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STATES OF AMERICA OPPORTUNITY COMMISSION
L. CALLEJA, Complainant, v. EEOC Case No. 510-2007-00443X AGENCY Case No. HS-06-CBP-006022-090118
MICHAEL CHERTOFF, SECRETARY, U.S. DEPARTMENT OF HOMELAND SECURITY, Agency.
Monday, November Deposition of;
DENISE L. CALLEJA taken at the instance of the Agency for purposes of discovery
and for use as evidence taken before Public Offices Border Florida
in the above-entitled
FROST, Court Reporter/Notary at Large, at the and
in and for the State of Florida of the Associate Protection, Chief Counsel,
909 S.E. 1st Avenue, at 9;00 a.m.
Room 606, Miami,
WARREN & ASSOCIATES
COURT REPORTERS TEL uruo NE FAX
(56/) 967-0262 (561) 649-21Mi
to tell you. There's no question out there. we know that -.206 1 Q Do you have any evideDce for prior I'm basing EEO activity? that it was in 2 3 retaliation A it upon my judgment I couldn't and my treatment. And you have no in assisting us on your case? Q A Q 22 23 24 25 problem with sharing information in your case with Gene Cavicchi? A Absolutely none. Just a few here." Q Now you used a phrase. CONRAD: Q 10 11 12 13 14 Just for the record. "good old boys sex club. when I would just rather hide away in my house and not face the public. No further questions. with both Mr. And Gene is working Yes. Cavicchi and I on Gene Cavicchi's 18 19 20 21 Yes. because struggle even begin all I know is every day I live with having through coming out -.going out that door and going with the Agency and the people and the to work and dealing public. WARREN & ASSOCIATES COURT REPORTERS TELEPHONE (561) 649-2166 FAX (56l) 967-0262 . MR. CONRAD. to 4 5 6 7 8 9 So as to the damages. CROSS-EXAMINATION BY MR.just want to you are 15 16 17 make it clear for the Agency working case? A and for the record. SCHRAGER: MR.
Chris Maston. different Walter of the elite seaport CET Team and the CET Team at the Chiefs and certain Airport. I first joined the Agency I was told that I was a new of meat and if I played my cards right and went to all and provided the favors that my -. I did not know him. Q Jeff Baldwin. Lee. Q A Q A And by fast track. Michael Sinclair. Garafano. 15 16 Was Chris Maston part of this group? When I first came in. You're talking about Jeff Balwin who's no longer here? WARREN & ASSOCIATES COURT REPORTERS TELEPHONE (561) 649-2166 FAX (50 I) 967"0262 . the time you started with INS in 2000 through are we talking including A the present. and that was Mr. about inclusive of everybody you named. International when piece -. Chris Maston? Yes. The Port Director. prime jobs. They have supervisors at the Miami the airport.207 1 2 3 Who are we talking boys involved A about when you talk about the good old in this? that I'm talking to the Agency. from But 17 18 19 20 21 22 23 24 25 since he's been reassigned Q I'll rephrase it. about from the When I mentioned 4 5 6 7 8 9 10 11 12 13 14 time I was first assigned Ahearn. back to the port. TDY's. so to speak. members Thomas Winkowski. no. yes.like I stated earlier. This club. what do you mean? Rapid promotions.I the social parties would be on the fast track in the Agency.
208 1 2 A Yes.did you overhear conversation party A 14 15 16 a or were you approached by a Chief to be a third in a sex-capade? Yes. 10 11 12 13 Okay. Chief Babock requesting she propositioned the two officers in my -. Did you with her and Candamaris Did you -.who else I couldn't tell you.I 6 was invited annual I think it was in 2005. I'm just going to be bouncing around here just to Q clear up some things. Q A 3 4 5 that it does.I was invited a year.you said this offended 25 report this to anybody? WARREN & ASSOCIATES COURT REPORTERS TELEPHONE (561) 649·2166 FAX (561) 967-0262 . I 17 18 19 20 21 22 23 24 wasn't approached. Did it include I had heard Jose Ramirez? He's from the seaport. Lopez? Q A What about Wilfredo I've heard of him as -. birthday. in fact -. I'm not aware of was Stanley Mongery sure if she's till with the Agency threesome Q any more or not. to go to their and I was told that it was a big bash 7 8 9 Christmas party and that I would have a good time and there are lots of favors to be had and it would be good Q A for my career. to do a for his fortieth you. At one time were you -. And I did not go. but I was offended It was because I was there and overheard the conversation. but the ones that I'm and Christina Abesu.
and she 2 3 4 told me that there was really nothing But then I brought my EEO when I to be done about it.a sexual Q A I could not file a sexual -- Harassment.I overheard a conversation. So I brought that." to that? A Did Gene Cavicchi No. was not aimed at me.that I so it -.209 1 A To my supervisor. Gooche when that information up to Lauren first contacted the EEO. that we've mentioned that I have a list of people or members. 'cause she wanted to show that it 5 6 7 8 9 10 11 12 13 14 to see if -. what I had as proof was discrimination. the one that I initially other assistance because went to and then 17 18 19 requested she made me feel like I was the perpetrator Q instead of the victim. -. belong of the ugood old boys sex club.VE (56!) 649-2166 FAX (561) 967-0262 . complaint. Q Have you ever had any encounters with Gene 25 Cavicchi? WARREN & ASSOCIATES COURT REPORTERS TELEPHO. Delise. proof. She said I had to show her a pattern of all these different incidents up and I mentioned couldn't And she told me that I could -. so therefore -. Virginia Delise. 20 21 22 23 24 were associates whatever terms you want to use.harassment Lauren Gooche.you know.that it was -. are we speaking about the South Q 15 16 Florida EEO officer? A Yes.
You're seeking compensatory damages. Q I've never had any problems with him. Yes. yes. asking the Q that. Schrager seeking asked you on damages. I'm saying you're you having Agency back? A to restore that to you without to buy it If possible. that 8 Q And without maximum -. Is it true Now Mr. yes. that are 24 25 Q There are any number of individuals in the Investigative Report contained who have indicated WARREN & ASSOCIATES COlJRT REPORTERS TELEP II one F:4X (561) Y67-0262 (561) 649-2166 .210 1 A The only encounters I had with Officer Cavicchi is 2 3 4 5 like the training or I've seen him at the seaport and talked to him. a dollar Q 12 13 14 15 16 17 18 amount.you understand damages 9 10 11 Statutory A compensatory is $300.00? Now that you told me.OOO. You're Yes. And you're seeking restoration of lost sick or of the stress this seeking attorneys' fees? Q A Q annual leave that you have used because has caused you? A I I 19 20 21 22 23 just recently understand bought them back. I've seen him at the range. in Houston? 6 7 that you're A a transfer Yes. but he's always professional. I would like to transfer getting to Houston. you're A seeking a transfer to Houston.
directly? Have you spoken to any of these people Since the investigation? all the time. the stand that they did. environment. when the phone. hope that my EEO complaint and you know.you know.I'm trying not to be better of them. that you had an EEO complaint a previous 25 supervisor about had hit you WARREN & ASSOCIATES COURT REPORTERS TELEPHONE (561) 649-2166 FAX (_'i()f) 967-0262 . to answer No. but bitter I expected 9 10 11 12 13 14 15 at the same time. Has everything testified belief? A drunk or smelled incidents on her breath or witnessed some of these today that you've said and and to been truthful to the best of your knowledge Yes. I expect think about their careers. they tell me they miss my cooking. doesn't make up for them lying about what they know. they That 19 20 goes well and that I win.211 1 2 3 4 5 6 7 8 that they have never seen Jan Jarrette alcohol here. They ask about my I call and 16 17 18 welfare They ask -. and those individuals against them because -. they're happy they happen to hear from me. Q You 'indicated that a supervisor. I understand that they're still in that they have to work in there and they have to So I understand forgive why they took them. because that they call her 21 22 23 24 it's the common joke around the airport drunken Jarrette or they make a bet to see how drunk she is that day. but I don't them to have a little Q A integrity.
Is it possible that Jan Jarrette or exotic was upset with looking? Q you because A Q you were attractive It could be. Spooner A referring to previously? it. but I heard the 25 rumor that she swung both ways and that there are quite a WARREN & ASSOCIATES COURT REPORTERS TELEPHOA'E (561) 649-2166 FAX (56!) 967-0262 . to make sure we're clear. I have no personal -. Yes. Q I just wanted who you're And nothing It's Mr. to you about Do you believe that Jan Jarrette's about your disability 7 8 9 comments empowered A Q she's not caring her to harass you? Yes. Hyman were the chief that Lorenzo instigators A of this hostile work environment? Most definitely. Do you believe that Jan Jarrette's efforts -. most definitely. because You can say anything.212 1 2 3 4 5 6 in the chest? A Yes. Spooner. I do. And is that because you told him no to sexual Q favors? A Yes. was done about Q All right. Supervisor Okay.or 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 dealings with you were part of an effort to create a hostile work environment? A Q I most definitely Do you believe do.can I say this? A knowledge.
were there any women Women. And she was one of the players. WARREN & ASSOCIATES COURT REPORTERS TELEPHO. and around of of -- 2 3 4 5 6 the sexual club. of what DSS stands No one's for. "Use your body. meaning like -- in that club? 15 16 Q Did anybody tell you.the baggage the passengers The sex club. passenger by.it's just a room that the Chief and they can look out through the going on on the walk sits in with the monitors double glass. And I'm -- 21 22 23 24 Q A not sure what happened She didn't 25 she didn't really go anywhere. to Veronica Estrada.213 1 few supervisors that they're different Q at the port. I think 19 20 she was a GS-9 and now she's Q A Who? Chief Cambiaso. that do. it was passing partners Again. She's still stuck in Miami. When I first met her she was a GS-9. use your 17 18 looks"? A Yes. What does DSS stand for? A To be honest with you. male and female. 7 8 9 10 11 ever given me an explanation Q A What happens there? It's just a -. I and that was the whole purpose apologize for bouncing around. I have no idea. Chief Cambiaso? Yeah.\'E (561) 649-2166 FAX (56!) 967-0262 . Q A to look out and see what's area and watch 12 13 14 -.
Q A she's now I think a Chief with She was another -. party was there and the public was there. compared My one cuss word to Officer to the language I heard. and Chief Cambiaso. Mr. How do you know this? Because they talk about it openly at the airport that I was told the time thing was 5 6 and at the seaport.working with one of the club members. when I got assigned It was during 7 8 9 10 11 12 13 14 here when the Ileana Gonzalez INS picnic the big thing and we had the legacy Smith Park out in Pembroke Pines. And I was literally floored. in particular. they're half undressed. Ahearn. is hanging drinking. witness because Q A it.'E (561) 649-2166 FAX (56}) 967-0262 . and the They could I was freaked. What did you see? These already are Federal law enforcement officers and the 15 16 17 18 19 20 21 22 23 24 25 public has a bad image of us because on. out.I mean watching in the dance area and I thought version of Dirty Dancing. And the first function that I had to go to was the picnic. and it was like that I expected That was not the conduct that are supposed to WARREN & ASSOCIATES COURT REPORTERS TELEPIlOl.214 1 2 3 4 Lois Hunter. of Federal officers who was there. an X-rated and that was with Garafano and Paul Sands and everybody I was floored. and here these female and Lois Hunter everything of the things Linda that are going Babock they're supervisors.. Hyman was clean on the They were dancing I was floor -. out at CB I think it is.
this is my opinion. Now you said Mr. You mentioned No. her conduct. "Are these real"? grabbed A your breasts Yes. she offends the way she approaches a lot of people person. somewhat. she showed up. came up to you. Would you be willing whether to take a polygraph your breasts? on Q 23 24 that question. there? I Q A Was Alice O'Donnell She was there briefly -.215 1 2 3 4 5 defend Q A our country. 25 WARREN & ASSOCIATES COURT REPORTERS TELEPHONE (561) M9-2166 FAX (5M) 967-02fi2 . Okay. MR. and that -.Alice O'Donnell in anybody's believe. that kind of a -. Hyman and basically said. because -. is if you're then you get female officers to the social club. Q You know that he has denied that In his affidavit? A 21 22 Yes.was Carol Gladden there? she was legacy Customs. That includes that they notice Q Okay. CONRAD: No further questions. yes I would. She doesn't 6 7 8 9 10 11 But she's fit really is a unique bird.because so that's she's not allowed the most attractive why she wasn't 12 13 14 15 16 17 18 19 20 to join the club because female and you're invited halfway from what I noticed decent looking. crudeness. A or not he grabbed Oh. Okay. circle and I think that has left her but I feel that maybe her people.
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