(1) Did Mark Mcfarland,
referring to your joke-fax of 8-4-2000, tell you that it was one of your
funniest, and that he thoroughly enjoyed receiving it and others, and that he
wanted to show you that he could also write well?
(2) Did Mcfarland then proceed
to show you a letter he had written to an ex-wife in California, who had asked
him for additional child support?
(3) Was this letter virtually
one long sentence, nearly devoid of punctuation, containing dozens of spelling
errors, and, in your view, written from the viewpoint of someone closer to 14
years of age?
(4) Were you saddened and
embarrassed for Mcfarland because of this?
(5) Did you, at that time, in
order to spare his feelings, tell Mcfarland that his letter was "a
masterpiece" and that you had seldom seen such fine writing?
(6) Did Mcfarland often ask
you to stay late and fix problems with his computer?
(7) Were you paid extra for
(8) Did Mcfarland once call
you into his office and explain that he had been instructed by Dart to
purchase Microsoft Excel, and that he had done so, but that even though he had
worked on it for several days, he was unable to get the program up and
running, and did he ask for your assistance?
(9) Did you agree to help him,
and did you discover that Mcfarland had not purchased Microsoft Excel at all,
but that he had erroneously purchased an Excel tutorial, which,
of course, only described how to use Microsoft Excel?
(10) Did you consider this act
by Mcfarland to be another in a long litany of incidents which, in your view,
could only be described as incompetence, and did this make you feel
embarrassed for Mcfarland?
(11) Were you often offended by
Mark Mcfarland's repeated racial slurs, which were spoken in the office,
during working hours, in front of witnesses and other employees?
(12) Did you overhear
conversations in the office, during working hours, between Mark Mcfarland and
two other Dart drivers, which led you to believe that the three were
transporting small amounts of illegal drugs between Los Angeles and Kent using
Dart equipment, for personal use?
(13) Did you witness Delann
Lamb standing in the office window, during business hours, smoking a substance
in a small pipe, and did you believe she was smoking illegal drugs?
(14) Did you find a small,
dismantled pot pipe in Mark Mcfarland's top right-hand desk drawer?
(15) Did Delann Lamb make this
comment, in the office, during working hours, when referring to a pornographic
magazine that one of the employees had brought in: "My favorite part was:
'Stick it in me baby; stick it in me hard.'"?
(16) Did Delann Lamb make this
statement to you, in the office, during working hours, in response to your
concerns that Dart was treating Sears badly for no apparent reason:
"Sears doesn't have any choice. Sears has to use Dart no
matter what we do."?
(17) Did Mark Mcfarland make
this statement to you, in the office, during working hours, in response to
your concern that Mcfarland had no valid reason for refusing to move the 4119
delivery time by one hour at Sears' request: "They [Sears] haven't been
very nice to us lately, so therefore we're not going to be very nice to them.
That's how it works."?
(18) Do you have reason to
believe that Mark Mcfarland dragged a garden hose across the rear fender of
your new motorcycle, causing approximately $250 damage, and then lied to you,
saying he had done no such thing?"
(19) Did you suffer a number of
pay discrepancies over the years, all of which, with no exception, were in
your employer's favor?
(20) Did Mark Mcfarland make
many comments to you over the years, in the office(s), during business hours,
in front of witnesses, to the effect that he and Bob Mcfetters "went way
back together", and that if there was ever a discrepancy in which it was
a matter of Mcfarland's word against someone else's, Mcfetters would side with
him no matter what?