Case 4:12-cv-00139-WTM-GRS Document 154-6 Filed 04/30/13 Page 1 of 43

Transcript of the Testimony of:

30 (b)(6) Deposition of Paula Deen Enterprises, LLC, et al., by Theresa Feuger
Date: November 20, 2012

Case: Lisa T. Jackson v. Paula Deen, et al. 4:12-CV-0139

Tom Crites & Associates International, Inc. P.O. Box 9438 Savannah, Georgia 31412 Phone: 800-631-3480 Fax: 912-233-7777 critesreporting@aol.com

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Page 1 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION LISA T. JACKSON, Plaintiff, vs. PAULA DEEN, PAULA DEEN 4:12-CV-0139 ENTERPRISES, LLC, THE LADY & SONS, LLC, THE LADY ENTERPRISES, INC., EARL W. "BUBBA" HIERS, and UNCLE BUBBA'S SEAFOOD and OYSTER HOUSE, INC., Defendants. _________________________________________________ CIVIL ACTION NO.

30(b)(6) Deposition of Paula Deen Enterprises, LLC, The Lady & Sons, LLC, The Lady Enterprises, Inc., and Uncle Bubba's Seafood and Oyster House, Inc., through its designated representative, THERESA FEUGER, taken by counsel for the Plaintiff, pursuant to notice and agreement, before Rachael Miller, Certified Court Reporter, at 218 West State Street, Savannah, Georgia, November 20, 2012, at 1:06 p.m.

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INDEX OPENING REMARKS AND STIPULATIONS ------- 8

APPEARANCE OF COUNSEL: FOR THE PLAINTIFF: MATTHEW C. BILLIPS, Esquire Billips & Benjamin, LLP 3101 Towercreek Parkway Suite 190 Atlanta, Georgia 30339 (770) 859-0753 S. WESLEY WOOLF, Esquire 408 East Bay Street Savannah, Georgia 31401 (912) 201-3696

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EXAMINATION By Mr. Billips -------------------- 9

ATTESTATION --------------------------- 97 ERRATA SHEET -------------------------- 98 CERTIFICATE --------------------------- 99

FOR THE DEFENDANTS: WILLIAM FRANKLIN, Esquire KELIN MURPHY, Esquire Oliver, Maner, LLP 218 West State Street Savannah, Georgia 31401 (912) 236-3311 Page 3

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FOR THE DEFENDANTS: THOMAS A. WITHERS, Esquire Gillen, Withers & Lake, LLC 8 East Liberty Street Savannah, Georgia 31401 (912) 447-8400 Also Present: Jody Farmer, Paula Deen, Earl Hiers

DOCUMENTARY EVIDENCE NUMBER DESCRIPTION PAGE 1 Amended Notice of Deposition 9 2 Amended Notice of Deposition 9 3 Amended Notice of Deposition 9 4 June 14, 2011 email 50 Subject: From Tanya/Conference call - retail coordination 5 August 18, 2010 email from 59 Tanya at Mackworks 6 December 12, 2011 email from 67 Karl Schumacher Subject: UB Christmas bonuses 7 August 19, 2010 email from 69 Schumacher CPA Subject: Catering for Sept. 11 8 September 27, 2010 email from 71 Schumacher CPA Subject: UB - food costs at Lady & Sons 9 October 2010 emails 73 Subject: No Harassment Policy Form

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August 13, 2010 email from 75 Schumacher CPA Subject: UB needing managers July 28, 2010 emails 76 Subject: Bubba's Posters The Lady Enterprises, Inc. 95 Organizational structure Uncle Bubba's Seafood & 96 Oyster House, Inc. Race and gender composition The Lady Enterprises, Inc. 96 race and gender composition (Original Exhibits attached.)

MR. BILLIPS: This will be the deposition of Defendant Uncle Bubba's Seafood and Oyster House, Incorporated, taken pursuant to notice and agreement of counsel. All objections, except objections to the form of the question and responsiveness of the answer, will be reserved until such time as the deposition is sought to be used in evidence in this matter. The deposition is on cross-examination for purposes of discovery and all other purposes allowed under the Federal Rules of Civil Procedure and the Federal Rules of Evidence. MR. FRANKLIN: Ms. Feuger is speaking -responding for all of the defendants to those -those numbered ones. MR. BILLIPS: I understand that. I was anticipating that we would take the depositions separately, but if she wants to go over it for all of them, that will work too. MR. FRANKLIN: I think that would streamline it. MR. BILLIPS: I think it probably will. MR. FRANKLIN: And she will read and sign the deposition and can do so in the presence

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DISCLOSURE STATEMENT STATE OF GEORGIA: COUNTY OF CHATHAM: Pursuant to Article 10.B. of the Rules and Regulations of the Board of Court Reporting of the Judicial Council of Georgia, I make the following disclosure. I am a Georgia Certified Court Reporter. I am not disqualified for a relationship of interest under the provisions of O.C.G.A. 9-11-28(c). Tom Crites & Associates International, Inc. was contacted by S. Wesley Woolf, P.C. to provide court reporting services for this proceeding. Tom Crites & Associates International, Inc. will not be taking this proceeding under any contract that is prohibited by Georgia law. This, the 5th day of December, 2012. _________________________

of any notary public. MR. BILLIPS: All right. Then this will also be the deposition under the same stipulation and for the same purposes of Defendant Paula Deen Enterprises, LLC, and Defendant The Lady Enterprises, Incorporated. And I need copies of those. If you will mark as 2 and 3. (Exhibit 1 marked for identification.) (Exhibit 2 marked for identification.) (Exhibit 3 marked for identification.) THERESA FEUGER, having been first duly sworn, was examined and testified as follows: EXAMINATION BY MR. BILLIPS: Q. Please state your full legal name. A. Mary Theresa Feuger. Q. I'm sorry. A. Mary Theresa Feuger. Q. How do you spell Feuger? A. F-e-u-g-e-r. Q. Okay. And where and in what capacity are you presently employed? A. I am operations manager for Paula Deen Enterprises.

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Q. Okay. I'm going to show you what we've marked as Exhibits 1, 2 and 3 to your deposition. And have you -- do you recognize these as being the deposition notices pursuant to which you are appearing today? A. Yes, I do. Q. Okay. And in your capacity as operations manager for Paula Deen Enterprises, you are appearing as the representative of Uncle Bubba's Seafood and Oyster House, Incorporated, The Lady Enterprises, Incorporated, and Paula Deen Enterprises, LLC; is that correct? A. Yes, I am. MR. FRANKLIN: And The Lady & Sons, LLC. Did you leave that out? There are four corporation defendants, aren't there? MR. BILLIPS: That's fine. BY MR. BILLIPS: Q. The matters on which you are giving testimony are items number 1 -- and if you need to look at the deposition notice -A. I have them. Q. Items number 1, 2, 3, 10, 19 and 23; is that correct? A. Yes, sir.

parent subsidiary or are all they are -- are they all kind of on equal footing? A. They're all individually operating. Q. Okay. Now, the -- all of these corporations are at least, in part, owned by Paula Deen, correct? A. Yes, they are. Q. And -A. And it actually tells you the ownerships. Q. Okay. Now, the Lady & Sons restaurant is operated by which of these? A. What do you mean by that? Q. Which -A. It's run -- it's under The Lady & Sons Enterprises. Q. Okay. Dustin Walls is general manager of The Lady Enterprises; is that right? A. No, he's not. Q. Okay. He was previously? A. He was previously. Q. Okay. And sometime in 20 -- in October of 2012, he left that position; is that right? A. He resigned that position to become a manager.

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Q. And have you prepared yourself to give testimony as to those items? A. Yes, I have. Q. What have you done to prepare? A. I actually put together some documentation for you for questions number 1 and number 23. And then answers for the -- read through the deposition and know the questions that I need to be able to answer. Q. Okay. Items number 2, 3 and 10, are those matters on which you can testify from your own personal knowledge? A. Yes. Q. Okay. Then describe for me, if you would, the organizational structure of Paula Deen Enterprises, LLC. A. I am going to give you -- and this is actually -- can I move these? Q. Sure. A. These are actually the three organizations, Uncle Bubba's, Lady & Sons, and Paula Deen Enterprises. I think they're pretty self-explanatory to the question. Q. All right. Is there any relationship between these corporations as -- in the sense of

Q. Okay. So he is a manager where? A. At The Lady & Sons. Q. What kind of a manager? A. Floor manager for the front of the house. Q. Okay. All right. Now, Paula Deen Enterprises has as its -- the officers of Paula Deen Enterprises, there's listed as officers, per Secretary of State, CEO, Paula Deen; CFO and secretary, Robert Deen. And then below that it has managerial employees since January 1, 2008. Member, Paula Deen; CFO, Karl Schumacher; operations manager, Theresa Feuger. Feuger. A. Feuger. Q. Feuger. Okay. As the operations manager for Paula Deen Enterprises, do you perform any managerial tasks or recite functions for the -- for Uncle Bubba's or for The Lady Enterprises? A. I have at one time. Q. Okay. And when did that stop? A. Middle of this year. May of this year. Q. Okay. So May of 2012? A. Yes, sir. Q. And when did your employment begin? A. 2003.

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Q. Okay. So throughout 2003 through 2012, you performed managerial functions for Uncle Bubba's and The Lady Enterprises? A. I helped out, yes. Q. Okay. Did you -- how would you describe your role with those entities during that time period? A. From -- well, in -- it would actually be later. It would be -- Uncle Bubba's opened in 2005. So from about 2005 to 2010, I was working directly with Paula. And anything that she would need at either Lady & Sons or Uncle Bubba's, I helped out with. I also oversaw operations from August 2010 until May of 2012 for all of the operating areas. Q. And when you say anything she would need, what would that consist of? A. We had events that we would work and I'd oversee those events. Q. Okay. Did you oversee any -- prior to 2010, did you oversee any of the day-to-day operations of the restaurant? A. No, I did not. Q. Did you have any role in supervising employees at the restaurants?

at either of the restaurants? A. Absolutely. Q. Would Paula have had the authority to hire, fire, terminate, demote, promote or otherwise set the terms and conditions of employment for every employee at every one of these places? A. As an owner she could. Q. Okay. A. But she didn't. Q. Okay. But she had retained that level of authority? A. She was the owner. Q. Okay. Is that a yes? A. Yes. Q. Okay. Karl Schumacher had a more active operational role with regard to the restaurants; is that true? A. Yes. Q. And Mr. Schumacher actually dealt more hands on day-to-day with employment concerns, employment issues at, for example, Lady & Sons? A. I'm not aware of him being on a day-to-day issue, no. Q. Well, you're aware of the situation

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A. No, I did not. Q. Okay. Karl Schumacher was -- is identified as CFO for PDE. Did Mr. Schumacher play any human resources type role for the restaurants? A. There were people that came and spoke to him, yes. Q. Okay. Explain to me what you mean by that. A. If there were issues -- I mean, and they could have come to me as well. We weren't identified as -- as decision makers, but if they had -- if someone had a concern, they were certainly welcome to come to our offices and have a conversation. Q. Okay. And what types of concerns are you referring to? Complaints of discrimination, would that be included? A. It could be absolutely anything they wanted to come and talk about. Q. Would you have had any authority to do anything? A. I would have taken it to Paula. Q. Okay. And Paula would have had authority to take action with regard to employees

involving Dustin Walls where Mr. Walls apparently called an African-American employee a monkey and that he was going to get rid of -- said he was going to get rid of all of you monkeys referring to the -- a group of employees? You're familiar with that incident? A. I'm familiar, yes. Q. And Mr. Schumacher took an active role in investigating that incident; is that correct? A. Yes. He took the initiative to investigate the incident. Q. And he took the initiative to tell the restaurant management what action they needed to take toward Mr. Walls? A. Yes, he did. Q. Okay. And they were obligated to follow his instructions, were they not? A. Yes, they were. Q. Okay. But in doing so, he was acting as an employee of Paula Deen Enterprises, correct? A. Correct. Q. So in his capacity as CFO of Paula Deen Enterprises, he had labor relations or human relations authority over employees of Uncle Bubba's and The Lady & Sons?

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A. He was the accountant. He paid them so, yes. Q. Okay. Well, he wasn't paying them with his money, right? A. But it was his role, yes. Q. Okay. And had he had that -- is Mr. Schumacher still with the company? A. Yes, he is. Q. Okay. Is he still in the same role? A. Yes, he is. Q. Does he still have the same role of overseeing operations among all of the companies that he used to have? A. Yes, he does. Q. Okay. So Mr. Schumacher -- and is Mr. Schumacher employed by The Lady & Sons Enterprises in any respect? A. No, he is not. Q. Okay. Or The Lady Enterprises. Excuse me. Or is he -A. He is the accountant for Paula Deen Enterprises. Q. Okay. And he's the CFO for Paula Deen Enterprises, and that's -- those are the only actual formal employment relationships that he

him an answer, that could be grounds for their termination? A. I can't answer that. Q. Okay. Is Robert Deen active in the management of Paula Deen Enterprises? A. No, he's not. Q. Okay. What relationship is Robert Deen to Paula Deen? A. Her son. Q. Does he go by Bobby? A. Yes. Q. Has he ever held an active role in the management of Paula Deen Enterprises? A. Not ever Paula Deen Enterprises, no. Q. Has he ever held an active role as an employee of any of the other Paula Deen organizations? A. Yes. The Lady & Sons. Q. Okay. And what was his role with The Lady & Sons? A. He was an owner. He is an owner. Q. Okay. Did he play a role in managing the restaurant? A. Yes, he did. Q. Okay. Well, I tell you what. Let me go

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has, correct? A. As far as I know. Q. Okay. And it's through that relationship that he has authority over employees at the two restaurants, correct? A. Yes. Q. Okay. Would he also have authority over the employees in the store where merchandise is sold? A. Yes. Q. During the course of investigating the allegation against Mr. Walls, Mr. Schumacher would have had the authority to require employees and their agents of Paula Deen to -- excuse me -employees of the restaurants or of Paula Deen Enterprises to answer his questions and provide information relevant to his investigation? A. State that again. Q. Would he have had the authority to ask questions of the employees of the Paula Deen organizations and insist that they give him an answer? A. Yes. He could go to each operational area and ask questions. Q. Okay. And if somebody refused to give

through here and just get one question answered. The ownership of The Lady Enterprises, Incorporated, is Paula Deen, James Deen and Robert Deen. What is the relationship of James Deen to Paula Deen? A. Son. Q. Okay. And the Robert Deen that is also an owner is the same Robert Deen who is an owner of Paula Deen Enterprises, correct? A. He's not an owner of Paula Deen Enterprises. He's an officer. Q. An officer. I'm sorry. My mistake. But he's the same person? A. Yes. Q. Okay. His compensation, Robert Deen's compensation, is identified as being from The Lady & Sons and from DM. What is DM? A. Deen Management. Q. Okay. What is Deen Management? A. A business that was developed for Bobby and Jamie as they have their own individual events, happenings. Q. Okay. Does it have any relationship or affiliation with the Paula Deen organizations? A. No, it does not.

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Q. Does it -- is it called upon by the Paula Deen organizations to do events? A. No, it is not. Q. Okay. So it's totally separate? A. Totally separate. Q. Does it receive any money, or loans, or employees, or anything else from the Paula Deen organizations? A. No employees as far as -- you would have to ask our accountant. Q. About the money? A. Money. Q. Okay. So Robert Deen does not receive any compensation from Paula Deen Enterprises? A. Again, I can't answer that. Q. Okay. That is one of the items in the matter of examination, the sources of compensation and benefits for each director, officer and manager or employee. So then at Paula Deen Enterprises, the only two -- the owner is Paula Deen, she's the CEO, and Robert Deen is CFO and secretary, correct? A. Listed on paper, yes. Q. Okay. Just because you have to have

removed from his position of CEO and CFO at some time period? A. Not that I was made aware of, no. Q. I may be mistaken about that. Okay. So are Earl Hiers, Paula Deen, Robert Deen and James Deen the only blood relatives who own or are employed by the Paula Deen organizations? A. That are owned by, yes. Q. That own or are employed. Okay. Are there other blood relatives that are employed by the Paula Deen organizations? A. I have to run through the entire list to be honest. Q. Please. A. You mean as far as managers? Q. No. Just employees. Employees including managers. MR. WITHERS: Is that from 2008 to the present? MR. BILLIPS: Well, I'm sorry. Just managers down. THE WITNESS: To the rank of manager? MR. BILLIPS: Down to the rank of manager, correct. THE WITNESS: No, there is not.

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somebody to put down or -A. Most probably, yes. Q. Okay. Now, Uncle Bubba -- let me get that correct. Uncle Bubba's Seafood and Oyster House, Incorporated, which I will refer to hereafter as Uncle Bubba's, Uncle Bubba's is owned 50/50 by Paula Deen and Earl Hiers; is that correct? A. That's correct. Q. Earl Hiers is also known as Bubba Hiers? A. Yes. Q. And he is the Uncle Bubba of Uncle Bubba's? A. Yes, he is. Q. According to the Secretary of State, he is the CEO and CFO at present of that entity, correct? A. That's correct. Q. And the secretary is Paula Deen, correct? A. Correct. Q. That was not true, however, throughout the period January 1, 2008 to the present, was it? A. I'm not sure what you're asking. Q. Well, didn't Earl -- wasn't Earl Hiers

BY MR. BILLIPS: Q. Okay. Are any of the individuals down to the rank of manager romantically involved with any members of the -- of the family to your knowledge? A. I'm not aware of people's personal. Q. Okay. Now, just -- I've been referring to the Paula Deen organizations, and do you understand by that I'm asking you about Paula Deen Enterprises, LLC, the Lady & Sons, LLC, Lady Enterprises, Incorporated, and Uncle Bubba's Seafood and Oyster House, Incorporated? A. Yes, I do. Q. Are there any other organizations which have a relationship such that they would fall within the Paula Deen family of companies of the Paula Deen organizations? A. All of our companies are run individually. They're set up as individual companies, so they're not really a family of companies. There's the Paula Deen retail store that you haven't mentioned. Q. Okay. A. And I'm not aware of any others, but... Q. Okay. Now, when you say that they're

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run independently -A. Uh-huh. Q. -- in light of your and Mr. Schumacher's role and authority over the other two -- employees of the other two companies, it wouldn't actually be true to say they're completely independent, would it? MR. WITHERS: Objection. Calls for a conclusion. BY MR. BILLIPS: Q. You can answer. A. State the question again. Q. It wouldn't be true to say that these companies are entirely independent given that you and Mr. Schumacher as employees of Paula Deen Enterprises have authority over the employees of Uncle Bubba's and The Lady Enterprises? A. Well, I don't have authority over all of those operating areas. And Karl has the authority over the financial piece which, of course, makes it impossible for him to help those areas if he doesn't know what's going on. But they still run as independent. They have their own general managers, they have their own owners. Q. But he also had authority over human

general managers couldn't handle it, the owner was. Q. Okay. Then why did Mr. Schumacher handle it? A. He took the initiative. Q. Okay. Now, were there employees that were shared between the companies? A. Explain to me what you mean by shared. Q. That would perform services for more than one company. A. There are employees that work under different umbrellas, yes, that have helped perform, but have never been -- have always been paid by the company that they worked for. Would you like me to give you an example? Q. Sure. A. We have graphic design teams, creative teams that fall under me. They handle all of the brochures and catalogs so that we can manage the brand. So I have a Michelle White and an Evan Russell that would be considered shared or interchanged, but they're -- they're reports, they're direct reports out of Paula Deen Enterprises and they're paid out of Paula Deen Enterprises.

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resources functions, correct? A. No. He took initiative to handle some human resource issues. Q. Right. And he took initiative because he had the authority to do it, right? A. Yes. Q. I mean, I could take the initiative to go over and handle human resources problems, but it's unlikely anyone would listen to me. Is that fair? As Mr. Schumacher in contrast had the authority to take over responsibility for human resources issues at the restaurants? A. He had the ability to get to Paula to talk to Paula about, yes, what needed to be done. Q. Okay. And he did not always go to Paula before he went and did something, did he? A. I'm not aware of that. Q. As a matter of fact, wasn't part of his job to oversee operational and human resources issues at these restaurants during the period of time prior to the company hiring human resources employees? A. No. The general managers were responsible for handling those. And if the

Q. Okay. And they perform work for the benefit of all three corporations, correct? A. I wouldn't say that -- yes. Yes. Q. Okay. And so you're responsible for the marketing? A. Yes, I am. Q. And the marketing program for these -for the Paula Deen organizations is jointly operated, jointly run? You leverage the Paula Deen name to assist in the marketing of Uncle Bubba's and vice versa? A. We use Paula Deen's name in Uncle Bubba's because she's one of the owners, yes. Q. Okay. And does Uncle Bubba's have anybody that does marketing for them independently of you? A. We have brought on a person within the last 90 days that now handles sales and marketing for Uncle Bubba's, for Lady & Sons, Paula Deen Retail. Q. Okay. So prior to the last 90 days, the person who was responsible for the marketing program for those three organizations was you? A. No. Q. Who was?

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A. The individual areas. The general managers were responsible for their marketing plans. We merely helped support the collateral that was necessary. Q. What does that mean? A. If they needed a brochure developed, I had graphic designers that could actually create a brochure. They told us what they wanted. They told us how they wanted it marketed. We made it happen. They don't have those teams on their -they don't have people on their teams to do that. Q. Okay. During 2010 did the corporations have discussions at the direction of Paula Deen of working more closely together in their marketing operation? A. I'm not aware. Q. Okay. Did any employees ever get loaned from one -- one company to another? A. Did any employee? Q. Right. A. Explain that a little better. I'm sorry. Q. Let's say that The Lady & Sons was -let me back up just a second. Did Dustin Walls ever serve as the general manager for Uncle

restaurants to support our events and we pay those locations based on the services that they render. And the general managers, whether we do it at Lady & Sons or whether we do it at Uncle Bubba's, it's our expectation that they run the event. Q. Okay. And they get paid by the actual entity which employs them, right? A. Correct. They're running one of their own shifts so, yes. It's part of their job. Q. Okay. For what is it that Dustin Walls has been paid by Paula Deen Enterprises? A. I am not sure. That would have to come from our accountant. Q. Mr. Schumacher? A. Yes. Oh, I'm sorry. Can I -Q. Sure. A. I bet I can clarify what it is. Q. Sure. A. We have four restaurants that are outside of the restaurants that are located here in Savannah. And actually, we've used both managers from Lady & Sons and managers from Uncle Bubba's to help open those locations by going in. They are actually Lady & Sons, Uncle Bubba's and

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Bubba's? A. Not that I'm aware of. Q. Okay. Did he ever do any work for Paula Deen Enterprises? A. If we had had events that were being hosted by Paula but were being catered by The Lady & Sons, yes, he would have done work for us. Q. Okay. And who would he have been paid by? A. He would have been paid by Lady & Sons. Q. Okay. Would you have filled out a new employment personnel file, I-9 -A. No. Because he would have been representing The Lady & Sons. We just would have been using his services. Q. Okay. And so would The Lady -- excuse me. Would Paula Deen Enterprises have written a check to Dustin Walls? A. No. We would not have. Q. So he would have been compensated under those circumstances through The Lady & Sons if he was working an event for Paula Deen, right? A. When we run Paula Deen events, it would behoove us to utilize one of our two restaurants if food and beverage are needed, so we use our

they have a few other features in them. So they go as representatives of their restaurants, but Paula Deen Enterprises would have paid for those hours, because it would have been -- we would have -- we would have had to bring in another manager to cover their shift in order for those people to -Q. Okay. So would they have a separate personnel file at Paula Deen? A. No. Q. So how would their hours get paid, directly from Paula Deen or by running it through Lady & Sons? A. They would have been paid directly through Paula Deen Enterprises. An expense report would have been submitted for that time frame. Q. Why? A. What do you mean why? Q. I mean, if I'm understanding what you're telling me, Lady -- you have Lady & Sons restaurants at other locations? A. Well, it's entities of the Lady & Sons. So, for example, we have a Paula Deen buffet. Within the buffet, there is a section that is the Lady & Sons, there's a section that's Uncle

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Bubba's. We have a section called Little Jack's Corner. If you've ever been to a casino, it's a huge, large buffet area. So as the licensees, we are responsible for giving them recipes and overseeing just the basic opening. And we send -- you know, as part of the opening lineup, we send a representative from the Lady & Sons and a representative from Uncle Bubba's. But Paula Deen Enterprises pays for that particular time because we're having -- Lady & Sons is actually having to find someone else to cover that shift for that person while that person is traveling. Q. Okay. So when you say we send someone to the event, you're referring to Paula Deen Enterprises? A. Paula Deen Enterprises. Q. And you're sending someone to cover a buffet that is essentially a joint operation of all of the restaurants, correct? A. Yes. That is owned and managed by another company. They have purchased a licensing agreement with us. Q. Okay. And who did they purchase that licensing agreement with?

resources from Lady & Sons and Uncle Bubba's to assist -- to assist openings at new restaurants. Q. And actually, you sent the general managers of those? A. Yes, I have. Q. Okay. And one of the general managers that you've sent to those events was Lisa Jackson; is that correct? A. Yes, she was. Q. And is Dustin Walls a full-time employee of The Lady Enterprises? A. Yes, he is. Q. What does he do for Deen Management? A. There was a time when his -- part of his pay was coming out of Deen management. He wasn't working for Deen Management, no. Q. So part of his pay for performing work for The Lady Enterprises was coming from Deen Management? A. The two owners that owned Deen Management also own Lady & Sons. Q. Okay. So the answer is, yes, Deen Management was paying part of Dustin Walls' pay and the reason for that is that they had joint ownership in part?

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A. Paula Deen Enterprises. Q. Okay. Did they purchase a licensing agreement from Lady & Sons? A. Not that I'm aware of. Q. Does Paula Deen Enterprises compensate Lady & Sons through -- for the using the Lady & Sons' name at that event? A. Not that I'm aware of. Q. Does it compensate Uncle Bubba's for using the Uncle Bubba's name? A. Not that I'm aware of. Q. Okay. But it is -- are you talking about the buffets at Harrah's? A. Uh-huh. Q. That's a yes? MR. FRANKLIN: You have to answer yes. THE WITNESS: I'm sorry. Yes. BY MR. BILLIPS: Q. And so Paula Deen Enterprises directs employees of Lady & Sons and Uncle Bubba's to go to Harrah's for the opening of these buffets? A. We confer with the general managers of the locations to identify people, yes. During -if they can go. We don't direct them. We don't say they absolutely have to. But, yes, we use

A. Well, they had -- I mean, yes, they had -Q. Okay. Rance Jackson is -- has had the same situation where he is receiving part of his pay from Deen Management? A. That's correct. Q. Is he presently receiving part of his pay from Deen Management? A. Not that I'm aware of. Q. Okay. When did that stop? A. This year. Q. Why did it stop, if you know? A. I'm not aware. Q. Okay. Scott -- what did Scott Hopke do for Deen Management, if you know? A. I believe his situation is the same as the other two you've asked me. Q. And Rance Jackson, what about him? A. Same. Q. Okay. So he does nothing at all for Deen Management but gets part of his pay from Deen Management? A. Correct. Q. Okay. Now, do any of these -- okay. Jody Farmer is a human resources manager for Paula

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Deen Enterprises, correct? A. Yes, he is. Q. And does Jody Farmer have human resources authority over all of the companies? A. Yes, he does. Q. Does he have subject to the approval of -- strike that. Who does he report to, Mr. Schumacher or Ms. Deen? A. He has dual reporting to myself and to Karl. Q. Okay. Is Ms. Deen active in the operation of the restaurants? A. Yes, she is. Q. Okay. Does Jody Farmer -- is he responsible for drafting policies, human resources policies for all of the entities? A. Yes. Q. Is he responsible for dealing with EEOC or discrimination matters for all of the entities? A. He needs to be made aware of all of them. The general managers usually handle them on an individual basis, but Jody is absolutely brought into the loop so that we know. Q. Who do you -- who is -- if the general manager is the person alleged to have engaged in

to the owners' approval, you're talking about Ms. Deen? A. No. I'm talking about whoever is part of the owners depending on which business unit you're discussing. Q. Okay. And Ms. Deen is -A. Paula Deen Enterprises and all others. Q. She is a part owner of all of them? A. Yes. Q. Okay. Has the level of her ownership interest in these various entities changed at any time in, say, the last five years? A. I'm not aware of that. That would be an accountant question. Q. Okay. Who is Brandon Branch? A. He's our creative director. Q. Okay. For Paula Deen Enterprises, correct? A. Yes. Q. Which of the organizations -- strike. What does Paula Deen Enterprises do? A. We're an entertainment company. Q. Okay. And is Paula Deen Enterprises the entity which is responsible for the TV shows and tours and cruises and things of that sort?

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discrimination, to whom would an employee be able to complain? A. They could go to the owner. Q. All right. A. They could now go to the director of human resources. Q. Okay. Before that they could go to Karl Schumacher? A. They could. Or myself. Q. Or yourself. Who makes decisions about the pay level within these various organizations about how much, for example, general managers are going to be paid? A. I would believe that would come from Karl Schumacher with the assistance of each of the owners of each of the locations. Q. Okay. A. The locations actually set their salaries. Q. Well, does Karl Schumacher have the authority to override the general manager's desires when it comes to compensation of employees? A. If he has the owners' approval, yes. Q. Okay. And the owners -- when it comes

A. Yes. Q. Does Paula Deen Enterprises ever use any of the restaurant staff from Uncle Bubba's or The Lady & Sons to assist in preparing for these -for TV episodes or -A. Not that I'm aware. We may get catering from those locations, but those again would be a service of the restaurant. Q. All right. And the entertainment that Paula Deen Enterprises provides has to do with cooking, correct? A. For the most part, yes. Q. All right. And the -- The Lady & Sons restaurant and Uncle Bubba's are both to a degree part of the marketing of Paula Deen; is that true? A. In what capacity? Q. Well, I mean, they're actually restaurants that are serving food that Ms. Deen talks about and cooks on her show? A. Cooks on her show, yes. Q. Okay. She does talk about it on her show, too, right? A. She may mention the restaurant. I don't think she has the ability to actually name them. Q. I'm sorry. I mean talks about the food.

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A. Okay. Yes. Yes. I'm sorry. Q. Okay. And so The Lady & Sons restaurant and Uncle Bubba's are both part of the brand that is affiliated with Paula Deen? A. Yes, they are. Q. Okay. You have an individual working at Paula Deen Enterprises, a brand manager? A. Yes. Q. What is her function? A. She oversees all of our product packaging for licensing -Q. Okay. A. -- so we have a consistent look in the marketplace. Q. Okay. And the products you're referring to are what? A. We have cookware. We have all types of kitchenware. We have candles, furniture, food product. Q. Okay. Are some of these items marketed under the Uncle Bubba's name? A. Not in the national market, no. Q. In the local market? A. Maybe as a specialty in the Paula Deen store, but only in the Paula Deen stores.

Bubba's also operated by Paula Deen Retail? A. No. It's part of Uncle Bubba's operation. It's their store. Q. Okay. So both Uncle Bubba's and Lady & Sons have stores next to them for selling souvenirs? A. Yes, sir. Q. And who is responsible for managing the stores? A. The general manager at Uncle Bubba's manages the Uncle Bubba's store. And due to the size of the store down near the Lady & Sons, it actually has its own general manager. Q. For how long has that been the case? A. Since 2008, I believe. Close enough, I think. Q. Let's see. Have Paula Deen organizations ever referred to themselves in any written form which you're aware of as the Paula Deen family of companies? A. Not within our own organization, no. Q. What about externally? A. We had a company, Mackworks, who referenced it on one of their documents, but that's the only time I've ever seen it.

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Q. Okay. What about The Lady & Sons, any of the -- any of the product marketed under the name of The Lady & Sons? A. Yes. We have some Lady & Sons products, but they're not sold nationally through our licensing agents. They're sold in what we call souvenir shops. Q. Does Ms. White have any responsibilities for those? A. Yes. She will help in overseeing just the look and feel. Q. Okay. So ensure that it's -A. Lady & Sons looks like Lady & Sons. Or if it's Uncle Bubba's, it looks like Uncle Bubba's. Q. Okay. And to ensure that the look is consistent throughout the organizations? A. The looks that we do at Lady & Sons and Uncle Bubba's are not as -- don't have to be as consistent with the national brand, no. Q. Okay. When you refer to the souvenir shop, is that PDR, Paula Deen Retail? A. Paula Deen Retail and the store that's next to Uncle Bubba's. Q. Okay. Is that store next to Uncle

Q. Okay. Is there any other -- any other name by which the Paula Deen organizations are referenced as a collective group by the organization itself? A. Not that I'm aware of. Q. Okay. The Paula -- who is responsible for operating the Web site? A. Paula Deen Enterprises. Q. And who specifically at Paula Deen Enterprises? A. Myself. Q. Okay. Paula Deen Enterprises also contains information about Uncle Bubba's and the Lady & Sons, correct? A. We list them as restaurants on our Web site, yes. Q. Right. Do you list any non-Paula Deen related restaurants on your Web sites? A. No. Q. The organization -- the restaurants refer potential customers back and forth between each other? A. I would certainly hope so. Q. Okay. The restaurants have manager meetings which involve the managers of all of

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the -- of both of the restaurants and managers of Paula Deen? MR. FRANKLIN: Are you asking regularly, ever or -MR. BILLIPS: Well, first -MR. FRANKLIN: -- in the history of man, since 2005, what? BY MR. BILLIPS: Q. Well, first ever. Are there ever such meetings and then we'll discuss the level of regularity. A. Okay. In the beginning, no, there were no meetings amongst everyone. Q. Okay. A. Probably around 2009, late 2009, the groups started -- the general managers started meeting as a group just because they were requesting more information on what was happening in the broader Paula Deen picture. So they met as general managers and -- but I believe that meeting no longer exists. I believe that they've gone back to just individuals with Karl to go over financials. Q. Okay. A. But I could be wrong on the -- they may

Enterprises to make them run more effectively? A. I don't know that I would call it integrating. I think it would be saying we were trying to open up the doors to communication to ensure that everyone was saying the same things. Q. Right. Okay. And the general managers would take the message back to their employees? A. Correct. May I ask a question. Are we still on question 1? Q. We've been getting kind of on through 1, 2 and 3 -A. Okay. Q. -- as we're going along. MR. WITHERS: Do you need a break? THE WITNESS: No. I'm fine. I'm fine. MR. BILLIPS: Any time you need to take a break, just let me know. THE WITNESS: Okay. I will. MR. BILLIPS: As long as we don't have a question pending, we will. THE WITNESS: No. I'm fine. BY MR. BILLIPS: Q. Okay. During the -- now, you earlier referred to an entity known as Mackworks. A. Yes.

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meet that I'm not aware of. Q. Do they -- when the general managers would meet, would they meet with someone with Paula Deen Enterprises? A. Yes. Q. Who? A. Karl. Q. Okay. And did they have these meetings on a regular basis? A. There was a time frame that they were running on a monthly basis, yes. Q. And what is your understanding of the reason for these meetings? A. As I said, to review the big picture of what was going on with where Paula was, what she was doing. A lot of it was just communication so that the teams would know what to tell their teams. Because everybody comes to the Lady & Sons and Uncle Bubba's thinking they're going to see Paula, so it's extremely important people know where Paula is. So that was one part. They also discuss best practices. Q. Uh-huh. And so they were essentially trying to see how better to integrate the operations of the restaurants and Paula Deen

Q. And tell me what Mackworks is. A. It's a human resources company that offers consulting. Q. Okay. And did Paula Deen Enterprises retain Mackworks in 2000 -- when was it, 2010, 2011? A. 2010, yes. Q. Okay. MR. FRANKLIN: I'm not objecting at this point, but she -- but Ms. Feuger is not offered as human resources. Jody Farmer will testify to that and about the Mack report. MR. BILLIPS: I understand. I wasn't asking her about that. MR. FRANKLIN: I just don't want to go down some rabbit holes we don't need to with this witness who is not being offered for that. MR. BILLIPS: Right. BY MR. BILLIPS: Q. Did Mackworks also assist in coordination of the retail store activities and brand coordination across the entities? A. What do you mean by brand coordination? I mean, brand is creative and, no, they were not part of the creative. They came in for human

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resources only. (Exhibit 4 marked for identification.) BY MR. BILLIPS: Q. I'll show you what's been marked as Exhibit 4. Is Exhibit 4 an email from Tanya at Mackworks setting up a meeting for June 17th of 2011, the goal being to get better coordination and leverage from retail store activities, brand coordination where we can, savings across ordering, work as a retail team built into an action plan that you can implement? Is that what that is? MR. FRANKLIN: That's what it says. Is that what you're asking her? THE WITNESS: That's what it says. BY MR. BILLIPS: Q. And it was copied to you, correct? A. Yes, it was. Q. Do you recall receiving it? A. Yes, I do. Q. Do you recall Mackworks actually working on this? A. They worked with the managers to develop plans to execute, and that was why we brought them in was to help with our management teams to do

the Paula Deen retail managers were just pitching in to help. Q. Tanya isn't a Paula Deen manager. A. No. Tanya helped them get together as a group as a task -- kind of as a task force to give it some discipline to the actual meeting and some structure so that they would -- they would have an agenda to follow. And she oversaw the meeting. Q. So she was coordinating -- she was assisting them in coordinating the operation of the retail store activities and the brands? A. I would say coordinating, yes. I wouldn't say the brands, because the brands are two separate brands. Q. Didn't she -- her email actually says brand coordination where we can. A. Well, just because she wrote that in there and what she actually -- this was an initial meeting to bring up -- to bring to us what they wanted to do. It never meant -- it doesn't mean that any of this got approved. Q. Okay. I'm sorry. Did you say that's something that y'all started doing back in 2009 when Uncle Bubba's store started? A. I said I wasn't clear on the date. When

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their jobs better. It wasn't that they came in to oversee brand. The individual teams did that. Q. Right. MR. FRANKLIN: I'm going to object to you -- well, if you would show me which enumerated item this is responsive to where you're asking about it. MR. BILLIPS: Item number 3. BY MR. BILLIPS: Q. So they were bringing in the managers of the various organizations to help better coordinate the operations of these entities? A. When we brought onboard the Uncle Bubba's store, which happened in -- I'm not really -- 2009, 2010, we put together meetings in an effort to streamline the ordering process, because we have a warehouse that runs out of Paula Deen Enterprises. We have a store, a Paula Deen retail store and an Uncle Bubba's store. Paula Deen Retail and Uncle Bubba's was going to be selling much of the same items. We were trying to come up with streamlined ways to coordinate how to make that happen. And the manager that was at Uncle Bubba's had not handled merchandise before. So

we opened Uncle Bubba's store, it was -- we did a renovation to Uncle Bubba's. And the renovation included us moving a bar area to the back and making a full retail store. And when we were doing that retail store, that was at the time that Mackworks was helping us with our human resource efforts. So it became a project that they helped take on coordinating, getting all of the right people in the room. But everything that they did and all of the -- all of the actions that they came up with had to go to the general managers of each location as well as myself for approval. Q. Okay. Do Uncle Bubba's and Lady & Sons attempt to hire or promote from -- strike. If there is a position at Uncle Bubba's that would be a promotion for a Lady & Sons' employee, would -- would the organization attempt to promote that employee into that other position? Is that a goal within the organization? MR. FRANKLIN: Object to you asking a hypothetical question on a 30(b)(6) deposition. Subject to that, you can answer. MR. WITHERS: I object because I don't think that's part of the scope under the notice

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that this witness has been propounded for. MR. FRANKLIN: Are you still on number 3? MR. BILLIPS: Actually, I've been kind of going back and forth between them. MR. FRANKLIN: It doesn't seem to fit into any of those categories of 1, 2 or 3. MR. BILLIPS: You can answer. MR. FRANKLIN: You can answer. THE WITNESS: You said I could answer? MR. FRANKLIN: Yeah. You can answer. THE WITNESS: I'm sorry. We post positions. The position would, yes, be posted at all of the locations. It is always our goal to promote from within. I don't know many cases where Uncle Bubba's employees have left Uncle Bubba's or Lady & Sons have wanted to leave Lady & Sons. They usually go for promotions within their own areas. BY MR. BILLIPS: Q. Okay. And has Paula Deen Enterprises provided training sessions for managers at Uncle Bubba's and Lady & Sons? MR. WITHERS: Objection. That's plainly outside of the scope of the matters for which she

Q. Okay. Who would have the authority to supervise or direct Mr. Hiers' work at Uncle Bubba's? A. The other owner, Paula Deen. Q. Okay. One of the functions that Mackworks performed -- strike. When Mackworks was hired, did they come in and actually perform a human resources role? MR. FRANKLIN: Object to that. It's outside the scope. MR. BILLIPS: If you would let me finish my question, you might find that it's within the scope. MR. FRANKLIN: I don't think I will. MR. BILLIPS: Please let me finish. MR. FRANKLIN: Go on. BY MR. BILLIPS: Q. Did Mackworks come in and perform a human resources role as if they were employed by Paula Deen Enterprises? MR. FRANKLIN: I'll object. MR. WITHERS: Object. Object. Calls for speculation with respect to what as if they did something. Calls for speculation and conclusion. And object it's outside the scope of

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is being offered under the notice. MR. BILLIPS: It is within the scope of having the same or substantially identical operation business purpose supervision. MR. WITHERS: I think it's plainly within your paragraph 7 of your notice, description of the training. Provide managerial supervisory personnel. MR. BILLIPS: The question that I'm asking this witness is whether one entity, Paula Deen Enterprises, has provided training to employees of the other entities. Go ahead. THE WITNESS: We have through Mackworks. BY MR. BILLIPS: Q. Okay. Who paid for it? A. You would need to ask our accountant. Q. Okay. Was there a period of time between January 2008 to the present during which Earl Hiers was removed from any direct managerial role at Uncle Bubba's? A. Not to my understanding, no. Q. Was he -- are you aware of a time in which he was directed not to interfere with the operation of the restaurant? A. No, I'm not.

the matters which this witness has been propounded for the purpose of your questioning. MR. FRANKLIN: He beat me to it. MR. BILLIPS: You can answer. MR. FRANKLIN: You can answer. THE WITNESS: Can you say the question again. I'm sorry. BY MR. BILLIPS: Q. Did Mackworks perform human resources supervision and functions for the Paula Deen organizations? A. Can I clarify that by asking -Q. Sure. A. Are you asking if they did disciplinary action or are you just asking did they help in training? Q. Well, neither really. A. Okay. Q. I'm asking, for example, did they come in and audit human resources personnel files and direct the entities to change the way they were maintaining them? A. Yes, they did. Q. Okay. And did they provide training to managers on how to perform disciplinary functions?

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MR. WITHERS: Same objection with respect to being offered outside of the -- or a question that is squarely outside the matters that this witness has been propounded to respond to. MR. BILLIPS: You can answer. MR. FRANKLIN: And I join in that. We're about at the end of the rope with you asking questions outside the scope. I don't want to start instructing her not to answer, but I'm going to if you persist. MR. BILLIPS: Are you going to seek a protective order? MR. FRANKLIN: I beg your pardon? MR. BILLIPS: Are you going to seek a protective order? MR. FRANKLIN: We'll do what's appropriate. MR. BILLIPS: Because I'm not aware of a privilege that would apply. But let me ask you. Who are you going to identify to give testimony on the remaining items? MR. FRANKLIN: We are going to have Jody Farmer testify as to human relations issues. We are going to -MR. BILLIPS: Could you do them by

recipients. A. Yes. Q. And in light of the limitations of your role as a deponent, earlier I asked you if there was a period during which Mr. Hiers' role was limited. If you look under item number two where it says HR issues, Bubba and Willy encounter. Plan: Jim Gerard notified. Karl meeting with Uncle Bubba today to reinforce, quote, no operations interference. Do not come onsite impaired. Do contribute via interaction with tourists, guests, photo ops as appropriate. Do you see that? A. Uh-huh. Q. Is it true that during this time period in August of 2010 Mr. Hiers -MR. FRANKLIN: Object to that. That's not covered by any of these categories, and I'm going to instruct her not to answer. MR. BILLIPS: Counsel, the item number 1 -MR. FRANKLIN: It's not up for debate. MR. BILLIPS: Item number 1 asks the witness to testify to the duties of each such

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number, so I could -MR. FRANKLIN: Where are we. Mr. Farmer will testify and respond to 4, 5, 6, 7, 8, 14, 15, 16, 17, 18, and that's it. MR. BILLIPS: Did you say 16? MR. WITHERS: Yes. MR. FRANKLIN: I did. MR. BILLIPS: 18. Was he -- that's one of his? MR. WITHERS: Yes. MR. FRANKLIN: Yes. Mr. Schumacher will respond to 9, 11, which we are objecting to, and he will not answer any questions with regard to number 11 -- I'm sorry, 12, 13. And Melissa McCurry will respond to 20, 21, 22. That's it. I think that ought to add up. While you're contemplating your next question, let's take about a five-minute break. MR. BILLIPS: Sure. (Recess from 2:27 p.m. to 2:38 p.m.) (Exhibit 5 marked for identification.) BY MR. BILLIPS: Q. I'll show you what's been marked as Exhibit 5 to your deposition. This is an August 18, 2010 email of which you were one of the

director, officer and manager. MR. FRANKLIN: And she's testified to duties. MR. BILLIPS: And I am asking her and impeaching her with regard to a specific manager. MR. FRANKLIN: A 30(b)(6) deposition is not designed for impeachment. MR. BILLIPS: I don't know where you saw that in the rules, because it's not contained in the book that I've seen. MR. FRANKLIN: She's not going to answer that question. BY MR. BILLIPS: Q. Ma'am, was there a time period -- let me get the question out. Was there a time period in August of 2010 in which Mr. Hiers was instructed not to have any -- not to interfere with the operations of Uncle Bubba's restaurant? MR. FRANKLIN: And I'm going to instruct her not to answer. That does not fall within the scope of -- if you say it's covered by 1, I say it isn't. 2 or 3. MR. WITHERS: Same objection. MR. BILLIPS: You're instructing her not to answer?

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MR. FRANKLIN: That's what I'm instructing her. MR. BILLIPS: Are you following -MR. FRANKLIN: And if we need to, we'll get a protective order. So if you want to star that and we'll come back another day, that's fine. MR. BILLIPS: You will need to get a protective order. BY MR. BILLIPS: Q. Was there a time period in August of 2010 when Mr. Hiers' role was limited to interacting with tourists, guests and photo ops as appropriate? MR. WITHERS: Objection and same instructions. MR. FRANKLIN: Yeah. Same instruction. MR. BILLIPS: I'm sorry. MR. FRANKLIN: That's the same question in a different body. MR. BILLIPS: Okay. It's not really what I'm about to say. Well, I guess you're representing this witness, too, to the extent she's here as an agent of Uncle Bubba's, right? Okay. I was forgetting that she had a tripartite role.

his duties were financial. Q. Okay. A. General managers would have written documentation for files. Q. And were you unaware that Mr. Schumacher would write such documentation and give it to them to issue? A. Say that again. I'm sorry. Q. Were you unaware that Mr. Schumacher would draft such documentation and give it to managers to issue to the employees? A. I was never made aware, no. Q. Was Mr. Schumacher the person with whom the Mackworks people communicated regarding their audit and findings, their -- their human resources audit and findings? A. He was the initial person, yes. Q. Okay. And was he their contact? A. As far as I know, yes, he was their main contact. Q. All right. And that was for all three of the companies he was the contact? A. Yes. Q. And when Mackworks was doing its audit, it was also including the Paula Deen Retail?

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MR. FRANKLIN: And now you know. MR. BILLIPS: Now I remember. MR. FRANKLIN: We're here to please. MR. BILLIPS: That's working out so far, so that's good. MR. FRANKLIN: Glad you're so happy. BY MR. BILLIPS: Q. Was it within the scope of the duties of Mr. Schumacher to send written warnings to managers for them to issue to employees? MR. FRANKLIN: About what? What are you -MR. BILLIPS: About anything. For a disciplinary action. BY MR. BILLIPS: Q. Did Mr. Schumacher draft those to send to managers to issue to employees? You don't know? A. I don't know. Q. Okay. A. He has not sent one to me so, no. Q. Do you know if that was within the scope of his duties during the period of time 2008 -2008 to the present? A. No. My understanding of the scope of

A. Yes. Q. Okay. Was it including any other companies? A. Not that I'm aware. Q. Did PDR operate the store at Uncle Bubba's? I think I asked that. I don't remember the answer. A. No, they did not. Q. That was operated by Uncle Bubba's? A. Yes. Q. Did Mr. Schumacher have the authority to write-up general managers of the restaurants? MR. WITHERS: Object to the term write-up. It's vague and ambiguous. MR. BILLIPS: Issue disciplinary reprimand. BY MR. BILLIPS: Q. Ma'am? A. Yes. Q. Okay. Did he, in fact, issue reprimands to general managers on occasion? A. I'm sure he has, yes. Q. Okay. He issued reprimands to Dustin over the monkey incident, correct? A. Yes.

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Q. Did the -- did Uncle Bubba's and Lady & Sons have policies and procedures manuals? A. Yes, they did. Q. And were they identical except with regard to the names on the front and on various forms? A. I would believe so. They're both restaurants. Q. All right. And they were prepared by Paula Deen Enterprises; is that correct? A. No, they were not. Q. Who were they prepared by? A. By the individual locations. Q. So you're not suggesting that they prepared them independently, are you? A. Well, Lady & Sons. There was no Paula Deen Enterprises when The Lady & Sons started, so they had to have had a manual prior to us coming in to -Q. So Lady & Sons and Uncle Bubba's have policy manuals? A. Yes. Q. And they're identical, correct, except for the names? A. I would think so, yes.

Deen Enterprises contributing money toward the compensation of employees of Uncle Bubba's? A. Uh-huh. Yes. I'm sorry. Q. All right. So according to this email, Paula Deen Enterprises provided funds to compensate for a bonus for all of the employees of Uncle Bubba's; is that correct? A. That's what this reads, yes. Q. Okay. MR. FRANKLIN: Surely you're not going to amend and sue them for generosity. THE WITNESS: Well, Paula would have the right under Paula Deen Enterprises to. MR. BILLIPS: I'm not suggesting that generosity is something for which they could be sued. I'm merely suggesting that these are entirely integrated enterprises, as is apparently recognized by everybody in the company. BY MR. BILLIPS: Q. Did Uncle Bubba's and Lady & Sons coordinate in setting prices for catering for outside customers? A. I wouldn't think that they would have done it together, no. Lady & Sons has their own catering and Uncle Bubba's has their own catering.

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Q. And you -- were they -- strike. By whom were -- was the Lady & Sons manual prepared? A. That happened before my time. I don't know who drafted it. I know Jim Gerard has approved manuals for us, so... Q. Okay. During 2010? A. Can I clarify. These are employee manuals, right? You're talking about employee manuals? Q. I'm talking about policy and procedure manuals. A. Okay. Policy and procedure manuals. Procedures would be different at both locations, so they would have to be done by the locations. But employee policies would -- are pretty much all law. Q. Okay. A. You lawyers kill a lot of trees. Q. You know, that is what happens when things are produced in paper. (Exhibit 6 marked for identification.) BY MR. BILLIPS: Q. I'll show you what's marked as Exhibit 6. Do you recognize Exhibit 6 being an email dated December 12th, 2011 that reflects Paula

And the food offered at each is somewhat different. (Exhibit 7 marked for identification.) Q. I'll show you what's marked as Exhibit 7. Is Exhibit 7 an email from Mr. Schumacher discussing a catering event and the prices offered by L&S, and his suggestion that the price offered by Uncle Bubba's be increased in light of the profit -- the price offered from L&S? A. That's what this reads. Q. Okay. Was it common for the two restaurants to communicate with each other about catering events where either one of them might do the event? A. This was an actual event for Karl. Q. Right. A. The Elks Lodge was his, so he asked for both of them to be part of it. In most cases, unless they request for both restaurants, they're two different types of food. So it's rare that one would want the other. Now, if Lady & Sons couldn't handle an event, I would certainly hope that they would send the business over to Uncle Bubba's. It only makes sense. But, no, I don't think that they -- they

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sit together and talk about joint opportunities. Q. Okay. Lady & Sons and Uncle Bubba's, are they in competition with each other? A. Not really, no. Q. Okay. And employees are instructed at the two restaurants to refer customers between the restaurants, correct? A. Absolutely. Q. So that the common goal is to get the customers into one of those two restaurants? A. The common goal is to get them into both restaurants. Q. Okay. Preferably not at the same time. A. Yes. Correct. Q. So if there is a -- an issue about a customer or if you have a potential customer and they're going out to dinner, you want them to come to one of the two? A. Correct. Q. And the two restaurants work together to refer customers to each other where that opportunity is available, correct? A. They are supposed to. Q. Okay. And do the restaurants provide coupons for each others' operations?

A. Not that I'm aware of. Q. Okay. Do you know one way or the other? A. I don't know one way or the other. Q. I'm sorry. For the record, counsel was showing the witness a note. MR. FRANKLIN: I'll even read what I said. You deserve a raise. MR. BILLIPS: Okay. THE WITNESS: You can make that happen. MR. FRANKLIN: Make sure that's in the record now. MR. WITHERS: That was another gotcha moment. MR. BILLIPS: If I could, I would certainly try. THE WITNESS: Thank you. Put that in the record. MR. FRANKLIN: It's good we agree on something. You want to destroy their brand, but you want Theresa to get a raise. MR. BILLIPS: I have no desire to destroy their brand. MR. FRANKLIN: I guess it's Mr. Woolf. MR WOOLF: Me either. MR. BILLIPS: I would like the brand to

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A. I believe they do, yes. Q. Okay. So you can go to Lady & Sons and get a coupon to Uncle Bubba's? A. At times, yes. And vice versa. Q. And vice versa. Do the restaurants also coordinate in buying and purchasing food? A. Not that I'm aware. Q. Okay. Did they determine -- do they do anything to see if they're getting the same food costs from the same vendors? A. They may have discussions. Chef to chef may have a discussion, but nothing formal. Q. Okay. (Exhibit 8 marked for identification.) BY MR. BILLIPS: Q. I'll show you what's marked as Exhibit 8. Is Exhibit 8 an email from Karl Schumacher September 27, 2010 in which you are copied talking about one major item that I heard came from the panel that met to interview the human resource candidates last week was people from Lady & Sons and Uncle Bubba's want to work closer. One area is to see if we're getting the same food costs. A. Uh-huh. Yes. Q. So did this get carried out?

remain as popular as possible and financially lucrative as possible. THE WITNESS: I need to look at his paper. It goes JFTF -- never mind. I'm just trying to find humor in all of this. MR. FRANKLIN: I missed that one. THE WITNESS: When you're looking down his list, my initials end in F, and his end in F. So it looks like -- I'm trying to figure out where he's at. I can't tell whether he's at a J.F. or a T.F. MR. BILLIPS: This actually won't help you. I'm just marking who was responsible for what, so it's not going to help you know where I am. MR. FRANKLIN: It's the blind leading the blind. BY MR. BILLIPS: Q. Now, Ms. Feuger, has there been any effort to change the forms or logos or other identifying items between Paula Deen Enterprises and Lady & Sons and Uncle Bubba's because of this lawsuit? A. No. (Exhibit 9 marked for identification.)

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BY MR. BILLIPS: Q. Is Exhibit 9 an email from Karl Schumacher to you and other individuals dated October 28th, 2010? A. Yes. Q. And is this email relating to no harassment policy forms? A. Yes, it is. Q. And there is a question, need to order these forms for Uncle Bubba's and Paula Deen Retail. There was a talk about company-wide logos. You passed that question on. Is there a logo we can use company wide, and then asked Karl Schumacher what is the parent company that all companies fall under. And then the top of the email is his response, correct? A. Correct. Q. He says, "I do not want to use a company-wide form. We're trying to keep each company with their own identity and not be treated as a family of companies, as someone recently has tried to treat us." Was that referring to Ms. Jackson's EEOC charge or do you know? A. I never caught that. That's what it was referring to.

employee going to a managerial position at Uncle Bubba's from a lower level position at Lady & Sons as being an in-house promotion? MR. WITHERS: Objection. Compound and asks her to comment upon your question. BY MR. BILLIPS: Q. You can answer. A. This looks like an email coming from Karl to Jamie just suggesting that if there's a Lady & Sons manager that's ready for a promotion, he'd like to recommend you for Uncle Bubba's position. Q. Right. A. Yes. Q. And he refers to that as an in-house move? A. Yes. He does refer to it as an in-house move. Q. Okay. (Exhibit 11 marked for identification.) BY MR. BILLIPS: Q. I'll show you what's been marked as Exhibit 11. Do you recall earlier I asked you if -MR. FRANKLIN: Why don't you let her

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Q. Okay. But the people who were determining what the logos would be were all the same people for all the companies, right? A. With input from each of the locations, yes. Q. Sure. (Exhibit 10 marked for identification.) BY MR. BILLIPS: Q. Is Exhibit 10 an example of what I was asking about earlier with employees being considered for an in-house promotion for an employee to go from Lady & Sons to a front house manager position at Uncle Bubba's? A. Yes. MR. FRANKLIN: Why don't you let her read the thing. THE WITNESS: Yeah. I'm sorry. MR. FRANKLIN: I want you to read it first and then -MR. BILLIPS: Sure. THE WITNESS: Okay. What was the question? BY MR. BILLIPS: Q. Is this an example of what I had asked you about earlier with the company treating an

read it first. MR. BILLIPS: Sure. That's fine. THE WITNESS: Okay. I'm sorry. BY MR. BILLIPS: Q. Is Exhibit 11 a July 28th, 2010 email from Karl Schumacher? A. Yes. Q. And do you recall me asking you earlier if Ms. Deen had made it a priority for the restaurants to work closer? A. Yes. Q. And in this email, July 28th, 2010, Mr. Schumacher indicates that Ms. Deen has made it more of a priority for the restaurants to work closer, correct? A. I see where he says Paula has mentioned in the past that she wants the two restaurants -I don't know where you say it's a priority, unless I'm missing something. Q. The next sentence. Mentioned in the past, she wants the two restaurants to work closer. A. I'm not aware of this email, so my answer is still I didn't know it was a priority. Q. All right. Well, were you aware that

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the restaurant -- excuse me -- that Paula Deen organizations were working on -- working closer with regard to walk-in guests, large groups and catering? A. I knew that there had been discussions, yes. I was not part of any of those meetings. Q. Okay. Do you know the outcome of those discussions? A. I do not. Q. Do you know whether they were -- whether they did, in fact, put into effect the items mentioned in Exhibit 11? A. I've seen brochures in The Lady & Sons for Uncle Bubba's and vice versa, so I would say, yes, that has happened. I'm not aware of number two. Q. Number two is to have -A. Large groups. Have The Lady & Sons banquet staff recommend people to try Paula's seafood restaurant. I don't -- I'm not in that operational day-to-day basis, so I don't know that they're doing it. Personally I hope they are. Q. Right. A. Catering, again, I'm not in on a day-to-day basis. If there was a meeting that was

Q. Okay. And as a matter of fact, he had a greater role in actually overseeing operational issues as well, correct? A. At times, yes. Q. Okay. Who is Michelle Elizabeth White? A. She's my brand manager. Q. Okay. And the UBLJ at Uncle Bubba's is Lisa Jackson; is that right? A. I don't remember Lisa's email address, but if that's what it says, yes. Q. Okay. MR WOOLF: Let me just say out loud, we would -- to the extent that our questions have relied on documents, we would be a little more prepared except we got 60,000 pages of documents put on our desk on Friday. That's fine. That's why it's taking a little longer here. MR. WITHERS: No worries. We've all been working hard to get a grip on these documents. MR. BILLIPS: And if we could, I think we put this in a letter, but to the extent that documents are electronic, we did request that they be produced in native format. And it would be a whole lot easier, I

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held, it was discussed. I can't tell you whether it was implemented or not. Q. Mr. Schumacher would have more information about that? A. Yes. Q. Mr. Schumacher would have more information than you about the integration of the operations of the restaurants and Paula Deen Enterprises; is that true? A. I don't really know what you mean by integration. Q. To the extent that they were operated as divisions or departments of the single entity, would Mr. -A. Yes. Q. He would have more information about that? A. Yes. Q. Okay. He would have more information about the identity of the business purpose and operation of those organizations? A. What do you mean by the identity? Q. By the extent to which they are identified. A. As far as on paper, yes.

think for everybody, if native -- if electronic documents were produced in native format. There was no -- and I will note that there was no objection to not producing them in native format. So I think the rules entitle us to receive them that way. BY MR. BILLIPS: Q. I'm going to go through and come back to this in a minute. But while we're looking, the -item 19 is -- requests to state, describe and explain the nature of the relationship between Dustin Walls and/or Jamie Deen and Bobby Deen. A. Okay. Jamie and Bobby are brothers. They're both owners of The Lady & Sons. Dustin came onboard at The Lady & Sons in April of 1999 working as a -- I think he produced Hoecakes. Worked his way up. Was promoted to general manager in 2005. They've developed a friendship over those years. Q. Is that it? A. That's it. Q. What did you do to prepare yourself to testify on that item? A. I have been with the company for almost ten years, so I knew most of it myself.

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Q. Okay. Well, did you ask anybody for information to prepare yourself? A. Yes. Q. Who? A. I checked with Jamie to find out when Dustin started. Q. Did you ask -A. I checked with Karl to make sure that the dates were accurate. Q. Okay. What else? A. That's it. Q. Did you ask them the nature of their relationship? A. No, I did not. Q. And had you ever heard of there being any different relationship between them? A. What do you mean by different? Q. Something beyond what you've described? MR. FRANKLIN: Like what? THE WITNESS: Like what? MR. BILLIPS: Anything. MR. FRANKLIN: Same sex marriage. What are you talking about? BY MR. BILLIPS: Q. Sure. Same sex marriage, same sex

BY MR. BILLIPS: Q. Just a couple more questions and then we'll need to have a discussion. Does Uncle Bubba's Seafood and Oyster House, Incorporated, have board of directors meetings? A. Not that I'm aware of. Q. Does it have minutes to your knowledge? A. Not that I'm aware of. Q. Okay. What about The Lady Enterprises, Incorporated? Do they have board of director meetings? A. Not that I'm aware of. Q. Do they have minutes of board of directors? A. Not that I'm aware of. Q. Boards -- is there a board of directors? A. We had one meeting -- board of directors meeting for Paula Deen Enterprises one time, and that was dissolved. So there is no board, to my knowledge, for any of the companies. Q. Okay. You had one meeting -- one -A. Time meeting. Q. -- board of directors meeting for Paula Deen Enterprises, Incorporated? A. Yes.

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relationship, one of them saved the other one's life from an attack by killer bees. You know, anything. MR. FRANKLIN: You heard about that incident. THE WITNESS: I know that they're friends. They've hung out together on many occasions. If I'm not mistaken, they were in each others weddings. BY MR. BILLIPS: Q. Okay. Who had the -- please name everyone within the organizations, Paula Deen organizations who had the authority to fire Dustin Walls after he had referred to an African-American employee as a monkey. A. The owners, Jamie, Bobby, Paula. Karl would have had authority, if those three gave him so. But the three that have the overarching authority are the owners. MR. BILLIPS: Okay. Give us about ten minutes. MR. FRANKLIN: Okay. MR. BILLIPS: If we could have the room for that time. (Recess from 3:31 p.m. to 3:39 p.m.)

Q. Okay. And now it's become Paula Deen Enterprises, LLC? A. I don't know whether -- I'm sorry. I don't know whether it was incorporated. I don't know whether the board was put under incorporated or LLC. We had one board meeting and it never -we never -- it was to discuss putting together a board and asking people to be on the board. And it was dissolved before it ever got started. Q. What was dissolved, the meeting or the corporation? A. The board. The actual board itself. Q. Okay. A. So there is no board for any of the organizations -Q. Okay. A. -- with any owners to include Paula Deen. Q. Okay. What is The Lady & Sons, LLC? What function does it perform? A. That's a Karl -- I mean, I apologize. That's a Karl question, the difference between The Lady & Sons, Inc., versus -Q. Lady & Sons, LLC? A. Uh-huh.

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Q. Okay. A. For accounting purposes. Q. Okay. So the business purpose of The Lady & Sons, LLC, is something that Karl Schumacher would have to testify to? A. Yes. Q. Okay. As a matter of fact, the business purpose of having all of these entities at least nominally distinct is something that Mr. Schumacher would have to testify to; is that fair? A. He could, yes. Q. He would have greater information and more knowledge and better ability to provide accurate testimony on that subject than you would, correct? A. He would have greater knowledge from the accounting perspective on how paperwork is filled out and LLCs and Inc.'s are developed, yes, and what goes to those different accounts. But from an operational standpoint, I have just as much knowledge. Q. Okay. Except for the items that we've discussed earlier -A. Right. Q. -- where you acknowledge that Mr.

Schumacher those questions. Is he going to be here tomorrow? MR. FRANKLIN: He may be here today or tomorrow. MR. BILLIPS: Okay. But subject -- and there is the one issue where we had -- where you instructed the witness not to answer. MR. FRANKLIN: Right. I think that was if Mr. Hiers came in drunk or lucid. MR. BILLIPS: No. It was about whether Mr. Hiers was told that he -- whether he was barred from having operational -- interfering in the operations of the restaurant. MR. FRANKLIN: I'm not sure that was the question, but the record will speak for itself. THE WITNESS: Would you allow me to ask that question to the witness, was Mr. Hiers barred from having -- from interfering in the operation of The Lady & Sons restaurant? MR. FRANKLIN: And you can answer that. You can answer that. THE WITNESS: Based on the document that you showed me, I'm not sure what exhibit it was, it states yes. BY MR. BILLIPS:

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Schumacher will have to answer questions about the extent to which there was an effort to coordinate for purposes of the entities, correct? A. Yes. Q. Okay. A. That was something he was hoping to do. Q. Okay. And according to his email, it was something that Ms. Deen was hoping to do, correct? A. Correct. MR. BILLIPS: All right. It's apparent that Mr. Schumacher would have greater knowledge on at least items 1 and 3 than this witness. There have been items that -MR. FRANKLIN: I'm not sure she said -finish. I'm sorry to interrupt you. MR. BILLIPS: There's been questions where she has been unable to answer and has had to defer to Mr. Schumacher with regard to the coordination of the -- of the operation of the businesses, whether they have substantially identical business operations in particular areas. And we would hope that you would stipulate, since Mr. Schumacher is going to be appearing anyway, to allowing us to ask Mr.

Q. Okay. And do you know why? A. No. I'm not aware. Q. Okay. Do you know who barred him from having that operational role? A. That would be Karl to Paula apparently, because that's what it states in the email. Q. Okay. A. If Mr. Hiers is a 50 percent owner of Uncle Bubba's Seafood and Oyster House, Incorporated, how could Paula tell him what to do? MR. FRANKLIN: Objection. That calls for speculation on her part. MR. BILLIPS: Well, it -- no. That calls -MR. FRANKLIN: It does. MR. BILLIPS: It calls for a properly educated witness to testify to the organizational structure of these entities and the duties and powers of officers and directors. MR. FRANKLIN: She has testified, as I recall, that Mrs. Deen is an owner and she can fire. MR. BILLIPS: Can a 50 percent owner fire a 50 percent owner? That's my question. MR. FRANKLIN: That's really a

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contention issue -MR. BILLIPS: No. My question -MR. FRANKLIN: -- that needs to be answered -- is more suited to an interrogatory. MR. BILLIPS: You may feel that way. MR. FRANKLIN: I do feel that way. MR. BILLIPS: I disagree. MR. FRANKLIN: Well, that's good. BY MR. BILLIPS: Q. My question, ma'am, is given that Ms. Deen is a 50 percent owner of Uncle Bubba's and that Mr. Hiers is a 50 percent owner of Uncle Bubba's, how would she have the authority to fire him? MR. FRANKLIN: Once again, that -- I object to that and I instruct her not to answer, because that's not -- that's a question more suited to an interrogatory that requires participation by counsel because it's a legal issue. MR. WITHERS: I object on the basis it's calling for a conclusion. And with respect to it's calling for a legal conclusion, I think we've already plowed this ground to be honest with you. Mr. Billips, it is my longstanding practice not to

said, I'm not going to argue with you. MR. BILLIPS: And all of those you believe under the federal rules are a basis for instructing the witness not to answer? Can you identify a privilege for me? MR. FRANKLIN: I just stated it. I'm not going to argue with you. That's why we have a courthouse. MR. BILLIPS: Ma'am -MR. FRANKLIN: She's not going to answer that question. MR. BILLIPS: Let's do this, because it's obvious we'll have to go to the courthouse over it, but whether it's appropriate to bring this witness back or another witness back, let me ask one question to see where we're going. BY MR. BILLIPS: Q. Ma'am, do you know the answer to the question? Not answering, just give me a yes or no, do you know the answer to the question can Paula Deen fire Bubba Hiers? A. No. MR. BILLIPS: Okay. So like I was saying before, we'd ask your -- that you stipulate to Mr. Schumacher testifying on some of these

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engage in conversations and dialogue with counsel. You know, we make our objections. You ask the question. If we instruct the witness not to answer then, you know, we move on to the next matter. It's not -- it's not a dialogue between counsel. BY MR. BILLIPS: Q. Does Paula Deen have the authority to fire Bubba Hiers? MR. FRANKLIN: Objection. MR. WITHERS: Objection. Asked and answered. MR. FRANKLIN: Same thing. BY MR. BILLIPS: Q. You can answer. MR. FRANKLIN: No. It's been asked and answered. MR. BILLIPS: You're instructing the witness not to answer a question on the basis that it's been asked and answered? MR. FRANKLIN: It's asked and answered and it calls for a conclusion and that is -MR. BILLIPS: Most questions do. MR. FRANKLIN: Well, that is more suited to a written interrogatory. And as Mr. Withers

issues since this witness does not know some of the answers to some of our questions. MR. FRANKLIN: I'll have to think about it. MR. BILLIPS: Well -MR. WITHERS: Let me just -- I don't mean to interrupt you, Mr. Billips. I thought you were finished. But let me just say this. The questions that she was uncertain of dealt with -or the answers that she was uncertain of when you were asking her dealt with the documents that you were showing her, which primarily were Exhibits 4 through 11, Plaintiff's Exhibits 4 through 11 in the deposition, which were either to or from Mr. Schumacher. To the -- I would suggest, Mr. Franklin, to the extent that she was unable to answer a question -- particular question about those exhibits, if you want to pose the same questions to Mr. Schumacher during his deposition as corporate designee, we can do that. The only other thing I recall her being unable to answer was the last question, last line of questioning where you were asking about The Lady & Sons, LLC, and the reason for those

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particular designations. And if you want to ask Mr. Schumacher about that, I think that's agreeable as well. In terms of replowing things that she's already testified to, I don't want to do that. MR. BILLIPS: Well, okay. And I have no desire to replow items to which she's already testified. There are documents in that similar vain to those which I've used here today that I haven't bothered to waste our time asking her because she wouldn't know the answer to the question. If she didn't know the answer to these that we showed her, she wouldn't know the answer to the others either. So, you know, I don't think it would take that much longer of Mr. Schumacher as a witness, but -MR. WITHERS: Let's just -- I don't mean to interrupt you again. I apologize. MR. BILLIPS: Yes, you do too mean to interrupt me. I was going on and on. MR. WITHERS: You've got these long pauses. But I would say let's just start down that road and see how long it takes us. How about

House, Incorporated. And let's stipulate as Exhibit 14 the same document except that it relates to The Lady Enterprises, Incorporated. MR. WITHERS: Agreed. MR. FRANKLIN: That's fine. (Exhibit 13 marked for identification.) (Exhibit 14 marked for identification.) (Signature reserved.) (Deposition concluded at 4:08 p.m.)

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that? MR. BILLIPS: All right. Then subject to all of those -- the matters on which the witness has been instructed not to answer and that issue, then we can be through with this portion of the 30(b)(6). MR. WITHERS: Okeydokey. Thank you very much. MR. FRANKLIN: Thank you. You can stay or you can go. THE WITNESS: Oh, I'd like to go. MR. BILLIPS: Let's stipulate into the record as Exhibit 12 the document brought by the prior representative showing the names and compensation sources for the various officers, owners, managers. MR. WITHERS: Okay. MR. FRANKLIN: Yeah. That's fine. MR. WITHERS: Agreeable. (Exhibit 12 marked for identification.) MR. BILLIPS: And let's see. Let's stipulate into the record as 13 the documents prepared by the prior representative concerning race and gender composition and identification of employees at Uncle Bubba's Seafood and Oyster

ATTESTATION I, the undersigned, have read the foregoing transcript, and, with the exception of any corrections specified on the attached correction sheet, attest it constitutes a true and correct transcription of my testimony given at the time and place specified therein.

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

(Signed):___________________ Theresa Feuger WITNESS:____________________

DATE:_______________________

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ERRATA SHEET STATE OF GEORGIA ) ) COUNTY OF CHATHAM ) I wish to make the following changes for the following reasons: PAGE LINE ____ ____ CHANGE:________________________ REASON:________________________ ____ ____ CHANGE:________________________ REASON:________________________ ____ ____ CHANGE:________________________ REASON:________________________ ____ ____ CHANGE:________________________ REASON:________________________ ____ ____ CHANGE:________________________ REASON:________________________ ____ ____ CHANGE:________________________ REASON:________________________ ____ ____ CHANGE:________________________ REASON:________________________

(Signed) ________________________________ Theresa Feuger

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CERTIFICATE STATE OF GEORGIA: COUNTY OF CHATHAM: I hereby certify that the foregoing transcript was taken down, as stated in the caption, and the questions and answers thereto were reduced to typewriting under my direction; that the foregoing pages 1 through 98 represent a true, complete, and correct transcript of the evidence given upon said hearing, and I further certify that I am not of kin or counsel to the parties in the case; am not in the regular employ of counsel for any of said parties; nor am I in anywise interested in the result of said case. This, the 5th day of December, 2012.

__________________________________ RACHAEL MILLER, RPR, CSR, CCR 2807

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catering 5:16 41:6 68:21,25 68:25 69:6,13 78:4,24 caught 74:24 ccr 99:24 ceo 13:9 22:22 23:16 24:1 certainly 15:14 45:23 69:23 72:15 certificate 4:15 certified 1:22 7:9 certify 99:6,14 cfo 13:9,12 15:3 17:22 18:23 22:22 23:16 24:1 change 57:21 73:20 98:7,9 98:11,13,15 98:17,19 changed 40:11 changes 98:5 charge 74:23 chatham 7:3 98:3 99:4 check 31:18 checked 82:5,8 chef 71:11,11 christmas 5:13 circumstances 31:21 civil 1:5 8:12 clarify 32:18 57:12 67:7 clear 52:25 close 44:15 closely 30:14 closer 71:22 77:10,15,22 78:2 collateral 30:3 collective 45:3 come 15:11,14 15:20 32:13

39:14 51:22 56:7,18 57:19 60:11 62:6 70:17 81:8 comes 39:22,25 47:18 coming 36:15 36:18 66:18 76:8 comment 76:5 common 69:11 70:9,11 communicate 69:12 communicated 64:14 communication 47:16 48:4 companies 18:12 25:16 25:18,20,21 26:5,14 28:7 38:4 44:20 64:22 65:3 74:15,21 75:3 84:20 company 18:7 27:22 28:10 28:14 30:18 34:22 40:22 44:23 49:2 68:18 74:13 74:14,20 75:25 81:24 companywide 74:11,19 compensate 35:5,9 68:6 compensated 31:20 compensation 21:15,16 22:14,17 39:22 68:2 95:15 competition 70:3

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daytoday 14:21 16:21,24 78:21,25 dealing 38:18 dealt 16:20 93:9 93:11 debate 60:23 december 5:11 7:20 67:25 99:20 decision 15:12 decisions 39:10 deen 1:7,7,16 3:9 9:4,24 10:8,11 11:15 11:22 12:6 13:6,8,9,10,12 13:16 17:20 17:22 18:21 18:23 19:14 19:15,20 20:4 20:5,7,8,13,14 20:16 21:3,3,4 21:4,5,7,8,9 21:10,18,19 21:24 22:2,7 22:13,14,20 22:21,22 23:7 23:19 24:5,5,6 24:7,11 25:8,9 25:16,17,21 26:15 28:23 28:24 29:8,10 29:19 30:13 31:4,17,22,23 32:12 33:3,9 33:12,15,23 34:9,15,17 35:1,5,19 36:13,15,16 36:18,20,22 37:5,8,15,21 37:21 38:1,8 38:11 40:2,6,7 40:17,21,23 41:2,10,15,18 42:4,7,24,25

43:22,23 44:1 44:17,20 45:2 45:8,9,12,17 46:2,19 47:4 47:25 49:4 51:18,18,20 52:1,3 54:21 55:11 56:4,20 57:10 64:25 66:10,17 68:1 68:5,13 73:21 74:10 77:9,13 78:1 79:8 81:12,12 83:12 84:18 84:24 85:1,18 87:8 89:21 90:11 91:8 92:21 deens 21:15 29:12 defendant 8:2 9:4,5 defendants 1:11 2:19 3:2 8:15 10:16 defer 87:19 degree 41:14 demote 16:4 departments 79:13 depending 40:4 deponent 60:4 deposition 1:16 5:3,4,5 8:2,8 8:10,25 9:3 10:2,4,21 11:8 53:22 59:24 61:6 93:14,20 96:10 depositions 8:18 describe 11:14 14:5 81:10 described 82:18 description 5:2 55:7 deserve 72:7

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76:9 77:6 82:8 83:16 85:21 85:22 86:4 89:5 keep 74:19 kelin 2:21 kill 67:18 killer 83:2 kin 99:15 kind 12:2 13:3 48:10 52:5 54:4 kitchenware 42:18 knew 78:5 81:25 know 11:8 19:2 26:22 34:6 37:12,15 38:23 47:17 47:20 48:2,17 54:15 61:8 63:1,18,19,22 64:19 67:4,4 67:19 72:2,3 73:14 74:23 77:18,24 78:7 78:10,21 79:10 83:2,6 85:3,4,5 89:1 89:3 91:2,4 92:18,20 93:1 94:11,13,14 94:16 knowledge 11:12 25:5 84:7,20 86:13 86:16,21 87:12 known 23:10 48:24 L l 7:1 69:7,9 labor 17:23 lady 1:8,8,17,17 5:20 6:6,11 9:5 10:11,14

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requires 90:18 reserved 8:7 96:9 resigned 12:24 resource 27:3 53:6 71:20 resources 15:4 27:1,8,13,20 27:22 36:1 37:25 38:4,15 39:6 49:2,11 50:1 56:8,19 57:9,20 64:15 respect 18:17 56:23 58:2 90:22 respond 58:4 59:3,12,15 responding 8:15 response 74:16 responsibilities 43:8 responsibility 27:12 responsible 27:25 29:4,22 30:2 34:4 38:15,18 40:24 44:8 45:6 73:13 responsive 51:6 responsiveness 8:6 restaurant 12:11 14:22 17:13 20:23 41:3,8,14,23 42:2 55:24 61:18 78:1,20 88:13,19 restaurants 14:25 15:5 16:1,17 19:5 19:15 27:13 27:21 31:24 32:1,20,21 33:2,21 34:20 36:2 38:12 41:18 45:15 45:18,20,24 46:1 47:25 65:12 66:8 69:12,19 70:6 70:7,10,12,20 70:24 71:5 77:10,14,17 77:21 79:8 result 99:18 retail 5:8 25:21 29:20 43:22 43:23 44:1 49:21 50:8,10 51:19,20 52:1 52:11 53:4,5 64:25 74:11 retain 49:5 retained 16:11 review 47:14 rid 17:3,4 right 9:2 11:24 12:18,23 13:6 18:4 27:4,5 30:20 31:22 32:8 39:4 41:9 41:13,22 45:17 48:6 49:18 51:3 53:9 62:23 64:21 66:9 67:8 68:4,13 69:16 75:3 76:13 77:25 78:23 80:8 86:24 87:11 88:8 95:2 road 94:25 robert 13:10 20:4,7 21:3,7 21:8,15 22:13 22:22 24:5 role 14:6,24 15:4 16:17 17:8 18:5,9,11 20:12,15,19 20:22 26:4 55:20 56:8,19 60:4,5 62:11 62:25 80:2 89:4 romantically 25:3 room 53:10 83:23 rope 58:7 rpr 99:24 rules 7:5 8:12 8:13 61:9 81:5 92:3 run 12:15 24:12 25:18 26:1,22 29:9 31:23 32:5 48:1 running 32:9 33:12 47:11 runs 51:17 russell 28:21 S s 2:13 7:1,1,1,14 69:7,9 86:18 97:1 salaries 39:19 sales 29:18 savannah 1:3 1:23 2:15,24 3:6 32:22 saved 83:1 savings 50:9 saw 61:8 saying 48:3,5 92:24 says 50:13,15 52:15 60:8 74:18 77:16 80:10 schumacher 5:12,15,18 6:2 13:12 15:2,3 16:16,20 17:8 18:7,15,16 19:12 26:15 27:11 28:3
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69:25 sent 36:3,7 63:21 sentence 77:20 separate 22:4,5 33:8 52:14 separately 8:19 sept 5:16 september 5:17 71:18 serve 30:25 service 41:8 services 7:15 28:9 31:15 32:2 serving 41:18 sessions 54:22 set 16:5 25:19 39:18 setting 50:6 68:21 sex 82:22,25,25 shared 28:7,8 28:21 sheet 4:14 97:6 98:1 shes 22:21 29:13 61:2,11 62:23 80:6 92:10 94:4,7 shift 33:6 34:12 shifts 32:10 shop 43:22 shops 43:7 show 10:1 41:19 41:20,22 50:4 51:5 59:23 67:23 69:4 71:16 76:22 showed 88:23 94:14 showing 72:5 93:12 95:14 shows 40:24 sign 8:25 signature 96:9 signed 97:12

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theres 13:8 25:21 33:25 76:9 87:17 theresa 1:20 9:11,17,19 13:13 72:20 97:13 98:24 thereto 99:9 theyre 11:22 12:3 25:19,20 25:25 26:6 28:22,22,23 28:24 32:9 41:17 43:5,6 47:19 66:7,23 69:19 70:17 71:9 78:22 81:14 83:6 theyve 46:21 81:18 83:7 thing 75:16 91:13 93:22 things 40:25 48:5 67:20 94:3 think 8:21,23 11:22 41:24 44:16 48:3 53:25 55:5 56:14 59:16 65:6 66:25 68:23 69:25 80:21 81:1,5 81:16 88:8 90:23 93:3 94:2,16 thinking 47:19 thomas 3:3 thought 93:7 three 11:20 29:2 29:23 64:21 83:17,18 time 8:7 13:19 14:6 24:2 27:22 33:16 34:10 36:14 40:12 44:25 47:10 48:16 53:5 55:17,22 60:16 61:14 61:15 62:10 63:23 67:3 70:13 83:24 84:18,22 94:10 97:8 times 71:4 80:4 today 10:5 60:10 88:3 94:9 told 30:8,9 88:11 tom 7:13,17 tomorrow 88:2 88:4 top 74:15 totally 22:4,5 tourists 60:13 62:12 tours 40:25 towercreek 2:8 training 54:22 55:7,11 57:16 57:24 transcript 97:4 99:7,12 transcription 97:7 traveling 34:13 treat 74:22 treated 74:20 treating 75:25 trees 67:18 tried 74:22 tripartite 62:24 true 16:18 23:22 26:6,13 41:15 60:16 79:9 97:6 99:12 try 72:15 78:19 trying 47:24 48:4 51:21 73:5,9 74:19 tv 40:24 41:5 two 19:5 22:21 26:4,5 31:24 36:20 37:17 52:14 60:7 69:11,20 70:6 70:10,18,20 77:17,21 78:16,17 type 15:4 types 15:16 42:17 69:20 typewriting 99:10 U u 5:1 7:1 ub 5:13,19 6:3 ublj 80:7 uhhuh 26:2 35:14 47:23 60:15 68:3 71:24 85:25 umbrellas 28:12 unable 87:18 93:17,23 unaware 64:5,9 uncertain 93:9 93:10 uncle 1:9,18 6:8 8:2 10:9 11:21 13:18 14:2,9 14:12 17:24 23:3,4,6,6,12 23:12 25:11 26:17 29:10 29:12,14,19 30:25 32:4,23 32:25 33:25 34:8 35:9,10 35:20 36:1 41:3,14 42:3 42:21 43:14 43:14,19,24 43:25 44:2,4 44:10,11 45:13 47:19 51:13,19,20 51:24 52:24
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white 28:20 43:8 80:5 wide 74:13 william 2:20 willy 60:8 wish 98:4 withers 3:3,4 24:18 26:8 48:14 53:24 54:24 55:5 56:22 58:1 59:6,10 61:23 62:14 65:13 72:12 76:4 80:18 90:21 91:11,25 93:6 94:19,23 95:7 95:17,19 96:5 witness 24:22 24:25 35:17 48:15,18,21 49:17 50:15 54:1,10,12 55:10,13 57:1 57:6 58:4 60:25 62:22 68:12 72:5,9 72:16 73:3,7 75:17,21 77:3 82:20 83:6 87:13 88:7,16 88:17,22 89:17 91:3,19 92:4,15,15 93:1 94:18 95:4,11 97:15 wont 73:12 woolf 2:13 7:14 72:23,24 80:12 work 8:20 14:18 28:11 29:1 31:3,7 36:17 50:10 56:2 70:20 71:22 77:10,14,21 worked 28:14 50:23 81:17 working 14:10 30:14 31:22 36:16 42:6 50:21 63:4 78:2,2 80:19 81:16 worries 80:18 wouldnt 26:5,13 29:3 52:13 68:23 94:11 94:14 write 64:6 writeup 65:12 65:14 written 31:17 44:19 63:9 64:3 91:25 wrong 46:25 wrote 52:17 X x 4:1 Y y 5:1 yall 52:23 yeah 54:11 62:16 75:17 95:18 year 13:21,21 37:11 years 40:12 81:19,25 youre 16:25 17:5 23:24 29:4 33:19 34:15,18 40:1 40:5 42:15 44:19 50:14 51:6 59:17 61:24 62:21 63:6 66:14 67:8 68:10 73:7 91:18 youve 34:2 36:7 37:17 82:18 94:23 Z 0 000 80:15 06 1:24 08 96:10 1 1 1:24 5:3 9:8 10:2,20,23 11:6 13:11 23:23 48:9,10 54:7 60:22,24 61:21 87:13 99:11 10 6:1 7:5 10:23 11:10 75:7,9 11 5:16 6:4 59:12,14 76:20,23 77:5 78:12 93:13 93:13 12 5:11 6:6 59:14 95:13 95:20 12cv0139 1:7 12th 67:25 13 6:1,8 59:14 95:22 96:7 14 5:6 6:11 59:3 96:2,8 15 59:3 16 59:4,5 17 59:4 17th 50:6 18 5:9 59:4,8,25 19 5:14 10:23 81:10 190 2:9 1999 81:15 2 2 5:4 9:7,9 10:2 10:23 11:10 48:11 54:7 59:20,20 61:22 20 1:24 12:22
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