Chapter Thirteen“This is tape one of the deposition of James Nolan being taken on behalf of Plaintiff at the Law Offices of Simmons and Winslow, 1462 Lake Ave., Pasadena,” the videographer announced. “May I have counsel introduce themselves for the record please?”
“Scott Winslow on behalf of the Plaintiff, Sarah Willis. Ms. Willis is also present.”
“Michael Graber on behalf of Defendants and Robert Berg, Ellison's HR Director is also present.”
“Ms. Reporter, will you please swear the witness?”
“Please raise your right hand Mr. Nolan. Do you swear to tell the truth, the whole truth and nothing but the truth?”
“I do.”
Scott said, “Good morning, Mr. Nolan. You realize that you are testifying under oath today?”
“Yes.”
“As a result, you are subject to the same penalties of perjury that
