(1) Did you witness Mark
Mcfarland and Delann Lamb, sitting together in Mcfarland's green van, while
parked near Sears SLS, during business hours, passing a small, smoking object
back and forth which you believed to be a pot or crack pipe?
(2) In the fall of 2000,
did you become so disgusted with what you perceived to be dishonesty and
incompetence by Delann Lamb that you blocked your email address so that she
could no longer email you?
(3) Delann Lamb was required to
fax a worksheet to you at the end of each shift so that you could complete and
post the drivers' dispatches from the Sears SLS center. You began calling Lamb
using your own cellular phone roughly 35 minutes before you arrived at Sears
SLS, reminding her to fax the worksheet. Is it true that when you arrived 35
minutes later, the worksheet had been faxed to Sears SLS in almost no
(4) Once you arrived at Sears
SLS did you then commence to calling Lamb repeatedly, roughly every seven
minutes, reminding her to send the fax, and did it often take as many as ten
or more calls over more than an hour for Lamb to send the fax so you could
complete your dispatches and go home?
(5) Was Lamb's excuse for this
most often that she had simply forgotten?
(6) Was this behavior by Lamb a
matter of significant amusement and disgust for Sears SLS employees who
witnessed this problem night after night and month after month?
(7) Did you attribute Lamb's
inability to perform this very simple and repetitive scheduled task to copious
use of illegal drugs and the resultant loss of cognitive abilities on the part
(8) Did Lamb tell you numerous
stories on numerous occasions, during working hours, in the office, about her
live-in boyfriend, who hosted illegal "rave parties"
in the Kent and Seattle areas, and did Lamb state that she and her boyfriend
sometimes spent as much or more than $50,000 to host such a party for one
(9) Did Lamb also tell you, on
several occasions, during working hours, in the office, in front of witnesses,
that these illegal rave parties were "just big drug parties" and
that illegal drugs were "everywhere" and available to
"everyone" during these parties?
(10) Did Delann Lamb tell
you that Mark Mcfarland often turned his cellular phone off when he was away
from the office during business hours, because he didn't like being bothered?
(11) In approximately
February of 2001, at a time when Sarah, the office secretary, was visiting you
at your home, did you show Sarah a copy of your exit interview that you had
typed and were considering submitting to Dart and posting on the Internet?
(12) Did that document contain direct
information regarding your knowledge of Mark Mcfarland's and Delann Lamb's
illegal drug use?
(13) Did you relate to Sarah that it was
your intention to remove the sections pertaining to illegal drug use because
you didn't want to cause anyone that much trouble?
(14) Did Sarah then, several times,
encourage you vehemently to include the sections pertaining to Mcfarland's and
Lamb's illegal drug use, saying, "Why not? I think you oughta do it. I think
you should. Fuck them. They asked for it."?
(15) Did Sarah express this sentiment to
you several times during that visit and particularly at the end of that visit?
(16) Have you ever hosted, posted, or
had anything to do with a site called "Revenge on the Boss" or anything
remotely similar in any way?
(17) Have you ever made a gag product which depicted Mark Mcfarland, or anyone else, as a pedophile or
anything similar along these lines?
(18) Did Mark Mcfarland invite you on a
fishing trip with him, and did you decline?
(19) Did mark Mcfarland and Delann Lamb
both tell you, at various times, that they had to remove all of their
pornographic pictures from the walls of the office and from Mcfarland's office
while corporate employees from Los Angeles were in town?
(20) Did Tim Conner indicate to you that
he was disgusted with Mcfarland's drug use and associated incompetence, saying
he had "just about had it" with Mcfarland because of this?