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Filing # 143352342 E-Filed 02/04/2022 05:11:28 PM
IN THE CIRCUIT COURT OF THE
SECOND JUDICIAL CIRCUIT, IN AND
FOR GADSDEN COUNTY, FLORIDA
CATHERINE ROBINSON,
Plaintiff,
Vv. CASE NO.: 2020-CA-000859
CITY OF QUINCY,
Defendant.
—/
DEFENDANT’S REPLY TO PLAINTIFF’S RESPONSE IN
OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
Exhibit A
Plaintiff's Response, Exhibit 87,
Beason’s Dep., p.10:5-11:14
EXHIBITA
IN THE CIRCUIT COURT OF THE
SECOND JUDICIAL CIRCUIT IN
AND FOR GADSDEN COUNTY, FLORIDA
CASE NO. 20-CA-859
CATHERINE ROBINSON,
Plaintiff,
Vv
CITY OF QUINCY,
Defendant
10
11
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DEPOSITION OF: TED BEASON
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DATE: DECEMBER 13, 2021
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TIME: COMMENCING AT: 10:30 a.m.
15 CONCLUDING AT: 10:47 a.m.
16 LOCATION: VIA VIDEOCONFERENCE
(ZOOM)
17
REPORTED BY: YVONNE LaFLAMME, RPR, FPR
18 COURT REPORTER
19
20
APEX REPORTING, INC.
21 P.O. BOX 5785
TALLAHASSEE, FLORIDA 32314
22 (850) 597-5185
apexreportingservices@gmail.com
23 tallycourtreporting.com
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APEX REPORTING, INC. TALLAHASSEE, FLORIDA 850-597-5185
EXHIBITA
10
believe, testified that she took an extended leave of
absence and your understanding was that it was something
related to her neck. Am I right so far?
A Yes, that's correct.
Q Did you ever tell Jack McLean that plaintiff
had neck issues?
A Did I ever tell Jack McLean that Catherine had
neck issues; is that correct, sir?
Q Yes. That's my question.
10 A Yeah; no, I did not. Excuse me. To this
11 extent, I think Catherine came in and gave me, like, a
12 document, like, she's going, like, okay I'm going to be
13 out for 90 days and y'all might have that document. I
14 don't know. But I think she had said, okay. I'm going
15 to be out for 90 days. Here's the document. And then,
16 I, of course, would have let Mr. McLean know right after
17 that, that had been presented to me.
18 Q Okay. Are you still there I didn't know if
19 you were frozen.
20 A Yeah. No, I'm good.
21 Q Okay. But you didn't tell Jack McLean that
22 plaintiff had neck issues; do I have that right?
23 A Yeah. I didn't tell her that Catherine had
24 neck issues. I only delivered the FMLA paperwork to
25 Jack as soon as it was presented to me.
APEX REPORTING, INC. TALLAHASSEE, FLORIDA 850-597-5185
EXHIBITA
11
Q Do you know if Jack McLean was city manager at
the time that Catherine went out on leave?
A Yes, he was.
Q Let me ask you this: Do you have specific
knowledge of actually handing that note to Jack McLean?
A Well, I certainly couldn't tell you a date and
time. I mean, whenever it was presented to me, I would
think that day, I would have gone down to his office and
said, "Oh, this is what's coming up."
10 Q And so I know you're testifying that's what
11 you would have normally done. Do you have any specific
12 memory of actually giving that note to Jack McLean in
13 this case?
14 A I do not.
15 MR. PAFFORD: Okay. I don't have any other
16 questions.
17 MR. GAGLIARDI: I don't have any follow-ups.
18 Mr. Beason, you'll have the opportunity to
19 read the transcript should it be ordered. Or you
20 can waive your right to read the transcript if you
21 believe that it's likely to have been transcribed
22 accurately.
23 THE WITNESS: Well, can you send it to me?
24 (Deposition concluded.)
25
APEX REPORTING, INC. TALLAHASSEE, FLORIDA (850) 597-5185
EXHIBITA
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ERRATA SHEET
PAGE/LINE NO. EXPLANATION FOR CORRECTION
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14 STATE OF FLORIDA
15 COUNTY OF
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17 I, the undersigned, declare under penalty of
18 perjury that I have read the foregoing transcript, and I
19 have made any corrections, additions or deletions that I
20 was desirous of making; that the foregoing is a true and
21 correct transcript of my testimony contained therein.
22 EXECUTED this day of , 2021,
23 at
24
25 TED BEASON
APEX REPORTING, INC TALLAHASSEE, FLORIDA 850-597-5185
EXHIBITA
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CERTIFICATE OF OATH
STATE OF FLORIDA )
COUNTY OF LEON )
I, the undersigned authority, certify that TED
BEASON personally appeared before me via
videoconference, Zoom, and was duly sworn, and identity
was verified through Florida Driver's License.
10
11 WITNESS my hand and official seal this 18TH
12 day of DECEMBER, 2021.
13
14
15
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17 YVONNE LaFLAMME, RPR, CCR, FPR-C
Notary Public - State of Florida
18 My Commission Expires 10/15/22
Commission #GG229501
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21
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APEX REPORTING, INC. TALLAHASSEE, FLORIDA 850-597-5185
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Filing # 143352342 E-Filed 02/04/2022 05:11:28 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR GADSDEN COUNTY, FLORIDA CATHERINE ROBINSON, Plaintiff, Vv. CASE NO.: 2020-CA-000859 CITY OF QUINCY, Defendant. —/ DEFENDANT’S REPLY TO PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT Exhibit A Plaintiff's Response, Exhibit 87, Beason’s Dep., p.10:5-11:14 EXHIBITA IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR GADSDEN COUNTY, FLORIDA CASE NO. 20-CA-859 CATHERINE ROBINSON, Plaintiff, Vv CITY OF QUINCY, Defendant 10 11 12 DEPOSITION OF: TED BEASON 13 DATE: DECEMBER 13, 2021 14 TIME: COMMENCING AT: 10:30 a.m. 15 CONCLUDING AT: 10:47 a.m. 16 LOCATION: VIA VIDEOCONFERENCE (ZOOM) 17 REPORTED BY: YVONNE LaFLAMME, RPR, FPR 18 COURT REPORTER 19 20 APEX REPORTING, INC. 21 P.O. BOX 5785 TALLAHASSEE, FLORIDA 32314 22 (850) 597-5185 apexreportingservices@gmail.com 23 tallycourtreporting.com 24 25 APEX REPORTING, INC. TALLAHASSEE, FLORIDA 850-597-5185 EXHIBITA 10 believe, testified that she took an extended leave of absence and your understanding was that it was something related to her neck. Am I right so far? A Yes, that's correct. Q Did you ever tell Jack McLean that plaintiff had neck issues? A Did I ever tell Jack McLean that Catherine had neck issues; is that correct, sir? Q Yes. That's my question. 10 A Yeah; no, I did not. Excuse me. To this 11 extent, I think Catherine came in and gave me, like, a 12 document, like, she's going, like, okay I'm going to be 13 out for 90 days and y'all might have that document. I 14 don't know. But I think she had said, okay. I'm going 15 to be out for 90 days. Here's the document. And then, 16 I, of course, would have let Mr. McLean know right after 17 that, that had been presented to me. 18 Q Okay. Are you still there I didn't know if 19 you were frozen. 20 A Yeah. No, I'm good. 21 Q Okay. But you didn't tell Jack McLean that 22 plaintiff had neck issues; do I have that right? 23 A Yeah. I didn't tell her that Catherine had 24 neck issues. I only delivered the FMLA paperwork to 25 Jack as soon as it was presented to me. APEX REPORTING, INC. TALLAHASSEE, FLORIDA 850-597-5185 EXHIBITA 11 Q Do you know if Jack McLean was city manager at the time that Catherine went out on leave? A Yes, he was. Q Let me ask you this: Do you have specific knowledge of actually handing that note to Jack McLean? A Well, I certainly couldn't tell you a date and time. I mean, whenever it was presented to me, I would think that day, I would have gone down to his office and said, "Oh, this is what's coming up." 10 Q And so I know you're testifying that's what 11 you would have normally done. Do you have any specific 12 memory of actually giving that note to Jack McLean in 13 this case? 14 A I do not. 15 MR. PAFFORD: Okay. I don't have any other 16 questions. 17 MR. GAGLIARDI: I don't have any follow-ups. 18 Mr. Beason, you'll have the opportunity to 19 read the transcript should it be ordered. Or you 20 can waive your right to read the transcript if you 21 believe that it's likely to have been transcribed 22 accurately. 23 THE WITNESS: Well, can you send it to me? 24 (Deposition concluded.) 25 APEX REPORTING, INC. TALLAHASSEE, FLORIDA (850) 597-5185 EXHIBITA 12 ERRATA SHEET PAGE/LINE NO. EXPLANATION FOR CORRECTION —----+ --- a+ --- aa --- a+ --- ee Re ee ee ee —---- —-- ee Re ee ee ee 10 —---- —-- 11 see ee Se ee es 12 a+ —-- 13 ae ee Se ae re a 14 STATE OF FLORIDA 15 COUNTY OF 16 17 I, the undersigned, declare under penalty of 18 perjury that I have read the foregoing transcript, and I 19 have made any corrections, additions or deletions that I 20 was desirous of making; that the foregoing is a true and 21 correct transcript of my testimony contained therein. 22 EXECUTED this day of , 2021, 23 at 24 25 TED BEASON APEX REPORTING, INC TALLAHASSEE, FLORIDA 850-597-5185 EXHIBITA 13 CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF LEON ) I, the undersigned authority, certify that TED BEASON personally appeared before me via videoconference, Zoom, and was duly sworn, and identity was verified through Florida Driver's License. 10 11 WITNESS my hand and official seal this 18TH 12 day of DECEMBER, 2021. 13 14 15 16 17 YVONNE LaFLAMME, RPR, CCR, FPR-C Notary Public - State of Florida 18 My Commission Expires 10/15/22 Commission #GG229501 19 20 21 22 23 24 25 APEX REPORTING, INC. TALLAHASSEE, FLORIDA 850-597-5185