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Robin Litaker Case 2:14-cv-02176-MHH Document 21-1 Filed 01/15/16 Page 1 of 135 FILED 2016 Jan-15 PM 07:58 U.S. DISTRICT COURT N.D. OF ALABAMA Exhibit 1 Case 2:14-cv-02176-MHH Document 21-1 Filed 01/15/16 Page 2 of 135 Robin Litaker 1 Page 1 Page 3 1 IN THE UNITED STATES DISTRICT COURT 1 A P P E A R A N C E S (Continuing) 2 NORTHERN DISTRICT OF ALABAMA 2 3 SOUTHERN DIVISION 3 FOR THE DEFENDANT: 4 4 Ms. Anne R. Yuengert 5 CIVIL ACTION NO. 2:14-cv-2176-MHH 5 and Donald B. Sweeney, Jr. 6 6 Attorneys at Law 7 ROBIN LITAKER, 7 Bradley Arant Boult Cummings LLP 8 Plaintiff, 8 One Federal Place 9 vs. 9 1819 Fifth Avenue North 10 HOOVER BOARD OF EDUCATION, et al., 10 Birmingham, Alabama 35203-2119 11 Defendants. 11 (205) 521-8000 12 12 [email protected] 13 DEPOSITION OF ROBIN ANN LITAKER 13 [email protected] 14 Bradley Arant Boult Cummings LLP 14 15 One Federal Place 15 OTHERS PRESENT: 16 1819 Fifth Avenue North 16 Mr. Andy Craig 17 Birmingham, Alabama 35203-2119 17 Ms. Carol Barber 18 May 27, 2015 18 Ms. Mary Veal 19 19 Ms. Niya McCray 20 REPORTED BY: Laura H. Nichols 20 21 Certified Realtime Reporter, 21 22 Registered Professional 22 23 Reporter and Notary Public 23 Page 2 Page 4 1 A P P E A R A N C E S 1 INDEX OF EXAMINATION 2 2 3 FOR THE PLAINTIFF: 3 Page: 4 Mr. Kevin W. Jent 4 EXAMINATION BY MS. YUENGERT 7 5 Attorney at Law 5 EXAMINATION BY MR. JENT 269 6 Wiggins, Childs, Pantazis, 6 REEXAMINATION BY MS. YUENGERT 270 7 Fisher & Goldfarb, LLC 7 8 The Kress Building 8 9 301 19th Street North 9 INDEX OF DEFENDANT'S EXHIBITS 10 Birmingham, Alabama 35203 10 11 (205) 314-0549 11 Page: 12 [email protected] 12 Defendant's Exhibit 1 57 13 13 (Email) 14 14 Defendant's Exhibit 2 59 15 15 (Email) 16 16 Defendant's Exhibit 3 138 17 17 (Series of emails) 18 18 Defendant's Exhibit 4 147 19 19 (Resignation letter) 20 20 Defendant's Exhibit 5 164 21 21 (Principal employment contract, 22 22 probationary contract principal) 23 23 Tyler Eaton Morgan Nichols & Pritchett 877-373-3660 Case 2:14-cv-02176-MHH Document 21-1 Filed 01/15/16 Page 3 of 135 Robin Litaker 2 Page 5 Page 7 1 INDEX OF DEFENDANT'S EXHIBITS (Continuing) 1 I, Laura H. Nichols, a Certified 2 2 Realtime Reporter and Registered Professional 3 Page: 3 Reporter of Birmingham, Alabama, and a Notary 4 Defendant's Exhibit 6 166 4 Public for the State of Alabama at Large, 5 (First evaluation, probationary 5 acting as Commissioner, certify that on this 6 principal) 6 date, as provided by the Federal Rules of Civil 7 Defendant's Exhibit 7 168 7 Procedure of the United States District Court, 8 (Second evaluation, probationary 8 and the foregoing stipulation of counsel, there 9 contract principal) 9 came before me at the offices of Bradley Arant 10 Defendant's Exhibit 8 170 10 Boult Cummings LLP, One Federal Place, 11 (Three-year contract) 11 1819 Fifth Avenue North, Birmingham, Alabama 12 Defendant's Exhibit 9 186 12 35203, on May 27, 2015, commencing at 9:59 13 (Email from Litaker to Mary Veal 13 a.m., ROBIN ANN LITAKER, witness in the above 14 on April 1st, 2013) 14 cause, for oral examination, whereupon the 15 Defendant's Exhibit 10 190 15 following proceedings were had: 16 (Attachment to the email marked 16 17 as Defendant's Exhibit 9) 17 ROBIN ANN LITAKER, 18 Defendant's Exhibit 11 196 18 being first duly sworn, was examined and 19 (EEOC charge) 19 testified as follows: 20 20 21 21 EXAMINATION BY MS. YUENGERT: 22 22 Q. Okay. Ms. Litaker, my name is 23 23 Anne Yuengert. I am here to take your Page 6 Page 8 1 S T I P U L A T I O N 1 deposition today. 2 IT IS STIPULATED AND AGREED, by 2 A. Okay. 3 and between the parties, through their 3 Q. Have you ever had your deposition 4 respective counsel, that the deposition of 4 taken before? 5 ROBIN ANN LITAKER may be taken before Laura H. 5 A. No. 6 Nichols, Commissioner, Certified Realtime 6 Q. Okay. As I am sure your lawyer 7 Reporter, Registered Professional Reporter and 7 has explained to you, I am going to ask you 8 Notary Public; 8 questions, and you are going to give me 9 That the signature to and reading 9 answers. The ground rules are that you have to 10 of the deposition by the witness is waived, the 10 wait for me to finish my question before you 11 deposition to have the same force and effect as 11 give me an answer, so our court reporter, 12 if full compliance had been had with all laws 12 Laura, can get us both down. 13 and rules of Court relating to the taking of 13 A. (Nodding.) 14 depositions; 14 Q. You also need to give me a verbal 15 That it shall not be necessary for 15 response. So if you shake your head or go 16 any objections to be made by counsel to any 16 "uh-huh" or something like that, I am going to 17 questions, except as to form or leading 17 prompt you just to give me a clearer response 18 questions, and that counsel for the parties may 18 so that our transcript will be clear. 19 make objections and assign grounds at the time 19 A. (Nodding.) 20 of trial, or at the time said deposition is 20 Q. If at any point you need to take a 21 offered in evidence, or prior thereto. 21 break or consult with your attorney, just let 22 22 me know. We will be here the better part of 23 23 the day, I think. So don't feel like you can't Tyler Eaton Morgan Nichols & Pritchett 877-373-3660 Case 2:14-cv-02176-MHH Document 21-1 Filed 01/15/16 Page 4 of 135 Robin Litaker 3 Page 9 Page 11 1 stop if you need to. 1 A. That is my brother's business. 2 A. Okay. 2 Q. Okay. 3 Q. You understand that you are under 3 A. He lets me help out just -- 4 oath? 4 Q. Okay. 5 A. Yes. 5 A. I have been trying to stay busy. 6 Q. If at any time I ask you a 6 Q. What is the name of his business? 7 question that you don't understand, you need to 7 A. It is Wise Technology. He does 8 ask me to clarify it. If you don't ask me to 8 educational software, and for no pay, because 9 clarify a question, I am going to assume that 9 it is a start-up company, I have just gone 10 you understood it. Is that fair? 10 around and helped different school districts 11 A. Yes. 11 with some transportation software, but not a 12 Q. Are you taking any medication 12 lot. 13 today that would interfere with your ability to 13 Q. Where did you go to high school? 14 answer my questions truthfully? 14 A. I went to Lower Richland High 15 A. No. 15 School in Columbia, South Carolina. 16 Q. Could you state your name for me? 16 Q. After high school, where did you 17 A. Robin Ann Litaker. 17 go to college? 18 Q. Have you ever had any name other 18 A. I went to Winthrop College. I got 19 than Robin Ann Litaker? 19 my BS and my MAT from Winthrop. 20 A. No. 20 Q. What is an MAT? 21 Q. And where do you currently live? 21 A. It is a Master of Arts in 22 A. I live at 312 Gainswood Road -- it 22 Teaching. 23 is one word, G-A-I-N-S-W-O-O-D, Homewood. 23 Q. After you finished at Winthrop, Page 10 Page 12 1 Q. How long have you lived at the 1 did you start working? 2 Gainswood Road address? 2 A. I worked in Mobile County at two 3 A. I think this is -- I think this is 3 different schools. I was at Maryville 4 my eleventh year, close to it. 4 Elementary; I left for a year, and then went 5 Q. Does anybody live at the Gainswood 5 back to Maryville. And I don't remember the 6 Road address with you? 6 year I left. 7 A. No. 7 Q. That is okay. 8 Q. Do you have any family who live in 8 A. But it was ten years from '82 9 the Northern District of Alabama? 9 to '92 when I started working in Hoover. 10 A. No. I have just moved my father 10 Q. What did you do the year that you 11 to Fairhope, so it is just me. 11 left? 12 Q. Okay. Do you have other family in 12 A. That I left? 13 Fairhope? 13 Q. Yes. 14 A. Yes. 14 A. I went to Dodge Elementary in 15 Q. Who is down there? 15 Mobile County. 16 A. I have a brother, a sister-in-law, 16 Q.
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