 16;44:5, 10; 99:21; 123:9; 157:5; 159:18 2:13 (1) 141:8 2:23 (1) 141:11
2:52(1)

166:7
20(2)

24:2; 66:25
2002(1)

7:9
2004 (4)

8:24; 17:23; 19:11

2005(l)

79:13
2007 (20)

20:4; 51:17, 19;52:2; 56:4; 67:14, 17; 69:19; 78:2,11; 79:17;

57:4; 94:16, 18,22, 25;95:3, 17; 100:3; 107:23; 108:15; 109:11; 110:10; 113:21; 117:19; 123:12; 124:23; 129:13; 130:5; 134:1,4, 7,19; 135:12; 137:8; 138:2,7; 139:16; 143:18; 145:17; 150:11; 154:5, 23; 155:12; 156:19, 20; 160:16
2011 (5)

143:18; 150:11; 154:5; 155:12

280(1)

134:1

7(l)

156:6

115:23
2896(l)

77:19
80(1)

19:4
3(l)

124:19
30(1) 64:25 31 (1)

9 (1) 158:14
912 (2)

156:19
320(l)

151:10, 12
912-441-3090 (1)

124:13

151:5

4 (2)

133:14; 134:15
401k (1)

56:13
1404(1)

151:11
404-989-9022 (1)

113:22; 114:6;

151:7 48th (5) 35:25; 76:25; 77:2,6, 10

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(204) 15th - 912-441-3090