Appendix — Madigan v. Nabisco Brands, Inc./RJ Reynolds Co.
Supreme Court brief2003
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Supremes Gourt, U8.
FILED
02 1562 FEB 18 2003
N
Sag
IN THE ,
Supreme Court of the Anited States
MARGARET A. MADIGAN,
Petitioner, pro se,
Fi.
NABISCO BRANDS, INC./RJ REYNOLDS
COMPANY, INC.,
Respondent.
On Petition For Writ Of Certiorari
To The United States Court of Appeals for The Sixth.
Circuit
PETITION FOR WRIT OF CERTIORARI
Margaret A. Madigan,
Petitioner, pro se
295 Westview Ave.
Wadsworth, Ohio 44281
(330)-336-6987
APPENDIX D (EXHIBITS) \
SNOILISOdIG
S. WANOLLILAd
et oe & Be
QUESTIONS FOR DEPOSITION
1) Did Peggy Madigan park daily in designated handicap parking space?
Ylot dure :
2) Was that space visible from plant manager, Mark Perkins office?
3) Did you ever complain of respiratory problems incurred on job at RJR Nabisco ~ Seville, Ohio Plant
to RJR Nabisco Management cither directly or through union or any other representative of you? If
yes, please elaborate. Ulo.
4) Did you ever witness Peggy Madigan being exposed to excessive heat on her job at RJR Nabisco
Seville, Ohio Plant? Yaa)
5) Was Peggy Madigan’s desk located beside a sliding glass window, which was opened frequently to
access the plant in order to communicate with other employees or truck drivers?
Yow)
6) Do you recall the temperature in the plant ever reaching an excessive temperature?
“ted butt! 90 gt Lemon’
7) Were you ever exposed to excessive heat on your job at RJR Nabisco, Seville, Ohio Plant?
5 al , dete Play bul
pau LALEKS ‘
8) Were you asked to sign RJR Nabisco’s Separation Agreement? If 0, did it include the following #14
on attached page? (Let court record indicate that exhibit #9, page 4 of 5, being presented to witness
and is agreement to which witness is acknowleging in reference to this question. )
po
9) Have you ever witnessed Peggy Madigan’s work being praised? If yes, who praised work
Ye. Alweye aokung fod Bee
no s/mattrer:
= iy: If yes, did you know while she was still
employed with RJR Nabisco?
tins from) Ae sen itp, preuestil) ee
ofp’ (btating- Me Aaclk YS.
nt cei Nabisco? If yes, please
state illness. Ty.
12) Were you directly or indirectly aware that Peggy Madigan had made request to management of RJR
Nabisco for “...Better air Ventilation?” aa
13) Were you aware of any ventilation problems or issues at RJR Nabisco's Seville Plant?
\ aad
14) Were you aware of Peggy Madigan’s assisting in training of the new production planner?
15) Did you witness Peggy Madigan being subjected to duress by any member of RJR Nabisco’s
2
Management? If yes, please elaborate. : Abuey) beng
16) Did any member of RJR Nabisco’s management subject you to duress? If yes, please elaborate. :
pee IS i eaeh brivis deveiinettiis
with ventilation within Seville, Oiio Ptant? ee Alden)
uw Mure polort Yo wre
To we retere) hin Yto arcu-
Parme lust (product)
18) Do you or anyone else of whom you are aware who was employed at Seville Ohio RJR Nabisco Plant
have multiple Sclerosis? If yes, please identify individual afflicted.
jabs Giligr Cipla Korg
19) Did you or amyone else of whom you are aware who was employed at Seville, Ohio Plant feel
Cjew: f hn J dedet Lega ance Linke
tae “AL2
20) Are you aware of iocation of any existing or previously existing RJR Nabisco facilities, which have
and or #ze currently handling processing and/or production of any aspartame materials and/or
products? If yes, please list plant and location.
ary eas ova Limes but rad
ohh:
21) Are you aware of any OSHA investigations, which took place, while you were employed at RJR
Nabisco's Seville, Ohio piant? If yes, please elaborate
Ap. (KSeacds -_ rrr plant adsttse 2
Y(abeed Leta) pel) lull
Afar a 90's:
22) Were you or anyone of whom you are aware, who was employed at RJR Nabisco's Seville, Ohio plant
“Encouraged” to retire or resign? If yes, what was age of this individual?
\Y wees 53, pthircw MhMOAL 4fe Lett 7
herve Msc SS,
24) Were you or was anyone of whom you are aware diagnosed with any ailment while employed at RJR
Nabisco? If yes, please claborate. rary
drrken, feat pitechi), iabe/e) , Lance.
25) Are you aware of any former employee or coworker of RIR Nabisco who died during or since their
cpp wi IR Nest ve po ce ne) gna |
yo Laney Lenna Lnaele” whe "
pes 2 TE nee Brna- laud
his or her life.
Constance J. Bihari
4865 W. West Salem Road
Burbank, Ohio 44214
wine Goalies pac %-AO-2/
Notary Public: pe om naw ae dO ;
ll
QUESTIONS FOR DEPOSITION
1) Did Peggy Madigan park daily in designated handicap parking space” yo
2) Was that space visible from plant manager, Mark Perkins office? ad
3) Did you ever complain of respiratory problems incurred on job st RJR Nabisco ~ Seville, Ohio Plant
w RR Nabaco Management ite ctor through sion ox my oer ANS SEY If
yes, please elaborate. 42H, Cimphared Jo ing Goss at fla fee, es
Ault OF petsswe AMAL tr Qnla —— i a
pf hte due wise Aluple amibing. Tes a
QWta wfirt fa 9¢ tat ashe-
4) Did you ever witness Peggy Madigan being exposed to excessive heat on her job at RJR Nabwco
Seville, Ohio Plant? Gf”
5) Was Peggy Madigan’s desk located beside a sliding glass window, which was opened frequently to
access the plant in order to communicate with other employees or truck drivers? yo
6) Do you recall the temperature in the plant ever reaching an excessive temperature? am
7) Were you ever exposed to excessive heat on your job at RIR Nabisco, Seville, Ohio Plant?
Mo , had 74 0-7 aaa Pct Soe
FOP TER TS PP. OT ME ns Newt e ee SUEY OF RET « . OLE SOREN SINE NP Depa ANTE a:
8) Were you asked to sign RJR Nabieco's Separation Agreement? If so, did it inchude the following #14
on attached page? (Let court record indicate that exhibit #9, page 4 of 5, being presented to witness
and is agreement to which witness is acknowleging in reference to this question.)
9) Have you ever witnessed Peggy Madigan’s work being praised? If yea, who praised work
Ye Bil Knute
10) Were you aware that Peggy Madigan has multiple Sclerosis? If yes, did you know while she was still
employed with RIR Nabisco? yew, ? td freer ohile Ke wae
tnflogd at ‘atc
11) Do you have any health ailments that were diagnosed while employed at RJR Nabisco? If yes, please
state ilincss. 770
12) Were you directly or indirectly aware thst Peggy Madigan had made request to management of RR
Nabisco for “...Better air Ventilation?” ye drectly Qe
13) Were you aware of any ventilation problems or issues at RJR Nabssco’s Seville Plant?
pe, on te ha
Cantu
14) Did you witness Peggy Madigan being subjected to duress by any member of RJR Nabssco's
aan "yor Ton hilt, Nor, Elor. Voll ba,
ly gee lp coe Pg er, yor
Piggys pr He jrt- Aut >
Katt Lith
a ae ee
ee ain Wine ane. tone fo if yes,
Nuk fens , Oiung awe
Vab As, @re .
SK Ye: OI, mip aig w felt badipred! Lao
Veo yas arty, wes my member of IR Nabiac’ management awa of ay problems & SA
ere aie a If yes, please claborate.
Hat Tn Ault woe Maple Wit
Ue Vtir4: Satior pJS ey Or+9- WIth AR MNG?.
M Vabts
19) Are you aware of location of any existing or previously existing RJR Nabisco facilities, which have
and or are currently handling processing and/or production of any aspartame materials and/or
products? If yes, please list plant and location.
Mo, pup Lute. plant v0 Py Kipewleage
20) Are you aware of any OSHA investigations, which took place, while you were employed st RR
Nabisco’s Seville, Ohio plant? If yea, please elaboratc.
V0 oT gua .
21) Were you or anyone of whom you are aware, who was employed at RJR Nabisco's Seville, Ohio plant
“Encouraged” to retire or resign? if yes, what was age of this individual?
ype, Peiyy Madigan - Age 47
ye, ripe « a5t 40
:
22) Did you ever complain of skin irritations, which you or your doctor attributed to exposure '
aspartame dust, which occurred while employed at RJR Nabisco’s Seville, Ohio plant? If yes, please
elaborate. 141 a
23) Were you or was anyone of whom you are aware diagnosed with any ailment while employed st RJR
Nabisco? If yes, please elaborate. yy lor 0 ,
24) Are you aware of any former employee or coworker af RJR Nabisco who died during or since thew
employment with RJR Nabisco? If yea, please state name of individual & affliction, which claimed his or
Neri Yt, boib--Lalletin Atart prblena «
25) egy align ener en ee nn ee ae
token. I fis horde Valitse Stage ontrtar
Lo He Wee, fee 1 Wada sitar
worked.
I have answered this foregoing to the best of knowledge.
Jean Boling
$310 Maple Crest
pue_ 9/24/o/
QUESTIONS FOR DEPOSITION
1) Did Peggy Madigan park daily in designated handicap parking space?
NOT SURE
2) Was that space visible from plant manager, Mark Perkins office?
NOT suR&
3) Did you ever complain of respiratory problems incurred on job at RJR Nabisco - Seville, Ohio Plant
. to RJR Nabisco Management either directly or through union or any other representative of you? If
yes, please elaborate. YES, Once WHE A LAB PERSow AUT A
CHEMICAL Two THE CombAertoR And THE BbusT corbewe
Bie ot onto THE Nocr WHITeh TWAS wWoRKez6E. atoTrFrtds
SuPeniasor C BoB BAKERS) Awh WAS SET TO THE conbaat dAocra.
Foht TESTS.
4) Did you ever witness Peggy Madigan being exposed to excessive heat on her job at RJR Nabisco
Seville, Ohio Plant? “YES
5) Was Peggy Madigan’s desk located beside a sliding glass window, which was opened frequently to
access the plant in order to communicate with other employees or truck drivers?
YES
6) Do you recall the temperature in the plant cver reaching an excessive temperature?
YES
7) Were you ever exposed to excessive heat on your job at RJR Nabisco, Seville, Ohio Plant?
YES
8) Were you asked to sign RJR Nabisco’s Separation Agreement? If so, did it include the following #14
on attached page? (Let court record indicate that exhibit #9, page 4 of 5, being presented to witness
and is agreement to which witness is acknowleging in reference to this question.)
YES. I RELETvE So.
9) Have you ever witnessed Peggy Madigan’s work being praised? If yes, who praised work
4¥ES, BK HER Bosses, BoB BXERS AND SEVERAL OTHERS |
10) Were you aware that Peggy Madigan has multiple Sclerosis? If yes, did you know while she was still
employed with RJR Nabisco? + whs Awang THAT SHE WAS HAvLTHG Sov€
HEALTH, PROBLEMS, BUT WAST SURE WHAT WAS THE PRORLEN.
11) Do you have any health ailments that were diagnosed while employed at RJR Nabisco? If yes, please
tate iliness. 4ES, HEADACHES AWA Avy¥TBTY Arew Bi EMS ,
ASAARTAME WAS STONED ABOVE MX OFFICE Onc ABOUT
10’ Fon A HEATER THAT MEATER THE wARE MOUSE Dey THE
WR yt ER
12) Were you directly or indirectly aware that Peggy Madigan had made request to management of RJR
Nabisco for “...Better ir Ventilation™ ‘ES.
13) Were you aware of any ventilation problems or issues at RJR Nabisco’s Seville Plant?
YES.
14) Were you aware of Peggy Madigan’s assisting in training of the new production planner?
WES
15) Did you witness Peggy Madigan being subjected to duress by any member of RJR Nabisco's
a
A oe
ee AM SELF, E PLATS Down STIG ,
THERS TO cover. THOSE THAT wEReE
please elaborate
6 huRTwG TH
member of RJR Nabisco’s management subject you to duress? If yes, please elaborate.
van any member of BIR Nsbaco's management swe Of a5 Problems SS
Seville, Ohio Plant? If yes, please elaborate.
wiwTEht wHev EvVERTHING ut$ CLOoEA UP, THE
causes A vAcuEnN"” tw THE
ofe To THE
brat OF NO FRESH
17)To your knowledge,
with ventilation within
YES, IN THE
Dust COLtcTons tv THE Prat
wpu CouULsA WwiTtTrEss THIS WHEV
ouTsrac. wAD SEVERAL PeoPl— t~ sum
ATrAwd TIrREd wESs.
ExrTwe aw 4 Do
Ppmwe com
se of wham you are aware wo wan empoyed a Seville Ohio RIR NaBHSD FT
have multiple Sclerosis? Uf yes, please identify individual afflicted
NOT THAT rwAs Aw ARE OF.
18) Do you or anyone ¢
c, Omo Plant fee!
cement? if yes, please elaborate and identify individual
raw o THERS Qube. "7 APPEAL
ermucnr screw tT
senza your nyenn cn cons You 0 or SIT OT
pressured imo signing separation 28°
wes, mM SELF An 2 BL. seve
To HAVE AY of Tio. SEEMED To BE THAT WE
of— wt wourkw'7 Re cEIre Aw THIVG .
“ ee Pee
20) Are you aware of location of any existing OF previously existing RJR Nabisco facilities, which have
sa or are curently handling processing and/or proguction of SN aspartame materias 22025
products? If yes, please list plant and location. Yes, ALL THE ALPANTAME Awd
OTHER ta GREATENTS WERE SET TO uk tae THAT TOOK oveR
ouh. PloebuctTsza.
21) Are you aware of any OSHA investigations, which took place, while you were employed at RJR
Nabisco’s Seville, Ohio plant? If yes, picase elaborate.
NO.
22) Were you or amyone of whom you are aware, who was employed at RJR Nabiaco’s Seville, Ohio plant
“Encouraged” to retire or resign? If yes, what was age of this individual?
THERE WERE SEVERAL PEpALE SulinG tHe “hoon Str”
THAT WERE “LET Go", tecitunawe “4 BOSS Rok B4UERS. NOT
Rea SURE OF HIS of OTHERS AGES.
PO a) ON Ne Om ODER A mn
NCE Rg ARN CL NIE Et, ANE
23)Did you ever complain of skin iritations, which you or your doctor sttribuied to exposare to
aspartame dust, which occurred while employed at RJR Nabisco’s Seville, Ohio plant? If yes, please
elaborate. NO
14) Were you or was anyone of whom you are amare diagnosed with any ailment while employed st FUR
Nabisco? If yes, please elaborate. YES, CHUCK WwAGCARS' Hand AtwAXS
RRrore out Avb cRACKEA WHILE wohrtearse WLTH Acsbarqrame.
PRodULrTSs .
25) Are you aware of any former employee or coworker of FUR Nabiaco who died daring or sinc s Se
employment with RJR Nabisco? If yes, please state name of individual & affliction, which claimed
his or her life. THERE HAVE BEE SEVERAL TN GUDIN GS CHUCK whta
THAT HALE O TEA. NOT suRé of FIMAt RrASrOSTS,, oR HAMES
OF OTHERS.
Ihave answered this foregoing to the best of knowledge.
George Dafo
311 East Walms Street
Wadsworth, Ohio 44281
ay pears?) a Date %- 25-0]
Svgweel f Presence Yh: s 25 day of Sepr 200/
on
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THE CLEVELAND Ci 6 WN
FOUNDA = 5 w
of
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Ran 9! 216 oS
—E od kenket f-
it can answer any further questions please fee! free to contact my office.
WMWAa fal Jirng Hower
Notary Public-State of Ohso
My Commission Expires Feb. 10, 2005
Enclosure
YS00 Fuctd Avenue Cleveland Ot 441
A Facttres toe Mirarreree Seve meses Tarsswere otto Rese sorts
eee
THE CLEVELAND CLINIC FOUNDATION
9500
Euclid Avenue Cleveland. Onio 44195-5226
A National Referral Center An intemational Health Resource
1390
September 16, 1992
Mrs. Margaret Madigan
295 Westview
Wadsworth, O08 44281
cc#: 1-805-531-7
Dear Mrs. Madigan:
meeting you on July 21, 1992- You were
Departzent at the Cleveland
Clinic. Let me summarize your complaints.
About 10 days prior to ot visit you noticed left upper
extremity weakness. You also
ing an indian pow wow, you began
dropping things when using your left >
days, this got worse to the point that the left hand was quite
was loss, cranial nerve symptoms,
useless. There no sensory
or problems with bladder or bowel. The other
unaffected. There was no progression of your
ied pain and tingling-
In 1988, you were seen by Dr. Sweeney at the Cleveland Clinic
for a history of rightsided incoordination and slurred speech and
blurred vision. An MRI at that time showed right middle cerebellar
improved over six weeks. Later,
peduncle ®lesion". These sysptoms
ou had & transient episode of ®— shade being pulled in front of
Y
your right eye".
Your past history was significant for fibromyalgia in 1985,
urinary tract infection and being overweight.
physical examination was unremarkable. On the
ination there was & left arm adrift. Pronation and
the wrist dorsiflexion was 3+/5,
we did a number of laboratory tests. A complete blood count
and serum chenistry profile were normal. Sedimentation rate was 10
COPY PHART COM:
Mrs. Margaret Madigan
cc#: 1-805-531-7
Page 2
wa /hour. Blood lead levels were normal. A visual evoked potential
was within normal limits. Serums Bi2 level was 240 pog/ml (normal) .
showed an increased CSF IgG of 15.1 mg/dl, IgG/albumin ratio of
0.60, IgG synthesis rate of 55.2 mg/day and an IgG index of 1.77.
All these clearly abnormal values. A serum anticardiolipin
antibody was obtained and this showed moderately elevated IgG but
An MRI of the head showed multiple foci of abnormal si 1 in
po white matter bilaterally, compatible with a denyel nating
lesion.
A surface echocardiogram was within normal limits.
A lipid profile showed a total cholesterol of 235 which is
poderately elevated and an LDL cholesterol of 161 which is high and
a HDL cholesterol of 36-
As I discussed with you, the overall picture seens to fit best
with a demyelinating illness such as multiple sclerosis. we
suggest the following: 1) avoid situations which could potentially
increase body temperature; 2) follow-up with us in six months.
Please call for an appointment approximately two months' prior to
the expected date of the appointment; 3) if you are interested in
looking at research protocols for multiple sclerosis, we could
indicated at this time; 5) consultation with & general physician
regarding panagenent of the moderately elevated cholesterol.
once again, it was a pleasure participating in your care.
Please do not hesitate to call us with any questions.
Y sincerely,
SkK/as
rec'd 9-17-92/tr- 9-18-92
COPY
Chart Note: Madigan, Margaret A (MR # 18055317) Encounter Date: 09/19/200
Office Visit Margaret A Madigan (4R@ 1806551
Patient Info Patient Name Sex DOB SSN
Madigan, Margaret A Femate OB8/i21949 261-86-40-
(18055317) at
Contact .
Information Date & Time Provider Department Encounter® Center
09/72/2001 4:00 PM Revere Kinkel Neur Metien Ctr 14967498 NEUR
Mae U Bidg
Allergies as of
09/19/2001 Agaot Noted Allerzy Reaction
NONE 07/31/2001 Not Noted
Date Verified: 07/31/2001
Reason for
Visit Reseon for Visit
FRrechack [82]
tC Visit Di :
MULTIPLE SCLEROSIS [340}
Follow-up and
Disposition Dispomiben
Retum visit in approximately
6 months, kinkeYnamey
Progress Not -3
REASON FOR VISIT: Report after MRI
PRINCIPLE NEUROLOGIC DIAGNOSIS: Definite MS
HISTORY OF ILLNESS:
Date of onset: 11/88
Date of diagnosis: 12/92
Disease course from Onset: Exacerbat ing/Remitting
Disease course last year: Exacerbat ing/Remitting
Medications for MS Used in the Past: none
Narrative Describing Problems :
FROM 7/31/01 VISIT RPK WROTE: Last seen 4 years ago. Relatively
stable until chis Spring. While driving in car experienced an ‘out
of body* experience. Felt dissociated. Episode lasted 30 minutes.
Since this time she reports more difficulty with comprehending
questions and queries, remembering things, and sceading.
Concerned about her ability to continue working
Now working a8 an eccountent for a new company. Let go from Nabisco
in 1997. There is @ law suit pending against nabisco for failure to
accomodate her disability.
Madigan, Mergaret A (MR # 16055317) Page 1 of 3
Chart Note. Madigan, Margaret A (MR # 18055317) Encounter Date: 08/19/2001
Never got CPAP since she had no insurance coverage.
TODAYS VISIT HISTORY: reports completing NP testing. reviewed Dr
Chelunes note. Relatively normal and not substantiating complaints.
No other new problems
Diagnostic Testing since last visit:
MRI BRAIN $/19/01 : No old films available to compare today. No
active lesions. Moderate T2 burden. No signficant atrophy
Domestic Violence: Have you been hit, kicked, punched, or otherwise
hurt by someone within the past year? no If so, by whom?
REVIEW OF SYSTEMS:
Review of systems including systemic, neurologic, ophthalmologic,
respiratory, gastrointestinal, dermatologic, and gynecologic were
all reviewed from the patient questionnaire and were negative with
the exception of those listed above in the narrative.
PHYSICAL EXAMINATION:
Mental Status: There are no deficits of cognition, language or
prosody on interview buc she scems easily baffled following
directions on examination. Formal NP testing was not performed
today.
Cranial Nerves:
Visual Acuity OD: 20/25 OS: 20/30 Corrected: yes
Optic Discs OD: NT OS : NT
CN III, IV. VI Pursuit and saccadic eye movement are normal
CN V-XII Normal
Motor Function:
Strength: Right Left
Deltoids 5 5
Wrist Extensors 5 5
Hand Intrinsics 5 5
Hip Plexors 5 5
Ankle Dorsiflexors 5 5
Spasticity:
RUE: None
LUE: None
RLE :None
LLE: None
Cerebellar: finger to nose testing was normal. Heel to shin testing
was normal.
Sensation: Normal to ell modalities.
Gait: Unstressed observation of gait was normal. The patient was
able to tandem walk 10 steps but wes hesitant. The petient did not
require assistance for safe ambulation.
DISABILITY SCORES:
EDSS (estimated): 1.5
Ambulation Time (25 feet): 7.0 secs.
Madigan, Margaret A (MA # 18055317) Page 2 of 3
Chart Note: Madigan, Margaret A (MR # 18055317)
Distance Walk: 500m
Assistance Required: independent
9-Hole Peg Test:
Encounter Date: 09/19/200
First Second
RUE NT NT
LUE NT NT
ASSESSMENT :
340 MULTIPLE SCLEROSIS
Note: Relatively stable by all criteria (exam, MRI and NP testing).
Embroiled in legal controversy with former employer which may have
increased stress and contributed to current cognitive complaints.
Plan:
1. Compere todays MRI to 1995 MRI and write letter
2. No disease modifying therapy for now
780.57 Sleep apnea
Mote: Persists and responsible for fatigue
Plan: Get CPAP when she can
Pollow-up: 6 months
R. Philip Kinkel. MD
Problem List Problem Noted Resolved
MULTIPLE SCLEROSIS[340] 9/19/2001 No
Madigan, Margaret A (MR # 18055317) Page 3 of 3
Otpy ie CAME 1 GPL ene ORY /G2
Tras Lette. Qrbmettig.! te B-
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Vow $ 4s my drama tatey (Motte
THE CLEVELAND CLINIC FOUNDATION —_
93500 Euchd Avenue — Cke-veland. Oluo 44195-3226
A National Referral Cconter AD titenwthowl thealth Resource
tieroshi Misano. MD
Neurokyt, Soo
216/444-5415 September 16, 1992
Mrs. Margaret Madigan
295 Westview
Wadsworth, OH 44281
CCF: 2-805-531-7
Dea. Mrs. Madigan:
It was a pleasure meeting you on July 21, 1992. You were
referred to us from the Primary Care Department at the Cleveland
Clinic. Let me summarize your complaints.
About 10 days prior to your visit you noticed left upper
extremity weakness. You also had mild tingling in the left hand,
lasting minutes. The next day during an indian pow wow, you began
dropping things when using your left hand. Over the next five
days, this got worse to the point that the left hand was quite
useless. There was no sensory loss, cranial nerve symptoms,
balance problems or problems with bladder or bowel. The other
three limbs were unaffected. There was no progression of your
symptoms. You denied pain and tingling.
In 1988, you were seen by Dr. Sweeney at the Cleveland Clinic
for a history of rightsided incoordination and slurred speech and
blurred vision. An MRI at that time showed right middle cerebellar
peduncle “lesion”. These symptoms improved over six weeks. Later,
you had a transient episode of “a shade being pulled in front of
your right eye”.
Your past history was significant for fibromyalgia in 1985,
urinary tract infection and being overweight.
The general physical examination was unremarkable. On the
neurological examination there was a left arm drift. Pronation and
supination were mildly weak and the wrist dorsiflexion was 3+/5,
wrist volar flexion was 2+/5, finger extensors 1/5, hand intrinsic
0/5. Muscle stretch reflexes were slightly diminished in the left
biceps. The remainder were normal. The remainder of the neurolog-
ic examination was within normal limits.
We did a number of laboratory tests. A complete blood count
and serum chemistry profile were normal. Sedimentation rat
Mrs. Margaret Madigan
CcC#: 1-805-531-7
Page 2
mn/hour. Blood lead levels were normal. A visual evoked potential
was within normal limits. Serum B12 level was 240 mcg/ml (normal).
Cerebral spinal fluid (spinal tap) evaluation showed an RBC count
of 3/ul, WBC count of 18/ul and a differential count was 93%
lymphocytes and 3% monocytes. The CSF glucose was 63 against a
blood glucose of 89. A Tourtellotte formula was obtained and this
showed an increased CSF IgG of 15.1 mg/dl, IgG/albumin ratio of
0.60, IgG synthesis rate of 55.2 mg/day and an IgG index of 1.77.
All these clearly abnormal values. A serum anticardiolipin
antibody was obtained and this showed moderately elevated IgG but
normal IgM and IgA.
An MRI of the head showed multiple foci of abnormal signal in
the white matter bilaterally, compatible with a demyelinating
lesion.
A surface echocardiogram was within normal limits.
A lipid profile showed a total cholesterol of 235 which is
moderately elevated and an LDL cholesterol of 161 which is high and
a HDL cholesterol of 36.
As I discussed with you,
the overall picture seems to fit best
with a demyelinating ill —_ : i :
situations which could potentia
otrow-up is in six months.
: : an apne approximately two months' prior to
the expected date of the appointment; 3) if you are interested in
looking at research protocols for multiple sclerosis, we could
refer you to the Mellen Center; 4) no specific intervention is
indicated at this time; 5) consultation with a general physician
regarding management of the moderately elevated cholesterol.
Once again, it was a pleasure participating in your c=re.
Please do not hesitate to call us with any questions.
Yours sincerely,
)
Suresh Kumar,
Hiroshi Mitsumoto, M.D.
SK/as
rec'd 9-17-92/tr. 9-18-92
a aa 6
" Ast PRESCRIBED
NOT VALIO FOR
RUGS | +43 /9\—
12/21/96
) [have made the following observation of Peg’s condition:
xacerbation of her multiple sclerosis as a direct result of undue stress being subjected to at
ork by hostile work environment which is being perpetuated by management. For example,
counseling notes” which were presented to her on 12/20/96 by Tim Ault and Maryellen Valaitis
outside of a structured review - citing alleged incidents from various coworkers which these
dividuals neither presented to Peg ncr resulted in confrontation. Thus, she was unaware of
Peg is and has been experiencing physical symptoms which may lead to a more serious
ese alleged perceptions of interactions.
) Nabisco was presented with standards which were to be immediately met and sustained:
| -Several years ago when Peg was diagnosed with MS- i.e. the necessity for temperature
ontrol of work environment and avoidance of undue stress.
) These standards are important because of the following impact on Peg’s life:
If the aforementioned conditions are not met and respected then Peg's health may be
ffected on a temporary or even permanent basis.
) Lam informing Nabisco of the following with respect to these aforementioned issues:
Peg has organized her office space for maximum efficiency of job performance based on
novations she has created over her “years” of successful service to Nabisco.
) These issues are very serious:
As her neat of kin, | will see that her legal rights are protected, even if Peg lacks stamina to
fo so.
e: Please see attached copy of Counseling Notes
Lynn Madigan :
rer Souther wae
Maryetien Valaitis
Sandi VonDraltein
COUNSELING NOTES
1. I have made the following observation of Peggy’s conduct/performance:
Peggy you have-“blocked” the access window with binders. It prevents drivers and
employees from having easy and direct access to vou to conduct business.
Peggy you have built an office area around you that separates you from
the rest of the team and makes it difficult for open communications
Your comment to Cathy Roy on Wedriesday, December 4th that you “deserve
lunch because you do everything” is an example of placing yourself outside
the team.
©: I have informed Pegey of the following rds that are to be
immediately met and sustained:
Do not block the access window between the warehouse and your office
area.
Address Bob as well as employees, visitors, phone calls etc in & Courteous business
like manner.
Communicate with your team members inci i your manager on all appropriate
work related issues (i.e., warehouse issues, overtime). :
3. These standards are important because of the following impact on the
: work environment:
It is important that drivers have professional and easy access to you to
conduct business in a timely and efficient manner.
We work as a team within the warehouse and the Seville Plant. It is
critical that open two-way communication takes place.
hag Rika
pain Mand is Cle ie lk
portion. If you get the job done but have isolated others while doing so you have
not been truly successful as a team member.
4. I have informed Peggy of the following with respect to these performance issues
These issues will be reflected in the performance review. The review will either state that
the issues have been addressed or that improvement is still required.
these issues are not addressed adequately in the next 30 days, further disciplinary action will
be taken including being placed on a Plan of Corrective Action to formally address these
issues.
; P-oueeteeaee ‘
S
P 043 339 370
ou ae pre agg a
ao . oor tea
EECBES Bony eiie% VALAITIS tee —
pr GREENWICH ROAD Katt
SEVILLE OHIO 44273 —
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5180 Greenwich Road
Seville. Ohio 44273.95.%)
NABISCO (216) 769-2031
Fax: (216) 769-3053
January 10, 1997
Peggy Madigan
295 Westview
Wadsworth,OH 44281
Dear Peggy.
In response to Lynn Madigan’s letter of December 21, 1996.
2. Regarding standards presented to Nabisco.
Maryellen Valaitis has reviewed your personnel file and found no
accommodation from your physician.
request for a job
ee JOB ACCOMMODATION REQUEST FORM wean.
i S STATEMENT OF REVIEWING PHYSICIAN
U
The requesting employee is responsible for the completion of this form.
TO BE COMPLETED BY LOCAL MANAGEMENT
3 =
TO BE COMPLETED BY THE EMPLOYEE
— COMPONENT. SPL
— EFFECTIVE pare__ 3h
‘ieee apie ere ANCHO within Job summary) This Is not exhaustive ang
; oe ae
| , kewave POSITS OS chdeny Carmen)
;
PSE ONE IN EACH CATEGORY
SICAL ACTIVITY Not At Ag Occasionaily Frequently Cc
enna FOR DESCRIPTION) _ (O%) — (1% - 33%)
(34% - 66%)
Ss. i , ~
Ge {_ (67% - 100%)
PAGE |}
i
~~
~
. a a
, il
FULL REQUIREMENT FOR EACH ACTIVITY PER DAY)
DAY Megular atlendance is
erent HOUR | HouRs | Hours wours | Hours
IFUL Te L : 3 ‘ $ 6 7 8
Base ) 2 3 4a s é ; ve.
| MOTIONS 1 2 3 é © oO) 7 a
“ TECHNIGUES J 2 3 4 + Tom ; -
(nitiaf
PAGE 2
APPENDIX °A‘
PHYSICAL ACTIVITY DESCRIPTIONS
Walking: Moving about on foot to accomplish tasks. particularly for long distances.
Pushing: Using upper extremities to press against something with steady force in onder to
trwust forword. downward or outword.
Pyaing: Using upper extremities to exert force in onder to draw, drag, houl or objects
in o sustained motion. si
Fingering: Picking. pinching. typing or otherwise working. primarily with fingers rather
with the whole hand or arm as in handling. oor
Expressing or exchanging ideas by meons of the spoken word, those octivities in
which Getoled or important spoken instructions must be conveyed fo other workers
occurctely. loudly. or quicidy.
Bending Assuming o Curved. crooked or angular form or direction.
Twisfing: Rotating or revolving: also. to tum as fo foce another way.
S@fing: To be oF remain in that posture in which the weight of the body rests upon the
Conrying: Moving an object from one ploce to onother.
GENERAL EDUCATION - REASONING ABILITY: te anaty to apply common
sense or logic to © problem solving situation. Describes the MINIMUM (not optimum) reasoning
ability for the odequate completion of the position.
| (Circle ONE)
Abilty to apply Common sense understanding to cary out simple one step or two step
instructions: to deal with standardized situations with occasional or no variables in or from
these situations encountered on the job.
Ability to apply common sense understanding to cary out detailed. invoived instructions:
to deci with problems involving several concrete variables in or from -stondardized
situctions. 3 é
Ability to apply principles of logical or scientific thinking to define probiems. collect dato.
establish facts. ond draw valid Conclusions: fo interpret an extensive variety of technical
inetructions in mathematical or other form. Deal with several abstroct ond concrete
variables.
GENERAL EDUCATION - MATHEMATICS ABILITY: me LevE. of abaty to
undestand mathematical concepts and apply them to problem solving situations. Describes the
MINIMUM (not optimum) math obilty for the successful completion of the position.
(Circle ONE)
Ability to perform mathematics is not required.
B. Ability to Odd ond subtroct two-digit numbers: to multiply and divide 10's and 100's by 2.
3. 4. 5: tO perform the four basic arithmetic operations with coins as part of o dollar: to
Perform operations with unis such as inch. foot, and yard: ounce ond pound (and thex
metic Courtempoarts).
3 Ability to odd. subtract. muttiply. ond divide of unis of measure: to perform the four
operations with fike or Common decimal functions: to compute ratio. rate. and percent:
to Grow and interpret bor graphs: to perfor arlthmetic operations involving all American
monetary unis.
PAGE 6
ENVIRONMENTAL REQUIREMENTS
PHYSICAL SURROUNDINGS AND HAZARDS: the Conditions the worker wil be
suDjeCt to In this position.
(Circle ALL that apply)
Conditions but not necessarfy from temperature
The worker is subject to Outside Environmental conditions: No effective protection from
weotner.
The worker Is subject to Inside Environmental conditions: Protection from weather
changes.
The worker is subject to Both Environmental conditions: Activities occur inside ond outside.
D. The worker is subject to Extreme Cold: Temperatures below 32 degrees for periods of more
than one hour.
The worker is subject to Extreme Heat: Temperatures above 100 degrees for periods of
more than one hour.
The worker is subject to Environmental Conditions: One or more of the following Conditions
thot affect the respiratory system or the sidn: Fumes. Odors. Gusts, mists. gases. or poor
ventiiation. -
The worker is subject to Oas: There is Gir and/or skin exposure to oils and other cutting
fluicis. ;
The worker is required to wear Respirator.
None: The worker is not substantioly exposed to adverse environmental conaiifions (such
Gs in typical office or odministrative work).
PAGE 9
INU TICE
This Job analyss profile in no way states or implies that these are the only tasks to be
performed by the employee occupying this position. He or she wil be required to follow
any other instructions Gnd to perform any other job related duties requested by his or her
Supervisor.
The foctors cited above represent minimum levels of knowledge. sidis, and/or abilities. To
perform this job successfully. Incumbent wil possess the abilities and aptitudes to
Al foctors ore subject to possible modification to reasonably occommodate Individuals
with Gisobiities.
Some requirements may exclude individuals who pose a direct threat or significant risk to
the health and sofety of themselves or other employees.
This document does not create on employment contract. implied or otherwise. other than
Gn “at wil employment reiationship.
PAGE 1
“ nal
(W NABISCO
DESCRIPTION/REQUISITION waane
TITLE Traffic Clerk
INCUMBENTS NAME _ Peggy Madigan
SPC LOCATION _ Seville, OM
EFFECTIVE DATE 1/5/37
TITLE _ Production Manager NAME _ Tim Ault
THE BROAD FUNCTION AND SCOPE OF THE POSITION:
4s Concmineniog @D elpeemets ces hovilie Meet «i> onde processing Geeo a Oietnien Proce aes gaperewort tor all
i Nanny weaceirdaes rdbecs mit ccoetdng erders we er ctheepengy Oxpariomend, nchecheleg oats sed Wennciilens 2t
iabtzins wecectity recenta for Grished goods laventory and reconciling physics’ Sabehed gnosks
THE PRINCIPAL CONTINUING RESPONSIBILITIES OF THE POSITION IN ORDER OF IMPORTANCE:
opty erdars from Oietribution Order Control, Confirm inventory avaltabdity, schedule shipments, prepare Bilis of
varity baad counts on ad outbound shipments
fwweks for Gnished, raw, und packaging materials. Maintain contact with tucking dispatchers of
Some Oo were acthecdetes ore todicrmsac:
meintaim shipment gata into inventory control PC to releve warehouse stock inventory, generate lot breakdorm
ane establish record for af shipreent history. ‘
Cao Ceroagh tao reapers sa reguened iy éesiribethen werchouse:, prepwadion am tadwece of Y Change
ww onteniited te compete room, and daly reconciliation of tushed tansachons agetnal reports subedtied to ALLALS.
arotniuled ourekeus log mato paiern salhe arn io ice locaton and producthen date of thaished sma pactcaging
proper sceck rotation.
we ectvedathe afl wileonlameces cheprrenws., Sechudieg MO shipmests, daily UPS ard >* Greight aNpmerts, and bectosp
em Sonim itcapeemntant
tmpemeeRs a heated wei actieely comnmuméicates degertmentad cow _. ~ih tecility mamagement.
- — : ee eee oa = PTET as dail a
Oe ee
saw =
NUMBER OF INCUMBENTS GRADE
TITLES OF DIRECT REPORTS
TOTAL EMPLOYEES indirect reports) —
DIRECTLY ACCOUNTABLE FOR : OTHER ITEMS (such as number of plants, countries, etc)
4 ES AT RES
HRC AE PEE LIOTTA EN EEL OTE IEE INNER
eggs a tras Biggs YEARS OF EXPERIENCE: 3
caflic managementiiststnuion. Clarice! and computer etfie.
(eg TRAVEL)
IGS depertty aeaae EF vewer tet WORD PROCESSING HORT HAND “OTHER
PROCESSING [x] sprcavsneer = [J omtacase = [_] orveer
ReScpEr Tyre Dey. | DATE | SALARYGRADE| Man 7) Mie ly
BX _V491): Wok _\yhh
REPLACEMENT APPROVED SY OATE ADOITIONAL APPROVAL OATE
DITIONS, PROVIDE SPECIFIC JUS TION IN TERMS OF VALUE ADDED, ANTICIPATED PAYBACK AND OTHER
THAT WILL ACCRUE TO THE COMPANY.
GATE | ADOTIONAL “SPRL ——~SC* OTE
|
|
Pe RE OS LT TNE TE. AEE ATE
BY HUMAN RESOURCES | DATE REQ NO. FRLLED OY{EMPLOVEE'S NAME)
vo ae
284 286
1 deposition open when we're done. If | have too, 1 Q. Okay. New, are some of these damages that
2 ll file a motion with the court stating you're 2 yer've written on this relief sought relating to
3 betmg 200-reapeasive and you might have te come 3 yi ar prior claims that seme types of chemicals in
4 beck here to answer those questions. 4 the werkplace were exacerbating your condition?
$ | eaderstand that you're representiag 5 A. Agaim, you know I have to say I'm not an
6 yourself in this case, but | need to know, to the 6 attorney. When | presented this — I'm
7 best of yeur receiiection now, what the answer to 7 proceeding pro se and I'm only attempting to
8 these questions are. If the court will award 8 protect my rights as an American citizen — an
9 that, I'm also going to make a motion for 9 American citizen who has the disability of
10 sanctions. Which means that, if awarded, you 10 wswhtiple sclerosis. So | can say that because
11 would have te pay beth ary fees to make the motion | |! now ! can repeat «. | can memorize it. So I'm
12 to compel aed you'd have te pay for the court 12 not reading it. But that is what | want to get
13° reperter to bring you beck bere te auswer these 13 across to you. That anything that I filed — | OR ~
14 questions. So I just want you te keep that ta 14 want to let you know thet I'm not an attorney. = (T) [TI L
15 mind as we continue. 15 Tl filing pro se. ~N -
16 A. I don't understand what you just said. 16 Q. I completely understand that. ome ie
17 Could you repest that? 17 A. Okay. nO yw
18 Q Sure. What I'll do at the end of this 18 Q. What I'm telling you ts you're being om = “>
19 deposition is prebebly file 2 motion with the 19 nee-respousive to questions that I'm asking — OY) o>
20 court. It ts going te be 2 motion to compe! you 20 If we have te get this motion te compel, tha Om a
2) to answer the questions that you have choses to 21 fine. But ] want to know, regardless of wx 7 7 u
22 read a pre-writtes statement. I'm also golag to 22 + yeu're am attorney or net, you submitted th a W
23 make a motion for sanctions because of what we're | 23 documents to the court. You should have ti A be
24 having to ge through becaure you're pot answering | 24 responsibility te know what they mean, reg ‘
25 the questions te the best of your ability right 2> of whether you're am attorney at tew. Ww
285
1 mow. 1 A. Il understand what they mean to me and
2 Now, if the coert awards the motion to 2 Q. Thea —
3 compel, what that means is we'll come back for 3 A. And because I'm proceeding pro se.
4 another deposition for vou to answer these 4 Q. I got that. What I want to know ts what
5 questions la which you've choses to read this 5 they mean te you.
6 statement for. Aad sanctions would mean, if 6 A. I'm protecting my rights as a disabled
7 awarded, that you would have te pay my attoracy's 7 American citizen. I'm protect — I'm attempting
8 fees and you woeld have to pay for the court 8 to protect my rights as a disabled American
9 reporter and everything that's invoived in having 9 citizen.
10 to take that next deposition. 10 Q. Ft regard that 2s non-responsive as well.
WW Defendant's Exhibe EE 11 You list damages bere. I want to know in
12 te the M.A. Madigan deposition 12 yeur mind, are these damages all reiated to your
13 was marked fer purposes ef 13. disability discrimination claim? 7
14 identification. ) 14 A. [maot an attorney. I'm just a pro se
1S BY MS. STOUFFER: 15 person — I as proceeding pro se.
16 Q. i'm bending you what's been marked as 16 Q. What de you believe these damages are for?
17 Defendant's Exhibk EE. Can you identify this as 17 You dea't need a legal license to tell me what
\8 the retief sewght thet you were referring te la 18 you intend fer these damages te cover.
i9 terms of what your damages are? 19 A. My relief sought.
20 A. Yes, tis. 20 Q. Nime months severance pay. What is that
21 Q And is thet what you stated you submitted to 21 ~perted of time?
22 beth Jim Kurek sad the ENE evaluator? 22 A. No comment.
23 A. To Jim Kurek at the ENE. 23 Q. Thatis—
24 Q. And then yoo seat k again? 24 A. I don't recall.
25 A. | served it to you again, yes. 25 Q. Thst’s not an appropriate answer.
AKRON COURT REPORTERS CANTON COURT REPORTERS CLEVELAND COURT REPORTERS
330-376-8100 330-452-2400 216-621-6969
308 310
1 cerrect procedure. Because you need to serve a | Exhibtt HH. Here's a copy fer you. First, can
2 metice wpon me as you were sending them out te 2 you identify this as a letter you sent to me
3 ket me know what officer the depositions were 3 dated August 2, 2001 in response to mry July 20
4 being taken before and whe the person is you sent | 4 letter?
5 them to se that I have a chance to serve that 5 A. I'msorry?
6 tmdivideal with cross questions. 6 Q. Cam you identify the first page of Exhibit
7 A. That was not my understanding. That was not 7 HH as a letter you sent to me regarding my
8 my understanding. I'm proceeding pro se. I'm 8 correspondence dated July 20, 20017
9 not an — it's not my understanding. 9 A. Yes.
10 Q. You might want to take a look at the Rules. 10 Q. And were all these attachments attached te
11 And if you need a copy of that Rule 31, I'd be 11 this better?
12 happy te previde that te yeu. 12 A. Yes.
13 We had talked about the injections that you 13 Q. And it emys that these attachments beip
14 said you were unable to afford. Are there any |4. ctartfy your respeeses and answers to Defendant's
15 ether types of treatment that you're alleging you 1S First Set of Discovery Requests. Is that
16 canmet afford because you ne leager have 16 correct?
17 imsurance with Nabisco? 17 A. Yes. For the record, here's where |
18 A. The C-pap machine — at this moment, | can't 18 determined those amounts. These are the
19 recall. The injections, the C-pap machine. | 19 attachments right here on this exhibit, number
20 don't recall any others. 20 HH. That's where | determined the amounts for
21 Q. Have you determined whether your current 21 the relief sought for you.
22 imsurance covers amy type ef treatment for 22 Q. For the henith insurance issue?
23 multiple scleresis? 23 A. Yes.
24 A. No, | have not determined that. 24 Q. Okay. We can take a look at these. Thank
25 Q. Se tt's possible it does. You're not sure? 25 yeu.
09 3
1 A. I don't know. 1 A. And also in the nursing care, that’s where |
2 Q. Have you ever previously filed an EEOC or 2 presented you with these figures.
3 OCRC charge against another empleyer? 3 Q. Okay. If you could turn to your page number
4 A. No. 4 1. At the top of the page it says interrogatory
S Q. Om the lest page of Exhibit CC, I have 5 mumber 5 and you have a list of lay witnesses,
6 listed three requests for admission. The first 6 their eame and address. Are these addresses
7 one is "Admit that Plaintiff was terminated 7 where they live or where they work?
8 because of her performance deficiencies.” 8 A. The last known residence, or thought to be.
9 A. Where are you now? 9 And | also indicated on here that | would provide
10 Q. Page 30, the very last page. Would you 10 you with additional information snd addresses, as
1! adenit or deny Request for Admission number 17 11 many of these people had moved. And | didn't
12 A. Why aren't you showing me the final answers 12 have — this was something that | had to work on.
13 that | sent to you? 13 But I will get all of that information to you.
14 Q. Oh, let me make sure if you answered those. 14 Q. Okay. Mest of these people | think we
1S A. These were the originals, and | sent you 15 discussed the last ttme we met. But could vou
16 other answers. 16 tell me whe Ress Deermaa is?
17 (Thereupon, Defendant's Exhibit HH 17 A. Ross Deerman is — was an employee at
18 to the M.A. Madigan deposition 18 Nabisco. He worked im the warehouse.
19 was marked for purposes of 19 Q. At the same time as you?
20 identification.) 20 A. Yes.
21 BY MS. STOUFFER: 21 Q. And when did he leave Nabisce?
22 Q. Right. And | think in your second answers 22 A. I don't recall.
23 you objected te all three without stating 2 23 Q. De yeu know approximately how old be is?
24 greund. 24 A. He's — he’s im his 60s to the best — maybe
25 I'm handing yeu what's bees marked a1 25 70s.
AKRON COURT REPORTERS CANTON COURT REPORTERS CLEVELAND COURT REPORTERS
330-376-8100 330-452-2400 216-621-6969
ny Sian? >
Margaret A. Madigan
295 Westview Ave.
Wadsworth, Ohio 44281
Direct Dial 330-335-8051
August 2, 2001
Ashley M. Stouffer, Esq.
Buckingham, Doolittle & Burroughs, LLP
50 Main Street
P.O. Box 1500
Akron, Ohio 44309-1500
Re: Madigan v. Nabisco Brands, Inc./RJ Reynolds, Inc.
| US. District Court Case No. 1:00CV02919
Dear Ms. Stouffer:
«have received and reviewed your letter dated July 20, 2001, stating areas of
concern to which I am i
help further clarify my responses and answers to Defendant’s First Set of
Discovery Requests.
>
“laa
=
an
=
— ve oe
. ot.
\o,
AUTHORIZATION FOR RELEASE
OF MEDICAL RECORDS
Ou
mo UY4ATS
RE: Margaret A. Madigan
This is authority for you to give to Attorncy James D. Kurck, of Buckingham, Doolittle &
Burroughs, LLP. 50 S. Main Strect, P.O. Box 1500. Akron, Ohio 44309, or his designee. any
and all information pertaining to any and all injuries or conditions for which you cxamined and
treated mc, including, but not limited to. copics of your office charts. office notes. and any
documents contained in your files regarding, mc.
(‘ opr AM cdns cn
Margaret A. Magigan A
DATE: )— 4. O\
aAK}:424600 te
saat bane
AUTHORIZATION FOR RELEASE
OF MEDICAL RECORDS
RE: Margaret A. Madigan
DOB: 8/12/49
SSN: 261-86-4041
This is authority for you to give to Attorncy James D. Kurek, of Buckingham. Doolittle &
Burroughs. LLP. 50 S. Main Strect, P.O. Box 1500. Akron. Ohio 44309, or his designee. any
and all information pertaining to any and all injuries or conditions for which you examined and
treated me, including. but not limited to, copics of your office charts, office notes. and any
documents contained in your files regarding me.
AUTHORIZATION FOR RELEASE
OF MEDICAL RECORDS
TO: x... Katacrss ;MiD
1 3 Swodon: ABS BA.
Landay eee On 44 a8
RE: Margaret A. Madigan
DOB: 8/12/49
SSN: 261-86-4041
This is authority for you to give to Attorncy James D. Kurck, of Buckingham. Doolittle &
Burroughs, LLP. 50 S. Main Street, P.O. Box 1500, Akron, Ohio 44309, or his designee. any
and all information pertaining to any and all injurics or conditions for which vou examined and
treated me, including, but not limited to, copies of your office charts, office notes, and any
documents contained in your files regarding mc.
{Y\arag > &., eo
Margaret A. Madigan
DATE: i nto Ol
@AK V-484609 Ie
‘
}
ee ee
INTERROGATORY NO. 5: Identify any and all lay witnesses and
the subject matter of each such witness’s anticipated testimony, and all
documents upon which Plaintiff intends to rely in support of her claims at
the trial of this case.
ANSWER:
Lay Witness Name & Address _Testimony/Documents
Mark Perkins — Minneap lis MN ‘-cowledge of disability, and admissions
Maryellen Valaitis — Ccinnati OH knowledge of disability and admissions
Tim Ault — Canton OH knowledge of disability and admissions
Darrell Krueger — Creston OH work conditions
Robb Geissman - Des Moines IA work conditions
Bob Byers - Wadsworth OH work conditions, performance, and exhibit #15
Connie Bihari - Burbank OH work conditions
Dale Riley - Creston OH health
Shelly Moore — Wadsworth OH work conditions
Jean Boling - Parma OH work conditions
- Ross Deerman — Doylestown OH health
Becky Dillon - Rittman OH health
Kyle King - Medina OH health
Sandy Van Drotelyn - Parsippany NJ exhibit # 2
Trish Hilson - Cleveland OH work conditions
Jennette Langston - Akron OH work conditions and cause of death of
her
mother, Willic Brazil, former employee of Nabisco, Seville Ohio.
And the widows of:
Charles Wagar Cause of Death
Charlie Hrbeck Cause of Death
Bra psig HO Cause of Death
Tom Leasure Cause of Death
Bob Gallatin Cause of Death
There are additional deceased Nabisco employees whose names the Plaintiff
will provide as soon as possible. Also, additional information on addresses,
as many have moved and Plaintiff only has phone numbers.
_—--- es a oe
opr
INTERROGATORY NO. 17: Identify all medical expenses incurred
by Plaintiff which are allegedly related to any actions taken by Defendant.
ANSWER: All medical expenses thus far have been paid by insurance
companies or not paid at all. Future medical expenses Or Plaintiff, however,
are expressed in relief sought by Plaintiff.
INTERROGATORY NO. 26: Identify all evidence Plaintiff has
either within or outside her possession to support her allegation that the
ingredients in aspartame and nutrasweet are hazardous and toxic substances
which may cause neurological conditions.
ANSWER:
Exhibit #12 World Environmental Conference and Multiple Sclerosis
Foundation Report - 8 certified copy 1s forthcoming.
INTERROGATORY NO. 27: Identify all evidence Plaintiff has either
«tain or outside her possession v0 support er allegation thatthe ingreciea
in aspartame and nutrasweet exacerbate Multiple Sclerosis.
ANSWER:
Exhibit #12 World Environmental Conference and Multiple Sclerosis
} Foundation Report - & certified copy is forthcoming.
| Exhibit #14
Study done at University of Turku, Finland and presented to 17 World
Congress of Neurolgy in London England — June 21, 2001. — certified copy
forthcoming.
REQUEST FO DUCTION NO. 11: Produce any and all
document relating to any and all treatment identified in response to
Interrogatory No. 14.
RESPONSE: Defendant has been furnished with letters to release
medical information and records from the following Doctors:
Dr. Revere Kinkle, M.D., Multiple Sclerosis Cleveland Clinic, Cleve. OH
., General Practice, Wadsworth, OH
Practice, Wadsworth, OH
REQUEST FOR PRODUCTION NO. 12: Produce all medical records
reflecting the nature and extent of Plaintiff's disabilities.
RESPONSE: Please see MS letter of diagnosis from Cleveland Clinic.
Plaintiff does in fact have Multiple Sclerosis and Fibromyalgia, both
considered by ADA to be disabilities. Defendant has been furnished with
Fietters to release medical information from doctors. More information is
7 forthcoming from Plaintiff's recent medical appointments.
| REQUEST FOR PRODUCTION NO. 13; Produce a copy of all
{ document, notes, calendars, diaries or other documents in Plaintiff's
possession which relate in any way to her employment with Nabisco.
RESPONSE: Other than attached exhibits, Plaintiff can not locate any
other notes, diaries, etc. at this time.
REQUEST FOR PRODUCTION NO. 16: Produce all documents
identified in response to Interrogatory No. 26.
RESPONSE: See attached Exhibit #12 World Environmental
Conference and Multiple Sclerosis Foundation Report.
REQUE eo) ODUCTION NO. 17: Produce all documents
identified in responses to interrogatory No. 27.
RESPONSE: Please see the following attached documents:
Exhibit #12 World Environmental Conference and Multiple Sclerosis
Foundation Report - & certified copy 1s forthcoming.
{ Exhibit #14
} study done at University of Turku, Finland and presented to 17 World
| congress of Neurolgy in London England — June 21, 2001. — certified copy
| forthcoming.
i INTERROGATORY NO.6: Identify each and every expert witness
whose testimony Plaintiff intends to use at the tnal in this case, and describe
the subject matter of each such expert witness’s anticipated testimony, the
substance of the facts and opinions to which the expert is expected to testify
and a summary of the grounds of each opinion.
ANSWER: At this time the only expert witness that the Plaintiff intends to
use at the trial will be from the Cleveland Clinic, unsure of which doctor at
this time. The doctor will testify concerning the nature of Multiple Sclerosis
and how it applys to the Plaintiff.
INTERROGATORY NO. 8 Identify all documents not within
Plaintiff's custody, control, or possession which relate, in any way, to the
allegations set forth in Plaintiff's Complaint or Amended Complaints.
ANSWER: Certified copies of exhibits as needed and will be provided to
defendant, as soon as they become available. Also, see exhibits #15
Plaintiff's Job Review and #16 Maryelien Valaitis e-mail.
e EE ee
id
RE
tail
2
a
t
_ INTERROGATORY NO. 14: Identify any and all medical or health
care providers with whom Plaintiff has treated in the last ten (10) years for
| any physical conditions, including the following: (a) the name of the health
care provider, (b) the specialty of the health care provider, (c) the address of
| the health care provider, (d) the timeframe during which treatment was
provided, (e) the nature of the treatment, and (f) the ultimate results of the
treatment.
ANSWER: Please review your responses from the following doctors for
whom I have given you medical release resquests.
Dr. Revere Kinkle, MD. - Cleveland Clinic — Multiple Sclerosis
Dr. Peter Katsaros, MD.- Wadsworth Ohio general practice
Dr. Finneran, M.D. - Wadsworth, Ohio general practice
te i ease hohe cae’
pe eid cd 1 Uc A Sacto tat .
ES Ue Ses
contained in your pleadings. Please produce specific information and/ or
documents which correlate to the Interrogatory and Request for Production
of Documents.” |
PLAINTIFF'S ANSWER/RESPONSES* Please see Exhibits attached
herewith which have also been previously provided the Defendant.
INTERROGATORY NO. 2: “Beyond the Complaint and Amended
Complaint you filed, identify all specific documents which support the
Snsiiihaitdieianton
| claims that you made in your Complaint and Amended Complaint and who
' provide you with those documents.”
1 PLAINTIFF'S ANSWER: See Exhibits 1 through 16 (13 of which have
‘been previously provided the Defendant by the Plaintiff and are again being,
1 provided herewith). All documents provided thusfar have been
documents of Plaintiff, or documents plaintiff has obtained through research
(computer).
1.) DIAGNOSIS LEI TER FROM CLEVELAND CLINIC TO
, . YELLEN
VALAITIS, AND SANDI VONDRALTELN FROM LYNN MADIGAN
3.) INTEROFFICE COMMUNICATION TO DARRELL KRUEGER
FROM THE PLAINTIFF
4.) PRESCRIPTION FROM CLEVELAND CLINIC TO PLAINTIFF
5.) LETTER FROM DARYL BREWSTER TO PLAINTIFF
6.) INTER-OFFICE CORRESPONDENCE FROM MARK PERKINS
TO PLAINTIFF
7.) RECOGNITION NOTICE FROM BOB S3YERS TO PLAINTIFF
8.) INTEROFFICE CORRESPONDENCE FROM CAROL
LAUFENBERG TO PLAINTIFF
9.) SEPARATION LETTER FROM MARK PERKINS TO PLAINTIFF
10.) DETERMIN ATION LETTER FROM EEOC TO PLAINTIFF
DATED 8/22/00
10A.) LETTER FROM EEOC TO PLAINTIFF DATED 9/7/00
11.) DETERMINATION OF BENEFITS FROM OBES TO PLAINTIFF
12.) ASPARTAME REPORT FROM ENVIRONMENTAL
, REPORT
15.) PLAINTIFF'S JOB REVIEW
. 16.) E-MAIL FROM MARY ELLEN VALAITIS TO PLAINTIFF
9\7) UNIVERSITY OF TURKU, FINLAND RESEARCH
INTERROGATORY NO. 3: “Identify every person at Nabisco or
previously at Nabisco who is aware of the circumstances surrounding the
termination of your employment and any other claims you have made in this
case’
| pLAINTIFF’S ANSWER: To the Plaintiff's knowledge, persots aware
4 of the circumstances surrounding the termination of her employment are,
5 Mark Perkins, Maryellen Valaitis, and Tim Ault. Other persons that may be
} REQUEST FOR PRODUCTION NO. 2: “Beyond the general relief
you have requested in this case, produce every document which reflects the
amount of damages you are seeking.”
provide to the defendant, which shows appreciation of expenses based on
national inflation rates over Plaintiff's life expectancy of the next 40-50
Attached herewith to assist in compiling Plaintiff's relief sought:
Medical Mutual insurance Rate Chart
Liberty Residence schedule of Service Charges
INTERROGATORY NO.14: “You responded that you do not recall
the identity of any of your health care providers over the last 10 years or the
nature and extent of treatment that was provided, however, you completed
three Authorizations for release of Medical Records, naming three separate
physicians. Therefore, please provide the information requested in
Interrogatory No. 14 with respect to those physicians.”
PLAINTIFF'S ANSWER: The Cleveland Clinic has been my major
Healthcare Provider for the last 15 years. | have seen numerous doctors
there and cannot recall all the names. The doctor that I continue see,
specifically for Multiple Sclerosis, is Dr. Revere Kinkel, M.D. He has
access to all of my medical information, as do all doctors at the Cleveland
Clinic. The Cleveland Clinic is an internationally reknown Healthcare
facility. Dr. Katasaros, M_D. and Dr. Finneran, M_D. are local Wadsworth
facility. ee aoen for minor problems thos. on in order to
avoid the long distance drive to the Cleveland Clinic.
Pterty Residence
Gracious Independent & Assisted Living
Fee Schedule & Supplemental Service Charges}
' ROOM ROOM 0-1 2-3 4-5 6-10
3 NAME TYPE assists * ASSISTS ASSISTS ASSISTS
3 Jefferson Small | $75.00/day $85.00/day $95.00/day $105.00/day
Studio
Franklin a $85.C0/day $95.00/day $105.00/day $115.00/day
io
ashington One $90.00/day $100.00/day $110.00/day $120.00/day
Bedroom
Lincoln Suite | $100.00/day $110.00/day $120.00/day $130.00/day
*Q-1 assists is considered Independent
Above fee schedule includes room, basic services, and assist levels based
on functional assessments. Prices are per person.
Assist levels are determined by the HealthCare Coordinator after
completion of functional assessment.
| Guest Meals: Breakfast - $2.50 Lunch - $4.25 Dinner - $7.00
Pharmacy Services: In House pharmacy services are available at no charge. If
service is desired, it must be authorized with the HealthCare
Coordinator/Administrator.
Beauty Salon: Per Salon charges
Personal Laundry: If you prefer to have your laundry done by our staff, there is a
charge of $4.00 per joad to wash, dry & fold.
Cable Upgrade: Basic cable is included at no charge. To have your cable
upgraded, contact Wadsworth Cable @330-335-2888
Telephone Hookup: Contact GTE @ 1-800-483-4600 (community is not responsible)
Personal Transport: There is no fee for scheduled transportation on Tuesdays &
Thursdays. Non-scheduled days will incur 2 .50/mile charge.
Out- of- town transport is $6.00/hour after approval.
1034 Freedom Drive * Wadsworth, Ohio 44281 © (330) 334-3262
REQUE R PRODUCTION NO. 14.: “You stated that your state
and federal income tax returns for the years 1997 through 2000 and your W-
2 forms and paycheck receipts are inaccessible. Please attempt to locate any
such documents as they are necessary for the purpose of calculating your
damages in this case.”
PLAINTIFF'S RESPONSE: All tax returns and paycheck receipts for
years prior to 2000 have been destroyed by me. I ycheck
receipts, and, I can not locate my 2000 tax W-2 forms. ~
GA 0.19: “You answered it is “not applicable”
whether you have been convicted of a misdemeanor, felony or other crime
involving an act of dishonesty. This information is discoverable and an
answer must be provided.”
PLAINTIFF'S ANSWER: _ To the extent that the following can be
construed as “dishonest” I am providing the information following:
DWI conviction 1980 Medina, OH, Disagreement of monies due me 1985,
North Hollywood, CA., monies still due me. This all the information | have
on these two items.
uest for Nos. 1,2 & 3:
Request for Admission No.1: Admit that Plaintiff was terminated
because of her performance deficiencies.
Request for Admission No.2: Admit that Plaintiff was not as
qualified as her replacement for the position of Production Planner.
Answer: The Plaintiff Objects.
SE hen Bose te 60 hi ee 0 asm ee re . ‘ -
Request for Admission No. 3: Admit that Plaintiff was not
obligated to sign Nabisco’s Separation Agreement.
Answer: The Plaintiff Objects.
Respectfully, answered to the best of my knowledge this 3" day of
August 3, 2001. Bs
ena blll Mad ge so tary
A. Madigan prof, Plamtiff. ~ =
( LA po ‘J PRE CO Ler the MOF SI ae oe ge 1% Cf tt Ph
THE CLEVELAND CLINIC FOUNDATION
COTO Eceectiel Nwecraeees Che wehaned Oolpien 219m Soe,
N Nuttiemel Rkecteceec al Clecneters NUD Ge aterne netic ened bes abel Bless cere ce
Dhineoded Nlitseeseneotes NE OD
Netaokniy / seme
Po ee September 16, 1992
Mrs. Margaret Madigan
295 Westview
Wadsworth, OH 44281
Dear Mrs. Madigan:
It was a pleasure mecting you on July 21, 1992. You were
referred to us from the Primary Care Department at the Cleveland
Clinic. Let me summarize your complaints.
About 10 days prior to your visit you noticed left upper
extremity weakness. You also had mild tingling in the left hand,
lasting minutes. The next day during an indian pow wow, you began
dropping things when using your left hand. Over the next five
days, this got worse to the point that the left hand was quite
useless. There was no sensory loss, cranial nerve symptoms,
balance problems or problems with bladder or bowel. The other
three limbs were unaffected. There was no progression of your
symptoms. You denied pain and tingling.
In 1988, you were seen by Dr. Sweency at the Cleveland Clinic
for a history of rightsided incoordination and slurred speech and
blurred vision. An MRI at that time showed right middle cerebellar
peduncle "lesion". These symptoms improved over six wecks. Later,
you had a transient episode of "a shade being pulled in front of
your right eye".
Your past history was significant for fibromyalgia in 1985,
urinary tract infection and being overweight.
The general physical examination was unremarkable. On the
q neurological examination there was a left arm drift. Pronation and
4 supination were mildly weak and the wrist dorsiflexion was 3+/5,
wrist volar flexion was 2+/5, finger extensors 1/5, hand intrinsic
0/5. Muscle stretch reflexes were slightly diminished in the left’
biceps. The remainder were normal. The remainder of the neurolog-
ic examination was within normal limits.
We did a number of laboratory tests. A complete blood count
and serum chemistry profile were normal. Sedimentation rate was 10
Cy billnt a
! of On
dn ans
Sed
Mrs. Margaret Madigan
cC#: 1-805-531-7
Page 2
mm/hour. Blood lead levels were normal. A visual evoked potential
was within normal limits. Serum B12 level was 240 mcg/ml (normal).
Cerebral spinal fluid (spinal tap) evaluation showed an RBC count
of 3/ul, WBC count of 18/ul and a differential count was 93%
lymphocytes and 3% monocytes. The CSF glucose was G3 against a
blood glucose of 89. A Tourtellotte formula was obtained and this
showed an increased CSF IgG of 15.1 mg/dl, IgG/albumin ratio of
0.60, IgG synthesis rate of 55.2 mg/day and an IgG index of 1.77.
All these clearly abnormal values. A serum anticardiolipin
antibody was obtained and this showed moderately elevated IgG but
normal IgM and IgA.
An MRI of the head showed multiple foci of abnormal signal in
the white matter bilaterally, compatible with a demyelinating
lesion.
A surface echocardiogram was within normal limits.
A lipid profile showed a total cholesterol of 235 which is
moderately elevated and an LDL cholesterol of 161 which is high and
a HDL cholesterol of 36.
As I discussed with you, the overall picture seems to fit best
with a demyelinating illness such as multiple sclerosis. We
suggest the following: 1) avoid situations which could potentially
increase body temperature; 2) follow-up with us in six months.
-Please call for an appointment approximately two months' prior to
the expected date of the appointment; 3) if you are interested in
looking at research protocols for multiple sclerosis, we could
refer you to the Mellen Center; 4) no specific intervention is
indicated at this time; 5) consultation with a general physician
regarding management of the moderately elevated cholesterol.
Once again, it was a pieusure participating in
Please do not hesitate to call us with any questions.
Yours sincerely,
7
dawg h Kwrrar
Suresh Kumar, De
In the Serv }ce
Hiroshi Mitsumoto, M.D.
SK/as
rec'd 9-17-92/tr. 9-18-92
© xh ban -
de{ WK
12/21196
{Mave made the following observation of Peg’s condition:
Fea is and has been experiencing physical symptoms which may lead to a more serious.
sae rbation of her multiple sclerosis as a direct result of undue stress being subjected to at
Cs by hostile work environment which is being perpetuated by management. For example.
Manscling notes” which were presented to her on 12/20/96 by Tim Ault and Maryellen Vaiaitis
uide of a structured review - citing alieged incidents from various coworkers which thes2
@duais neither presented to Peg nox resulted in confrontation. Thus, she was unaware of
alleged perceptions of interactions.
‘Nabisco was presented with standards which were to be immediately met and sustained:
E A
| Several years ago when Peg was diagnosed with MS- i.e. the necessity for temperature
igo! of work environment and avoidance of undue stress.
Mese standards are important because of the following impact on Peg's life:
B the aforementioned conditions are not met and respected then Peg’s health may be
ted on a temporary or even permanent basis.
) m informing Nabisco of the following with respect to these aforementioned issues:
©
| Peg has organized her office space for maximum efficiency of job performance based on
ifevations she has Created over her “years” of successful service to Nabisco.
) These issues are very serious:
’ Ns her next of kin, | will see that her legal rights are protected, even if Peg lacks stamina to
sO.
eiPicase see attached copy of Counseling Notes
¥Pn Madigan ~ o Mebap—
Tim Ault
Mark Perkins
Maryellen Vaiaitis
Sandi VonDraltein
COUNSELING NOTES
I have made the following observation of Peggy’s conduct/performance:
Peggy you have “blocked” the access window with binders. It prevents drivers and
employees from having easy and direct access to you to conduct business.
Peggy you have built an office area around you that separates you from
the rest of the team and makes it difficult for open communications.
Your comment to Cathy Roy on Wednesday, December 4th that you “deserve
hunch because you do everything” is an example of placing yourself outside
the team.
Peggy, Schneider representatives, expressed concern over working with you and
being treated courteously. Bob, the shuttle driver, stated that you addressed him in
a mean and nasty way when he approached you about pulling loads out and that you
threw bills across the desk for him to sign. Bob also cited that there is
lack of communication between the two of you. You did not
on 12/3 that 2 loads were he is trying to service our
account but encount fel Sing. trie nel ortaar gi
I have informed Peggy of the following
immediately met and sustained:
that are to be
Do not block the access window between the warehouse and your office
area.
Address Bob as well as employees, visitors, phone calls etc in a courteous business
like manner.
Communicate with your team members including your manager on all appropriate
work related issues (i.¢ , warehouse issues, overtime)
These standards are important because of the following impact on the
work environment:
1 is important that drivers have professional and easy access to you to
conduct business in a timety and efficicnt manner,
We work as team within the warehouse and the Seville Plant. It is
critical that open two-way communication takes place
Getting the tangible work done is only a portion of your responsibilties. How you
get it Gone, and how you interact with the team and customers is also a significant
portion. If you get the job done but have isolated others while doing so you have
not been truly successful as a team member.
4. I have informed Peggy of the following with respect to these performance issues
These issues will be reflected in the performance review. The review will either state that
the issues have been addressed or that improvement is still required.
These performance issues in Teamwork and Cross-functional Effectiveness are very
serious. Pegay’s effectiveness as 2 Warehouse Clerk is dependent upon her immediate
attention and improvement. Tim Ault & Maryellen will continue to assist Peggy however, if
these issues are not addressed adequately in the next 30 days, further disciplinary action will
be taken including being placed on a Plan of Corrective Action to formally address these
issues.
5. These matters will be reviewed on Friday, January 24, 1996.
: To: Darrel Krueger
From: Peaay Madison
Date: April 26,1996
Subject: Utilization of office space
Use of the vacant office in shipping would provide the following benefits for the
shipping/receiving/warehouse functions:
1) Privacy would provide a more
: switchboard and shipping/receiv
is on the dock)
professional sounding background for answering
ing calls (presently sounds to the caller as though the
2) Privacy provides a quiet , more productive work environment (presently noise from p
j and other employees in the open office can be very distracting)
:
3) Better lighting benefits vision
4) More space provides room for better organization of current shipping/receiving record
(and more space for future paperwork for any cO-packing projects)
5) More space provides better access toe
quipment (calculator, computer, typewriter,
switchboard, printer)
6) Better air ventilation and circulation for the person who is in the office all day (Pea)
7) Access to window view of front parking lot gives a better idea of what trucks are arrivi:
or parked (expedites decision making)
8) Provides Capability to “lock up” switchboard if we deem necessary (security)
9) Open office (Peggys’ present Space) can then be used by employees to take on
responsibilities of printing tickets for cross docks
10) Bar-code printer can be moved to a more accessible area, so all employees can reach
11) Open office can provide space for trai
print receivers
ning of employees to trace Packaging materia!,
12) A private office would provide
a better atmosphere for Peggy to concentrate on
developing new procedures and co
mputer applications tc further streamline job functions
Exits * 3
Bride ne Aes es ae DIY
dai AK hades aeons
THE CLEVELAND CLINIC FOUNDATION DATE PRESCMBED
9500 Euclid Avenue (Ai East 930d Sireot) NOT VALID FOR
SCHEDULED DRUGS lI}
Cievetand, Ohio 44195 T : (246) 444-2200
Patient Name: Wiel 7 td History No.: hati AE
Sirect Address: U City: State.
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PANN a'tbean? "PES.
Dirvl Brewster
enseh-ent
December 22, 1996
Margaret Madigan
SPC/Seville
Dear Margaret,
| would like to extend to you, on behalf of the Specialty Products Company and
Nabisco, our sincere bes! wishes and appreciation on the occasion of your ten-
year anniversary with the Company.
| hope that the past ten years have been interesting and rewarding to you and
wish to thank you for your contribution over the years.
Again, congratulations and best wishes for your continued success and
happiness.
Best regards,
V We
Daryl Brewster
\ ale Slain PUINUDEWN
‘ TO DATE.
2 PEGGY MADIGAN JANUARY 3, 1995
FROM i wi corns TO
4 MARK PERKINS M. EVERS
K J. JONES
© ornecr. D. KRUEGER
4 PLANT MANAGER M. VALAITIS
y
SUNJECT
1994 ACTIVITIES
Niginadi bed iw BEERS,
As a member of the employee activity committee, you provided valuable
services to the Seville Team. The numerous activities your group planned
in 1994 were appreciated by many. I want to thank you for your ideas and
commitment to others on our team. This is an attitude that needs to be
fostered throughout our team.
Cee een Mr bag
f 1 a a ick oS i yh
—
1 look forward to your continued efforts in making Seville the best it can
‘
zl be. Together, we can achieve our goals. Thanks again for a job well
- done.
Pome Santa may have been the highlight. Great job Santa!!
MP95S .002
1 — | éy begets! L.
SSR A ELEM EN BME AI TET, BCR OO
PEE Oot ee toms
RECOGNITION NOTICE
Employee kt: Ce be Pleac!gg gan Date 97°15°9S
Team thee hous
This note is to express appreciation for:
Doe fe oe lack of commeoatabie. Attutin Ve wwarehoAe
Aad cor =p rn te lis %, betes wrseaac! aa eviccighe lee skyrmenT
ct a er Yonss pack SAipoe = . Reel & pe the nem
Ac Erteoh? , picky Peay Pas Keynes eel VkL pempeo~tance ak phos
chysonent Pry rT A oscksa ¥A home wirh Rien anal m
delwereel Tt pigranily fe the 7Aichoone of Free 2 ois ance’
vf 35 miles rod ondir Laut fe make phar enn Fhort
and to Gul Ove Commitment fu rhe sales prevple em 3 Toxas |
Her writhag ness fe Sac rife her Free may be oa Key tv
YL Seat Success ef Vy sanckwell liad,
This is the type of situation which contributes to the GOOD of the Seville
Plant. It is a real pleasure to take this moment to say Thank You!
Madigan, Margaret
From: Laufenberg, Carol Annc
} sent: July of 31, 1997 16:03 .
3 To: Lea, Tracy; Russ, Trent; Madigan, Margaret
@ Cc: Bruno, Anthony; Aull, Tim
* Subject: RE: Seville
* Seville Update:
Peggy has been speaking with Monica at Schneider on a daily basis about inbounds, and so far the results are
very positive! Loads are being identified earlier and brought in so we can turn them around and meet our case
fills at the DC’s. This is a big step and greal progress for Sevilic!
| Peggy.
* Please continuc to contact myself/and or Tracy when you sec late shipments from copackers in the system. We
will ensure that they take care of these laods so we do not run into the problems we have had in the past.
Trent,
> Thank you for all of your hard work coordinating Schneider and Seville and working with Tracy to help shorten
lead times.
Tracy and | are working on the MR fields with tier products. We hope to consolidate the information and enter it
4 into ORP within the next two weeks.
| would like to schedule thal conference call al the end of August/beginning of September if that is all right with
everyone.
Thanks everyone, great team effort, we arc making progess'
Carol Anne
5
4
From: Russ, Trent
Sent: Wednesday, July 30, 1997 11:06AM
To: Lea, Tracy
Ce: Laufenberg, Carol Anne
Subject: RE: Seville
That sounds great! This process will ensurc thal no loads arc lost between the cracks.
Thanks — Trent
From: Lea, Tracy
Sent: Wednesday, July 30, 1997 9:15AM
To: Russ, Trent
; Subject: Nt: Seville
ihn Sanh akan Ni i A adit Rett FRI a a wy $a VD dias
3 Deployment should contact the copacker. Peggy should e-mail Carol Anne and myself with the details,
a and then | will have my deployer follow up immediately and respond.
Sound good?
Sracy os
: SLAF
Page 1
Rae a et Sees
Se eee eae
ee
From: Russ, Trent
Sent: Wednesday, July 30, 1997 8:57AM
To: Lea, Tracy
Subject:
Schneider has confirmed that Seville is checking the inbound loads on a daily basis. The only
question | have is: If a load has been scheduled to ship out of a co-packer and the co-packer has not
contacted Schneider about the load and the load is past duc to ship, who should contact the co-
packer to see whal is going on? Peggy? Deployment?
1 would think Peggy should put up the flag to deployment who would follow up with the co-packer. Let
me know what you think.
Thanks — Trent
P.S. Any luck with the parameters on 384 and 208?
VEO Octo eons ie be Mee?
NABISCO kt gry dlls
Piss Chloe eee iN
September 2, 1997
Ms. Peggy Madigan
295 Westvicw
Wadsworth,OH 44281
Dear Ms. Madigan:
This letter constitutes the entire agreement between Specialty Products Company an operating
company of Nabisco, Inc. (the “"Company’), its successors and/or assigns, and you regarding the
separation of your employment relationship with the Company. You are eligible for the
Company's Salary and Benefit Continuation Program CSBC”) which is designed to provide you
with a period of time during which the Company will continue to pay salary and benefits so that
you can make arrangements for the next stage of your career. This letter scts forth the terms
and condi.ions under which you agree to participate in the SBC. Ptease read this letter carefully.
Then sign the copy of this Agreement where indicated on the fast page and return it to me by
September 23, 1997.
2 You will continue as a regular, full-time employee through September 30, 1997. If you
voluntarily quit or are terminated by the Company for violation of Company rules,
policies, guides or standards of conduct before that date, you will not participate in the
SBC or receive the SBC benefils described below.
On October 1, 1997, your SBC Date, you will be placed on a leave of absence with pay
for inactive employees and you will be paid semi-monthly at the rate of $24,400 per
year through December 15, 1997, your official “Separation Date” for Company records.
All payments are subject to normal deductions for taxes, benefit program Ccontridutions
and other payroll deductions. This period of paid icave of absence is referred to as
“Salary Contini:ation” and is provided in order to preserve the Company's access to
you during that period although you will be relieved of all your normal job duties and
responsibilities. You agree that you will personally provide reasonable assistance and
cooperation in locating or obtaining information conceming the Company (past or
present) about which you are knowledgeable.
You acknowledge that as of September 30, 1997, your active employment with the
Company, or any of its affiliates, will be terminatcd.
Z: if you beceme employed by any Company affiliate on a regular, full-time basis at any
time prior to the end of your period of Salary Continuation, all payments or bencfits
under this Agreement, shall cease as of your date cf hire and you agree that you will
Sign a waiver regarding the forfeiture of those rights and benefits.
If you become employca by any Company affiliate after you have commenccd to
receive an annuily from the Company, any monthly retirement payments will be
suspended during the period of your active employment. Upon your subsequent
retirement, your retirement benclits shall reficct the accrual of any additional retirement
benefits as provided by the applicable retirement plan for the period of service
occasioned by your rchirc.
During Salary Continuaiion, if you become employed by an employer not affiliated with
the Company, Salary Continuation payments and participation in the SELECT Flexible
i. ae
” x \" Ot
/ bert ar
—————— ee —
WA SLE GP DAIBESE.
Ae tae SP al a et ek Sa Fo
ip ttalpnint it arrose? Vera Mats ecater
SMa ASIN RRC iho LA SO
BNE LIL RAEI
Peggy Madigan -2- September 2, 1997
Benefits Program will continue until your Separation Date, subject to coordination of
benefits rules, as applicable.
If you dic during Salary Continuation, Salary Continuation payments will cease, but any
amounts that would have been paid to you had you lived until your Separation Date will
be paid in a lump sum to your spouse, or if you do not have a spouse, to your
designated beneficiary under the Company's Core Group Life Insurance plan.
All unused vacation attributable to the year in which your last day of active
employment occurs will be paid in a lump sum bascd on your current base salary, iess
applicable taxes, at the end of Salary Continuation.
Prior to your SBC Date, you are expected to submit Expense Reports for all
outstanding travel, entertainment and other business expenses. If ary expense
report(s) reflect any amounts owed to the Company, such expense will be deducted
from Salary Continuation payments, as necessary.
Prior to your SBC Date, you must return all Company equipment such as personal
computers or the value of such equipment, as determined by the Company, shail be
deducted from the calculation of your Salary Continuation, if applicabic.
Benefits
During Salary Continuation, you may continue to participate in the employee bencfit
programs in which you participated as of your SBC Date except as otherwise provided
in this Agreement or by the terms of the individual program. You may participate as
though you were an active employce, subject to the continuation of applicabic payroll
deductions. You are not cligible for Short or Long Term Disability benefits during
Salary Continuation.
Nabisco maintains the right to determine whether changes and/or new benefit
programs implemented after the date of this Ictter apply to you, unless otherwise
required by law.
The following is a summary of benefit continuation.
Pension
You are vested in the Retirement Plan for Employees of RJR Nabisco, Inc.
if your lump sum benefit is equal to or less than $3. 500, you will automatically receive
a lump sum payment shorily after your Separation Date. Otherwise, you will have an
irrevocable choice of receiving your benefit as a lump sum or an immediate annuity, or
electing a deferred annuity which can commence no later than age 65. Appropriate
election forms will be provided to you on or about your Separation Date. Note: If you
receive a lump-sum payout, you may elect to “roll it over” to your Capital Investment
Plan account, an IRA, or another company's qualified plan.
In addition, in an effort to streamline the pension processing effort, picase provide a
copy of your Birth Ceniificate, and where appropriate, Marriage Certificate, divorce
papers and spouse's Death Cenificate, along with your signed SBC Icticr.
Medical/Dental ]
Your present benefit ciections under the SELECT Flexible Bencfit Program as an
active employee will continue during the period of Salary Continualion. Should you
become employed by an employer not affiliated with the Company, health care
coverage provided by your ncw employer will be coordinated with our plan benefits.
Pegcy Madigan -3- ~ September 2, 1997
All coverage under SELECT benefits will cease at the end of the month during which
your Salary Continuation ends. Notice of continuation coverage options for medical
and/or dental (COBRA) will be mailed to you at that time. If you have not enrotied in
an allernative employer's medical and/or dental covcrage program, you may ciect
continuation coverage (COBRA). The monthly premium will be 102 percent of actual
plan cost as provided in COBRA. Specific costs and details will be provided at the
appropriate time.
apital inv ent Plan (CiP
During Salary Continuation, you may continue to make contributions to the Capital
Investment Plan (CIP*), and retain all other rights under the plan, including the right to
transfer investments between funds, change your contribution amount, and to requesi
withdrawals. However, no loan applications will be approved during Salary
Continuation. Following your Separation Date, your account balance will be distributed
to you in accordance with the terms of the Plan. If your vested account is less than
$3,500, a cash lump sum distribution will be processed automatically, otherwise, you
may elect to take distribution at anytime prior to age 65. If you leave your money in
your account following your Separation Date, you will no longer be eligible for partial
withdrawals. If you wish to receive any of your account following your Separation Date,
you must withdraw your entire account which can then be “rolied-over into an IRA or
another employer's Plan. If you have an outstanding loan, it must be repaid at
termination or it will be considered a withdrawal and you will be responsible for any
taxes due. For additional details of your account, please call 1-800-INTO ABC.
Scholastic Savings Plan (SSP)
| , You may continue to participate or newly enroll in the RJR Nabisco Scholastic Savings
4 Plan during Salary Continuation. Upon your Separation Date, no further contributions
: will be permitted, however, your accoun\(s) including the Company match will be
4 maintained with continucd interest growth. Distribution of your account(s) will be
processed in accordance with program rules for active employecs.
ig Sich tena atka
In addition, you may apply for an RJR Nabisco Scholastic Loan during Salary
5 Continuation. You will continue to be eligible for the interest subsidy for the life of your
‘ outstanding loans (e.g.. RJRN Plus Loan or RCFCU/RJRN Scholastic Loan).
8. You are entitled to use the outplacement counseling service designated by the
. Company for which the Company will pay not more than the normal and reasonable
: fee. You are not obligated to use this service, but the Company urges you to consider
; this service as one of the avenues to finding new employment. Details of this service
: will be provided by Edward Lultner and Associates.
9. You will be eligible for tuition aid reimbursement for courses which are approved and
commence prior to SBC. '
10. You shall maintain the terms and condilions of this Agreement in confidence. In
addition, you will not disclose (o any other employer or person any trade secrets or
other proprietary or confidentia! information penaining to the Company or its affiliates.
In accordance with normal ethical and professional standards, you will refrain from
taking actions or making statements, wrilten or oral, which disparage or defame the
goodwill or reputation of the Company, its directors, officers, execulives and
employees or which could adversely affect the morale of other empioyecs.
Bet BU aeah ENDL alae aa Ae ada BS
SG st Ae
' | 4
(345)
—oOorererr,S rere nT
Peggy Madigan -4- September 2, 1997
hk
12.
13.
14.
Except as otherwise stated herein, no benefits (other than those provided by a tax-
qualificd plan or trust) or promise hereunder shall be secured by any specific assets of
the Company. The payments under this Agreement shail not be assigned by you or
anlicipated in any way and any such attempted assignment will be void.
For your period of SBC, you agree not to make application for unemployment ;
compensalion applicable to that period.
a) You agrec that you will personally provide reasonable assistance and cooperation to
the Company in activities related to the Proseculion or defense of any pending or future
lawsuits or claims involving the Company. b) You will promptly notify the Company if
you reccive any requests from anyone other than an employee or agent of the
Company for information regarding the Company or if you become aware of any
potential claim or proposed litigation against the Company. c) You will refrain from
Providing any information related to any Claim or potential litigation against the
Company to any non-Company representatives without cither the Company’‘s written
permission or being required to provide information pursuant to legal process. d) if
requircd by law to provide sworn testimony regarding any Company-related maticr, you
will consult with and have Company-designated legal counse! present for such
testimony. ¢) The Company will be responsible for the costs of such designated
counsel and you will bear no cost for same. f) You will confine your testimony to items
about which you have knowiedge rather than speculation, unless otherwise directed by
legal process. g) You will cooperate with the Company's attomeys to assist their
efforts, especially on matters you have been Privy to, holding all privileged attomey-
client matters in strictest confidence.
Nothing in seniences c-g of the above paragraph is intended to apply to governmental
Of judicial investigations; provided, however, the Company will reimburse you for legal
expenses if you are compclied to appear in a governmental or judicial investigation.
THE COMPENSATION AND BENEFITS ARRANGEMENT SET FORTH IN THIS
AGREEMENT IS IN LIEU OF ALL RIGHTS OR CLAIMS THAT YOU MAY HAVE
WITH RESPECT TO SEVERANCE BENEFITS, REEMPLOYMENT, OR ANY OTHER
FORM OF REMUNERATION FROM THE COMPANY AND ITS AFFILIATES, AND IN
CONSIDERATION THEREOF, AFTER THE OPPORTUNITY TO CONSULT LEGAL
COUNSEL, WHICH YOU ARE HEREBY UNCONDITIONALLY SO ADVISED TO DO .
IN CONNECTION WITH THIS LETTER, AND PARTICULARLY, THIS PARAGRAPH
WHICH IS A WAIVER AND RELEASE, YOU HEREBY RELEASE THE COMPANY
ANDO ITS AFFILIATES, THEIR DIRECTORS, OFFICERS, EMPLOYEES. AND
STOCKHOLDERS FROM ALL CLAIMS OR ACTIONS ARISING FROM OR IN ANY
WAY RELATED TO YOUR EMPLOYMENT OR SEPARATION OF YOUR
EMPLOYMENT, INCLUDING, BUT NOT LIMITED TO, ANY CLAIMS ARISING
UNDER THE FEDERAL AGE DISCRIMINATION IN EMPLOYMENT ACT CADEA”),
AMERICANS WITH DISABILITIES ACT (ADA), TITLE Vil OF THE FEDERAL CIVIL
RIGHTS ACT, THE CIVIL RIGHTS ACT OF 1991, OR ANY OTHER FEDERAL.
STATE OR LOCAL STATUTES OR COMMON LAW CONCERNING EMPLOYMENT
ANDO YOU AGREE TO BRING NO ACTION, CHARGE, SUIT OR OTHER
PROCEEDING IN CONNECTION HEREUNDER. THIS SECTION AND THE
RELEASE HEREUNDER SHALL NOT APPLY TO CLAIMS ARISING UNDER ADEA
AFTER YOUR “SBC DATE”. IF. AFTER READING THE FOREGOING, YOU SIGN
THIS LETTER PRIOR TO A 21-DAY REVIEW PERIOD, YOU WAIVE SUCH REVIEW
PERIOD.
If the Company reasonably determines that you violate any of your obligations under
this Agreement, then the Company may. at its option, terminate the Salary
Continuation and any other benefits hereunder. The Company may demand the return
a9er mr eu °
, sake
Peggy Madigan -5- September 2, 1997
of all Salary Continuation payments already made and you hereby agree to return such
payments upon such demand. If you fail to do so, the Company has the right to
recover Costs and attomcey’s fees associated with such recovery. The RJR Nabisco
Employee Benefits Committee and its designated representatives have the exctusive
authorily to interpret this SBC and their decisions are final, conclusive and binding on
the Company and you.
16. This Agreement may not be amendcd except in writing signed by you and the
Company and no amendments or modifications are coniemplated at this time.
17. Your obligations as set forth in this Agreement will survive indefinitely.
18. A copy of the SBC Program is attached to this letter. If you have any questions,
contact Maryelien Valaitis.
19. This agreement may be revoked by you for a period of seven (7) consecutive calendar
days afier you have signed and dated it, and after such seven (7) days, it becomes
final.
Please indicate your acceptance of the terms of this Agreement by signing this ictter and
retuming it to me.
Sincerely,
Specialty Products Company
Whi MALE
Mark M. Perkins
Plant Manager
Understood and Agrecd:
Peggy Madigan
Date
mags A
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Cleveland District Office 1660 West Second Sucet, Suite $50
\ — Cleveland, Ol 44113-1454
‘ o°
¢ 4 (216) $22-2001
ae ,¢ Non, TTY (216) 522-8441
\ ac ‘ * » FAX (216) 522-7395
Charge No. 220981021
Margaret A. Madigan
295 Westview Avenuc
Wadsworth, Ohio 44281 Charging Party
Nabisce In=.
>i8O Greenwich Koad
Seville, Ohio 44273 Respondent
DETERMINATION
Under the au:honty vested in mc by the Commission, I issuc the following determination as to the
merits of the subject charge filed under the Age Discrimination in Employment Act of 1967, as
amended (ADEA), and Title I of the Americans with Disabilities Act of 1990, as amended
(ADA).
All requirements for coverage have been met. Charging Party alleged that she was discriminated
against by being terminated duc to her age (over 40), denied a reasonable accommodation duc to
her disability and asked to sign a General Release that was in violation of Title VII of the Civil
Rights Act of 1964, as amended (Title VII), the Age Discrimination in Employment Act of
1967, as amended (ADEA), the Equal Pay Act of 1963, as amended (EPA), and Title I of the
Americans with Disabilities Act of 1990, as amended (ADA).
Reenandent denies the zilegetions.
After a thorough review of the evidence, there is not reasonable cause to believe that Charging Party
was discniminated against duc to her age or her disability. Based on the foregoing, I have determined
that the evidence obtained during the investigation does not establish a violation of the statute.
The Charging Party may only pursue this matter by filing suit against the Respondent within
90 days of receipt of this letter. Otherwise, Charging Party’s right to suc will be lost.
However, with regard to the Waiver/Releasc, investigation reveals that Respondent asked Chargine
Party to sign a “General Release of Claims”. This "General Release” fails to mect the criteria
for a knowing and voluntary waiver, in accordance with the "EEOC Guidance on Waivers Under
Civil Rights Laws", dated April 10, 1997, final regulation published at 63 Fed. Reg. 30624 on July
5, 1998, and effective July 6, 1998. Pro, ee l S
( I of 2)
EE
Charge Number: 220981021 Page 2
‘
Moreover, the waiver provision may produce a chilling effect, thereby undermining the
Commission's ability to enforce Title VU, the ADEA, the EPA, and the ADA. Thesc provisions
may intimidate or have the cffcct of intimidating employces and create disincentives for them to
cooperate with EEOC in safeguarding the public interest.
Upon finding that there is reason to believe that a violation has occurred, the Commission attempts
io eliminate the alleged unlawful practice by informal methods of conciliation. Therefore, the
Commission now invites the Respondent to join with it in reaching a just resolution of this matter.
The confidentiality provisions of the Title VII, the ADEA, the EPA, the ADA, and Commission
Regulations apply to information obtained during conciliation.
if «ne Respondent deciines to discuss settlement or when, for any other reason, a settlement
acceptable to the office Director is not obtained, the Director will inform the parties and advise them
of the court enforcement alternatives available to aggricved persons and the Commission. A
Commission representative will contact each party in the near future to begin conciliation.
On Behalf of the Commission,
“AUG 2 2 2000 [Prabal CB
Date Michael C. Fetzer
District Director
— CCC
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Cleveland District Office 1660 West Second Street, Suite $50
Cleveland, O11 44113-1412
(216) $22-2¢31
| TTY (216) 522-8441
FAX (216) 522-7395
Website: www.ecoc.gov
Charge Number: 220981021
Charging Party: Margaret Madigan
Respondent: Nabisco, Inc.
Ms. Margaret A. Madigan
295 Westview Avenue
Wadsworth, Ohio 44281
Dear Ms. Madigan:
Your case will be referred to the Regional Attorney for review to determine whether EEOC will
bring civil action in Federal District Court against the respondent. A determination will be
forthcoming in the near future.
If EEOC decides not to bring a civil action under Title VII of the Civil Rights Act of 1964, as
| amended (Title VII), the Age Discrimination in Employment Act 1967, as amended
(ADEA), and Title I of the Americans with Disabilities Act of 1990, as amended (ADA), you
_ _ will have the right to seek to intervene in such an action. If EEOC decides that it will not bring a
civil action under Title VII, ADEA, and the ADA, based on your charge, you will be notified
and will reccive a Notice of Right to Suc, which will entitle you to sue the respondent under this
statute.
On Behalf of the Commission:
SEP 07 2000 ubouk¢. Aegr
0
r 6=-—dDate Michael C. Fetzer Y
Distnct Director
pita Oo
30{3)
OHIO BUREAU OF EMPLOYMENT SERVICES
DETERMINATION OF BENEFITS
i's Name Benefit Year Ending Date Social Security Account Number
DIGAN, MARGARET A. 35/98 26 1-86-4041
DTICE 1S A DETERMINATION ON A CLAIM FOR UNEMPLOYMENT BENEFITS ISSUED IN Date
€ WITH THE PROVISIONS OF SECTIONS 4141.28&(0H1) AND (0X2), OHIO REVISED COCE. 09/24/97
Local Office
4610
MADIGAN, MARGARET A.
295 WESTVIEW AVE THIS NOTICE IS A DETERMINATION OF:
WADSWORTH OH 44281 [3 First weekly claim
oO Additional (eopened) weekly claim
(1) Continued weekly clam
(C0 _~—s Other. See decision in Issues Section
APPLICABLE
E(S): LAW: ...
FREASON FOR SEPARATION: DISCHARGE SECTION 4141.29(D) (2) (a), ORC
FClaimant was discharged From employment with NABISCO
‘
because of an incident that resulted in a loss to the employer.
HA review of the facts establish that there was not enough fault on the
Ppart of the claimant in his/her acts, omissions, or course of conduct that
san ordinary person would find the discharge justifiable.
‘therefore, claim for week ending 09-06-97 is allowed.
‘
™
boas
* DEEN PI AOE: AILS
C: NABISCO ; Eybika
AL RIGHTS: 1f you turk this determmation is incorrect as to fact or law, or if you have additional facts which might affect the
franation, you may file a request for reconsideration m person at any burea office. You will be gwen assistance m preparing
written request If you deswe, you may write directly to the focal office in which the claim is filed. Your request should
e the item(s) with winch you disagree, the reasons) for the disagreement, the social security account number as shown on this
and must be signed by you To be considered twmely. your request must be filed in person or postmarked no later than
y-one calendar days after the date entered in “Date Mailed” above. If the twenty-first day falts on a Saturday, Sunday, or legal
zy. the period for filing is extended to mctude the next scheduled workday. Also, upon receipt of certified medical evidence
lg that claimant's physical condition or mental capacity prevented him/her from filing an appeal withun the specified 2 1-day period,
s time shall be extended and the request shall be considered timely if filed within twenty~one days after the end of the
at or mental condition
ASPARTAME
ORLD ENVIRONMENTAL CONFERENCE and the
ULTIPLE SCLEROSIS FOUNDATION
DA Issuing for collusion with Monsanto
Article written by Nancy Markle (1120197)
have spent several days lecturing al the WORLD
NVIRONMENTAL CONFERENCE on “ASPARTAME
keted as ‘NutraSweet’, ‘Equal’, and ‘Spooniul’. In the
eynote addressed by the EPA, they announced that there
vas an epidemic _of multiple sclerosis and systemic lupus,
and they did not understand what toxin was causing this to
be remeant across the Unitev States. | explained that | was
here to lecture on exactly that subject.
1en the temperature of Aspartame exceeds 88 degrees
|, the wood alcohol in ASPARTAME converts to
formaldehyde and then to formic acid, which in turn causes
metabolic acidosis. (Formic acid is the poison found in the
sting of fire ants). The icity mimics MULTI
tiple sclerosis 3 Multiole sclerosis i feath
sentenc methanol toxicity is.
in he case of SYSTEMIC LUPUS, we are finding it has
| 7 i i
Diet Cok Diet i_drink Also, with methanol
toxicity, the victims usually drink three to four 12-02 cans of
them per day, some even more. In the cases of sysfemic
lupus, which is ingqgered by ASPARTAME, the victim usually
' does not know that the ASPARTAME is the culprit. The victim
‘continues its use aggravating the lupus fo such a degree,
that sometimes it becomes life threatening.
When we get people off the Aspartame, those with
SYSTEMIC LUPUS usually become asymptomatic.
| Unfortunately, we cannot reverse this disease.
On the other hand, in the case of those diagnosed with
Muttiple Sclerosis, (when in reality, the disease is methanol
toxicity), most of the symptoms disappear. We have seen
cases where their vision has returned and even their hearing
F has returned. This also applies to cases of tinnitus.
| During a lecture | said ° ing ASPARTAM
(NutraSweet, Equal, Spoonful, etc.) and you sulfer from
5 EIBROMYA m ing pain
the lecture saying, “I've got this, is # reversible?” IT IS
some
(CaA4 2627/2) Reon t |
suffering from these symptoms.
In one lecture attended by the Ambassador of Uganda, he
told us that their sugar industry is adding aspartame! He
continued by saying that one of the industry leader's son
could no longer walk -- due in part by product usage!
We have a very serious problem. Even a stranger came up
to Dr. Espisto (one of my speakers) and myself and said,
“Could you tefl me why so many people seem to be coming
down with MS?° During a visit to a hospice, a nurse said
that six of her friends, who were heavy Diet Coke addicts,
had all been diaynosed with MS. This is beyond coincidence!
Here is the problem. There were Congressional Hearings
‘A AS AM t in
Since this initial hearing, there have been two subsequent
hearings, but to no avail. Nothing has been done. The DRUG
é i i]
there are
the PAT RED!
_ At the time of this first hearing, people were going BLINC.
T hangl in a ‘am f
b Formaldehyde is
grouped in the same class of drugs as cyanide and arsenic
— DEADLY POISONS!!! Unfortunately, it just takes longer
to quietly kill, but it is killing people and causing all kinds of
neurolugical problems.
rei n thi It ts NOT
A DIET PRODUCT!!! The Congressional record said, if
imakes you crave carbohydrates and wut Me my FAT”. Or.
Roberts slated that when he got palients off , their
average weight loss was 19 pounds per person. The
Formaldehyde stores in the fat cells, particularly in the hips
and thighs. ©
fi
ASPARTAME is especially DEADLY FOR DIABETICS. All
physicians know whal wood alcoho! will do to a diabetic. We
find that physicians believe that they have patients with
RETINOPATHY, when in fact, itis caused by Aspartame. The
A ! causing
may patients to go into a coma. Unfortunately, many have
died.
People were telling us at the Conference of the American
Callene af Physicians. that thev had relatrves that switched
i
ro Saccha *° to an Aspartame product and how that relabve
hc’ eventually gone into a coma. Their physicians could not
Set the blood sugar levels under control. Thus, the patients
Bullered acute memory loss and eventually coma and death.
; é
EMORY LOSS is due to the fact that Aspartic Acid and
enylalaine are neurotoxic without the other amino acids
und in protein. Thus it goes past the blood brain barrier
Ind deteriorates the neurons of the brain. Dr. Russell
Baylock, Neurosurgeon, said, “The ingredients stimulates
p neurons of the brain to death, causing brain damage of
Brying degrees. Dr. Blaylock has written a book entitled
EXITOTOXINS: THE TASTE THAT KILLS” (Health Press
#-800-644- 2665). Dr. H.J. Roberts, Diabetic Specialist and
v Work Expert on Aspartame poisoning, has also written a
Book entitled “DEFENSE AGAINST ALZHEIMER'S
BISEASE” (1-800-814-9800). Dr. Roberts tells how
partame Poisoning is escalating Alzheimer's Disease, and
: deed itis. As the hospice nurse told me, women are being
Bnitted at 30 years of age with Alzheimer's Disease. Dr.
Baylock and Dr. Roberts will be wriling a position paper with
@ne case histories and will post it on the Intemet. According
® the Conference of the American College of Physicians,
He are talking about a PLAGUE of neurological diseases
used by this deadly poison”.
1. Roberts realized what was happening when Aspartame
mas frst marketed. He said, “his diabetic patients presented
hemory loss, confusion, and_ severe vision loss”. At the
nlerence of the American College of Physicians, doctors
Bimitted that they did not know. They had wondered why
Pizures were rampant (the Phenylalaine in Aspartame
eaks down the seizure threshold and depletes Serotonin,
lich causes manic depression, panic attacks, rage and
plence).
st hefore the Conference, | received a FAX FROM
ORWAY, asking for a possible antidote for this poison
ause they are experiencing so many problems in their
oh This “Poison” is now available in 90 PLUS counines
ide. Fortunately, we had speakers and ambassadors
the eines from different nations who have pledged
Beir help. We ask that you help too.
int this article out and warn everyone you know. Take
thing that contains Aspartame back to the store. Take
Re "NO ASPARTAME TEST and send us your case history.
Ipssure you that MONSANTO, the creator of Aspartame,
U hoy dead it is. They fund the American Diabetes
fSocialion, American Dietetic Association, Congress, and
2 Conference of the American College of Physicians. The
York Times, on November 15, 1996, ram an article on
Mew the Amnerican Dietetic Association takes money from
P food industry to endorse their products. Therefore, they
» nA AEA ame adAitnane neo tall ahnred thaic Eanl tn
ASPARTAME DISEASE is partially the cause to what is
behind some of the ws of the Ooo Storm health
oan Aanecininn eraihit Several thousand pallets of Diet
Drinks were shipped to the Dessert Storm troops.
(Remember heat can liberate the Methanol from the
Aspartame al 86 degrees F). Diet drinks satin the 120 degree
F Arabian sun for weeks al a time on pallets. The service
men and women drank them ali day long. All of their
symptoms are identical to ASPARTAME POISONING. Dr.
Roberts says “consuming Aspartame at the time of
conception can cause birth defects”. The Phenylalaine
concentrates in the placenta, causing mental retardation,
according to Dr. Louis Elsas, Pediatrician Professor Genetics,
at Emory University in his testimony before Congress.
In the original lab tests, animals developed brain tumors
(Phenylalaine breaks down into DXP, a brain tumor agent).
When Dr. Espisto was lecturing on Aspartame , one physician
in the audience, tne, a neurosurgeon, said “whon they remove
brain tumors, they have found high levels of Aspartame in
them”.
STEVIA, A SWEET FOOD, NOT AN ADDITIVE, which helps
is the metabolism of sugar, which would be ideal for diabetics,
has ‘ been aporoved & ietan supHIEMe:nt Oy {ne FDA.
For years, the FDA has outlawed this sweet food because of
their loyalty to MONSANTO.
If it says “SUGAR FREE” on the label -- OU NOT EVEN
THINK ABOUT IT!
Senator Howard Hetzenbaum wrote a bill that would have
warned all pregnant mothers and children of the dangers of
Aspartame. The bill would have also instituted independent
studies on the problems existing in the population (seizures,
changes in brain chemistry, changes in neurological and
behavioral symptoms). !T WAS KILLED BY THE
POWERFUL DRUG AND CHEMICAL LOBBIES, LETTING
LOOSE THE HOUNDS OF DISEASE AND DEATH ON AN
UNSUSPECTING PUBLIC. Since the Conference of the
Ainerican College of Physicians, we hope to have the help
of some world Ieaders.
(Again, please help us. There are a lot of people out there
who must be warned, “please”* let them know this
information.)
SORIA ESTO A APR TY oe TARR BN ded nants OPER
GOO ONION Peer
eR RR RE SARTRE EG
ABE MO PRIM
Ji fetal OS tar Oyan ht ewtchaae? nine States Ife +
i ais 9d A De pics 2 ba SERRE SN ee
eee
|
TO ALL DIET POP POP (Diet Pepsi, Diet Coke, etc.) AND NUTRA-SWEET AND
“EQUAL CONSUMERS:
The "sugarless" sweetening agent of most diet drinks, toothpastes, chewing
gums, and other substances engineered by the food industry contains a synthetic
compound called Aspartame. Once in the body, Aspartame breaks down to
aspartic acid, phenylalanine and methyl-alcohol. Methyl-alcohol has long been
known to be severely toxic and a cause of blindness in humans. Aspartic acid
and phenylalanine are essential amino acids which occur naturally and are
needed in the normal human physiology. Amino acids occur in nature
predonunantly in one form, the so-called L-form. In this form, amino acids can
be absorbed and utilized by the body. D-forms of the same amino acids block
the action of the natural amino acids and are toxic and destructive to human
health. The studies that lead to the approval of Aspartame were only perfonned
on Aspartame that came fresh out of the refrigerator in the laboratory. However,
it has long been shown that when Aspartame is ingested, it warms up, mutates
and breaks down into the D-forms of aspartic acid and phenylalanine.
‘Aspartame coristitutes one of the most severe threats to the westem world at
Present, more so than radiation, organic toxins and heavy metals.
Here is a list of illnesses that have been shown to be caused by the ingestion of
Aspartame:
Neurologic: Atypical facial pain, confusion, dizziness, headaches,
insomuua, paresthesias, convulsions, hyperactivity, tremors, memory loss,
seizures, MS-lype symptoms. After exposure of a sensitive individual to
Aspartame (i.e, chewing “sugarless* gum or drinking Diet Pepsi), it
usually takes several months until recovery begins. However, most of
these symptoms are reversible up to a certain stage. At later stages,
malignant or benign brain tumors occur which usually result in death (or
other health problems).
0 -..
Psychological: Depression, ansiety, irritability, paneling changes.
Musculoskeletal: Severe joint pains, neck pain, low back pain, migraine
headaches, sciatica, GI symptoms (abdominal pain, nausea, diarrhea, food
allergies).
Skin: Severe itching, raslies, herpes-type outbreaks.
“hest é chest fan pet leita; sus ; Tachyen —_ hap ebewsiion
-. ———_—: oe ee ee
® sd . . ads .
, eae Ors: S week e waa os* & 58 P
3- meena, —_
Endocrine/ Metabolic: Aggravation of diabetes and diabetic neuropathy, _ ie,
paradoxic weight gain or weight loss, hair loss, hypoglycemia, menstrual
irregularities, infertility,-excessive thirst, fluid retention,-hypothyroidism,
goiter. »
Eye: Tunnel vision, eye pain, blurred vision, blindness, tearing, dryness,
retinopathy.
Ear. Tinnitus (ringing), vertigo, hearing loss.
Aspartame was approved by the FDA in 1981 based on fraudwent and faulty
studies. Immediately after the introduction of Aspartame, the incidence of
peunary beain lymphomas increased, aud shortly after that, the rise of more
coounon brain cancers skyrockeled, and has ever since (the increase in brain
cancers in the last ten years has been approximately 500%).
Aspartame Las been shown lo also cause bladder and related cancers and tc
contribute to chronic fatigue, multiple chemical sensitivities, Alzheimer’s disease
and chronic pain. A good publication on the subject is by H. J. Roberts, Clinical
Research 136 #3, 1988, 489 A. A good book written on the subject is by the same
author, Sweet'ner Dearest, by H. J. Roberts, M.D., sunshine Sentinel Press, Inc.;
PO Box 8697, West Palm Beach, Florida 33107; phone number. 407/832-2409. -
Please don't ask me why Aspartame has not been taken off the market since it is
so dangerous. In the past, government and industry have never shown much
interest in protecting the public, especially when everyone is getting paid well.
Beyond that, as the philosopher Schopenhauer said decades ago:
"Truth is always going through three stages:
First, it is ridiculed;
Then it is violently opposed;
Then it is accepted as being self-evident"
oO OM vwtter'
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[ro
Abstract
Title
Increasing brain tumor rates: is there a link to aspartame? [se
comments]
Author
Olney JW; Farber NB; Spitznagel E; Robins LN
Address
Department of Psychiatry, Washington University Medical Sct
Louis, MO 63110, USA.
Source
J Neuropathol Exp Neurol; VOL 55, ISS 11, 1996, P1115-23
Secondary Source !D
TOXBIB/97/093657;
Abstract
In the past two decades brain tumor rates have risen in severa
industrialized countries, including the United States. During tr
brain tumor data have been gathered by the National Cancer |
from catchment areas representing 10% of the United States
population. in the present study, we analyzed these data from
to 1992 and found that the brain tumor increases in the Unitec
occurred in two distinct phases, an early modest increase that
primarily reflect improved diagnostic technology, and a more r
sustained increase in the incidence and shift toward greater’
malignancy that must be explained by some other factor(s).
“BSHealthWatch- Library - TOXLINE Search Paue 2 of 2
Recent Additions tumors, the artificial sweetener aspartame isa promising cand
Clinical Trials explain the recent increase in incidence and degree of malign:
Recent Drug Approvals brain tumors. Evidence potentially implicating aspartame inc!
an early animal study revealing an exceedingly high incidence
brain tumors in aspartame-fed rats compared to no brain tum
aesindaioatee concurrent controls, the recent finding that the aspartame mo
Cit to recommend has mutagenic potential, and the close temporal association
<r ati (aspartame was introduced into US food and beverage marke
several years prior to the sharp increase in brain tumor incider
edscape Network malignancy). We conclude that there is need for reassessing t
lick here to go to carcinogenic potential of aspartame.
hedscape Professional Language
Eng
om. Catthe facts:
bag tram
gS Retin ay Publication Type
JOURNAL ARTICLE
CAS Registry Number
0 (Sweetening Agents); 22839-47-0 (Aspartame)
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HeatttPitch
a ee ee
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Abstract
Title
Aspartame intolerance.
Author
Garriga MM; Metcalfe OD
Address
Mast Cell Physiology Section, National Institute of Allergy and
infectious Diseases, Bethesda, Maryland.
Source
Ann Allergy; VOL 61, ISS 6 Pt 2. 1988. P63-9 (REF: 32)
Secondary Source !D
TOXBIB/89/086740;
Abstract
Aspartame is a food additive marketed under the brand name
Nutrasweet. Aspartame is a white, odorless, crystalline powd:
consists of two amino acids, L-aspartic acid and L-phenylalani
180 times as sweet as sugar. The Food and Drug Administrati
(FDA) first allowed its use in dry foods in July 1981 and then
.approved its use in carbonated beverages in July 1983. It has
subsequently been approved for use in a number of materials
including multivitamins, fruit juices, stick-type confections, bre
mints, and iced tea. The FDA requires the statement
“phenylketonurics: contains phenylalanine on labels of food pr
containing aspartame because individuals with phenylketonu
q CBStlealth Watch- Library - TOXLINI: Search Page 2 of 2
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= Medscape Professional.
Language
judged to be free of long-term cancer risks. Aspartame is not
under certain conditions including baking and cooking, and
prolonged exposure to acid conditions. In such situations it los
sweetness. Products formed from aspartame include its com;
amino acids (phenylalanine and aspartic acid), methanol, and
diketopiperazine (DKP). Animal studies show DKP to be nontc
Methanol occurs in small amounts and does not exceed that fc
during consumption of many foods including fresh fruits and
vegetables. FDA's Center for Food Safety and Applied Nuttritio
(CFSAN) monitors aspartame’s safety in part through reports
adverse reactions. After aspartame was approved for use in
carbonated beverages, the FDA received an increased numbe
reports concerning adverse reactions related to aspartame. T
Centers for Disease Control (CDC) reviewed these reports, wt
included complaints of neurologic, gastrointestinal, andallergic
reactions (ABSTRACT TRUNCATED AT 250 WORDS)
Eng
OS
Publication Type
CAS Registry Number
JOURNAL ARTICLE; REVIEW; REVIEW, TUTORIAL
0 (Dipeptides); 22839-47-0 (Aspartame)
HOME | HELP | CONTACT US | ABOUT_US | PRIVACY POLICY
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: RSHealthWatch- Library - TOXLINE Search ICé f a G Page 1 of 2
Mfticle Collections
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ference Tools
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o “ete oe Ss» Pies me aoe ee te ca -
aly At You Sirvesacy, Cut?
& Or Searct
4 TO
Abstract
Title
Health Hazard Evaluatior: Report HETA 86-035-2224, Nabisc
Brands, Inc., Seville, Ohio.
Author
Burr GA; Bernard BP
Address
National Inst. for Occupational Safety and Health, Cincinnati,
Hazard Evaluations and Technical Assistance Branch.
Source
Govt Reports Announcements & Index (GRA&I), Issue 24, 19¢
Secondary Source ID
NTIS/PB92-229079
Abstract
TD3: In response to a request from the United Food and Com:
Workers Union Local 880, an investigation was begun of poss
airway irritation symptoms among workers exposed to the artif
food sweetener aspartame (2283947C) at N2bisco Brands, In
(SIC-2099) in Seville, Ohio. Aspartame had been used as a f
additive in sugar free products since 1983 at this facility. A ser
on site surveys was conducted to evaluate work practices, ass
employee exposures to airborne dusts, and conduct a medical
evaluation. No relationship was found between airborne aspai
exposure and respiratory symptoms or changes in peak “xpire
sBticalthWatch- Library - ‘TOXLINE Search OS oO
Bent Additions
LThals
Magent Drug Approvals
: " A Friend
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4
aach
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cick hare
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res.
op SG
ES
| ay
Sponsor
Bs.
such as wheezing, shortness of breath, or chest tightness recc
the time of peak flow measurements and the presence of aspz
No dose response relationship was found for respiratory symp
recorded during peak expiratory flow rates and exposure to
aspartame. The authors conclude that there was no evidence
occupationally related lower respiratory disorder at this facility.
authors recommend that improvements be made to local exha
ventilation in several areas of the facility, and also recommend
implementation of a respiratory protection program.
ee ee ee me Oe a ee a a
Keywords
Occupational safety and health; Environmental surveys; Toxic
substances~industrial medicine, Ventilation, Occupational exp
Food additives, Food industry, Inhalation, Toxicity, Respirator
system, Dust, Asthma, Sweetening agents
ee aaeen«©»©,
eee cee Se ——S
: “r
You geta check-up every yoar - cis j
n° 5 on f Sure d a,
Pe ree ee eR
HOME | HELP | CONTACT US | ABOUT US | PRIVACY POLICY
€ 2001 Medscape, inc. | weew.CBSHeatthWatch.com | Terms of Use
rformance Review
cCubipa tops
( FOODS.
PEGGY MADIGAN REVIEW PERIOD FROM: 3/1/95 TO 3/1/96
TRAFFIC CLERK COMPONENT: SPC OPERATIONS - SEVILLE PLANT
PERFORMANCE RESULTS
SPONSIBILITIES & OBJECTIVES ACHIEVEMENTS wand Sovaas
e shipping orders from Distribution Order | Peggy continues to do an excellent job in this
1. Confirm inventory availability, responsibility. She has been a key to the JIT X lw
le shipments, prepare Bills of Lading,
fify load counts on all outbound
nts.
ule incoming/outgoing trucks for finished,
packaging materials. Maintain
with trucking dispatchers of preferred
base to assure schedules are followed.
nd maintain shipment data into
ry control PC to relieve warehouse
inventory, generate lot breat.down
lists, and establish record for all
by distribution warehouses,
tion and balance of T-change reports to
process in the cross docking by identifying
inventory availability and matching needs with
the orders. She works with production to
ensure inventory availability. She maintains a
consistent shipping schedule. OS&D are &
maintained at a division low.
Peggy effectively maintains a good working
partnership with the carriers and effectively
schedules materials to facilitate the smooth
daily operation of the department.
£
maintained on a timely basis. Peggy was
instumental in developing and monitoring th
method for entering cross dock material to
allow its’ tracing through our shipment history.
This responsibility is handled daily at a high
level of efficiency. <~ 2 ao * 4, ovp
All shipment data transactions are oy was)
e
This responsibility is effectively handled on a
daily basis. Peggy has maintained an effective
communication flow between Seville and all
required parties.
ie
m!
ee i 5
PRAEGER ’ a!
formance Review
o t P
PEGGY MADIGAN - PAGE 2 REVIEW PERIOD FROM: 3/1/95 TO 3/1/96
COMPONENT:
PERFORMANCE RESULTS
ONSIBILITIES & OBJECTIVES
ACHIEVEMENTS
DS | CM | EF | ov
OF
5 maintains warehouse log irito
ftware to show location and
date of finished and Packaging
for proper stock rotation.
d schedule all miscellaneous
. including MSO shipment. daily
Bir freight shipments, and backup
on these shipments.
tain files, and function within an
MD productive office environment and
er departments as required.
applicable policies, procedures,
gulations, and consults with
=e Supervisor Conceming issues,
4
Igi>blems or developments.
ished goods inventory count and
at
The tracer system is updated on a daily basis
and Peggy maintains effective contro! Over all
transactions involving stock rotation of
finished goods. The Packaging system is tess
effective due to timeliness issues beyond
Peggy's control.
Peggy handles this area of responsibility on a
timely basis. Paperwork is accurate and
shipments virtually always go on time.
ete daa * ot tre -dusl
Peggy has been a valuable and effective team =
member in promoting cross-functional <——
responsibilities across departments. Her own
office is very professionally maintained.
Peggy effectively follows all procedures of the
job. She brings ail applicable issues to her
Supervisors attention on a timely basis.
Peggy has become a very effective count
team member and does considerable research
to resolve inventory issues.
- wk we arwt - ae.
poten bata
A Vaaoey
ormance Analysis
1. FUNCTIONAU/TECHNICAL EXCELLENCE
PLANNING AND ORGANIZING
FICIENT DEVELOPMENTAL | EFFECTIVE X | COMMENDABLE | DISTINGUISHED
propery arganure and Orgarazes and manages mos! Ptans and manages sil phases of | Demonstrates a high degree of Extremely skilled at developing
aauigned aciribes phases of routine tasks well ssugnments wall Carelutty ald for orgamzing and managung and scheduling even the mos!
vehze resources Usually etiadtiahes plans which conssders time frames to even Compt ureque and comptex
Coes not properly outline requirements and target maxurmure opersting efiicsency Maintames hagh efficsency by assignments. Maintains
work. Gates. Requires some assistance eatabkaheng propecit schedules to efficiency and
and tollow-up on complex ensure mammum wazation of productraty by allocating
ateignmens avaiable resources. resources wath unusual
oflectreness
PLES Daily organization of shipping schedules, including shift of locus from two shift operation to one shufl. instrumental in scheduling of cross docks to
ize JIT. Matches customer direct shipments with production schedules
CONTINUOUS IMPROVEMENT
EFICIENT | OEVELOPMENTAL \ | EFFECTIVE | COMMENDABLE ] DISTINGUISHED
of iry to eMpsOve Looks to enprove eflectveness Seeks to enprove busmess Skilled in senting, posshomng Excets in developing creatwe
of acevites Does and efficiency of aciraes. Needs | processes through apphcation of and developing unproved methods to maurruze buwness
any new sdeas or | guidance mn wnplementng bes! practices/competive business processes and eflectweness in terms of cost.
unprove the quakty of bussness alternative methods wtuch to mmplement ailernatrve work ability to posdion and
processes enhance efiency, quabty and methods that ssgnificantly improve | wnplement
semnce. productredy. quaisty and sence concepts in all aspects of
busmness processes and
interactions.
PLES implementation of more efficient paperwork flow for cross dociang. Design of pallet bcket format for cross docking to mesh wath current traceabulty.
whereby code breakdown for shipments also rekeves inventory in one siep
FINANCIAL MANAGEMENT (IF APPLICABLE)
PDEFICIENT | OEVELOPMENTAL | EFFECTIVE | COMMENDABLE | DISTINGUISHED
. 4 ever, monitors Usually maentans cos! controts tMauntains eflecive cos! controls Stalled at accompirsteng Excels in manageng costs
or mamtaers Cosi but. af bres exceeds budgetary and rarely exceeds budget. objectwes while operating withen through the judicious use of
Contunuaily exceeds lumnsis Requres some atastance Readily produces sirategees for budgetary conatsamnts. Always resources. Can be counted on
in identifying Opportunies to reducing oF svoiding cost: vathout | tools for opportunities to improve to find innovatrve methods to
= (educe of avordd cous compromramg quehty. the bofioen ere whete wise aming reduce costs and elamnaw
AMPLES: NWA
©
E TEAMWORK/CROSS-FUNCTIONAL EFFECTIVENESS
a TEAMWORK
DEFICIENT X | DEVELOPMENTAL | EFFECTIVE | COMMENDABLE | DISTINGUISHED
awate Of fetpons~ve tO Mauntarns good relasonshsps and Mawniaens and improves rapport ctreehy develope and maertains Excephonaly adept st
of coworkers, comacts in suppor of business wath outesde agences. chents. produciwe buiness relahonshpe encourageng collaborate
and outsude sgenciss. actwbes Needs some help and coworkers to promote Skilled af encourageng open aad efforts and obtaireng
lo cooperate m the fetobang problems ar gasmung company wteresis. Successfully constructive Communcalions to enthwsiosiic cormmmernents.
ge of information wath acceptance of eas o1 plans avoids unnecessary solve problems or promote ideas Mighty successful in
Unable to get slong controntakons by rescbng Gaus lashng commaments trom espporing business efforts
6 op others through understandeng of cient
needs and company
PLES: Needs to expand the commurucation process between Selwaen Seville and corporate Gainbution to positively impact the order change system and the
9 of cross dock avadabiity Communicates well with hourly employees to faciitate the shipping process Yusdsa bh fafa. Thr tard
medusa AT at Se ees ee Caer a. to wily Cay one
seer &
bd
— otrml e@ est ee aE rere
CROSS-FUNCTIONAL EFFECTIVENESS
CIENT | OEVELOPMENTAL | EFFECTIVE X | COMMENDABLE _| DISTINGUISHED
pHporc 1 a}Or Follows through on mosi cross- Successhully implements cross - Actwely develops and follows Excets at faciitating the
fagath other funcbon a! functional efforts. Usually functional goals. Readity through on cross-functional development and successful
: not understand Communicates wssues and communicates tasves and objectives. Skilled at execution of cros<-tunctional
rhonal impkcations of | wnpacts of activities to increase wnpacts of activities and communicating sues and objyectrves. Unu ailly ainiled
avareness. Hes some difficulties | encourages participative decision | impact of activities and al nfuenceng rseues and
in the implementation of major mating developing siralegies to combine | impact of activities through
cross-functracal processes and capabilities management
Fosters perticipatwe decision
4 making.
: ES:Grealty expanded role in inventory process and reconciliation. Trained hourly employees to function as a back-up for her and did much traning to
i hourtys knowledge and hands on ability in computer systems. oo mela Velen cord Qc
9 til, PERSONAL/EMPLOYEE DEVELOPMENT
3 PERSONAL DEVELOPMENT
CIENT | DEVELOPMENTAL | EFFECTIVE | COMMENDABLE | DISTINGUISHED
: d to learn new
. Ges latie to denisty and
" Dees ant eset
feedback.
WALES. Completion of Associates Degree in night school during extreme transition in both her work life and personal iife. ay agg 2
py #5 i affects her job, and willingness and desire to learn more. ™) >
. C ov sped BIT ras a dow wf Urs ? Hac, £
3 EMPLOYEE PERFORMANCE (IF APPLICABLE) Vue. Br erat aaa
ICIENT _| DEVELOPMENTAL | EFFECTIVE Lc NDABLE STINGUISHE
. dentity ov Develops gosis and objectives, Provides specific, measurable Ensures that clear. measurable Excets in developing goats and
WER-2!e work goals OF but may not aweys achieve and relevant objectrves for work goals and performance obyectves wihwch are always
p expectations to comrmutment from subordinaies. subdordmaies. Obtains thew standards have been defined for speciic and stainable, yet
no effort to define Standards for measuring commitment to objectives and Staffs major actraties. Skilled n challenging. Obtains
slandards. poriormance are not atweys siandards. Performance oblawming commediment to commament to objectives and
clearly defined. measures are ciealty defined. objectives and slandards. standards by actwely wvohang
[ staff in thew development.
RCS WA
| EMPLOYEE DEVELOPMENT (IF APPLICABLE) ©
ICIENT | OEVELOPMENTAL _| EFFECTIVE | COMMENDABLE | DISTINGUISHED
r 0 assis! employees Supports subordsnates’ effons to Parucipates with subordinates in Skilled in helping employees Exceptionally eflective in
developmen further deveiop job skulls through ‘ne denufication of develapmen developmen! needs Wentdying development needs
iatle to provide pemcipatiion m professions! needs. Encourages thew Reguiary prowdes ging/supporting
. es, 4 development acineies. Needs pamespauon m professional and to further develop through the indrndual growth and
lormance or a@ssisiance in identhying personal development actwites coaching, ¢ development of subordinates
{ c Gevelopment needs, formutats Prowdes follow-up coaching and challenging work assignments Orsplays interesi, enthusiesm
Pg plans and applying coaching and other learning Opportunies and inspires subordwnates to
a
é
, ES NA
LEADERSHIP EFFECTIVENESS (iF APPLICABLE)
ICIENT _ | OEVELOPMENTAL X | EFFECTIVE | COMMENDABLE | OISTINGUISHED
Commurcate a Vision 18 usually commurucaied Communicates a clear vision and | Develops and communicates a Ext emmoty eflectrs af creating
ment to goats bul is noi aivesys Clear. Has obtans cormmmamen to goeis end | clear wsion whch promoles and erucutating a cleer wsr0n
plans is not Gitficutty budding Crechbility end action plens. Establishes and Comwriment to goals and action which inspwes comeuiment to
Unebie to developing the commament Masntaans Credebiiity and provaies plans. Buids credibility, trusi and | goes and scten plans. Highly
Getegate decisios necessary to acteeve gosts others with decmior matong mutual eapect skilled af busichng confidence
Liends the ability of others to k apportumsdies. indréduais are decia:on making authority. is able | by empowering ethers with he
make decruons motrveted to perform to create a leadershep authonty to make decialons.
anmronmnent wheren indraduats: Successful af cresting an
are haghly motewated to pertorm. ermaconmnant of rxdievechial 3 aif
motresbon.
ES
ely trained hourly employees to become more systems oriented using PC programs within the department.
-6-
PERFORMANCE SUMMARY
3
. as
z eggy has Continued to do an excellent job on all of her job responsibilities and odjectives. She has excelled in other
as required as a result of changes within the organization. Her Steady performance has allowed the department to
ion efficiently in all areas.
| tA -unlhd prio wle al Licwn bu, sltidiele
a icky ie ao a alla ond mle a it
be Loos the onl hilly nese to .
ytaals nphorvegansty take ga patina dmg dealin vou,
os CM EF Ov OF
LL RATING X
4 DEVELOPMENT PLAN
# Refer to the Performance Analysis and Development Planning Guide to identify strengths and development needs.
ths: Needs:
ing Technological updates and appropriate training
izing Teamwork concepts
m Solving
ifying Opportunities
3 Targeted
"4 ACTION PLAN ~ Completion
a Training Programs, Job Assignments, Coaching Activities Date
TIONAL/TECHNICAL EXCELLENCE
into planned bar coding technology. ongoing
ify uses and action plans for new technology. ongoing
frame interfacing ongoing
Putials (. 199l coutd on meee develrpunzut of now cm Lak
ORK/CROSS-FUNCTIONAL EFFECTIVENESS
stronger relationships with distribution personnel. _ June 96
stronger role in leadership of the department. - fear hr pur prths Aralireed eta ongoing
em Tees esti he rly mol adilibirnrndt peor xara
MPLOYEE DEVELOPMENT
ability Ushers ,
Setting
iser Signature Date Approval! Signature Date
ee Signature Date
Employee Comments
For additional comments, please attach addendum.
a A
i Pye FIC
igan, Margaret
Valaitis, Maryellen
iew
OS of December,1996 12:41
gust a quick follow up to our brief conversation this morning. | checked your personnel file and you did
ign off on your 95 perfor7nance review.
e will file away the 96 review prepared by Bol) Byers.
e gain, apologize that Darrell did not provide you a copy of the review earlier. ma
you have any questions or concerns, plesse let me know.
ENS tena ROE A ONCE
Page 1
= Vea es 868 OOS 8 8S Be NO) OO ieee he Sa ah. le Sad» Tal ty had in ps ; :
taal rte baits isehuantin , ia i.
aa : DATES AND REASONS FOR ONE ON ONE CONTACTS OR DOCUMENTED
DATE: 1996 CONTACTS
3 MANAGER: TIM AULT
tee "
:
S
cf
; i
g
2
a
i
g
j
S
5
i
5
&
SHLON
S.LNHQNOdSAY
ating again by asking for her to let me know when she plans to or has worked overtime. ido
want to be surprised by overtime marked on a time sheet.
dnt AOR RNY
’
; oS. leg ie oN
US
notes from the 9-18-96 meeting and again reviewed them with her. | stated again, it is not a
matter of her working overtime that is considered to be the issue at hand. It is an issue of not
communicating with me regarding why the overtime needs to be worked or why it was worked. |
set the expectation again for Peggy to notify me of overtime needed or overtime worked. | am
flexible enough that | do not even need to be notified 100% prior to the overtime being worked. |
simply want to know when and why, prior to the time sheet being turned in. Once again | restated
that the overtime work is not why we are having these meetings. | simply want to be able to better
understand what she does and by doing so, better enable her to do her job.
She did not officially log into her computer and | had to use my password for the shipping
employees to use during the day. Peggy's password expired and the computer could not be
accessed until it was reset by the help desk. Peggy then reported off from work the following day.
When she returned on 10-24-96, | approached her and told her what had to happen to get into her
computer. | also asked her why she left work and didn’t tell me. She stated that she was under
way too much stress, and that it was just best for her to leave for the day. | told her it was
inappropriate for her to leave and not let me know, or give someone else the responsibility for
11-25-96 A meeting was held with Peggy to discuss her working overtime without
notification to me. This is the 3rd time this topic has been discussed with Peggy. | anticipated
that Peggy would be upset with me so | asked Maryellen Vailaitis to set in on the meeting as a
witness. | began by going back over the prior two meetings with Peggy to review my expectation
of overtime notification. | then showed Peggy her time sheets where she had worked overtime
and had never notified me of such. Peggy became extremely defensive and indicated that | do
not have any right whatsoever to question her on why she works overtime. She again began to
state how valuable she is to the Nabisco organization and this plant. She indicated that she is
doing the work of four people and that | should be happy that she is doing it so well. Peggy said
that not a single person in this plant knows what she does and if she left, the shipping department
would not function. | broke in and brought Peggy back to why we were having the meeting in the
first place. | want to know why she has to work overtime and how | can help reduce her work
load. Peggy stated that | don’t care about her but only want to eliminate her overtime. | revisited
two situations where | did respond to her needs or request.
1) Condition of the shipping departrnent. (Smoking, temperature, and swearing)
2) Her request to alter her work hours so she could attend to her father in the afternoon.
Peggy fired back that “legally” we had to honor her requests for altering her work times so she
could assist her father. Maryelien then stepped in and reminded Peggy that “legally” we could
have made her file her request via the Family Medical Leave route. But instead, we choose to
acknowledge her request in a much simpler and humanistic way. She asked, we granted. Peggy
then stated that it was not her that wanted smoking eliminated in the shipping office. It was Jean
Bolling, the new scheduler. | reminder Peggy that was one of the reasons she used to move into
Bob Byers old office. Smoking was one of the irritants that she claimed bothered her M.S.
condition. | indicated to Peggy that this violation of a basic communication expectation has now
become a performance issue and would be noted during her review. | then restated the
expectation of overtime notification to Peggy. She refused to comply and indicated that a one
time blanket notification would be sufficient. And if | was so interested in information from her, |
could come to her and get t She would not take the time out of her busy day to update me on
shipping events or overtime situations. ~eggy then stated that she would fix this once and for all
without having to notify me of anything. She would simply stop working the overtime. | then
responded to her that by doing this would only spite herself and not resolve this conflict. | stil
must have communication from her as to events taking place within the shipping department.
Two listening checks were performed on Peggy to have her indicate what she had heard in the
- 45 Og ESTE
meeting. Once again she responded that | am taking away her overtime. At this point, i
. point, it
obvious to myself and Maryellen that the meeting was not improving and that Peggy had missed
the entire focus of all three meetings. | indicated that the meeting was over. But the expectation
of overtime communication was still in place and would be taken seriously.
tat Stl
chcotlatiil DS.
POy Ce TN ete ee are oo ee ee)
:
1997 Meeting Documentation File For Peggy Madigan
Production Manager. Tim Anit
January ~
Tuesday 1/7/97 - Confronted Peggy regarding the medical status report im her file. The file
- requirements such as climate controlled working conditions within her work arca. At this time Peggy
Wednesday 1/15/97 - Gave Peggy 2 copy of the job accommodations request form and her packet for
comaplebon of her performance self apprarsal | asked Peggy to complete her self apprarsal, posipon
description, and job analysis profile. ] also covered the job accommodations form and ssked her to
February
Tuesday 2/4/97 - Met with Peggy to discuss her responsibilities for completion from the warehouse /
crossdocking meeting. Peggy is to input accurate arrival dates of all inbound orders into B1 using the
Thursday 2/20/97 - Met with Peggy to discuss reconciling an ongoing inventory balance discrepancy with
Knox 3500 / 3502 products. Peggy was asked what she needed from me in the form of resources or time
to reconcile / search / locate the mussing inventory. Peggy responded with the need for quiet ume. I asked
Peggy if she could come in to work on Saturday, 2/22/97, to spend a quiet day in the process of looicing for
the lost inventory. Peggy responded that she could not work weekends and that she wes not going to work
any overtime to locate the product unless I instructed her to do so.
Tuesday 2/25/97 - Met with Peggy t0 follow-up on her statement of no weekend overtime work She
imdicated that working the 5 days during a regular work week is difficult enough for her considering that
she has MS, and that an additional day would be too much for ber physically. She indicated that she
Moreile needs to pay closer attention to checking the load tally shects. Apparently Mike had made a
couple of errors and disagreed with her with why this needed to be done. Peggy asked if | would convey
to Milke the importance of accuracy on the tally sheets.
going to make ber job more difficatt. She said that Bob began to make up lies about her and brought them
to my attention to get ber 1a trouble. 1 asked Peggy why it took her this long to bring this to my afication.
| also indicated that we would get back together to discuss this issue but meed to complete the
appraisal. At the close of the review, Peggy signed her review but indicated that she was going to publish
an attachment voicing her disagreement with the review documentation. Peggy stated that Maryciien and
myself should be ashamed in the face of God for giving someone such a horrible review and raise. I
summarized the mecting by indicatig that we as 2 group, must get back together to discuss the sexual
eramement allegahon made by Pegyy
Friday 3/14/97 - Met with Peggy and Maryelien to discuss the allegation of Sexual Harassment made by
Peggy agamst Bob Saunders. ] asked Peggy how Bob physically harassed ber via a scxsal uature. Peggy
stated that Bob approached her desk and asked her if she would like to come to a toy party at his house.
He allegedly indicated that he was going to be the toy. I questioned Peggy as to ber response and she said,
“Is your wildest dreams.” 1 asked Peggy wiry it took so long for her to bring this information forward.
She stated that she did not want to get anyone in trouble and feit that she could deal with it. But whea she
turaed Bob down, Bob got mad at her and brought false info to myself regarding Peggy to get her im
trouble. We discussed why it is 50 important to not accept this type of behavior aad put together a plan to
correct this situation. 1) Bob Saunders will be invited to the communication mectings im April that deats
with Sexual Harassment in the work place. 2) Peg’s work area will be opened up by removing the file
cabinet enclosures that she has placed around her desk This way it is more difficult for someone to
sexually harass her when she 1s out in the open.
Friday 3/21/97 - Peg’s work area is redesigned by removing all the file cabinets to the wails and opening
leer work site wp to cliviate the enclosed arca.
April
to daily orders. Peggy was encouraged to continue attending and contributing to the weekly staffing
meetings held on Wednesdays. She also needs to continue publishing the weekly shipping status report on
outbound shipping performance. Peggy also must keep an updated Tracer log available for staging loads.
Peggy and I will meet once a week to go over these plans and pursue improvement in communications and
base warchouse performance. I questioned Peggy as to why she was telling other people in the plant that
she was going to be fired in three months. She stated that she was very nervous sbout her review and that
she needed to vent on someone the frustration of getting a bed review. I also asked Peggy why she was
parking in the plant handicapped parking spot. She stated that her Dr. gave her the handscapped
accommodations because how tired the heat of the summer makes her while she walks into the plant, and
that winter weather is extremely difficult for her to walk around in. | asked Peggy if she had any follow-
ep from her Dr. on ber testing she had performed back on January 24, 1997. She stated that she did not
but meeds to get with her Dr. to go over the results and fill out the job accommodations form. However,
now that her area has been organized, things are much better and she may not need amy accommodations /
changes wade wo ber arta. A follow-ap meeting was scheduled for Friday, April 11, 1997, to comtimue the
review process of ber action plans.
' Friday 4/11/97 - Met with Peggy to follow-up on states completion of the Performance Review Acton
Plans. Peggy had reported off for work on 4-7 & 4-8 of this werk The following items were covered.
1) Lauproving clean order % by reducing (-changes: Semmary. Peggy hed made copies of the t-changr
tracking sheet and was going to share the report during the weekly Wedmesday staff mecting on 4-9-97.
She was not called upon and did not speak up to share her info with the group. Peggy also did not have
anry t-chenge tracking data on Uae report. Issues from the previous week had aot been snatyzed and
Casegorized as to the reason. Missing the first two days put her behind schedule The plan is to have the
7) Comsmemcanoes: Paggy is to improve Trace: system scomacy aad report m-bound / outbound info to
myself weekly. The shepping performance of material movement was imcorporated into the weekly t-
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5) Openty commensncate: Peggy is doing a better job of communicating but is not doing so independently.
Information is shared but only upon request. Issues continue to flare up where communication is mot
being dhared with myself that should be brought to my aeation, i¢., Sexual Harassment, warehouse Sam
member performance complaints, and load cancellations.
scoummeodsinons ;
cat support her until she sepports me with info and follow-up from her Doctor regarding Ssamary's
testing at the Cleveland clinic. A follow-up meeting was set for 4-18-97.
rrecaday 4-15-97 - A mecting was called with Jean Bolling, Bob Gallatin, Peggy Madigan, and myscit,t0
put together a start-up plan for operations on 4-21-97. We were planming for what the plant would
comunit to deployment for off the line production on that date. This meeting was intended to
Pegey dropped her head and indicated to the group that this will never woek' We as a plant will mess i
up. We can't handle what we are doing now little lone bring in more work | asked Peggy why she would
say ths? Peggy response was that the additional product would require additions) warchouse <Sapioy’Ss
and that Management would nct add amy more help. I stated back to Peggy that at this time, you do not
even know what the volume of product will be. It could be 1 pallet a year or 10,000. Until we know the
facts, let's not shoot this down. | indicated that Peggy and I mced to discuss this one on one because I
would not accept a member of my staff being objective to growth of our business. The meeting continued
regarding the deployment planning of start-up products.
1) Temawork - During the 4-15-97 meeting noted above, Peggy expressed concerns about bringing ™
2) Comamunication - Peggy was not being timely im delivering the weekly shipping summary to mr. The
t-change sheets are comang m late. The report is now electrosic and Peggy simply needs to update and
see ae th was discussed how corporate is tracking our results and itis imperative that we have good
medical coadition and work space accommodations have been brought =p over smd Over. This mecting
See communicate with Peggy that I have for the last 7 months been patient and supportive of her wiiie
these issues were presented to me. | indicated that today would be the last time we discuss the matter watil
She is ready to prove the matter with a Dr. slip and completed jb sovommnnsston es I want to devote
5) und thanked was very tae in reaarning t me the Sllow-ep responses to her performance
review. Lee ornwed thas ieems such as this, should be very timely and sot kept to the last mime
May
Tharsday 5-1-97 - Meeting held with Peggy to review activity against ber review plan.
Peggy has begun to show in various categories associated with her performance. T-change
positive and lively. Determined to make a positive change to performance. The meeting summarized and
we planned our next meeting for the 9th.
srmarwiay 5-29-97 - Meeting held with Peggy was a brief review of progress against the Sovmlopass
plan. Nn ov ng was imerrepsed when Jean Bolling indicated that she neaded to eave Gc to an lines
Peggy and I summarized and scheduled a follow-wp meeting for Func 2 1997.
Wednesday 6-11-97 - 1st quadrant of Peggy's developmental plan was reviewed with 2 rollost of sew
action plans and expectabons. The QI peiformance experieaced 2 sight improvement is ower! sole
LTE Oe: Moreiic on the shipping cletk functions 90 be can beer aad more acourecly Peat US
clerical function in Peggy's absence from the desk. This action plant is to also improve Mike's accuracy
age wea Adah DOR aha IP ea hte
in the mornings before Peggy comes to work. This way Peggy docs not have to go back and check Mike’s
work which puts her behind schedule. Peggy asked whether or not in September we were going to get rid
of her. Her impression of the developmental plan was one that would end in termination of her
She also indicated that by training Mike to do her job aiso made it easier for the company to
fire her. I responded to Peggy's concerns with the following 1) The company docs mot wish to scparate
or terminate ber employment. However, if performance issues noted on her performance reviews do not
show signs / evidence to support coatimucd employment, then the decision would be made to cad
employment relations. 2) This is Peggy's choice. She can either fulfill the conditions of the
developmental plan or not. If “mot”, then her chances of maintaining employment was slim at best. 3)
The request to train Mike was originally hers. Her complaints that Mike was “screwing up” and making
her job more difficult, was what drove this category for an action plan. I then explained to Peggy that it is
Dot my desire to terminate her employment. It is my desire to fulfill the actions from the developmental
pian and improve performance. The process involved would be rigorous and very challenging I
summariz=d the meeting by re-extending the invitation for a scparation package for Peggy. I also gave
her the opportunity to go to Maryeilen Valaitis for clarification on amy topec that we had discussed.
Friday 6-27-97 - Meeting held with Peggy to go over a few items associated with her activities
surrounding the developmental action pian. The items discussed were, warehouse key performance
measurements associated with clean orders, Inventory reconciliation process, and communications.
Warehouse KPM"s: The clean order % is showing improvement in comparison to the first 3 months of
1997. However the function of dealing with replacements has not changed. Orders still comtinne to be
processr4 in an “Un Clean” manner which generates more paperwork for Peggy to locate and mcorporate
replaceuents into ber daily routine. In an attempt to correct this issuc, was discussed with Peggy that
the process of reviewing a bill musi be performed prior to going status 30 and to do this, we must work
with Carol Aane, product deployment, to understand the order entry process. Peggy has made little effort
to improve the inventory reconciliation process. Inventory discrepancies continuc to mount especially
around Knox finished goods. Discrepancies are being deferred to a trailing month instead of being
researched and addressed. Communications continue to be a struggie for Peggy. Overtime needs are not
communicated either prior or post overtime fulfillment. Peggy simply refuses to commumicate her work
needs to me but chooses to work the overtime and assumes that I should sutomatically know what she was
Closed.
JULY
Wednesday 7-2-97 - Meeting held with Peggy to discuss an event that took place during the Wednesday
Production meeting. In that meeting, Peggy openly attacked Danette Cozart fo- not including her im any
of the Safety Day events. Peggy even went to the point that she didn’t know anything about the day at all.
The follow-up meeting with Peggy de"cussed the following items:
1) Peggy's commeunscation in the Wednesdzy morming mecting comfirmed that she is mot improving as a
Team Player. To the point that Peggy's actions were counter productive to building working relationships
within the plant Peggy never bothered to involve herself or ask what she could do to help out. As a fact,
Danette did not inciude Peggy simply because Peggy has constantly complained that she acver hes cnough
time to get anything done. Peggy cmberrassed Danette in front of the plant salaried staff and showed no
sign of remorse. The request should have beca handled with Danette one on one.
2) Peggy communicated to the plant salaned staff that everyone needed to teil her what thesr schedules
were and every time that we were going to leave the plan. She was tired of dealing with all the
emergencies and could never find anyone. The follow-up to Peggy was again the same situation of
abenasties. Peggy pushed cveryone sway with her request. She brought vatec to herself while attactung
everyone else Peggy should have asked for a beter way of communicating our schedules when we arc out
Of phat 20 she can cffectivety Commmumcatr wiih OUDcTs Unat Call ineo the plane
3) Peggy atso communicated that the deployment process of cider emtry was gomeg to change. More
importantly she verbally attacked both Mark Perkins and Derreil Kroeger, prior production mgrs., that
they mever listened to ber and mever betped correct Unctean Order rssucs. The onty ome that ever hstened
to me was Tim Aak, “ME™. Peggy exptamed that she was gomg to be able to perform ber ticks and
make the orders clean The way Peggy cxplained the process was incorrect. What was going to actually
change was how we as a shipping department view aad provide mput on the orders. The “Trick” that
Peggy must perform is a2 act of commumicaton with CarolAnne Lanfenberg. This is an arca that Peggy
has difficaity with. is
Mecnag Summary
1) Peggy further placed herself into a Non-Team Player role.
2) Embarrassed and bemlisted Dancte m front of her peers.
3) Eabanced the aegatrve perception with Mark and other members of the staff
4) Attacked prior production managers with a tack of support.
5) Info shared om deployment changes was mcorrect.
The meeting ended with the following statement made to Peggy. Today is a physical example of you mot
mecting ary expectations. I do not see you beng capable of mecting azy short term and or long term
expectahons. The road we are current on will not sustain your employment with Nabesco. | do mot sec
you making positrve performance changes in athtude / team work to meet the expectat_oms of the
development plan. If you want to exit Nabisco nght now, without going through the process of
scrmimation, let me know. I cam arrange for » transition package to be made today. If you choose
otherwise, a guaramtee of a package 15 mot assured if your employment 1 tenmmated
Thursday 7-3-97 A meeting was beid with Peggy with Mark Perkins, Ptant Manager, Maryelien Vataztrs.
H.R Mamager, and myself, in Mark Perkins office. The mecting was designed to ensurc that Peggy was
hearing and understanding everything that has been going on with ber for the past year. Peggy indicased
that she was not being communicated to by aryscif of her poor performance and back of teasswork issecs.
Mark imdscated to Peggy that the situation was extremety senows and that ber performance has and ts
unacceptable. Peggy's response was that “no ome has cver told me this. ‘This is a huge shock to me.”
Mark sumearized the mecting and indicated to Peggy that he is supportive of the role that I was
providing and would continue his support of me as we progressed through thes process.
Friday 7-11-97 A mecting was beid with Peggy to discuss compluance to the stcps outhmed by ber
1) Cover off the action plans from the 7-9-97 warehouse mecting that Peggy 1s responsible for.
This text is long and has been trimmed here. Open the source document for the complete record.
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.