(1) Did Delann Lamb tell you
that Mark Mcfarland and other office management maintained their own private
vehicles in "perfect condition" by using Dart or T&L company
supplies, goods and services?
(2) Does Mark Mcfarland
routinely drive a class-a vehicle in order to make deliveries for his company
in the Kent area even though he is not allowed to drive class-a vehicles?
(3) Did Delann Lamb state to
you that she felt you were the kind of person who would only take them to
court if they "screwed you over", as opposed to someone who would
act violently in the same situation, and did you find the motivation for
making this statement curious at the time?
(4) Did Delann Lamb boast to
you that she knew "many ways" to make sure an ex employee could not
get another job if that's what she desired?
(5) Have you witnessed office
management using vehicle maintenance services paid for by Dart or T&L to
have their own vehicles maintained, and did Delann Lamb tell you this was
something they felt they "deserved"?
(6) Did Mark Mcfarland state to
you, on several occasions, that he wasn't going to help Sears by altering
delivery times even by one hour, even though it would not inconvenience him in
any way, because, in Mcfarland's words: Sears had not been very nice to
(7) Have you witnessed Mark
Mcfarland promise a line driver with a family emergency, who had already been
out three weeks, that he could come home within two days, only to hang up
the phone, and to laugh, and to tell those in the office: "Little does he
know I'm going to keep him out for three more weeks"?
(8) Have you witnessed a number
of similar exchanges between Mark Mcfarland, his drivers, and the office
staff, and did you feel this behavior was reprehensible and dishonest?
(9) Did Delann Lamb make this
statement to you, in the office, during working hours, in front of witnesses,
about three days before you quit in December of 2000: "Mark is boring as
hell. If I was going to have an affair with anyone in this office, it would be
you. You're the one I'd be after."?
(10) Did you reply in any way
to that statement?
(11) Did the statement make you
feel uncomfortable, and did you feel it was an incredibly rude and
uncalled-for thing to say in front of Mcfarland and the office staff?
(12) Did Mark Mcfarland make
this statement to you, in the office, during working hours: "There are a
lot of ways to beat a drug screen for pot. I know a lot of good ways. The
other stuff is different, but pot is easy"?
(13) Before you quit working
for T&L, had you made any comment to Delann Lamb or Mark Mcfarland,
whatsoever, even one time, that could in any way, by any stretch of the
imagination, be considered threatening, alarming or abusive?
(14) After you quit T&L,
did you make any comment to Delann Lamb or Mark Mcfarland, that could in any
way be considered impolite?
(15) Was that comment,
"You two are not fit to run a Burger King"?
(16) Were you allowed to view
all of the pictures that Mcfarland, Lamb and Tift tried to infer to the court
had been posted on the Internet?
(17) Did you formally demand
copies of those pictures from Leigh Ann Tift so that you could at least
confirm or deny that you had even created the pictures?
(18) Did Leigh Ann Tift or her
firm ever respond to your demands regarding these pictures?
(19) Did Mark Mcfarland and/or
Delann Lamb ask you to consider promoting into the office as a dispatcher, or
to take on additional runs which required, in their words, their "best
and most reliable drivers", even as late as the day you quit?
(20) Did you have trouble with
Mark Mcfarland before you ever applied for work with Dart/T&L?