RE: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt & proposed Second Amd Complt

Lisa.

Voir dire is Act I of the trial. It's when the lawyers for either side get to ask questions of the jurors before they're impaneled. The purpose of voir dire is to determine if any jurors have any predetermined views or biases that would deny the parties a fair trial. In Federal Courts judges often limit voir dire and ask questions themselves. State courts usually allow a more liberal voir dire. One of my favorite lawyers and mentors believes a case can be won in voir dire. Without going into all the reasons why, I'll just say that it's an opportunity to build rapport and trust with the jury so that they'll know which lawyer they should follow on their trial journey. The words voir dire do come from the French and in the trial sense mean to speak the truth.

Haytham Faraj

Sent from my iPhone

On Apr 8, 2011, at 11:28 PM, "Wolford Lisa" <lisa@csss.net> wrote:

Voir Dire - I had to look that up. In French a direct translation means to see, to speak - ie to tell the truth. very good. Yes I do agree that all races, genders, ethnicities deserve equal respect. That is what I try to enforce in the company. However people are people and they have biases, so the best I can hope for is that they don't exhibit them in the workplace. I have never had anyone use the N word (Thank God!) However, certain individuals have

Btw, gentlemen, there was some kind of reference to them assuming I was italian, hence the reference to my own mixed bag of heritage, none of which includes italian, if it did I might be capable of tanning. (smile).

Have a great weekend thanks -

Lisa N. Wolford

CSSS.NET

402-393-8059w

402-393-1825f

www.csss.net

SDVOB, 8(a)/SDB & WOB - TS clearances

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Fri 04/08/2011 2:57 PM
To: 'Kevin Duff'; Wolford Lisa
Cc: jmurray@rddlaw.net; kpritchard@rddlaw.net
Subject: RE: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt & proposed Second Amd Complt

It appears that she failed to understand the judge’s order regarding what she can amend which doesn’t surprise me.

Voir dire thought:

No one would disagree that using the N word justifies firing someone. Shouldn’t every racial, gender, and ethnic epithet receive the same treatment?

From: Kevin Duff [mailto:kduff@rddlaw.net]
Sent: Friday, April 08, 2011 11:19 AM
To: 'Wolford Lisa'; slater@billslater.com
Cc: jmurray@rddlaw.net; kpritchard@rddlaw.net; 'Haytham'
Subject: RE: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt & proposed Second Amd Complt

Agreed

From: Wolford Lisa [mailto:lisa@csss.net]
Sent: Friday, April 08, 2011 10:16 AM
To: Kevin Duff; slater@billslater.com
Cc: jmurray@rddlaw.net; kpritchard@rddlaw.net; Haytham
Subject: RE: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt & proposed Second Amd Complt

Btw, I am of German, Irish, Scottish and a smidgen of American Indian descent so neither the Pollack or Dago reference were personal to me. My issue with such statements at a company party is they are derogatory regarding particular ethnicities. This cannot be allowed by an employer. To not take such references seriously would basically endorse them. As a matter of business practice I disciplined a corporate management employee in Omaha for using ethnic slurs at yet another Christmas party. (Is it any wonder that I am not overly enthusiastic about holiday parties??) The management employee was put on a PIP, given sensitivity training and assigned a mentor within the firm. He was a valued senior individual and needed to learn to be more sensitive to others and how he conducts himself in a professional environment. So this treatment of Cynowa was not personal to cynowa ith was merely the right thing to do. The fact that Slater defended Cynowa's statements does not drive company policy regarding ethnic slurs.

Mr. Cynowa's technical skills were never in question, his professional demeanor (the lack thereof) was the issue.

It is unlikely that Mr. Slater made taunting statements, it is completely counter to his personality style.

Btw, in the email from Randy Padal, the Larry mentioned is not Mr. Carver it is the PM prior to Mr. Slater. His name is Larry McKeehan and he was let go for cause.

Since it is unverifiable that Slater repeated any statements to anyone it is probably more likely that Mr. Cynowa made statements to to others about his belief that slater believed he had a gun thereby damaging his own reputation.

Lisa N. Wolford

CSSS.NET

402-393-8059w

402-393-1825f

www.csss.net

SDVOB, 8(a)/SDB & WOB - TS clearances

From: Kevin Duff [mailto:kduff@rddlaw.net]
Sent: Fri 04/08/2011 8:57 AM
To: Wolford Lisa; slater@billslater.com
Cc: jmurray@rddlaw.net; kpritchard@rddlaw.net; 'Haytham'
Subject: FW: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt & proposed Second Amd Complt

Lisa and Bill,

Attached is Cynowa’s motion for leave to amend his complaint along with the proposed second amended complaint. Our response to the motion is due May 5.

Kevin

From: THERESA JOHNSON [mailto:theresavjohnson@prodigy.net]
Sent: Thursday, April 07, 2011 6:40 PM
To: Kevin Duff
Cc: John Murray; Haytham Faraj
Subject: Cynowa - Pltf's Motion for Leave to File Second Amd. Complt & proposed Second Amd Complt

All,

Attached please find Plaintiff's Motion for Leave to File Second Amended Verified Complaint and proposed Second Amended Verified Complaint file today, April 7, 2011.

Sincerely,

Theresa V. Johnson
Attorney at Law
Law Office of Theresa V. Johnson
200 East Chicago Ave. Suite 200
Westmont, IL 60559
Tel.: (630) 321-1330
Fax: (630) 321-1185

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