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Campbell Colquitt

v.

Casey Hogg
Texas High School Mock Trial Competition
2013-2014 Case Materials
Cause No. 13-0169-A


CAMPBELL COLQUITT,
AN INDIVIDUAL

Plaintiff,

v.

CASEY HOGG,
AN INDIVIDUAL
Defendant.















IN THE LANDRY COUNTY



DISTRICT COURT


CASE MATERIALS

PREPARED BY:

Stephen L. Russell, Esquire
Vice Chair, Mock Trial Committee

J ennifer Carroll, Esquire
Vice Chair, Mock Trial Committee

Fred Moss, Esquire
Mock Trial Committee

Stephen W. Gwinn, Esquire
Chair, Mock Trial Committee

Greg Beane, Esq.
J ames D. Blume, Esq.
Shannon Conway, Esq.
Hon. David L. Horan
Brad J ohnson, Esq.
Elise Mitchell, Esq.
J ordan Konig, Esq.










Copyright 2013-2014 Texas High School Mock Trial Competition. All Rights Reserved.
Cause No. 13-0169-A


CAMPBELL COLQUITT,
AN INDIVIDUAL

Plaintiff,

v.

CASEY HOGG,
AN INDIVIDUAL
Defendant.















IN THE LANDRY COUNTY



DISTRICT COURT


STIPULATIONS OF THE PARTIES

The parties agree and stipulate as to the following:

I.

This is a civil action that will be tried before a jury. Plaintiff, Campbell Colquitt, an
individual, is suing in his/her individual capacity. Casey Hogg, an individual, is the Defendant.
The cause of action on which Plaintiff is going to trial is a claim for compensatory and punitive
damages based on the theory of defamation, specifically, Defendant published a statement about
Plaintiff which was defamatory and false. This will be a bifurcated trial. The parties will only
try the issue of defamation. Should the Defendant be found liable, there will be a separate trial
on the issue of damages at some future date. Monetary damages are, therefore, not at issue in
this trial and are not to be argued.


II.

There are no defects in the pleadings. Defendant has properly appeared and answered.
The court has both subject matter and in personam jurisdiction over the parties. All questions of
fact are being submitted to a jury. Questions of law will be decided by the court.

III.

All exhibits included in the case materials are authentic and are accurate copies of the
originals. No objections to the authenticity of the exhibits will be entertained. The only
exhibits to be used at trial are those included in the case packet. The signatures on the witness
statements and on all other documents are authentic. Each witness has personally typed their
own statement. Exhibits 1 and 2 have been on file for the required amount of time with
foundational affidavits. Exhibit 3, the space plan for the HOPco corporate offices, was admitted
into evidence at the pretrial hearing and may be used by either side. The interior facing walls of
the window offices (i.e., the walls that face the cubicles) are made of glass and have no blinds or
curtains.
STATEMENT OF STIPULATED FACTS
Page 1 of 3
1

IV.

Campbell Colquitt, Dr. Z. Sayers Stockdale, and Sterling Hobby are to testify on behalf
of Plaintiff. They may not testify for or be called on behalf of Defendant. Casey Hogg,
Ferguson Shivers, and Burnet Allred are to testify on behalf of Defendant. They may not testify
for or be called on behalf of Plaintiff.

V.

Plaintiff must establish the following elements by a preponderance of the evidence. To
sustain the burden of proof, Plaintiff must prove that Defendant published a statement of fact
referring to Plaintiff which was defamatory and false. The following are elements of the
defamation claim:

1. That on April 8, 2013, Defendant published a statement of fact.

2. The statement referred to Plaintiff.

3. The statement was defamatory.

4. The statement was false.

5. With regard to the truth of the statement, Defendant knew the statement was false;
and

6. Plaintiff suffered pecuniary injury.

Elements 2, 3, 4, and 6 are not in dispute.


VI.

The following instructions will be submitted to the jury:

The occurrence in question made the subject of this lawsuit is an occurrence that
happened on or about April 8, 2013.

The term "preponderance of the evidence" means the greater weight and degree of
credible evidence admitted in this case.

The term negligence means failure to use ordinary care, that is, failing to do that which
a person of ordinary prudence would have done under the same or similar circumstances or
doing that which a person of ordinary prudence would not have done under the same or similar
circumstances.

STATEMENT OF STIPULATED FACTS
Page 2 of 3
2
The term defamation is a statement expressed in written or other graphic form that
tends to injure a living persons reputation and thereby expose the person to public hatred,
contempt, ridicule, or financial injury.

VII.

The Charge of the Court is accurate in all respects, and no objections to the Charge will
be entertained.

VIII.

The following issue will be submitted to the jury:


QUESTION NUMBER ONE:

Did Defendant, Casey Hogg, publish a statement of fact referring to Plaintiff, Campbell
Colquitt, which was defamatory and false?

Answer Yes or No.

_______________________
STATEMENT OF STIPULATED FACTS
Page 3 of 3
3
FACT STATEMENT OF CAMPBELL COLQUITT 1
2
My name is Campbell Colquitt. I live in Patterson, Texoma. I moved here after I went to 3
Texoma Tech, where I got a degree in Mechanical Engineering. I have had a few jobs since I 4
graduated, but have worked the longest at HOPco, where I work in Quality Control. HOPco is a 5
very old company. It began in the 1890s when it made those wooden, hand-held, stereoscopic 6
picture viewers that you now see in antique stores. We produce other optical products such as 7
microscopes and telescopes, but they are best known for stereoscopic, 3-D picture viewers. The 8
latest and hottest product the company supports is Orange Computers MeGoggles, which 9
compete directly with Googles Glass. HOPco provides the lenses and other components for 10
the MeGoggles. It is a voice-controlled mini-computer in the frame of the MeGoggles that can 11
record what is seen by the wearer and can access the internet and various apps via Wi-Fi and 12
display them on the inside of the lenses. It is a very cool product and HOPco is very proud of 13
their contributions to its success. 14
15
I worked in the quality control department at HOPco for about 9 years up until May, 16
2013. Quality control makes sure products that go into MeGoggles pass the quality tests required 17
by Orange Computers and by government regulations. It is an important job and if it isnt done 18
correctly, HOPco can get sued or lose Orange Computers business. I took my work very 19
seriously. Sometimes I got into it with Casey Hogg, another engineer in the QC department, 20
because of work issues. Not everyone in the department felt as strongly as I did about making 21
sure our products passed the QC tests. Sometimes Hogg would say a product had passed the QC 22
test when it had not. In fact, Hogg did that all the time, and whenever I said something about it, 23
Hogg would make fun of me and ridicule me to our co-workers. 24
25
In March or 2013, during my kids spring school break, my family and I took our first 26
real vacation in several years. We went to Central America, camping off the coast of Honduras 27
on the Cochinos Cays, you know, in the jungle. I took this vacation against my better judgment. 28
Early that month, my supervisor, J udy Yarbro, announced her retirement as of March 27, which 29
was the last day of my scheduled vacation. I would miss the opportunity to be at work during her 30
last week. But we had scheduled this trip over a year earlier, and it was paid for and non- 31
refundable. My family expected to go, so it was just not an option to cancel. Some of my former 32
co-workers have commented that my being gone at that critical time was the major reason I 33
didnt get J udys job, but I strongly disagree. 34
35
J udy had been with HOPco for 40 years. I was her logical successor based on my 36
qualifications and years of experience. She said that her supervisor planned to begin interviews 37
in March, which was during my vacation. The timing was just unfortunate. I dont think my 38
being gone would ultimately result in Casey Hogg, of all people, getting J udys position. The 39
real reason is that Casey Hogg slandered me at work. This is the reason I lost the promotion and 40
have sued Hogg. 41
FACT STATEMENT OF CAMPBELL COLQUITT Page 1 of 5

4
1
I had never really been out of the country before, so I was careful to get all the necessary 2
inoculations. Luckily, I did not get sick while on vacation, but I did get a pretty terrible sunburn, 3
which blistered up on my arms and shoulders mostly. We returned from Honduras on March 27 4
and I went to work the next day with lots of pictures and stories and my sunburn -- about my 5
trip. I had a scheduled interview for J udy's position that afternoon. About an hour into that 6
interview, I began not feeling very well. I spent most of the afternoon in the restroom. I thought 7
it was just Montezumas Revenge from forgetting to use the bottled water all the time. But I 8
kept getting worse, so I went to my doctor, Dr. Z, the next day. My symptoms were stomach 9
ache, vomiting, and well, you know, diarrhea. Even though I had been given all the shots, Dr. Z 10
suspected that maybe I had gotten something during my trip. Dr. Z took blood and urine to check 11
for tropical diseases. Many of the people at work knew I wasnt well, and I missed a couple of 12
days of work. I told HOPCo that I had a stomach bug. 13
14
About three days after that, on April 1, when I was just about ready to return to work, I 15
got a call from Dr. Z telling me that I had a rare and really terrible tropical respiratory infection 16
called Seeliasis. It could be fatal if not treated quickly. Dr. Z asked me to return to the office 17
right away to start treatment. When I got to the doctors office, I was ordered to go home and 18
basically quarantine myself. I was supposed to return in a week, or sooner if skin lesions started 19
to appear. I went straight home, really scared and upset. I called my friend at HOPco, Sterling 20
Hobby and explained a little bit. I said I would be out for a few days, and made the mistake of 21
disclosing the Seeliasis diagnosis. I begged Sterling not to tell anyone. I was really afraid of 22
what the others at work would think, and that getting sick right now would hurt my chances for 23
the promotion. You cant imagine how depressed I was. 24
25
I stayed home for 4 days, until Friday, April 5, when I got a call from Dr. Z . Thankfully, 26
the lab had made a mistake. I did not have Seeliasis, only a stomach infection called Shigellosis 27
that could be treated with antibiotics. Dr. Z prescribed an antibiotic and lots of fluids. I picked 28
up my prescription, went home, and within a day was feeling much better. Although I was pretty 29
weak and looked pretty bad, I was able to go back to work the following Tuesday, April 9. 30
31
When I returned to work that day, I noticed that everyone was treating me very 32
strangely. No one would come into my office. No one would even come near me, except Casey 33
Hogg. Hogg came in, welcomed me back and said that the word was that the bosses were 34
about to announce Yarbros successor, and wasnt it too bad that I had been out of the office so 35
much. Even my best friend Sterling didnt come by my office. I tried to invite a couple of 36
people to go to lunch, and no one would accept. 37
38
Later that afternoon, I checked eHop, the online staff bulletin board. I had not looked at 39
it since I got back from my trip. I was just stunned, shocked really, to see a post there from 40
Casey Hogg dated April 8 stating that I had been diagnosed with Seeliasis, describing it in detail, 41
FACT STATEMENT OF CAMPBELL COLQUITT Page 2 of 5

5
explaining how I had become infected, and that I was dangerous to be around. I had said nothing 1
to anyone about my visits to Dr. Z, my blood tests, or the erroneous diagnosis except for one 2
person, Sterling. I had not really given any details in that conversation, just a few pieces of 3
information, certainly not all the information that was now on eHop, for everyone to see. I did 4
not know what else to do but to send my own posting to eHop saying that the Seeliasis diagnosis 5
was wrong, that all I ever had was Montezumas Revenge, that I was completely well now, 6
and that I was never contagious. 7
8
After I sent out my eHop posting, Sterling did come to my office to apologize for 9
avoiding me, but denied knowing anything about who sent the false eHop posting. After that, 10
Sterling was really my only work friend. No one else would have anything to do with me. No 11
matter what I said about not having Seeliasis, about the diagnosis being incorrect, about the 12
doctor calling back and giving me a different diagnosis, about being on antibiotics - nothing 13
would change the way I was treated. I got to where I could hardly go to work. I was so 14
depressed. I could not sleep or eat. I began to lose weight. I was still doing my work, but I was 15
barely hanging on. 16
17
Casey Hogg and I were competing for the same promotion, Manager of the QC 18
department. Sterling was also up for the job. I actually thought that if I did not get the job, 19
Sterling would have been a good choice and probably I could have worked for Sterling as my 20
manager. I had more seniority than Sterling and more experience overall, but Sterling had some 21
managerial experience in previous jobs that I did not have. Casey Hogg was clearly the least 22
qualified of the three of us. 23
24
I have nothing more to say about this at this time. 25
26
Campbell Colquitt 27
CAMPBELL COLQUITT 28
29
SIGNED AND SWORN TO BEFORE me the undersigned authority on this the 3
rd
day of J une, 30
2013. 31
32
Dottie Saver 33
Notary Public in and for the State of Texoma 34
35
My commission expires: 36
April 15, 2018 37
38
FACT STATEMENT OF CAMPBELL COLQUITT Page 3 of 5

6
ADDENDUM TO FACT STATEMENT OF CAMPBELL COLQUITT 1
2
I know that Fergie Shivers claims to have seen Sterling Hobby send the eHop Seeliasis 3
post. I dont believe it. Sterling denied doing it. Although Sterling was in the running for the 4
promotion too, Sterling was my friend and told me that I should get the job. I believe Sterling. 5
Also, Fergie is very tight with and beholden to Casey Hogg, so Fergie has plenty of reasons to 6
try to protect Casey. Hogg is Fergies supervisor, so Fergies possible pay raises and promotions 7
depend upon Hoggs job evaluations. Also, they are darts buddies. A couple of times every 8
week they go to some pub or tavern and compete in darts matches. Hogg is into darts big time. It 9
is all Hogg and Casey talk about at work (which drove me crazy). 10
11
As for our computer passwords at HOPco, we really didnt know each others passwords. 12
For example, I never gave mine to anyone in the QC department; I didnt know anyone elses, 13
except perhaps for Sterlings, but that was a unique situation. Sterling got sick one week around 14
the first of the year and needed some information off of the server. So, Sterling called me and 15
gave me the password so I could access the file and retrieve the information. Actually, the old 16
password policy was a problem for some. We had to change our passwords which could be at 17
least 4 letters or digits every two weeks. They changed so often that some had trouble 18
remembering them. So, some workers wrote their password down and put it in or about their 19
desk. I dont know if Hogg did that. I certainly never knew Hoggs password or if it was kept 20
around the desk. Since the slanderous Seeliasis posting, HOPco has increased its computer 21
security. We all must use strong case-sensitive passwords (minimum of 8 characters made up 22
of numbers, letters and punctuation signs, with at least one capital letter, and they must be 23
changed every three months). 24
25
I did not get the manager of QC position. The false Seeliasis eHop posting pretty much 26
took me out of the running. The position went to Casey. So, I sued Casey for defamation and 27
intentional infliction of emotional distress. My reputation in the QC department had been 28
destroyed. No one would speak to me or work with me. I had no friends and was spending all my 29
time alone in my office. If I told someone to do something, they just walked away from me as 30
fast as they could. I also could never work under Hogg, a person for whom I had zero respect. I 31
had no choice but to ask for a transfer. I was transferred to another department where I work on 32
engineering designs for HOPco toy products. I have no seniority in the new department and it 33
will be years before I will be considered for another managerial position. I am also in counseling 34
and taking prescription medications that I have never had to use before just to cope with this 35
situation at work. I still have trouble sleeping and eating. As for my family, Im sure Im not 36
very pleasant to be around now. In short, Casey Hogg has ruined my life. 37
38
39
40
41
FACT STATEMENT OF CAMPBELL COLQUITT Page 4 of 5

7
I have nothing more to add about this horrible, life-changing event. 1
2
3
Campbell Colquitt 4
CAMPBELL COLQUITT 5
6
SIGNED AND SWORN TO BEFORE ME the undersigned authority at on this the day 7
of trial. 8
Penny Forethought 9
Notary Public in and for the State of Texoma 10
11
My commission expires: 12
April 15, 2018 13
FACT STATEMENT OF CAMPBELL COLQUITT Page 5 of 5

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FACT STATEMENT OF DR. Z. SAYERS STOCKDALE 1
2
My name is Dr. Zamack Heusler, but pretty much everyone calls me Dr. Z. I am a 3
medical doctor with a family practice in Throckmorton, Texoma. I am originally from St. 4
Petersburg, Florida. After high school, I moved to Texoma and attended Texoma Tech 5
University. My original major in college was petroleum engineering, but a bout of Giardiasis 6
after a spring break backpacking trip to Big Bend National Park my sophomore year got me 7
interested in infectious diseases in general and parasites in particular. I changed my major to 8
biology, with a concentration in parasitology. Many folks do not know that humans are hosts to 9
several hundred species of parasitic worms and many species of protozoa. I found this all, well, 10
intriguing. I applied to medical schools during my junior year of college and was admitted to 11
Southwest Texoma Medical College. Although I remained interested in parasitic diseases, I 12
discovered during medical school that my real calling was family medicine. After graduating 13
med school, I did a family medicine residency here in Russellville and was later board certified 14
in family medicine. I joined an internal medicine practice group and have had a family medicine 15
practice now for over 15 years. 16
17
My medical office is close to the corporate offices of HOPco. Although physicians are 18
bound, both legally and ethically, to maintain the confidentiality of information about their 19
patients, I was asked by one of my patients, Campbell Colquitt, to give this statement. Campbell 20
works for HOPco and has been one of my patients for some years. Campbell came into my 21
clinic on March 29, 2013, complaining of stomach cramps, vomiting, and diarrhea. Campbell 22
also had some oozing on the lateral sides of both upper extremities and shoulders. I examined 23
Campbell and took a history. I learned in the history that Campbell had just returned from a 24
family vacation in the rain forest of Honduras. I suspected that Campbells gastrointestinal 25
symptoms were probably a mild form of travelers diarrhea, most likely caused by an E. coli 26
infection from drinking un-sanitized water, but I wondered if it might be Giardiasis, the disease 27
that set me on my path to medical practice, or Cryptosporidiosis, another infection commonly 28
seen after foreign travels. To rule out these and other possible infections, I ordered some 29
diagnostic tests and asked Campbell to go to the lab for blood and urine sampling. I told 30
Campbell that results would take a few days, possibly a week, and in the meantime to stay home 31
from work, drink plenty of fluids, and get some rest. 32
33
On April 1, 2013, I received the lab results. I was quite surprised to learn that Campbell 34
apparently had Seeliasis, a relatively rare tropical disease caused by drinking water contaminated 35
with the enterotoxigenic Seelhoffia bacteria. Seeliasis is most often associated with visitors to 36
less developed countries. Generally, the inhabitants of the tropical countries where the 37
Seelhoffia bacteria are found develop resistance to it. Seeliasis can be quite serious as the 38
bacteria produce enterotoxins that can cause multisystem organ failure. Mild cases can be 39
limited to the kinds of gastrointestinal symptoms seen in more common forms of travelers 40
FACT STATEMENT OF DR. Z. SAYERS STOCKDALE Page 1
9
diarrhea, but severe cases can involve heart, lung, and/or kidney failure. A hallmark sign of 1
Seeliasis is weeping blisters on the skin that appear anytime between three to fifteen days after 2
the initial exposure. The disease has a respiratory component and, as a result, is highly 3
contagious, with aerosol spread of the bacteria from coughing. Treatment options are available, 4
but expensive and limited. 5
6
Although I had heard about Seeliasis in my undergraduate studies of parasitic diseases 7
and in a tropical disease course I took in med school, I had never seen a case of it in my medical 8
practice. In fact, there had not been a confirmed diagnosis of Seeliasis in the United States in 9
over 30 years! Because the disease is so serious, contagious, and deadly (and because its cool, 10
frankly), I had lab samples sent by overnight delivery to the Centers for Disease Control in 11
Atlanta, Georgia so they could confirm the diagnosis and recommend treatment options. In the 12
meantime, I called Campbell to relay the preliminary diagnosis. I explained the Seeliasis 13
diagnosis and asked Campbell to return to the office to start treatment. Campbell came in an 14
hour later and I had my nurse administer an injection of a potent anti-bacterial agent. I gave 15
Campbell a prescription for ten days of oral antibiotics and instructions not to return to work 16
until further notice from me. Finally, I told Campbell to call my office immediately in the event 17
of onset of a high fever, onset of respiratory symptoms or if the GI symptoms worsened. 18
19
We received results back from the CDC on April 5. Although I see so many patients and 20
generally do not recall details of their treatment without reviewing the chart, I remember quite 21
well getting these lab results. I was standing at the front reception desk talking to my nurse 22
about a medication refill request when Yuri, one of the lab techs, came running down the hall. 23
Yuri can be a little excitable, but he seemed even more amped up than normal for him. I 24
remember him running towards me, waving a piece of paper and yelling Dr. Z.! Dr. Z.! We 25
just heard from the CDC! Campbell does not have Seeliasis! Its Shigellosis! 26
27
This was good news. Like Seeliasis, Shigellosis is a gastrointestinal infection. It is 28
caused by the Shigella bacteria and is common in travelers to less developed countries. Like 29
Seeliasis, it is generally contracted by drinking contaminated water. Unlike Seeliasis, the good 30
news is that Shigellosis is pretty much self-limiting, meaning it generally goes away by itself 31
after a few days. Treatment usually consists of replacing fluids. I immediately called Campbell 32
to pass on the good news and to say it was OK to return to work "as soon as you feel up to it" 33
(but to practice good hand washing). I told Campbell to call me if needed. 34
35
After speaking to Campbell, I then chastised Yuri for broadcasting confidential patient 36
information in our reception area. The last thing I need is another HIPAA complaint. 37
38
By coincidence, Casey Hogg, another HopCo employee, was in the reception room when 39
Yuri blasted the CDC news. I was interested in talking to Hogg about a recent darts match I had 40
FACT STATEMENT OF DR. Z. SAYERS STOCKDALE Page 2
10
been involved in and was disappointed to learn that Hogg had a family emergency and had left 1
the office. I do not know if Hogg heard Yuri talking about Campbell, but I do recall seeing 2
Hogg leave the office and telling my receptionist that something had suddenly come up, 3
requiring the Hogg's appointment to have to be rescheduled. I didnt think much of it at the time, 4
as I had a waiting room full of other patients to see. 5
6
Thats all I remember about this incident. 7
8
Z. Sayers Stockdale 9
Z. Sayers Stockdale, MD 10
11
SIGNED AND SWORN TO BEFORE me the undersigned authority on this the 11
th
day 12
of J une, 2013. 13
14
Dottie Saver 15
Notary Public in and for the State of Texoma 16
17
My commission expires: 18
April 15, 2018 19
20
FACT STATEMENT OF DR. Z. SAYERS STOCKDALE Page 3
11
ADDENDUM TO FACT STATEMENT OF DR. ZAMACK HEUSLER 1
2
Although I cant say for sure, since I was so distracted with Yuris imprudence, I think I 3
may have seen the other HOPco employee I mentioned talking on a cell phone on the way out of 4
my office. I can't remember who that might have been, though. I can't even remember a general 5
description 6
7
On an interesting side note, in October of 2013, I happened to be recruited to Selama in 8
Malaysia by Doctors Who Ignore International Borders to investigate a possible outbreak of 9
Seeliasis. When I got there, after over 36 hours of travel by plane, train, bus and ox cart, I was 10
excited to encounter the actual outbreak of the disease! 11
12
13
14
Z. Sayers Stockdale 15
Z. Sayers Stockdale, MD 16
17
SIGNED AND SWORN TO BEFORE me the undersigned authority on this the first day 18
of trial. 19
20
21
Notary Public, State of Texoma 22
My commission expires: 23
____________________ 24
25
26
27
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29
30
31
32
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39
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FACT STATEMENT OF DR. Z. SAYERS STOCKDALE Page 4
Penny Forethought
April 15, 2018
12
FACT STATEMENT OF STERLING HOBBY 1
2
My name is Sterling Hobby. I live at 1600 Pennsylvania Avenue, Hematite, Texoma. I 3
am married and have 2 kids. I got a degree in Electrical Engineering from Nita State ten years 4
ago. 5
6
I have worked for HOPco for 8 years. I am in the Quality Control (QC) department, and I 7
used to love it here. I made friends with almost everyone in the office and we had the best time. 8
Every morning before work, a group of us would hang out in my office and shoot the breeze. We 9
would tell stories about what was going on in our lives, both at home and at work. I would talk 10
about my kids baseball games, the trips my family went on, and things like that. We engaged in 11
some office gossip, too. But then J udy Yarbro, our department manager, would come around 12
about 9:00 and everyone would run back to their desks and get back to work. 13
14
Early in March, when J udy decided to retire , things certainly changed around here. 15
Things got tenser and we lost the sense of camaraderie. I decided to apply for the QC Manager 16
position, J udys old job. After all, I have been here for 8 years. I am good at my job and 17
everyone seems to like me. 18
19
I found out over the next couple of weeks that Campbell Colquitt and Casey Hogg both 20
applied for the job as well. Campbell is one of my best friends. Campbell's office was next to 21
mine and we would talk pretty much every day. I have met Campbells spouse as well as their 22
kids. They are a great family. Campbell is an accomplished, dedicated worker, too. Campbell 23
and I worked well together. If I was not going to get the promotion, I would have been excited to 24
work for Campbell. I didnt think J ester was as qualified as either of us. Plus, I have heard a lot 25
of stories about J ester Hogg. I heard that Hogg has an attitude problem and is not liked by a lot 26
of people in our department. I have heard that Hogg is really sneaky and will do anything to get 27
ahead, and have seen it for myself recently. People have also told me that J ester will take credit 28
for other peoples work, and talk behind coworkers backs. Campbell and I really do not care for 29
Hogg, and Hogg definitely despises Campbell. I have heard them in screaming matches, 30
especially when Hogg took credit for Campbells 3
rd
quarter TPS report, although it had the 31
wrong cover sheet. I have heard that Hogg has said untrue things behind my back, but I havent 32
confronted Hogg about it. Hoggs only friend at work is Ormolu Shivers. They get together once 33
a week and play in a darts league, and seem pretty tight at work. Also, Hogg is Shiverss boss 34
and is responsible for Shivers's performance evaluations. 35
36
In March, I started working extra hard, being the first one in the office and the last one 37
out. I wanted the vice president to see that I was working harder than anyone else, and that I 38
deserved the promotion. Of course, our group kept talking during the mornings, but fewer people 39
were coming around. Although I was competing against Campbell and Hogg for the job, I was 40
1

13
still friendly. Campbell and I, especially, remained on good terms. One morning, Campbell told 1
me the family was going to Central America in late March for a vacation. I thought it was 2
strange that Campbell decided to go on vacation while we were competing for the promotion. 3
Especially to Central America, since there are some crazy things going on there. But, I thought it 4
may give me an advantage for the Manager position. 5
6
Campbell got back from Central America on March 28. Campbell looked horrible, 7
covered in these disgusting blisters that were oozing. Also, Campbell was losing weight and was 8
going to the restroom often. I asked what was wrong and was told it must have been 9
Montezumas Revenge from camping in the jungle. I told Campbell that I hoped everything 10
was OK. 11
12
Campbell called in sick for the next few days, and I didnt hear anything more. Then, on 13
April 1, Campbell called me and said the doctor identified some disease called Seeliasis and that 14
Campbell got it on the trip to Central America. The doctor said it could be very serious. I thought 15
it was an April Fools joke, but Campbell insisted it wasnt. Campbell told me not to tell anyone 16
(mainly because of the promotion) and I gave my word I wouldnt. After all, Campbell told me 17
about the disease in confidence. Campbell would be out for several more days, and I just told 18
everyone at the office Campbell had a stomach bug. 19
20
The next day, I looked the disease up on Google. It was absolutely horrifying. Although I 21
thought Campbells illness may help my chances of getting the promotion, I felt horrible for 22
Campbell. I was also worried about the fact that Campbell had come to the office, since Seeliasis 23
is highly contagious. I didnt want anyone else in the office to catch it (especially me). Although 24
I had a lot to do, Seeliasis was all I could think about. After I read about how contagious the 25
disease is, I immediately went around the office and tried to disinfect it. I grabbed a bottle of 26
cleaner and a rag and went to every area I could think of where Campbell had been. I admit, 27
sometimes I get carried away with cleaning, and this is not the first time I have tried to disinfect 28
the office. I guess you could call me a germophobe I even tried to organize a disinfecting party 29
by posting on the eHop. You should have seen me scrub every inch of the office a couple of 30
years ago during flu season. I have sought treatment for it and now wear the germ necklace, like 31
all recovering germophobes. However, I couldnt take any chances. I cleaned everyone's desk, 32
including J esters's desk. Even though Hogg and I dont always see eye-to-eye, I wouldnt wish 33
Seeliasis on anyone, so I cleaned Hogg's desk while no one was there. I am pretty sure I cleaned 34
the desk on the 5
th
, but it might have been the 8
th
. I'm just not sure. 35
36
I was absolutely shocked to see the posting on eHop. I knew Campbell would be upset if 37
the whole company knew Campbell had Seeliasis. I'm not surprised at all that J ester was the one 38
who posted it, as that is exactly something J ester would do. After the posting, Campbell was the 39
talk of the whole office. People did not want to be anywhere near Campbell. I didn't tell anyone 40
2

14
about Campbell having Seeliasis before the eHop posting. I discussed it with people after the 1
posting, you know, to organize the cleaning parties. 2
3
The day after the posting, I finally saw Campbell back in the office. I wanted to go say hi, 4
but I was still scared to get sick. After I saw Campbells post on eHop stating that the Seeliasis 5
diagnosis was a mistake, and that it was just Montezumas Revenge, I went to Campbells office 6
to apologize for avoiding Campbell. 7
8
A few days later, the company announced that Hogg got the promotion. I was so angry 9
that J ester got the job after that dirty trick. Hogg even got Shivers to say that I sent out the post. I 10
cant believe someone would lie like that. I was also sad to see the horrible things that happened 11
to Campbell. After the promotion was announced, Campbell was devastated. Campbell is a 12
changed person. Campbell is under a doctors care for depression. Ultimately, Campbell 13
transferred to another department. Campbell just couldnt take it anymore. Meanwhile, Hogg is 14
the new QC manager and is just horrible. I hope Hogg gets what's coming. 15
16
This is all I have to say on this matter. 17
18
19
Sterling Hobby 20
STERLING HOBBY 21
22
SIGNED AND SWORN TO BEFORE ME the undersigned authority on this the 18
th
23
day of J uly , 2013. 24
25
Galena Wolfram 26
Notary Public in and for the State of Texoma 27
3

15
ADDENDUM TO WITNESS STATEMENT OF STERLING HOBBY 1
2
Oh yeah, I forgot to talk about the computer passwords at HOPco. I think the system we 3
had before was fine. I trust the people I worked with (except Hogg and Shivers), and have never 4
seen anyone on someone elses computer. No one else would do that. In fact, very few of us even 5
knew anyone else's passwords. Once I called in sick and told Campbell what my password was 6
so Campbell could find some information I needed on my computer, but otherwise we didnt 7
know each others passwords. I certainly did not know Hoggs password. It is true that they have 8
tightened up computer security at HOPco after the false eHop posting that torpedoed Campbells 9
chances of getting the promotion. Ill admit that it is better than it was before, when the 10
passwords had to change every two weeks. It made it hard to remember what your current 11
password was, and that caused some co-workers to write down their new password and keep it 12
around their computer. However, as I said, I never saw or learned Hoggs password, let alone on 13
April 8 when the false eHop posting was made. 14
15
Hogg has said that Hogg ran into me on the morning of April 8 around 10:15 a.m. as 16
Hogg was going into the employees lounge at work. The lounge is near the restrooms, so I guess 17
that is possible, but there is no reason I would remember that. So, no, I dont remember it 18
happening. However, I can say for an absolute certainty that Shivers is either lying to protect 19
Hogg or is mistaken when Shivers says I was at Hoggs computer around 10:30 that morning. I 20
was not. I dont recall where I was or what I was doing (why should I?), but I know I did not 21
post that false eHop note about Campbell. As I said, I had been at Hoggs computer disinfecting 22
it. Shivers may have seen me then, but that was before the false message was posted. 23
24
Oh, and I did ask Bernie Allred about the stuff I saw on "43 Minutes," but I was really 25
just kidding around. I dont care if HopCo has the ability to watch us or not. Now, I'm done 26
testifying. 27
28
Sterling Hobby 29
STERLING HOBBY 30
31
SIGNED AND SWORN TO BEFORE ME the undersigned authority on this the day of 32
trial. 33
34
Penny Forethought 35
Notary Public in and for the State of Texoma 36
My commission expires: 37
April 15, 2018 38
4

16
FACT STATEMENT OF CASEY "JESTER" HOGG 1
2
My name is Casey Hogg, but everyone calls me "J ester." I got that name in 4
th
grade 3
when I played the part of a court jester in a play and I guess the name literally stuck. I am 46 4
years old, and live in Sudbury, Texoma. I am not married, and live alone at the moment. Aside 5
from being very good at my job at HopCo, Inc., I am an excellent darter, playing on a local team, 6
the Forneytown Fletchers. We are the current league champions, and likely to win again this 7
year. My nickname on the team is Matador, because I can hit the bullseye so often. Several 8
other HopCo employees are on the team with me, including my good friend Fergie Shivers. 9
Some of the dart people call me Matador J ester, 10
11
I have worked in the Quality Control department at HopCo for several years, and was 12
recently promoted to supervisor in that department despite some serious competition from other 13
members of the department. I am completely qualified to take on the role of supervisor, having a 14
Masters Degree in Project Management from Garsquite Regional Institute (GRIN) along with 15
my technical certificate from Balch Electronics and Radionics Institute (BEaRIT). I have worked 16
in every area of QC at HopCo, starting out as a supply clerk while I was still getting my technical 17
training. I briefly worked in the IT Support section to learn about how HopCos computer system 18
supported the QC program, and then, once I got my certificate, I moved directly into being a QC 19
inspector for several years. I have been involved in inspecting and testing every product line 20
HopCo currently produces, and I am proud to say that for the last five years we have been below 21
the industry average in complaints about our product quality and consistency. 22
23
During the managements process of selecting the new QC supervisor, I was asked to 24
review and explain complaints that had been previously made about my own work as a QC 25
inspector, and whether I had passed products that should have been flagged for further 26
examination and possible reworking. I believe that I clearly explained and defended each of 27
those product evaluations, and apparently management was satisfied with my explanations, since 28
they ultimately gave me the promotion. I did not mention this during the management interviews, 29
but I believe that some of those inaccurate reports about my performance were made by 30
Campbell Colquitt during a time we were having some rather heated disagreements about how to 31
interpret some of the testing results we were getting from the Radionics and Nonintegral Digits 32
Onsite Meter (RANDOM). I felt, and still feel, that the results we get from that equipment are 33
reliable, but Campbell thought I was being sloppy by not correlating the RANDOM results with 34
the Digital Analysis Turing Array (DATA), and Campbell apparently reported that I was not 35
doing my job properly. We argued about this between ourselves for quite some time, but 36
eventually we came to an agreement about how to use the RANDOM/DATA results in the future 37
and that was, I thought, the end of that, 38
39
FACT STATEMENT OF CASEY HOGG Page 1 of 4

17
In March of 2013, HopCo QC Department Lead, J udy Yarbro, announced her pending 1
retirement. While all of us in QC were sad to see her go, I saw this as my opportunity to advance 2
my career, so naturally, I applied for her job. I was not surprised when Campbell was one of my 3
competitors for the QC supervisor position. I respect Campbells work, and, frankly, would have 4
been surprised if Campbell was not on the selection short list. I was puzzled when Campbell 5
decided to go on a vacation out of the country during the supervisor selection process, because I 6
thought it would be a good idea to be instantly available for any short-notice interviews, but Im 7
sure there were good reasons for that decision. 8
9
I remember Campbell returning to work at the end of March. Campbell did not look well 10
at all. Between the massive blisters and sores, Campbell looked like something out of a horror 11
movie. I mean, it was hard to even look. Campbell did not complain of nausea or any other 12
internal issues, and so I initially didnt think any more of it. 13
14
Then, the following week, Campbell didnt come into work. Everybody in the QC office 15
assumed that Campbell was ill from the trip, The morning of April 8, I was at work, at my 16
desk as usual. Around 10am or so, I just went to the employee lounge with the Texoma Tattler 17
(a gossip magazine that is a weakness of mine) for a coffee break. On my way into the lounge, I 18
passed Sterling Hobby, who made a joke about my taste in literature. I was away from my desk 19
for about 20 minutes, and when I came back, Im sure the workstation was locked, because I had 20
to log back in. Besides, my workstation locks automatically after 5 minutes. 21
22
Imagine my shock when I logged onto eHop and saw a posting about Campbell having 23
Seeliasis. And imagine my further shock when I realized that that the posting was from my 24
account! I know its hard to believe, since the post originated from my computer, but I did not 25
write it! I immediately called Human Resources and made them lock the thread. I never made 26
that posting, I only heard about the diagnosis after my colleagues started gossiping about it 27
after the post! 28
29
I remember very clearly my reaction, because I had a very dear aunt who died from 30
Seeliasis when I was fifteen years old, and it made a huge impression on me. I remember 31
visiting her in the hospital, and not even being allowed to enter her room because they told me 32
the disease was so dangerous to come in contact with. I watched the nurses and doctors put on 33
full-body protective suits and gloves before they went in her room, and how careful they were to 34
make sure that everything coming out of that room was placed in double biohazard bags to be 35
incinerated. I was able to see and talk to my aunt on closed-circuit television, and the damage the 36
disease did to her before she died still gives me occasional nightmares. I was terribly sad to hear 37
that Campbell had such an awful disease, but I also was extremely fearful of being anywhere 38
near Campbell and couldnt understand why the doctor hadnt hospitalized and isolated 39
Campbell immediately. I thought maybe medicine had progressed enough in the 30 years since 40
FACT STATEMENT OF CASEY HOGG Page 2 of 4

18
my aunt died that they didnt need to do things that drastic anymore, but I didnt want to take any 1
chance of getting such a disease. 2
3
I was incredibly relieved to hear that the initial diagnosis had been wrong, and that I no 4
longer had to use disinfectant wipes on everything Campbell touched near my workstation. Of 5
course, I was also relieved that the QC section would not be losing such a valuable employee. 6
7
I absolutely did not make that post myself, even if it did appear to come from my 8
computer. I have no idea who would have done this, but as I said, our department is pretty 9
compact; the workstations are close together, and its often easier to just use whatever computer 10
is closest at hand instead of walking all the way across the room to use your own computer. 11
Nobody in the office, including me (until this came up), has been very concerned about computer 12
security. We were supposed to change passwords every two weeks, and so some people were 13
taping their passwords to their monitors or keeping them somewhere else near their computers. 14
Nearly everybody in the office knew everybody elses password, and if somebody did change, 15
they always changed to something simple we all could guess in about two minutes. When that 16
post about Campbell was done, my password was DaRtS. I sometimes forgot my password, so 17
I wrote it on a sticky note, and put the note underneath my mousepad, Exhibit 4 is a picture of 18
the bottom of my mousepad. I always lock my workstation when I leave my desk, so Im pretty 19
sure I did that morning when that post was made. 20
21
I guarantee that as the new supervisor, I am going to make sure the entire QC staff is 22
better educated about computer security, and I will enforce the new rules about high-security 23
passwords. I will definitely be working with my contacts in the IT department to make sure there 24
wont be another incident like this one. 25
26
27
Casey Hogg 28
CASEY HOGG 29
30
SIGNED AND SWORN TO BEFORE ME the undersigned authority on this the 5
th
31
day of August, 2013. 32
33
Jumpy Gathers 34
Notary Public in and for the State of Texoma 35
36
My commission expires: 37
April 15, 2045 38
FACT STATEMENT OF CASEY HOGG Page 3 of 4

19
ADDENDUM TO FACT STATEMENT OF CASEY "JESTER" HOGG 1
2
I did have a routine annual physical scheduled with Dr. Stockdale for Friday, April 5
th
, 3
but I didnt think it was that important, I was unable to stay for that appointment because I got 4
a call that my grandmother, the one who lost her daughter to Seelialis, had broken her hip, and I 5
went to visit her in the hospital. I dont recall overhearing anything said by the doctor's staff 6
concerning Campbell Colquitt or any other patient. There were lots of people in the waiting 7
room that day, and my mind was on Nana B. I am sure that there was way too much noise for 8
me to have heard anything clearly that day. 9
10
Dr. Stockdale is my primary care physician. The doctor's office is pretty close to our 11
facilities and Dr. Z (that's a nickname) is on HopCo's insurance plan. I guess lots of us use Dr. Z 12
as our PCP, and Campbell is also a Dr. Z patient. I have seen Campbell in the waiting room on 13
more than one occasion. 14
15
I have nothing more to add. 16
17
Casey Hogg 18
CASEY HOGG 19
20
SIGNED AND SWORN TO BEFORE ME the undersigned authority on this the day of 21
trial. 22
23
Penny Forethought 24
Notary Public in and for the State of Texoma 25
26
27
My commission expires: 28
April 15, 2018 29
30
FACT STATEMENT OF CASEY HOGG Page 4 of 4

20
FACT STATEMENT OF FERGUSON "FERGIE" SHIVERS 1
2
My name is Ferguson Shivers, but I prefer to be called "Fergie." I live at 217A Baker 3
Road, Pentland, Texoma, in a moss covered, 250 year old brick house. Im about 3 miles from 4
town, just past the creek, about 500 yards past the oak tree on the south side. You cant miss it. 5
I live with my spouse of 13 years, give or take We have two children, J ules, 10 and Verne, 8. 6
7
I graduated from Pentlandite High School (Home of the Fighting Isotopes!) in 1999. I 8
attended Crane-Carroll J unior College from 1999-2001. I received my associates degree in 9
mathematics, with a minor in interpretive dance. Id intended to pursue my bachelors degree, 10
but I was denied admission to the J ulliard dance program. I briefly considered pursuing the math 11
thing, but figured why spend the money on a useless degree I would probably never use? Whats 12
the use in that? I have worked for Hopco, Inc. since 2001. I started in the mailroom delivering 13
mail and packages to Bldgs A-G, on the campus. I felt that this was the best use of my 14
education, given the excellent condition of my legs from all that dancing. 15
16
During my time at Hopco, I made regular deliveries to the QC department. That is where 17
I met Campbell Colquitt, Sterling Hobby and Casey Hogg. At first, I honestly had no clue what 18
they were up to in that department. After a while, it appeared that they were testing stuff that 19
Hopco made. They had all kinds of fancy testing tools and gadgetry. It looked like a lot of fun. 20
I entered the department one day, and they were testing a circuit board. The testing was 21
revealing some kind of defect that they appeared unable to solve. There was a fault in the 22
algorithm, and they appeared stumped. I looked at the equation they were trying to resolve. I 23
was able to work through the solution in about 15 minutes. I then shared with them my 24
interpretive dance of Pi. It has just over 3 steps per part and lasts just over 3 minutes long, and 25
none of the steps repeat. That totally blew their minds. 26
27
About a week later, I got a call from Casey Hogg. Casey was part of the QC team that 28
Id helped. Casey asked if I would like to join the QC department. Casey said discussions had 29
already occurred at higher levels about my insight and natural aptitude to see the solution, but 30
management was concerned about my lack of formal training. I guess my associates in math 31
falls well below the typical requirements, but Casey had already gone to bat for me, and got me 32
the new position. I was transferred to the QC department in that same month! 33
34
I have enjoyed my time in the QC department. The work is interesting. When I first 35
started, the QC Department was led by J udy Yarbro. She was excellent at Quality Control. 36
Nothing got past her. I was sad when she announced her retirement, but saw the opportunity for 37
the department to take a new direction. I knew that Campbell, Sterling and Casey were all 38
applying for the job. I had thought about applying for the job, but figured it would take up too 39
much of my time. Time that could be devoted to my latest performance work. I dont want to 40
FACT STATEMENT OF FERGUSON SHIVERS Page 1 of 4

21
get into too many details so as not to spoil the surprise, but this may be the first dance piece 1
devoted to the Fluke brand of electronic testing devices. 2
3
I have worked for Casey since joining the QC team. Ive been a direct report, and we 4
work great as a team. Casey constantly has my back when someone questions my methods, or 5
my credentials. Of course, Ive never let Casey down, nor would I ever. Additionally, Casey got 6
me into the fantastic sport of competitive Darts. At a HopCo happy hour a few years back, 7
Campbell and Casey were playing a round of Darts, and I was watching. Campbell handed me a 8
dart and told me to throw it. By some combination of my natural grace and ability to see the 9
mathematical curve, I got a Bull my first time! Casey was impressed, and now we compete 10
together in the intercorporate co-ed competitive dart league. We finished 4
th
in the Year End 11
Tournament last year! 12
13
Working day in and day out together, you learn a lot about people. Their interests, their 14
dislikes, lots of information. Casey and I even shared passwords so that we could cross check 15
each others work, respond to e-mails, and really cover for each other if some emergency comes 16
up. We have always had each others backs. Of course, it was pretty common in our department 17
to share passwords. Sometimes people clued others into their password with a picture on their 18
desk, or a screen saver. Some people even wrote down their password and hid them, under the 19
mouse pad or keyboard Casey did this often. IT has changed that, with rules about different 20
passwords, changing passwords, and all this other security stuff. I dont get it 21
22
I was happy to support Casey in applying for the managers job. Were friends, and I 23
want to see Casey do well. I also consider Campbell to be a friend, but not as good of a friend as 24
Casey. It became harder over the years to maintain both friendships. Campbell and Casey have 25
had run-ins over the years. Im not sure exactly what they were all about, but their relationship 26
has always been strained. When the supervisors job opened up, things got a bit more heated 27
between them. I tried not to take sides, but I did support Casey for the job. J udy Yarbro had 28
asked for my opinion about who should get the job. I told her honestly that Casey would make a 29
better manager. I mean, Campbell once told me that Captain Piccard was far superior to Captain 30
Kirk. While that did not affect our friendship, it certainly made me question Campbells 31
judgment. Seriously, how can anyone with that opinion be taken seriously as a manager? Plus, 32
Campbell went on vacation during the interview and selection process. Im all for people taking 33
their vacation days, but the timing was just strange, and I think it may have counted against 34
Campbell. 35
36
I cannot state that Casey did or didnt post stuff about the Campbell on eHop. I know 37
that they didn't really like each other, and Casey made jokes about the Campbells condition after 38
the post went up. Something about a likely-host and possible improvements to Campbells 39
appearance. 40
FACT STATEMENT OF FERGUSON SHIVERS Page 2 of 4

22
1
Casey was at work, at Caseys office all day on April 8
th
. I remember Sterling being 2
super weird around that same time. Sterling is somewhat of a germophobe, as in, washes hands 3
25 times a day, and is constantly spraying down surfaces to disinfect. Well, that Monday, and 4
the Friday before, Sterling had gone around to everyone workstations and scrubbed them from 5
top to bottom. I remember seeing Sterling in Caseys office sometime mid-morning on April 8
th
. 6
(The offices have interior walls made of glass, so everyone in the cube farm can clearly see into 7
all of the officeswhich makes for some interesting people watching sometime. The walls 8
between the offices are frosted glass that you can't see through.) 9
10
Casey had left for the typical mid-morning coffee break, and Sterling went into Caseys 11
office, though I didnt see clearly what Sterling was doing. Sterling was wearing those huge 12
rubber cleaning gloves and had a spray bottle and some rags. 13
14
Things have been going well since Casey took over the QC department. Other than the 15
new IT rules. But some of the other rules have been relaxed, and were not so uptight about 16
making sure everything works right all the time. It relieves a lot of pressure. Everyone seems so 17
much happier. 18
19
I really cannot think of anything else about this situation. Its just a shame that it has 20
come to a lawsuit. 21
22
Fergie Shivers 23
FERGUSON SHIVERS 24
25
SIGNED AND SWORN TO BEFORE ME the undersigned authority on this the ____ 26
day of ____, 2013. 27
28
Lexi McNuggett 29
Notary Public in and for the State of Texoma 30
31
My commission expires: 32
August 15, 2018 33
34
FACT STATEMENT OF FERGUSON SHIVERS Page 3 of 4
26th
July
23
ADDENDUM TO FACT STATEMENT OF FERGUSON "FERGIE" SHIVERS 1
2
I need to clarify a few things 3
4
Like I mentioned, Casey and I have each others backs, and always let each other know 5
when we'll be out of the office. Casey was out of the office part of the afternoon on Friday, 6
April 5. Casey had a doctor or dentist appointment or something that afternoon. 7
8
When Sterling went into Casey's office, I did say I noticed what might have been 9
cleaning supplies. I personally think that those were props meant to create an appearance. After 10
the eHop post that caused all the commotion (and this lawsuit), I mentioned to several of my co- 11
workers that I suspected that Sterling had been the author. After all, Sterling was at the 12
computer right around the time of the post and Sterling had a motive to do it, since it would hurt 13
both of them, Campbell and Casey. I get that Sterling has denied making the post, but really, 14
what does anyone expect? Sterling isn't going to just come out and admit something like that. 15
As for me, if I have not made it clear so far, I absolutely deny posting that message. Absolutely. 16
17
As for Campbell leaving QC after Casey got the promotion, all I can say is that some 18
people are sore losers. 19
20
21
Fergie Shivers 22
FERGUSON SHIVERS 23
24
SIGNED AND SWORN TO BEFORE ME the undersigned authority on this the day of 25
trial. 26
27
Penny Forethought 28
Notary Public in and for the State of Texoma 29
30
My commission expires: 31
April 15, 2018 32
FACT STATEMENT OF FERGUSON SHIVERS Page 4 of 4

24
FACT STATEMENT OF BURNET ALLRED 1
2
My name is Burnet Allred. I am 37 years old and live in Anita, Texoma. I am not 3
married and have no children. Between my demanding job, the time I spend playing Gothador 4
(an online role-playing game where I battle mythical creatures), and my leadership role in the 5
Texoma Steampunk Society, I dont really have time to worry about dating or marriage or kids. 6
I definitely dont have the time or the energy to get involved in the petty squabbles between 7
Campbell Colquitt and Casey Hogg. 8
9
Im only testifying in this case because Caseys attorney told me that I could be held in 10
contempt of court if I dont show up. The trial is on the same day as the Wild West Steampunk 11
Convention (we call it WWSC, for short). I was actually supposed to speak at a WWSC panel 12
about my recently-published steampunk paranormal romance novel, The Zombies of Mesmer. 13
Its really good. Ive sold over 30 copies on Fictionaut. Plus, I am the defending Southwestern 14
Champion in the grand sport of tea dueling, and I wont be able to defend my title this year. 15
16
I have a bachelors degree in computer science, with a minor in management information 17
systems, from The University of Texoma. I started taking online classes to get my MBA, but it 18
seemed like lots of work without much reward. I come by my business savvy naturally, so I 19
dont need any more formal training. I make over six figures a year, which is probably why most 20
of my co-workers resent me so much. Uneasy lies the head that wears the crown. 21
22
I am the Supervisory Information Technology Manager for HOPco and am responsible 23
for implementing and maintaining the technology infrastructure for the entire company. In 24
addition to the corporate office where I work, we have four branch offices. HOPco relies on a 25
central information processing system located in the corporate office to support the efficient data 26
management and communications for all its employees. In my role as Supervisory IT Manager, I 27
monitor the organizations operational requirements, research strategies, and technology 28
solutions, and aim to build the most cost-effective and efficient system to achieve those goals. In 29
the IT world, Im kind of a big deal. Not that anyone around here really notices. 30
31
Three years ago, Murrah Hansborough, HOPcos Executive Vice President for 32
Operations, contacted me because HOPcos executive board identified a problem with 33
communication in the corporate office. There was no central online community for the corporate 34
office employees. In laymans terms, that means that was that there was no way to communicate 35
the news and information that creates a high-functioning workplace environment. So, Mr. 36
Hansborough (he asked me to call him that because I kept calling him Baldy) asked me to set 37
up an electronic bulletin board that uses push-and-play technology so that corporate office 38
employees can share messages on everything from job safety to company goals to the latest 39
software updates. 40
41
FACT STATEMENT OF BURNET ALLRED Page 1
25
I set up a state-of-the-art electronic community called eHOP. (Management thinks I 1
named it after HOPco, but its actually an homage to chap hop music, which mixes hip hop with 2
elements from the Chappist and steampunk subcultures.) With this technology, which is 3
probably too intricate for most people to understand, HOPco is entirely integrated. Its really 4
quite a technological feat. 5
6
Unfortunately, the fools with whom I work dont know it when they have a good thing. 7
Instead of using eHOP to share workplace tips and spread best practices to improve efficiency, 8
they use it as a virtual high school lunchroom. Suddenly, everyone was on eHOP all day, talking 9
about competition darts, gossiping, and generally slacking off. And because most of HOPcos 10
employees dont have my computer skills and training, a lot of people had their passwords 11
stolen. Its really their own fault for sharing their passwords, posting them in plain view at their 12
desks, using easy-to-guess passwords, and refusing to change them regularly. I mean, people 13
were using passwords like password, 123456, and letmein and putting them on sticky 14
notes they stuck to their monitors. Really? Letmein? I guess they didnt think of 15
opensaysme. Anyway, just like that, people were posting scandalous messages 16
anonymously (meaning they posted under somebody elses user name), so you never really 17
knew where a rumor or insult started. Well, YOU couldn't tell where it all started. I, on the 18
other hand, was able, if I wanted, to discern from where any such message emanated. 19
20
Exhibit 1 is a print-out showing eHOP activity from 3:37 PM on April 5, 2013, to 4:45 21
PM on April 10, 2013. This print-out, which I printed from HOPcos computer systems, shows 22
various posts to eHOP on the dates and times indicated. The print-out also shows the name of 23
the system user who made the post and how many replies it generated. For example, the posting 24
at 4:45 PM on April 10 was a post by the Marketing Department about the meGoggles press 25
release policy that generated 4 replies. As you can see, the records do not show you the name of 26
the person who actually made the post, just the computer user name used by the person who 27
made the post. We have some generic user names, such as Marketing Department, but every 28
HOPco employee has his or her own specific user name. An example of a specific user name is 29
the next post on Exhibit 1, titled Free kittens need good home, which was posted by user 30
CAROLANNCARROL, a HOPco employee who works in the HR department. 31
32
Exhibit 2 is a print-out showing the full eHOP post that started this mess. This print-out 33
shows the original post, which was made on April 8, 2013, at 10:12 AM by user CASEYHOGG, 34
and all the replies to that post. The post generated a lot of traffic on eHOP and I remember 35
getting a call from HR asking me to shut it down for further comments. I did that at 11:55 AM 36
on April 8, 2013, as shown by the last entry on Exhibit 2. No telling how many goofy replies we 37
would have had if I had not shut it down when I did. 38
39
In May, a few weeks after the Seeliasis rumor got started, Mr. Hansborough asked me to 40
do a little sleuthing as part of his internal investigation. Lucky for Baldy -- I mean Mr. 41
FACT STATEMENT OF BURNET ALLRED Page 2
26
Hansborough -- I set up eHOP so the systems administrator can track every keystroke from every 1
computer logged onto the database. Its the same technology used by the NSA, and HOPco is 2
darn lucky that I was savvy enough to include it in the code. I was able to go back and discover 3
a bunch of important facts. Sterling Hobby accessed the internet on Sterlings office computer 4
and Googled Seeliasis on April 2, 2013. Sterling spent 20 minutes researching the disease that 5
day. The Seeliasis post, including the color pictures from the So You Think Youve Got a 6
Horrible Disease website, was posted on April 8, 2013, at 10:37 a.m. by RAMSEYBUTTONS 7
as a reply to the original posting. The original Seeliasis message was definitely posted from 8
Caseys workstation in the Texoma branch office. 9
10
Well, you can imagine how crazy it got at work after the rumor about Campbell having 11
Seeliasis went viral, especially when the eHOP post showed the rumor was started by Casey. 12
Everyone was taking sides, bickering about stupid promotions, and nobody was doing their darn 13
job. Except for me, of course. Eventually, management forced us all to go to a trust-building 14
workshop at a camp site about 20 miles outside of Texoma. It was a total waste of time, in my 15
opinion. Im pretty sure theres still a lot of animosity between Campbell and Casey, and I 16
missed a perfectly good weekend of Gothador so that I could spend two days doing trust-falls. 17
18
A day or two before the posting that started all of this (the April 8 posting), Sterling 19
Hobby asked me whether what was on the TV News Magazine "43 Minutes" the night before 20
was true that private companies had the ability to record the faces of those using HOPco 21
computers with "reverse webcam" technology. I informed Hobby that HOPco did not have this 22
capability, yet; but we would certainly be looking into it. I remember Hobby asking this 23
question because it was a weird question and only Hobby asked me about it. 24
25
Thats all I remember about this incident. 26
27
28
Burnet Allred 29
BURNET ALLRED 30
31
SIGNED AND SWORN TO BEFORE me the undersigned authority on this the 25
th
day of J uly, 32
2013. 33
34
Twinkie McPhee 35
Notary Public in and for the State of Texoma 36
37
My commission expires: 38
April 24, 2014 39
40
41
FACT STATEMENT OF BURNET ALLRED Page 3
27
ADDENDUM TO FACT STATEMENT OF BURNET ALLRED 1
2
I guess I should mention that I cant say for sure that it was Casey who actually wrote the 3
scandalous post about Campbell and Seeliasis. Anyone with Caseys password could have 4
logged onto that workstation because HOPco initially refused to adopt my ideas for computer 5
security. When I wrote the code, I included an advanced feature that remotely activated each 6
users webcam and snapped a picture each time the user logged on to eHOP. The pictures would 7
then be archived so that management could assure that each employee was working a full eight- 8
hour day and wasnt spending too much time on eHOP. When I told Mr. Hansborough about 9
that state-of-the-art feature, he instructed me to delete it immediately and said that it was creepy 10
and an invasion of privacy. I bet he wishes he had that picture archive now. 11
12
What I can say for sure is that someone manually locked Caseys computer at 10:20 AM 13
on April 8, 2013, and that someone entered Caseys password at 10:32 AM. The Seeliasis email 14
was typed and posted at 10:37 AM. The computer then automatically locked itself at 10:43 AM, 15
after 5 minutes of inactivity. The password was entered again at 10:50 AM and someone then 16
wrote a note to Caseys mom. All this information is logged at the server level, something the 17
HOPco drones have no way of knowing. We can track everything they do on their computers, 18
including looking at what web sites they visit and how long they stay on each page. If they knew 19
what we can see about their web surfing, theyd probably do a whole lot less of it. 20
21
After this whole Seeliasis thing erupted, the executive committee had me write code 22
instituting a new electronic security policy. The purpose of these changes was to try to prevent 23
any more unauthorized use of HOPcos network resources. Now, passwords must be changed 24
every 30 days and they must be strong passwords (which means at least eight characters, with 25
at least three of the following: numbers, upper case letters, lower case letters, and special 26
characters). 27
28
Too little, too late, if you ask me. 29
30
31
Burnet Allred 32
BURNET ALLRED 33
34
SIGNED AND SWORN TO BEFORE ME the undersigned authority at on this the day 35
of trial. 36
37
Penny Forethought 38
Notary Public in and for the State of Texoma 39
40
My commission expires: 41
April 15, 2018 42
FACT STATEMENT OF BURNET ALLRED Page 4
28
....
meGoggles press release policy April 10, 2013 @ 4:45pm
posted by MARKETING DEPARTMENT 4 replies
....
Free Kittens need good home April 10, 2013 @ 2:13pm
Posted by CAROLANNCARROLL 11 replies
....
To the Owner of the moldy Potato Salad in the Lounge April 10, 2013 @ 12:02pm
Posted by JIMMYHENDERICKS 1 reply
....
Donuts in Conference Room C-2 April 10, 2013 @ 9:37am
Posted by HELGANOSH 47 replies
....
More Pictures of Seeliasis April 9, 2013 @ 10:10pm
Posted by DAVEPOSTMANN LOCKED BY ADMIN 1 reply
....
Crazy Sock Fridays!!!! April 9, 2013 @ 3:20pm
Posted by CARLITADANGER 14 replies
....
I DO NOT HAVE SEELIASIS April 9, 2013 @ 2:42pm
Posted by CAMPBELLCOLQUITT 2 replies
....
Welcome Baby Anita Bathe! April 9, 2013 @ 10:10am
Posted by IMMAPIGG 25 replies
....
Can we please stop with the Pictures, srlsly? April 8, 2013 @ 5:45pm
Posted by CARAHAAS 3 replies
....
If you thought THAT was bad, look at these Blisters! April 8, 2013 @ 3:15pm
Posted by RICHARDRICHARDSON LOCKED BY ADMIN 4 replies
....
PUBLIC SERVICE ANNOUNCEMENT: Seeliasis Exposure April 8, 2013 @ 10:12am
Posted by CASEYHOGG LOCKED BY ADMIN 19 replies
....
Free Pasckis in Conference Room D-1 April 8, 2013 @ 8:55am
Posted by OSKARCHOMICKI 2 replies
....
Does anyone know where Judy Yarbor left the extra keys to the roof? April 5, 2013 @ 3:44pm
Posted by AMYSMITH 5 replies
....
Despicable You Minion Blimp, Outside RIGHT Now! April 5, 2013 @ 3:37pm
Posted by AMYSMITH 12 replies
....
Exhibit 1
29










PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:12am
It has come to my attention that our office has literally been exposed to a highly contagious and horrible disease:
Seelialosis. For those of you who may not know, Seelialosis causes large sores on the legs and arms, which weep
copious amounts of pus, Once even the smallest amount of pus has touched the surface, the virus can contaminate
the entire area for up to a week. This is literally the most disgusting and loathsome disease you will ever see.
Further symptoms include nausea, vomiting, diarrhea, scalp zits, fuzzy tongue, loss of smell, and even vanishing
fingerprints (if the sores reach your far extremities). My skin just crawls thinking about it, And who do we have to
thank for this exposure? Why the only person who traveled to South America, literally the last outpost of this
loathsome disease, within the past month: Campbell Colquitt!
Posted by: CASEYHOGG
RE: RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:17am
Colquitt looked really bad, last I saw. Just to be safe, Im steering clear. Can you imagine working
for someone that brought back something as awful as this!?
Posted by: JASPERHILTON
RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:15am
Ewww that sounds disgusting. Are you sure Campbell has this?
Posted by: MARYANNSKIPPER
RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:17am
Dude, that stuffs no joke. I saw Campbell the other day, wow, did Campbell look rough. Time for me to
disinfect, well, everything. Does anyone have an industrial strength steam cleaner!?
Posted by: JOHNNYBGOODE
RE: RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:19am
ColquittS arms were all scaly, and I heard Colquitt was in the bathroom for a week ago. Just like
Colquitt to bring back a deadly virus as a souvenir
Posted by: ICHABODCRANE
RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:18am
Remind me to avoid Colquitt like the plague!!
Posted by: WALTERHIGGINS
RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:25am
I see what you did there
Posted by: JOSHUATREE
RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 10:30am
No, but seriously, I think we all need to stay far far away from Campbell.
Posted by: SALLYHUMBUG
Exhibit 2-1
30
RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:01am
Check out how gross this is:
Posted by: ICHABODRANE
RE: RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:04am
See this one?!
Posted by: IVANSCRATCH
RE:RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:13 am
Can we stop with the pictures?!
Posted by: SALLYBRAGIN
Exhibit 2-2
31
B
RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:01am
Dont forget the scalp zits!
Posted by: RUSSELLSTOPHERS
RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:12am
Dont forget the scalp zits!
Posted by: RUSSELLSTOPHERS
RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:23am
Or Vanishing Fingertips!
Posted by: DAVIDHARLEY
RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:31 am
I am organizing a disinfecting party ASAP. Let me know if youre interested in helping!!!! (And you should be)
Posted by: STERLINGHOBBY
RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:36 am
You know, Campbell should be punished for exposing all of us. Has anyone called the CDC?
Posted by: QUINNROJO
Exhibit 2-3
32
RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:39 am
Can you imagine working for Campbell after this!?
Posted by: ROBERTKAGNY
RE:RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:43 am
Working for!? Try: speaking to, standing near.
Posted by: AUDREYBURNHEP
RE:RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:47 am
Colquitt should be locked out of the office, and not allowed to return. EVER. Oh, Ive got the
heebee geebees so bad. Im going home and taking a shower.
Posted by: GRIFFINROBERT
RE:RE:RE:RE: PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:52 am
Agreed! Campbell should be fired
Posted by: AUDREYBURNHEP
PUBLIC SERVICE ANNOUNCEMENT: Seelialosis Exposure April 8, 2013 @ 11:55 am
THIS THREAD HAD BEEN LOCKED BY ADMINISTRATION AT THE REQUEST OF HUMAN RESOURCES
Posted by: ADMINISTRATOR
Exhibit 2-4
33
Floor 27 29,014 r.s.f.
September 27, 2010 | 2010 Gensler. JMC Test Fits
227 W. Monroe | 27th Floor
Test Fit Summary:
RSF: 29,014 sf
USF: 23,310 sf
1,810 sf Support
(1) Executive Oce
(10) 210 sf Private Oces
(14) 140 sf Private Oces
(92) 6x8 workstations
(117) seats total
Conference:
(1) Boardroom- 20 seats
(3) Conference- 8 seats
(1) Conference- 6 seats
(5) Conference/Team- 4 seats
(70) seats total
Reception
Conf Pantry
Boardroom
20 seats
8 seats 8 seats
6 seats
8 seats
Employee
Lounge
IT Support
Private Oce
220 + sf
Private Oce
140 sf
Conference
HOPco Corporate Offices - Building A, 2d Floor space plan
M
e
n
W
o
m
e
n
Yarbro
Hogg
Colquitt Hobby
Shivers
Exhibit 4
34
Exhibit 4
35
Annual Review of Sterling Hobby
Areas of Evaluation Score
(1 lowest, 10 highest)
Technical Expertise 7
Sterling has a gift for finding solutions to unsolvable problems. Sterling thinks outside the box, and
frequently arises at elegant and simple solutions to the most complex problemsquite an asset to our
team. Occasionally Sterlings solution, while brilliant, are out-of-scope and an incompatible with
company vision. I would encourage Sterling to develop a better understanding of all of HopCos
product offerings, and company vision/strategy in advance of quality control issues to help link together
our products and become more efficient in our problem-solving process.
Project Management 5
Sterling needs to focus on time management. While yet to miss a deadline, Sterling spends much time
dancing to decisions or using movement-based interpretations of mathematical equations to explain
potential solutions. Often times, these methods of communication are ineffective, and delay productive
brainstorming. However, Sterlings sharp mind will often deliver remarkable resolutions just within the
appropriate timeframe. I would encourage Sterling to work on time management and effective
communication skills.
Personnel Management 6
Sterling gets along well with our quality control team. While Sterling has not taken a leadership
position in the team, I would like Sterling to consider leading QC subgroups, especially as is one of the
best at finding work-arounds and solutions to the most complex problems. I would encourage Sterling to
take more of a leadership role as time management and effective communication skills develop. We all
have a lot to learn from Sterling.
Quality Assurance 8
Sterling finds problems and solutions before most of us even turn the product on. Sterlings attention to
detail is unmatched and is an invaluable member of our team
Total Score 26
Judy Yarbro Sterling Hobby
Evaluator Signature Reviewee Signature
Exhibit 5-1
36
Annual Review of Casey Hogg
Areas of Evaluation Score
(1 lowest, 10 highest)
Technical Expertise 7
Casey Hogg is one of our best Quality Control team members. Hogg, as expected, is very adept at
finding workable solutions in a time-efficient and collaborative manner. While Hoggs technical
background is sufficient, I would encourage Hogg to attend a few more industry conferences and
continuing education classes to keep abreast of the rapidly changing electronics world, especially as
given Hoggs goals regarding career advancement.
Project Management 8
Hogg truly shines with regards to project and time management. Hogg communicates well with
colleagues at all levels, articulating each persons role and responsibility in any given project. Hogg
appropriately supervises teammates to ensure freedom and flexibility to perform the task at hand, but
also to move the project alone in a time-efficient manner. Hogg knows how to get the best efforts out
of each team member.
Personnel Management 8
Hogg does very well at leadership and interpersonal relationships among the Quality Control team.
However, if Hogg wishes to advance in Quality Control at HopCo, I would encourage Hogg to expand his
working relationship with other colleagues, and not just revisit the same favorites. If Hogg wishes to
rise to management levels, Hogg should demonstrate an ability to work well with everyone.
Quality Assurance 7
Hogg is very attentive to detail, and with team members, produces excellent results. However, I would
highly encourage Hogg to become a technical lead, if Hogg desires to move up in HopCo management.
Total Score 30
Judy Yarbro Casey Hogg
Evaluator Signature Reviewee Signature
Exhibit 5-2
37
Annual Review of Campbell Colquitt
Areas of Evaluation Score
(1 lowest, 10 highest)
Technical Expertise 9
Campbell Colquitt is my right hand in the Quality Control department. Colquitt excels at finding
problems and workable solutions in a budget-friendly and time-efficient manner. Colquitts intuition
and keen eye find technically-superior solutions for every problem assigned.
Project Management 8
Colquitt does a remarkable job with Project management, always coming in on-time and under budget.
Colquitts team works efficiently to provide not only solutions, but suggestions for product designers to
reduce QC issues in the future
Personnel Management 7
Colquitt is very much a one-person solution strategyI would strongly encourage Colquitt to delegate
work to other team members, and focus on finding team based solutions. While Colquitt is well-liked
and friendly with everyone in the Quality Control department, Colquitt would benefit from becoming
more managerial and less worker-bee if Colquitt desires to advance the corporate ladder.
Quality Assurance 10
Colquitt is beyond technically proficient, and has no blemishes on the resolutions record. Keep up the
good work!
Total Score 34
Judy Yarbro Campbell Colquitt
Evaluator Signature Reviewee Signature
Exhibit 5-3
38
0
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Exhibit 6
39



T E A M R O S T E R
2014

Team roster forms are to be duplicated and completed by each team prior to each round and presented to
the presiding judge, other judges and opposing counsel before the round begins.
(Minimum 4 per trial.)

TEAM LETTER: __________


ROUND (circle one): I II III IV V VI VII

Students listed on this roster represent the (circle one): PLAINTIFF/PROSECUTION DEFENSE

NAMES OF ATTORNEYS: TASKS: NAMES OF WITNESSES EXAMINED:

1)_____________________________ Opening/Dir/C-X Direct:_____________________________
(Students Name) (Witness)
Cross:_____________________________
(Witness)

2)_____________________________ Closing/Dir/C-X Direct:_____________________________
(Students Name) (Witness)
Cross:_____________________________
(Witness)

3)_____________________________ Dir/C-X Direct:_____________________________
(Students Name) (Witness)
Cross:_____________________________
(Witness)

NAMES OF WITNESSES: P ROLES: D ROLES:
(# the order of appearance) (# the order of appearance)

4)_____________________________ Campbell Colquitt #___ Casey Hogg #___

5)_____________________________ Dr. Z. Sayers Stockdale #___ Burnet Allred #___

6)___________________________ ___ Sterling Hobby #___ Fergie Shivers #___

7)_____________________________ Timekeeper (may not communicate with team)
---------------------------------------------------------------------------------------------------------------------------------------------------
TEAM MEMBERS - NOT PARTICIPATING IN THIS ROUND:

8)_____________________________

9)_____________________________

10)____________________________

NOTE: Team members not participating must sit behind the bar and may not communicate with participating team
members during round.
40