03-08-2016 Justin Biggs Testimony - Vukadinovich Trial

Stacy L. Drohosky, FCRR, CRR, RPR
(219) 852-3462 - stacy_drohosky@innd.uscourts.gov
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
HAMMOND DIVISION
BRIAN VUKADINOVICH, )
)
vs. 2:13-CV-144)
)
HANOVER COMMUNITY SCHOOL )
CORPORATION, et al. )
TRANSCRIPT OF EXCERPT TESTIMONY OF JUSTIN BIGGS
March 8, 2016
BEFORE THE HONORABLE PHILIP P. SIMON
UNITED STATES DISTRICT JUDGE
A P P E A R A N C E S:
FOR THE PLAINTIFF:
BRIAN VUKADINOVICH
1129 E 1300 N
Wheatfield, Indiana 46392
(219) 956-2462
FOR THE DEFENDANTS:
MARSHA VOLK BUGALLA
CHAD M. BUELL
Frost Brown Todd LLC
201 North Illinois Street, Suite 1900
P.O. Box 44961
Indianapolis, Indiana 46244
(317) 237-3800
Court Reporter: Stacy L. Drohosky, FCRR, CRR, RPR
Official Court Reporter
United States District Court
5400 Federal Plaza, Suite 4005
Hammond, Indiana 46320
(219) 852-3462
Proceedings reported by stenotype. Transcript produced by
computer-aided transcription.
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JUSTIN BIGGS- DIRECT
(The following is an excerpt transcript of the testimony
of Justin Biggs called in the plaintiff's case in chief:)
THE COURT: All right. You all may be seated.
Mr. Vukadinovich, you may call your next witness.
MR. VUKADINOVICH: Thank you, Your Honor.
I call Justin Biggs.
THE COURT: Mr. Biggs, if you would, please come
forward, sir.
Please raise your right hand, sir, to take an oath.
(The oath was administered.)
THE WITNESS: I do.
THE COURT: All right. You may be seated.
JUSTIN BIGGS, PLAINTIFF WITNESS, SWORN
DIRECT EXAMINATION
BY MR. VUKADINOVICH:
Q. Could you please state your name and spell your name,
please.
A. Justin Biggs; B-, as in boy, I-G-G-S.
Q. Are you currently employed?
A. Yes.
Q. Where is that?
A. Michigan City area schools.
Q. What is your position?
A. I am an assistant principal.
Q. And how long have you been employed there?
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A. This is my second year.
Q. Were you previously employed to that? Prior to going to
Michigan City.
A. I was previously employed, yes.
Q. And where was that?
A. Hanover Community School Corporation.
Q. What was your position there?
A. Principal.
Q. Were you my principal?
A. Yes.
Q. Now, prior to coming to Hanover Central, where were you
employed?
A. The School City of Hammond.
Q. Did you enjoy your time at the School City of Hammond?
A. I did.
Q. Are you loyal to the School City of Hammond?
A. I don't understand.
Q. Do you feel any sense of loyalty because they employed you
and you worked there for a period of time?
A. I don't --
Q. Are you grateful for that?
A. Sure, I'm grateful for the employment.
Q. You couldn't say if you feel like you were being loyal to
the school system?
A. I'd like to answer your question. I just don't know how.
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Q. If there was anything you could do to make the School City
of Hammond feel better, would you do it?
A. Not anything, no.
Q. Okay. But you would do some things?
A. It is hard for me to understand how I would make a whole
school city of Hammond feel better. I don't understand.
Q. You said you wouldn't do anything, but then would you do
some things? Were there some things you would say, yeah, I'll,
you know, if I can do something to make them feel better, if I
can, I will?
A. I don't think so, no.
Q. You would not do that?
A. (No audible response.)
Q. But a little while ago you said that there are any -- some
things you would do. Are you changing your answer?
Q. The bottom line is, would you do anything -- is there
anything that you would do for the School City of Hammond if it
would make -- if you know that it would make them feel better?
A. I don't understand how I could make a whole school city
feel better, so I can't answer the question.
Q. Okay. What were the positions you held with the School
City of Hammond?
A. I was a dean, and then I was assistant principal.
Q. Where were you the assistant principal?
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A. At Morton High School and then Hammond Clark Middle
School/High School.
Q. Now, how is it that you came about being employed at
Hanover?
A. I applied for the position.
Q. Okay. And what position did you apply for?
A. Principal.
Q. For what school?
A. The middle school/high school at the time.
Q. That's the position you applied for?
A. Yes.
Q. Okay. I'm looking at Plaintiff's Exhibit No. 72.
THE COURT: Is this document in evidence or not?
MR. VUKADINOVICH: Yes, Your Honor, it is.
THE COURT: Is it, Noel?
MS. BUGALLA: We don't have a record of it.
DEPUTY CLERK: I don't show it.
THE COURT: Approach the bench.
(Bench conference.)
THE COURT: Here is the deal: You have to stop
representing to me that things have been admitted into
evidence --
MR. VUKADINOVICH: No, it is not in evidence.
THE COURT: -- and it has not.
I just asked you, has this been admitted into evidence,
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and you said, yes.
MR. VUKADINOVICH: Your Honor, I thought you meant is
it in the evidence book. I'm sorry.
THE COURT: There's a term of art I'm using. Has it
been formally admitted into evidence.
MR. VUKADINOVICH: No, it hasn't. I meant in the
book.
THE COURT: Fair enough. It is important.
MR. VUKADINOVICH: Yes. Yes, sir. Thank you.
(End of bench conference.)
Q. Mr. Biggs, this document, Plaintiff's Exhibit No. 72,
could you describe that document.
A. Yes. It is an e-mail message from Karleen Adler -- from
me to human resources at Hanover, et cetera.
Q. Now, you just testified that you applied for the principal
position at the middle school, is that correct?
A. At the middle school/high school, yes.
Q. Yes. Now, this document here, is this your actual letter
of application for employment at Hanover?
A. That's an e-mail message as -- a message to Ms. Adler
regarding a different position.
Q. Okay. And what position was that for?
A. Assistant principal at Jane Ball Elementary School.
Q. At the elementary school, correct?
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A. Yes.
Q. But you said you applied to be the principal at the middle
school and the high school?
A. I did.
Q. Well, which one did you apply for first?
A. Assistant principal at Jane Ball.
Q. But when I asked you what position you applied for, you
didn't say at the elementary school. You said at the high
school.
MS. BUGALLA: Your Honor, I'm going to object.
THE COURT: That's argumentative. That's not --
that's not how it went down, Mr. Vukadinovich. That's
argumentative. Sustained.
MR. VUKADINOVICH: Okay. I move to admit Plaintiff's
Exhibit 72.
THE COURT: Do you have any objection to 72?
MS. BUGALLA: No.
THE COURT: All right. Seventy-two is admitted.
(Plaintiff's Exhibit No. 72, previously marked, was
admitted in evidence.)
Q. So then at some point then you did become the principal at
the middle school/high school, correct?
A. Yes.
Q. Okay. Now, were you the principal of both the middle
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school and the high school at the same time?
A. Yes, for the 2011-2012 school year.
Q. And were both the middle school and the high school within
the one building?
A. Yes, they were within one building. Although the middle
school was nearer the cafeteria than the high school, which was
closer to my office.
Q. And why are you no longer employed by the Hanover
Community School Corporation?
A. I accepted a position at the Michigan City area schools.
Q. Was there any push by Hanover to -- for you to leave?
THE COURT: Sustained.
Q. What position do you have with the Michigan City schools?
A. Assistant principal.
Q. But you were the principal at Hanover, is that correct?
A. That's correct.
Q. In status, wouldn't that be a lesser position?
A. I guess that depends on who's asking and whose question it
is.
Q. I'm asking you. It is my question.
A. Do I believe it is a lesser status? No.
Q. To be an assistant principal over a principal?
A. Correct.
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Q. But you were an assistant principal when you were in
Hammond and then you went to the principal position at Hanover.
Wasn't that an elevation in status?
A. Some would say that, yes.
Q. Okay. Well, if it was an elevation in status, if you went
back to assistant principal, wouldn't that be --
A. Again, I don't see it that way.
Q. All right. Are you making -- how much money are you
making?
Q. Are you making less money than you were making at Hanover?
MS. BUGALLA: I'm going to object again.
THE COURT: Overruled. I think that's fair.
THE WITNESS: No.
Q. So you took a position of an assistant principal with a
less paying position, is that correct?
A. No.
Q. That's not correct?
A. No.
Q. You took an assistant principal position at Michigan City,
correct?
A. Yes.
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Q. And it is a lower paying position, is it not?
A. No.
Q. You are making more money at Michigan City than you were
making at Hanover?
A. Yes.
Q. Did you make more money the first year you were at
Michigan City than you made at Hanover?
A. Yes.
Q. I'm looking at Plaintiff's Exhibit No. 73. Could you
please describe that document.
A. Yes. It looks to be my contract for the Hanover Community
School Corporation.
Q. When you were the principal, correct?
A. Yes.
Q. All right. And what does that contract call for pay?
A. It shows effective date July 8, 2011. Contract amount
$85,000.
Q. Okay.
MR. VUKADINOVICH: I move to admit Plaintiff's
Exhibit 73.
THE COURT: Any objection?
MS. BUGALLA: I guess not.
THE COURT: All right. It is admitted.
Seventy-three is admitted.
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Q. Okay. I'm looking at Plaintiff's Exhibit No. 74. Could
you please describe that document.
A. That appears to be a regular teacher contract for my
Michigan City area schools for -- it looks like beginning
August 15, 2014.
Q. Okay. Now, what's the salary for in that contract?
A. $78,000.
Q. But you were making 85 at Hanover, correct?
A. Yes.
Q. And you were making 78,000 at Michigan City. Isn't 78,000
less than 85,000?
A. There's two questions there.
Q. Were you making -- I asked you earlier, and you said that
you were making more money at Michigan City. But according to
this contract isn't that less -- isn't $78,000 less than
$85,000?
A. $78,000 is less than $85,000, yes.
Q. But you testified that you were making more money on your
job at Michigan City than you were making?
A. I do.
Q. Could you explain that.
A. Sure. Over the summer I'm given a stipend to run the
summer school program. I'm principal during that time, and for
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that I receive $10,000 additional.
Q. Okay. So that's an extra stipend position, correct?
A. Yes.
Q. As far as being principal, you were making less money,
correct?
A. No.
Q. As far as your actual contractual duties as principal, you
were making 78,000 at Michigan City, correct?
A. An assistant principal.
Q. Assistant principal.
A. And my total salary last year was $88,462 I believe.
Q. I'm talking about just for principal, not any stipends or
anything.
A. That's for principal because I do those two positions.
Q. Well, then why doesn't it say that in here?
A. That's my original contract, which is 78,000; but then I
also work over the summer, and that's an additional month's pay
at my hourly rate.
Q. At a stipend?
A. Yes.
Q. Okay.
MR. VUKADINOVICH: I move to admit No. 74.
THE COURT: Any objection to 74?
MS. BUGALLA: No.
THE COURT: It is admitted.
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Q. Before you went to -- when you left Hanover, did you apply
for any other jobs before you went to Michigan City?
A. I'm trying to think. Yes, there were a couple of
positions.
Q. Did you apply for any teaching jobs?
A. I don't recall.
Q. I'm looking at Plaintiff's Exhibit No. 75. Could you
please describe that?
A. It looks like a letter to River Forest School Corporation;
any available position, whether it is intermediate, assistant
principal, or art teacher.
Q. What is the date of it?
A. That looks like 2014.
Q. That's after Hanover, correct?
A. No, I was still employed there.
Q. Okay. But you were applying to be an art teacher at River
Forest, correct?
A. That was one of my letters of interest there, yes.
Q. Okay. And is an art teacher at River Forest, the pay
there, is it greater than a principal makes at Hanover Central?
MS. BUGALLA: Your Honor, I'm going to object. I
just don't see the relevance of this.
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Q. Were you happy at Hanover Central?
A. No.
Q. Why weren't you happy?
A. There were things that were difficult at Hanover.
Q. What was difficult?
A. This litigation, I think, was one. I think that was
primarily it.
Q. What was difficult about it?
A. It was difficult to undergo the constant defamation of my
character that you made me undergo.
Q. In what way?
A. By making up statements that I was alleged to have made
when I handed you that RIF letter.
Q. And then did you tell -- did you tell the Hanover people
that you did not make those statements?
A. Yes.
Q. When did you tell them that?
A. Must have been after I had learned of your statements to
that effect over the summer sometime.
Q. After I had been terminated?
A. Yes.
Q. Who did you tell?
A. I imagine, although I'm not certain, but the legal
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counsel.
Q. Did you tell anybody at Hanover?
A. I don't believe so.
Q. You didn't tell Ms. Kaiser?
A. I may have. I may have.
Q. Did you tell Ms. Dixon?
A. No --
Q. Why not?
A. -- I don't believe so.
I didn't speak with her on that level about this
particular case.
Q. What prompted you to speak to Ms. Kaiser?
A. Because it was litigation, and it was something that I
needed to speak with her about because of the attorneys
involved and the case as it went forward.
Q. Well, isn't the school board relevant there? Shouldn't
they know? They are your employer, correct?
A. I didn't have a clear line of communication with the
school board members that way.
Q. When you say you didn't have a clear line of
communication, what do you mean?
A. I did not directly address the Board members with respect
to my day-to-day operations.
Q. Could you have e-mailed them?
A. No.
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Q. You could not?
A. No. I would typically just speak with Carol, Ms. Kaiser.
Q. I asked you if you could e-mail them. Could you have
e-mailed them?
A. Was it physically possible for me to type in the e-mail
address, yes.
Q. Could you have called them on the telephone?
A. I don't know what their extensions were. I did have
Ms. Dixon's cell phone number. I do have that ability to
communicate.
Q. So you didn't have any ability to find out what the school
board members' phone numbers were?
A. I could have asked if I had chosen to do that, yeah.
Q. But you chose not to?
A. That's correct.
Q. How about Ms. Kounelis, do you know her?
A. I do.
Q. Could you have called Ms. Kounelis and said, Hey, I want
this particular school board member's telephone number?
A. Yes, I could have asked that.
Q. Could you have said to Ms. Kounelis, Could you please
leave a message for me for this school board member. I need to
talk to her about this particular thing?
A. I'm sorry. Could you repeat that.
Q. Could you have asked Ms. Kounelis to leave a message for a
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school board member, that you needed to discuss something with
the school board member?
A. I could possibly have done that, yes.
Q. But you didn't, is that correct?
A. That's correct.
Q. Okay. Now -- so the only person that you spoke to about
this was Ms. Kaiser, is that correct?
MS. BUGALLA: Your Honor, I believe that's a
mischaracterization of the evidence.
THE COURT: Sustained. I think he also testified
that he talked to counsel. That's sustained.
The question is stricken. You are admonished to disregard
it.
Proceed.
Q. What did you tell Ms. Kaiser?
A. I don't recall.
Q. You have any idea what you told her? Anything?
A. We spoke about lots of things. I can't say specifically
what I said with respect to that.
Q. You don't remember saying to Ms. Kaiser,
Brian Vukadinovich is making these claims about that I said --
you know, about the settlement with the School City of Hammond
and I called him an old man. You didn't tell Ms. Kaiser that?
A. I don't recall. If she already know -- or if she had
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already known or if it were even mentioned. I don't know what
her knowledge was our conversation would have been. I don't
recall.
Q. Well, how would she already know if you didn't tell her?
Did you tell anybody else?
A. No, sir. You wrote it in the e-mail, and that's how I
first understood that it existed.
Q. Okay. And that e-mail was from me to you, correct?
A. If I recall correctly, yes.
Q. Well, then how would Ms. Kaiser know it?
A. I imagine that I forwarded it on to the counsel and Board.
Yes, I must have forwarded it to counsel and to her.
Q. Did you forward it to counsel -- but you never forwarded
it to Ms. Kaiser?
A. I imagine that I would have. That kind of message I
probably would have sent directly to her.
Q. Would it have been on a school e-mail?
A. Yes.
Q. Do you know if that e-mail was ever provided to me in this
litigation?
A. I know that every e-mail I have ever written from the time
I started work at Hanover until now has been provided to you.
Q. Including the e-mail that you forwarded to Ms. Kaiser
about --
A. Whatever I wrote, it was there.
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Q. Would you have any problem with bringing that e-mail here
and showing it to the Court?
MS. BUGALLA: Your Honor --
Q. At what point did you forward that e-mail out? What
proximate time period? What date was it?
A. If it happened, which I believe it probably did, I would
have forwarded it immediately.
Q. I'm sorry?
A. Immediately upon my receipt of it.
Q. Okay. All right. Now, how many e-mails did I send to you
particularly about the comments and the litigation?
A. Several. I don't have an exact number.
Q. Did you respond back to me on any of them?
A. No.
Q. Why not?
A. Because they were attacking my personal character, and I
didn't believe that a response was warranted because it would
probably just fuel further argument.
Q. But you chose not to deny the statements, is that correct?
A. Not to you.
Q. You chose not to deny the statements back to me, correct?
A. I chose not to deny them to you, that's correct.
Q. When somebody makes an allegation against somebody, you
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don't feel that if the allegation is unwarranted there should
be a denial?
A. I'm sorry. Could you repeat the question.
Q. If you feel that an allegation is being made against you
that is unwarranted, you don't feel that a denial of it is
appropriate?
A. There's a lot of negatives in that question, so could you
please rephrase it. I don't understand.
Q. If somebody makes an allegation against you that you feel
is not -- wasn't true or whatever, you do not feel that it is
appropriate to deny and say, I did not make those statements,
you're harassing me, or whatever? You didn't feel that would
be appropriate?
A. I didn't feel any communication with you, sir, was
appropriate at that point.
Q. Okay. Was I still a teacher at the school?
A. Yes.
Q. So you said that you didn't feel that any communication
with me was appropriate at that point, correct?
A. Yes.
Q. Did you have any communication with me after that?
A. Yes.
Q. But you just said that you didn't think any communication
was appropriate after that.
A. That's correct.
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Q. Okay. What communication did you have with me after that?
A. Things relating to your behavior and disrespect.
Q. Tell us about that.
A. The first notice that I gave to you, I handed you the
letter; and you took it and left. And then I had to call you
back in to sign and date it, which you did. And at that point
you asked me, you know, if there was anything about your
performance that had to do with this letter, and I said no, and
you thanked me and left. From that point forward, there were
several instances where you behaved in a way that I felt was
disrespectful.
A. The first was the receipt that you asked me for in my
office. Initially, I refused because it was accompanied by a
letter that was extensive, and I didn't want to sign something
that I didn't agree to. Then after reading the letter and
acknowledging that, I signed the receipt, and I gave it to you.
When I presented it to you in the classroom, I gave it to you;
and then you stared at me and yelled, Anything else? And then,
again, as I backed away in front of this classroom, you yelled
at me again, Anything else? And that was one instance.
Q. I'm gonna stop you there for a second. Did you say that
you didn't want to sign the receipt for that letter because it
was expensive?
THE COURT: He said it was extensive.
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MR. VUKADINOVICH: Oh, I'm sorry. I thought you said
expensive.
Q. What was extensive, the receipt or the actual letter?
A. The letter was a page long. The receipt accompanying it
was very short.
Q. So it was a page-long letter. You thought that was
extensive?
A. Yes.
Q. And what was the letter?
A. I don't have it in front of me. I can't recall.
Q. You don't remember what it was?
A. I believe it dealt with a request for your personnel file
in my office.
Q. Okay. That's for my records of my employment, correct?
A. Those were some of the records, yes.
Q. Okay. And are you required to give me my personnel
records when I ask for them?
A. Yes.
Q. And you said that it was an extensive thing that you chose
not to accommodate with me at the time, correct?
MS. BUGALLA: Your Honor, I'm going to object. He
did not -- the testimony was not that he did not accede to the
request. The testimony was that he wished to review the
request.
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THE COURT: All right. Ladies and gentlemen, you've
heard the evidence. It is for you to decide what your -- in
your collective judgment what the evidence is in that regard.
So proceed.
Q. Now, at what point did you then change your mind and come
into my classroom? How long of a time period from the time I
was in your office and asked you to sign the receipt for the
letter to the time you came into my classroom?
A. Half an hour.
Q. Half an hour.
So did you talk to Ms. Kaiser between that time about
that, about me being in there?
A. No.
Q. Did you fax the request to Ms. Kaiser?
A. No.
MR. VUKADINOVICH: I just need a minute, Your Honor,
to -- are these the exhibits that have been admitted?
THE COURT: Yes.
Q. Mr. Biggs, this is Plaintiff's Exhibit 33. It has been
previously admitted. What is that?
A. This is -- appears to be a letter to me from you, and the
first line says, "I request that the following information be
provided for my inspection and copying pursuant to IC 5-14-3."
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Q. And what's the date of that letter?
A. May 8.
Q. Is that the one that I'm asking for my personnel file and
so forth?
A. I believe so.
Q. All right. Now, look at the upper left corner there.
What do you see there?
A. It is blank. Next to your name? Twenty-four doesn't
show.
Q. There it is.
A. "May 8, 2012, 15:42, Fax 374-4408."
Q. That was May 8. That was the same day that this happened
in the classroom, is that correct?
A. I believe so.
Q. Okay. And then whose fax number is that?
A. I want to say it is my own -- or the Hanover High School.
Q. So you're saying somebody faxed that to you?
A. It's possible. Honestly, I don't recall.
Q. Okay. So -- well, according to this document here, this
letter was faxed by somebody to somebody, correct?
A. It appears to be, yes.
Q. Okay. Well, do you know who that was?
A. I don't.
Q. You didn't fax this?
A. I don't recall.
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THE COURT: He's already answered he doesn't know.
Q. Okay. Now, when you came into my classroom, was actually
class in session?
A. Yes.
Q. And was I teaching the class?
A. I think you were reviewing a video or playing a video or
about to play a video.
Q. Classroom related?
A. I don't know.
Q. Well, you were in the room, weren't you?
A. I did enter the room, yes.
Q. It wasn't a Bugs Bunny cartoon, was it?
A. I don't know.
Q. Well, if it would have been a Bugs Bunny cartoon, would
you have said something to me?
A. I can't guess.
Q. Would that be appropriate to be showing a Bugs Bunny
cartoon in class?
A. It depends on the course.
Q. Well, I was the industrial arts teacher, correct? You
didn't bother to see what was on the video?
A. I didn't look. I didn't notice. I don't recall what was
there.
Q. All right. Now, you said that I yelled at you, is that
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right?
A. Yes.
Q. What did I yell?
A. "Anything else?"
Q. Okay. Did you tell me what you were doing in the room
when you walked in there?
A. I believe I handed you the letter and I said,
Mr. Vukadinovich.
Q. Okay. Now -- so would you say it was a real loud yell?
A. Yes.
Q. How far away from me were you standing from me?
A. About 10 feet.
Q. Ten feet. Okay.
And I yelled real loud?
A. Yes.
Q. Okay. Now -- and how long did you stand there at that
point in time?
A. I wasn't standing. I was backing away.
Q. I'm sorry?
A. I was backing away.
Q. Okay. Well, how long did you stay in the room?
A. As I backed toward the door, I waited -- I didn't wait. I
backed and I found the door and I left.
Q. And then was I written up for that?
A. Not as far as I know.
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Q. Did you tell Ms. Kaiser what happened?
A. Yes.
Q. When did you tell her?
A. Soon thereafter.
Q. Okay. Do you recall ever calling me into the office and
giving me a letter on behalf of Ms. Kaiser?
A. Yes.
Q. And then do you remember what the letter said?
A. No.
Q. Did you discuss with Ms. Kaiser about when you came into
the room?
A. I'm not sure.
Q. Did you tell Ms. Kaiser what happened when you came into
the room?
A. Are you speaking about the video --
Q. Yes.
A. -- and the receipt?
Q. Yes.
A. Then yes.
Q. And now, in my classroom, is there a video camera in
there?
A. I don't know.
Q. Are there video cameras throughout the building in the
school?
A. Yes.
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Q. Okay. So if there was a video camera in the room, you
could have actually have had a video of this where you say I
was yelling at you in front of the students, that would
actually be on the video if there was a camera in the room,
correct?
A. I can't guess because I don't know if there was a camera
in there.
Q. So as a principal, you didn't know if there was a camera
in my room?
A. I don't know now.
Q. You what?
A. I don't know now if there's a camera in that room.
Q. Okay. And you didn't know at the time?
A. I don't recall. There is 105 cameras in that building.
Q. Okay.
Then was there any other instances?
A. Instances of what?
Q. Of anything where I disrespected you or anything like that
along those lines?
A. Yes.
Q. Okay. Go ahead.
A. There was a meeting where you spoke brusquely to me when I
poked my head in. And there was a meeting that we had, I
believe it was May 22nd, that dealt with my intent to address
you about an issue with a meeting with the special education
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cooperative.
A. I received an e-mail message explaining that you had been
rude toward the presenter and that you had left. I called you
in to discuss that.
MR. VUKADINOVICH: Can I take these over with me,
Your Honor?
THE COURT: Sure. Just make sure they return to the
table when you're done.
Q. You said that the e-mail you received stated that I
disrespected the presenter, is that correct?
A. Yes.
Q. Okay. Do you remember -- did the e-mail say it was me?
A. No.
Q. What did it say?
A. From what I recall, it gave a description of the person
that had made a comment and then left. I don't think that the
presenter knew who you were; and after some investigation, I
discovered that it was you.
Q. And tell us about this investigation.
A. From what I recall, I spoke with -- or I looked at the
sign-in log. I asked for some clarification from the presenter
and from the special education director at the time, and from
the description that I could glean, it was you.
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Q. Was my name ever stated by anybody?
A. I don't -- I don't understand, sir.
Q. In your investigation to try to figure out who this person
was that disrespected the presenter, did anybody say it was
Brian Vukadinovich? Did anybody say that to you?
A. It is possible. I don't -- I don't know.
Q. The person that actually sent the e-mail didn't say it was
me, correct?
A. That's true.
Q. And you don't know if anybody else said it was me?
A. It could have happened. I don't know.
Q. Okay. Did you know all the people that work in the
Hanover building?
A. Yes, I know most of them.
Q. Do you think it would have been hard to find out if it was
me or anybody else?
A. No.
Q. Mr. Biggs, I'm gonna show you Plaintiff's Exhibit No. 13
[verbatim] and ask you to describe that, identify it.
A. That looks like a message from me to Candi Cress and
copying Carol Kaiser and Jane Winkoff, subject is regarding
"your failure to respond." Candi -- yes, I do recognize it as
an e-mail.
Q. You said the subject is, "your failure to respond" --
THE COURT: Is this in evidence?
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MR. VUKADINOVICH: Yes, it has been, Your Honor.
THE COURT: Okay.
MR. VUKADINOVICH: It is 113.
THE COURT: Let me just display it for the jury then,
so they can follow along.
MS. BUGALLA: Is that 13, Mr. Vukadinovich?
MR. VUKADINOVICH: 113.
MS. BUGALLA: 113.
Q. Who was trying to get a response?
Q. You said this is an e-mail about a response. Who was
trying to get a response?
A. An e-mail -- e-mail messages are about responses. I don't
understand.
Q. Now, what is she telling you in this e-mail, Ms. Cress?
A. Ms. Cress?
Q. Yes.
A. It looks like she's saying FYI, and she's forwarding me
this message.
Q. Okay. And then did you respond back to Ms. Cress?
A. Yes.
Q. And then what was your response?
A. You want me to read it?
Q. Yeah, please read it.
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A. "Candi, I'm so sorry to have brought you into this issue.
I believe, though I need to confirm with Carol, that you
needn't respond. I tried you yesterday, but it was after
hours. Is there a good time to call."
Q. Okay. So are you telling Candi Cress that she needn't
respond back to me about my concerns about what was happening?
A. I'm saying that I believe, though I need to confirm with
Carol, that she needn't respond.
Q. Okay. And then did you also tell her specifically -- did
you say to her that you're sorry that you brought Cress into
the issue? Did you say that in the e-mail?
A. That's implied, yes.
Q. Well, did you say that in the e-mail?
A. No.
Q. You did not say, I am so sorry to have brought you into
this issue, with an exclamation mark after it?
A. I did say that.
Q. Okay. So you said that you brought her in, correct?
A. Like I said, that's implied in what I'm saying. I'm so
sorry to have brought you into that issue, yes, that implies
that it was me.
Q. What were you sorry about?
A. Because she sent -- you sent her several messages that
were haranguing, disparaging, and, I felt, intimidating.
Q. Was I asking her about who this presenter was?
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A. I don't recall.
Q. Take a look underneath where it says, "Dear Mrs. Cress."
Read the first five sentences there.
A. It says, "Dear Mrs. Cress. As you know, I sent you an
e-mail on May 25, 2012, regarding an e-mail you sent to Mr.
Biggs on May 15, 2012, wherein you made certain accusatory
statements that have resulted in severe admonishments and
threat of job action against me."
Q. Okay. Just for a second, I want to stop you there. Is
there anything disparaging about that sentence?
A. You want me to characterize the sentence?
Q. You said that the e-mail was disparaging, and was there
anything disparaging -- I'm asking her about these accusations
that are being made, correct?
A. There's a couple questions there. I'm not sure how to
answer.
Q. Was that first sentence disparaging?
A. When -- yes. When you say that she made certain
accusatory statements that have resulted in severe
admonishments and threat of job action against me, that's
disparaging.
Q. Did she make any accusatory statements?
A. I'm sorry?
Q. Did she make any accusatory statements?
A. No.
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Q. Did I get called in -- you called me in on a discipline
for it off her e-mail, did you not?
A. No.
Q. We didn't have a meeting over that?
A. We did.
Q. Did you call me in for a meeting?
A. I did.
Q. Was it a disciplinary meeting?
A. It was not.
Q. The e-mail wouldn't say disciplinary meeting at the top?
A. The e-mail said it may be disciplinary.
Q. But you're saying it wasn't disciplinary?
A. That's correct.
Q. Okay. Did you ever find out who this person was that
abused the presenter?
A. You're assuming that there was someone who abused a
presenter, and I disagree with that.
Q. Didn't you call me in for that?
A. I didn't call you in to accuse you of abusing someone.
Q. Was there any other incidents after that?
A. After our May 22 meeting, there was another incident that
involved the -- whether or not you had administered a final
exam to all students at the allotted time.
Q. You remember the date of that?
A. It was around June 6, June 7; that was when our meeting, I
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believe, was.
Q. Was there anything that happened before that?
A. Lots of things happened before that. I don't understand
what you're asking.
Q. Tell us what they were.
THE COURT: You need to be specific. To just say,
what happened, in a three week period of time doesn't help him
in what you're trying to get at.
Q. Did anything happen on May 11? Was there an incident on
May 11.
A. Was there an incident on May 11?
Q. Uh-huh.
A. Can you please be more specific.
Q. Did you walk in -- did you know that I was having a
meeting with Ms. Kaiser on May 11?
A. Did I know ahead of time?
Q. Yeah.
A. I can't recall.
Q. Okay. Did you -- do you recall ever coming into the
meeting I was having with Ms. Kaiser?
A. I do.
Q. Okay. Do you remember if that was May 11?
A. Yes, it was.
Q. Okay. Well, how did you know about that meeting with
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Ms. Kaiser?
A. I must have heard about it from someone at the time.
Q. You know who that was?
A. I don't recall.
Q. Okay. And were you actually allowed to be in that
meeting?
A. Looking back, no, I was not.
Q. Okay. Well, looking forward, before the meeting, did you
check out -- did Ms. Kaiser tell you to come to the meeting?
A. No.
Q. So you just came on your own?
A. I did.
Q. And you knew I was in there with Ms. Kaiser, correct?
A. I did.
Q. Okay. And do you know why I was in there with Ms. Kaiser?
A. I know now.
Q. You didn't know at the time?
A. I don't think I was specific on exactly why you were
meeting.
Q. Okay. And what is it -- you said you know now. What was
the meeting?
A. I believe that you were discussing your continued
employment with Ms. Kaiser.
Q. Well, actually, not continued employment, correct?
A. Yes.
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Q. You made a decision for my employment not to continue,
correct?
A. I issued the letter that talked about a preliminary
decision, yes.
Q. Okay. And then that was my discussion with Ms. Kaiser as
you say, correct?
A. As I said, I was there for about 10 seconds and then I
left, so from looking back at the records, yes.
Q. Okay. Exactly what happened when you came into the room
when I was with Ms. Kaiser? Exactly what happened?
A. I entered the room. I asked Ms. Kaiser if she needed me
there. And you made some comments that were accusatory, maybe
loud, certainly not very kind, and saying that I needed to
leave.
Q. What were the comments?
A. I don't recall.
Q. Ms. Kaiser say anything to you?
A. She said I needed to go.
Q. You were told to leave by the superintendent, correct?
A. That's correct.
Q. Did you get in trouble for that?
A. I don't know what you mean.
Q. Did you get reprimanded for coming into a meeting that you
weren't supposed to be in?
A. No.
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Q. Did I? Did I get in trouble for it?
A. I don't think so.
Q. This has been previously admitted as Plaintiff's Exhibit
40. What is this document, Mr. Biggs?
A. It is a letter to you from Ms. Kaiser May 15th.
Q. Of 2012, correct?
A. Yes.
Q. And then on the bottom there, did you receive this letter?
A. Yes.
Q. Okay. And then does it talk about the incident on May 11
in the administration building?
A. It mentions an incident on May 11, yes.
Q. Is it fair to say that's the incident when you came into
the room?
A. Yes.
Q. Okay. Now, was there a threat against me in this letter?
A. No.
Q. Did it state in the letter that any further incident in
the above regard will result in a recommendation for
administrative leave?
A. That's what it says, yes.
Q. Is that a threat of adverse job action, administrative
leave?
A. (No response.)
Q. Would that be a threat of adverse job action to say to an
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employee you may be placed on administrative leave out of your
job, administrative leave? Would that be adverse job action?
A. You've asked a couple of questions there. I'm not sure
how to answer.
Q. Would the threat to an employee of an -- being placed on
administrative leave be considered an adverse job action?
A. I can't guess.
Q. Now, you're a principal -- you're an administrator in an
Indiana public school system, correct?
A. Yes.
Q. Have you ever heard the term "administrative leave"?
A. Yes.
Q. What is that?
A. It can mean a variety of different things. It could mean
anything from a conference to a sickness to some separation of
time during which an investigation takes place.
Q. And could it be for behavior; a penalty, a consequence?
A. I think it goes with whatever consequence comes, but
typically it is kind of a stay-put provision that comes when
there's an investigation going on.
Q. Well, in the context of this letter that you received a
copy of here, in that context, was this for a behavior thing, a
threat?
Q. When the superintendent, Ms. Kaiser, is telling me --
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she's talked about the incident in my classroom that you came
into, the incident in the office that you came into, and an
incident in the library, three separate incidents, and she's
saying to me that because of those incidents and anything
further that happens like that that it will result in
administrative leave to me, would you consider that to be
adverse job action, a penalty that I have been threatened with?
A. No.
Q. Is that something -- would you be happy to receive a
letter from your superior saying, all of this conduct here,
anything further, you're gonna be put on administrative leave?
Would you be happy to receive a letter like that?
A. I can't guess.
Q. Now, the letter you gave me for your decision -- you made
the decision, correct?
A. Yes.
Q. Okay.
A. Well, I made the preliminary decision.
Q. Was that also made in conjunction with Ms. Kaiser?
A. She sent me the letter.
Q. She actually sent you the letter?
A. Uh-huh.
Q. Okay. And then did the letter -- what did the letter say
to me?
A. I would have to have it up on the screen. I don't want to
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misquote.
Q. Was it a justifiable decrease in the number of teaching
positions?
A. Again, I can't guess without having it in front of me.
Q. Did you have any discussions with Ms. Kaiser about class
sizes in the schools at Hanover Central?
A. Yes.
Q. Did you have any discussions particularly about my
classes?
A. Yes.
Q. And what were those discussions?
A. They varied. We talked about enrollment. We talked about
the scope of the course. We talked about CTE, the career and
technical education. We talked about funding for different
courses. We talked about career preparation. I think that
was --
Q. Yeah, I'm gonna stop you for just a second. In terms of
actual numbers for the classes, what was talked about?
A. The numbers of yours and all classes that were on the
master schedule in terms of students' interest in taking those
courses.
Q. Okay. And what was talked about? What was said?
A. I explained --
Q. Was there a number given for we have to have so many
students in a particular class?
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A. No.
Q. There was no number at all for my class?
A. No.
Q. Okay. So was there any criteria at all for -- to decide
as to whether or not my classes should continue or not continue
due to a class size number? Was there any criteria for that?
A. You're putting things into the question that I don't agree
with so I can't answer.
Q. Well, you may not agree with it, but I'm asking you the
question. Was there any criteria, was there anything stated by
Ms. Kaiser to you or to you to Ms. Kaiser where it was stated,
this is what has to happen for this class to continue or not
continue in terms of numbers of students?
MR. VUKADINOVICH: Judge, I don't know how to be more
clear about it.
THE COURT: He's saying he doesn't understand the
question, so maybe you can try to break it up. I don't know.
Q. Did you have any discussion about student numbers for my
classes?
A. Yes.
Q. Okay. And what were those discussions?
A. What the numbers were? I mean, there were lots of
conversations about yours and other classes with respect to
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student course requests and where those would fit in which time
slots.
Q. Was there ever a specific number that was stated that said
we have to have this number of students for this class to
continue?
A. No.
Q. Now, I taught the Project Lead the Way classes at the
middle school, is that right?
A. Yes.
Q. Did you know about my Project Lead the Way training when
you were the principal there?
A. No.
Q. I'm looking at Plaintiff's Exhibit No. 80. Excuse me.
Yes.
THE COURT: Is this in evidence, Noel?
DEPUTY CLERK: (No response.)
MR. VUKADINOVICH: No, it is not.
MS. BUGALLA: I'm sorry. What number is this?
MR. VUKADINOVICH: This is No. 80.
MS. BUGALLA: Eighty.
Q. Could you please describe that.
A. It is an e-mail message from me to Dana Bogathy.
Q. And then what is the date of it?
A. April 3, 2012.
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Q. And what are you asking her?
A. I'm asking, "Is Brian Vukadinovich, do you know, trained
to teach PLTW?"
Q. And why were you asking her that?
A. We were looking at high school course requests and
accommodating those as far as I can tell.
Q. And did you get an answer?
A. I don't recall.
Exhibit No. 80.
MS. BUGALLA: No objection.
THE COURT: Eighty is admitted.
Q. You don't remember if she answered you back?
A. I don't recall.
Q. Okay. I'm looking at Plaintiff's Exhibit No. 81. It
hasn't been admitted.
THE COURT: Has not?
MR. VUKADINOVICH: Has not.
THE COURT: It might be helpful to try to admit the
exhibit, so when you are asking the questions the jury can have
an opportunity to follow along with you if it does get
admitted.
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MR. VUKADINOVICH: Okay.
Q. Could you please describe it.
A. Sure.
It is an e-mail message from me to Michelle Davlantis
May 1, 2012.
Q. And then I'm gonna take you to the first paragraph.
THE COURT: Are you gonna have an objection to this?
MS. BUGALLA: I'm looking at it.
THE COURT: Okay. Just take a minute to look at it
and that way the jury can follow along if you don't have an
objection.
MS. BUGALLA: Your Honor, I don't believe I have an
objection depending, of course, on how Mr. Vukadinovich tends
to use it. On the face of it, I don't.
THE COURT: Are you gonna offer it?
MR. VUKADINOVICH: Yes, Your Honor.
THE COURT: What number is it?
MR. VUKADINOVICH: It is No. 81.
THE COURT: All right. It is admitted. I will
display it for the jury. Go ahead.
Q. Mr. Biggs, in the first paragraph, it is starting at the
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third line where it says, "Arden Smith and Brian Vukadinovich,"
do you see that?
A. I do.
Q. What does that say?
A. That says -- do you want me to read the sentence?
Q. Yes.
A. It says, "Arden Smith and Brian Vukadinovich are currently
involved with the engineering branch of PLTW, so they a couple
of good options."
Q. So she's telling you that I would be a good option to be
what?
A. (No response.)
Q. To be what?
A. I'm just reading the sentence. I don't have the context.
Q. Yeah. It's in the second sentence on the top.
A. Are you asking me to do something?
Q. Yeah. Well, what is she telling you that I would be a
good option for?
A. It looks --
THE COURT: Just take a moment to read it to
yourself.
THE WITNESS: Okay. Thank you.
THE COURT: Yeah.
THE WITNESS: Okay.
THE COURT: What's your question, sir?
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Q. What is she telling you that I would be a good option for,
to be what?
A. In that paragraph it is saying that you would be a good
district delegate.
Q. For what?
A. For PLTW, Project Lead the Way.
Q. Okay. And then what was the date of that document?
A. That's May 1.
Q. Is that the day before you gave me the termination letter?
A. Yes.
Q. So you're being told that I would be a good option for
district delegate for Project Lead the Way and then you
terminated me the following day, is that correct?
A. Yes.
Q. Was there a mess going on with the student enrollment with
the students for the following school year, the 2012-2013
school year?
Q. There is a registration process with the students
registering for classes, correct?
A. Yes.
Q. Were you involved in that process?
A. Yes.
Q. Was there a mess going on?
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THE COURT: What do you mean? He doesn't understand
what you're talking about, "was there a mess?" That's too
ill-defined. You need to be specific.
Q. Were there problems going on to the point with
registration that you had to have discussions with the guidance
counselor?
A. There were problems.
Q. Yes.
A. There were -- yes. I did have discussions with the
guidance counselor.
Q. How about with any other administrators? For example,
Mr. Brooks. Did you have any discussions with him?
A. Yeah. Yes, I did.
Q. Did you specifically call him in to discuss the problems
with the student registration?
A. I don't recall.
Q. Okay. And were the problems with the students becoming
registered for the classes?
A. Could you rephrase the question. I'm not sure.
Q. The problems with the registration process, were there
problems with the students getting registered for classes for
the following school year, 2012-2013?
A. No more than usual. I think that -- problems, I think, is
severe to characterize that. I mean, we had course requests,
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and we were accommodating those. We were working them through
the schedule. You know, part of administration is dealing with
problems and finding solutions; so in answer to your question,
yes.
Q. And did you terminate the guidance counselor over the
problems with the registration?
A. I did not, no.
Q. Did you recommend termination?
A. I did not.
MR. VUKADINOVICH: I'm sorry. Excuse me.
Q. Did there come a time that you allowed another teacher to
put posters up around the school building to create interest
for students to sign up for his classes?
A. Yes.
Q. Who was that teacher?
A. Jason Yurechko.
Q. Who?
A. Jason Yurechko.
Q. These were previously admitted yesterday as No. 48. Is
that your signature on the bottom of that poster?
A. Yes.
Q. And then what were you approving?
A. That flier.
Q. And were there several different fliers?
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A. Yes.
Q. Okay. And you were approving the students to come in and
sign up for Mr. Yurechko's classes today, is that correct?
A. Yes.
Q. Okay. Was there a problem with Mr. Yurechko's enrollment
numbers in his classes?
A. His enrollment numbers could have been better. Was it a
problem, no.
Q. Did you fire him?
A. No.
Q. Could my enrollment numbers have been better?
A. Yes.
Q. Did I get fired?
A. Yes.
Q. Did I ask you to let me put the posters up around the
building?
A. You did.
Q. Did you let me?
A. No.
Q. Did I ask you to let me get on the PA system like you let
Mr. Yurechko?
A. Yes.
Q. Did you let me?
A. No.
Q. Why not?
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A. Your courses were already discontinued.
Q. So it was a done deal?
A. Pending Board action; but according to the schedule, they
were taken out of the course schedule.
Q. Okay. Pending Board action. Did you discuss that with
Ms. Kaiser?
A. Yes.
Q. What did she tell you?
A. I don't understand what you're asking.
Q. Did Ms. Kaiser tell you that it was a done deal that my
classes -- he can't do the posters and so forth because we're
not going to have his classes?
A. No.
Q. So why didn't you let me put the posters out?
A. Because your classes weren't on the schedule.
Q. But why weren't they on the schedule?
A. Because they were taken out.
Q. Why? Why were my classes taken out?
A. Because of the preliminary notice to discontinue your
contract for the next year.
Q. But what's the reason for that? Why did I receive that
preliminary notice? Why were my classes taken off the
curriculum?
A. In answer to your question, there were a lot of reasons
why your classes were discontinued. One of them was that the
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courses that you taught did not adequately prepare students for
careers, college, et cetera.
Q. Did you say that to me in the notice letter that I got?
You're gonna be fired because the courses you taught didn't
prepare the middle school -- did you say that to me in the
notice letter?
A. No.
Q. When is the first time that came up?
A. I don't recall.
Q. What else?
A. Don't understand your question.
Q. What were the other reasons that my courses weren't
continued?
A. Those were the reasons.
Q. You said there were many reasons.
A. Those were them.
Q. This is Plaintiff's Exhibit No. 100. It is an e-mail from
--
THE COURT: I want to make sure it is in evidence,
ladies and gentlemen.
MR. VUKADINOVICH: This one is not.
THE COURT: Okay. Proceed.
Q. So could you please describe that. Identify it.
A. Sure. It's an e-mail message from Karleen Adler to me.
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I'm copying Jennifer Grcich.
Q. You received that e-mail, correct?
A. It appears so, yes.
Exhibit 100.
THE COURT: Any objection to 100?
MS. BUGALLA: No objection, Your Honor.
THE COURT: All right. It is admitted. I'll display
it for the jury. You may proceed.
Q. Okay. Now, what is the e-mail all about?
A. I would have to read it. If you give me a moment, I'll do
that.
It appears that Ms. Adler is referencing a couple "issues"
as she says.
Q. Well, specifically, what is the subject of the e-mail?
What does it say for subject?
A. "Student counts."
Q. Student counts. Let's take a look. Is there a list of
teachers down there?
A. There is.
Q. What does the list demonstrate?
A. It is a list of teachers. That's as much as I can guess.
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Q. And then is it about student counts?
A. I would presume so given the subject title.
Q. You didn't follow-up on that e-mail?
A. I don't recall.
Q. Okay. Does it say, "Yurechko, first hour"?
A. It does say that.
Q. For student counts, correct?
A. Yes.
Q. Did he get fired?
A. No.
Q. Does it say, "Szanyi, third, sixth, and seventh hour,"
three periods?
A. Yes, it does.
A. No.
Q. Does it say, "Lechien, fifth hour"?
A. Yes.
A. Yes.
Q. For that?
A. No.
Q. How about Mr. Landis, is his name on there?
A. It is.
Q. He get fired?
A. No.
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Q. Of course my name is on there for removed, right?
A. It shows, "SRT, remove."
Q. How about Mosak, is her name on there?
A. It is.
Q. Does it say for first and second semester?
A. It looks -- it doesn't say first and second semester, no.
Q. It does not say first and second semester?
A. No.
Q. By Mosak?
A. No.
Q. Oh, "first hour, second semester"?
A. Yes.
Q. Did she get fired?
A. Not as far as I know.
Q. How many teacher's names are on there?
A. Do you want me to count everyone in the subject title too
or no?
Q. I asked how many teacher's names are on there for the
actual subject where it is talking about the student count
issues.
A. One, two, three, four, five, six.
Q. Out of those six teachers that are listed with student
count issues, how many of them got fired?
A. Two.
Q. For student count issues. Not for anything else, about
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anything else that might have happened, about something else.
For student issues, how many got fired?
A. I don't understand the question.
Q. Of these teachers how many got fired because there was a
problem with student counts in their classes?
A. Zero.
Q. I didn't?
A. You're asking me something that I dispute in your
question, so I can't answer that.
Q. So you're saying I didn't get fired because of the student
numbers in my classes?
A. That's correct.
Q. Student numbers didn't have anything to do with it?
A. That's not correct.
Q. You said it's correct but it's not correct. Did student
numbers in my classes, was that a reason that was used to get
me fired?
A. Yes.
Q. So out of that list of six, how many teachers got fired
for that?
A. Zero.
Q. Out of that list of six how many teachers got fired for
student count issues?
A. Zero.
Q. Not me?
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A. Not you.
MR. VUKADINOVICH: I move to admit 100 here.
THE COURT: I think it has been admitted already but
maybe not. Do you object to 100 if it hasn't been admitted.
MS. BUGALLA: No, Your Honor, I don't object.
THE COURT: If it hasn't been admitted, it is now.
MR. VUKADINOVICH: Thank you.
THE COURT: Mr. Vukadinovich, about how much longer
do you think you are going to have with this witness on --
MR. VUKADINOVICH: It is probably an hour.
THE COURT: Okay. You can keep going. We are gonna
break in 10 minutes.
Q. This is Plaintiff's Exhibit No. 99. It has not been
admitted. Could you please describe that.
A. It is a document that shows PowerSchool at the top. It is
hard for me to read much else. It says, "Teacher Schedule,
Spencer, Ryan."
Q. Okay. And for what school year was that?
A. I don't know.
Q. It is real hard to tell on there. Underneath where it
says "term," do you see where it says "term"?
A. No.
Q. Okay. Second column?
A. Yes.
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Q. Okay. Can you make out if it says "12-13"?
A. It looks like it says "12-13."
Q. You'd take my word for it if I said it was 12-13?
A. I would say so.
Q. Okay. I'm gonna direct your attention over to where it
says "enrollment" over to the right side?
A. Uh-huh.
Q. All right. Now, for this particular teacher is -- did he
have a class with zero students?
A. Who?
Q. This particular teacher Ryan Spencer.
A. I can't tell.
THE COURT: Would you give him the document because
it is just difficult to look at it on the screen?
MR. VUKADINOVICH: Yes.
Q. I'm sorry.
A. Okay. It looks like in the enrollment column for this
particular printout it shows a variety of numbers. Your
question was were there any of these rows and lines that showed
zero in the enrollment column? Yes.
Q. Is there any numbers in there with nine students in them?
A. Yeah, it looks like.
Q. Anything under nine students?
A. There's one that's six. There's one that's four.
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Q. So we have zero, nine, six, four students in a class,
correct?
A. If I recall what I just said correctly, then yes.
Q. That teacher get fired?
A. No.
MR. VUKADINOVICH: I move to admit No. 99, Your
Honor.
THE COURT: Mr. Vukadinovich, just to remind you,
once they've been admitted, I want them up here so we can track
which ones have been admitted and which ones haven't.
THE COURT: So this is a repository for those,
please.
Q. This document number 98 has not been admitted. Would you
please describe that document.
A. It appears to be a fax, although I can't say for sure. It
looks like maybe an e-mail message.
MR. VUKADINOVICH: I'm gonna hand it to the witness,
okay?
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THE COURT: Sure.
(Document tendered.)
THE WITNESS: Okay.
Q. What does the document say?
A. It says, "Begin forwarded message. From, Justin Biggs.
Date, July 4, 2012. To, Dana Bogathy. Subject, regarding info
for software."
I state, "There are 12 students in biotech, 25 or so in
biomed."
Then, "Happy Fourth of July. Justin."
Q. Okay. Now, you received that, correct?
A. Well, I sent that.
Q. Okay. You sent it. So you are telling somebody there's
12 students in a class, correct?
A. It appears so, yes.
Q. That teacher get fired?
A. Could I have a look -- can you put it on the screen again.
I'm not sure which teacher it was.
Q. (Complied.)
A. No.
MR. VUKADINOVICH: I move to admit No. 98, Your
Honor.
THE COURT: Ninety-eight is admitted.
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Q. This is document number 85. It has not been admitted.
Could you please describe that.
A. That's an e-mail from me to Nicole Satterfield, Thursday,
May 3, 2012. There it is.
Q. Okay. And did you actually -- is that a back and forth
between you and Nicole Satterfield?
A. I don't understand what you mean by back and forth.
Q. Is this an e-mail string -- on May 3 there are several
e-mails between you and Ms. Satterfield?
A. It appears that there's a dialogue there, yes.
Q. Okay.
Exhibit 85.
Q. Okay. Now, what is -- is Ms. Satterfield the guidance
counselor?
A. She is not.
Q. At the time she wasn't?
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A. At the time she was.
Q. But she's not now, correct?
A. Correct.
Q. Did she get terminated?
A. Yes.
Q. Okay. Now, is she telling you that a certain number of
students are requesting my classes?
A. Yes.
Q. Okay. And then what did you tell her?
A. I said, "Yes, we need to counsel them into other classes."
Q. But she's telling you they want my classes, is that
correct?
A. It says, "Fourteen students requested transportation
systems and construction systems."
Q. And are those the classes that I taught?
A. Yes.
Q. Okay. And you told her to put them in other classes,
correct?
A. That's correct.
Q. Okay. Well, those numbers there, 14 for the one and 15
for the other one, are those higher numbers than some of those
other teachers that had six, nine, and zero in their classes?
A. Is 14 higher than six or nine or others, yes.
Q. And those teachers didn't lose their jobs though, correct?
A. Some --
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Q. For the student numbers?
A. Correct.
Q. Okay.
MR. VUKADINOVICH: Has that been admitted, 85?
THE COURT: Yes.
Q. How many years were you the principal at Hanover Central?
A. Three.
Q. How many full-time teachers did you make a decision to
terminate, full-time teachers?
A. Full-time?
Q. Yes.
A. One.
Q. Who was that?
A. You.
THE COURT: Is this a convenient spot to break for
you, Mr. Vukadinovich?
MR. VUKADINOVICH: It would be, Your Honor.
THE COURT: We're gonna take our lunch recess at this
time. Remember the admonitions I've been giving you during the
trial. Don't discuss the case amongst yourselves over the
lunch break. Of course, you have to continue to keep an open
mind. We'll pick back up here at 1:15. We'll pick up at that
time.
(Jury out at 12:01 p.m.)
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THE COURT: You may step down.
THE WITNESS: Thank you.
THE COURT: All right. Just be back here by 10 after
one just in case there's any issues you want to take up before
the jury gets in here at 1:15.
(A recess was had at 12:02 p.m.)
(The proceedings resumed in open court, reported as
follows:)
DEPUTY CLERK: All rise.
THE COURT: You can be seated. Everybody ready to
proceed?
MS. BUGALLA: Yes, Your Honor.
THE COURT: You ready to go, Mr. Vukadinovich?
Your Honor, just for a minute, could we set some kind of a
timetable as far as so we can get the things concluded and so
forth so we know exactly the time factors that are gonna be
involved? What I would like to request, Your Honor -- I really
would like to be able to have tomorrow. I've still got several
witnesses and so forth that are really very important, and if I
could have tomorrow -- I mean, I'm gonna promise you --
THE COURT: You mean take the day off?
MR. VUKADINOVICH: No, no. I mean for me to have
tomorrow for my part of the case.
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THE COURT: Yeah, absolutely.
MR. VUKADINOVICH: Okay. I just wanted to make sure.
THE COURT: I mean, I think you're moving things
along.
THE COURT: Here is the thing: You are doing fine,
but you are belaboring things. You don't have to continue to
say things over and over again. These are smart people, you
know, so --
How long do you think your case is gonna take?
MS. BUGALLA: Part of a day.
THE COURT: Okay. So we're gonna get this done this
week, right?
MS. BUGALLA: Oh, I hope so. I hope so.
THE COURT: So who do you have left besides
Mr. Biggs? We'll finish up with him. You're gonna call
Ms. Kaiser?
MR. VUKADINOVICH: Ms. Kaiser and then -- actually,
after Mr. Biggs, I'm gonna call Mr. Landis.
MS. BUGALLA: Can I just say something?
THE COURT: Sure. You asked us to have Mr. Hiatt
here.
MS. BUGALLA: And he is here.
MR. VUKADINOVICH: I intend to put him on.
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MS. BUGALLA: Okay. Just saying.
MR. VUKADINOVICH: And then Mr. Landis. Ms. Adler
who's a former employee, briefly, put her on. Mr. McCray,
former principal, briefly put him on, and then Mr. Hiatt. My
plan is to have those people finish today.
THE COURT: Okay. Well, we'll see how it goes.
MS. BUGALLA: I would just hate for Mr. Hiatt to have
to come back.
THE COURT: I'm gonna instruct you to put Mr. Hiatt
on next just to verify -- so we get him out of here.
THE COURT: Okay.
THE COURT: You willing to do that?
MR. VUKADINOVICH: Absolutely.
THE COURT: Okay. Mr. Biggs, you want to come on
back up here.
And, Carlos, if you want to call the jury.
(Jury in at 1:18 p.m.)
THE COURT: All right. You may be seated.
All right. Mr. Vukadinovich, you may continue with your
direct examination.
JUSTIN BIGGS, PLAINTIFF WITNESS, SWORN
DIRECT EXAMINATION - RESUMED
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Q. Mr. Biggs, you had earlier testified that you actually
came into the room -- you entered the room when I was having my
due process meeting with Ms. Kaiser.
A. Yes.
Q. So did you actually -- you came into the room then,
correct, so there's no question about that?
A. Yes.
Q. Okay. Did you hear your attorney yesterday tell the jury
in the opening statement that you peeked your head into the
room?
A. Yes.
Q. Was that true?
A. Yes.
Q. But didn't you testify under oath that you actually came
into the room?
A. Yes.
Q. Which one was it?
A. It is the same thing.
Q. The same thing as peeking your head in as opposed to
coming into the room?
A. My head and body was in the room.
Q. Okay. So you didn't just peek your head in, so we're
clear, you came -- your whole body came into the room?
A. Yes.
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Q. What areas -- as principal, my supervisor, did you know
what areas I was able to teach -- that I was licensed for?
A. Yes.
Q. What were they?
A. Drivers ed instruction and industrial arts. I also was
aware that you were teaching middle school Gateway to
Technology, which is the same thing as Project Lead the Way at
the middle school.
Q. When you say industrial arts and you said construction,
there are actually a number of classes under industrial arts,
isn't that correct?
A. I didn't say construction.
Q. I might have misheard. I thought you did. I thought you
did. If you didn't, that's fine. So what classes would be
included under industrial arts?
A. There are a variety of classes. The State publishes a
grid of the licenses and the subjects that a teacher with that
license can teach. Without having that in front of me, I can't
give you an exhaustive list of those classes.
Q. Actually, there is no such thing as industrial arts
anymore, is there?
A. I'm not aware of that.
Q. It is industrial technology, instructional technology?
A. I'm not aware of that.
Q. Okay. That's fine.
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Was there an opening for the 2012-2013 school year for an
instructional technology teacher?
A. Not that I know of.
Q. Was I licensed to be an instructional technology teacher?
A. I don't know what course you're referring to. I'd have to
know that, and I'd have to have the course number for that to
match up to your license and then match that to the grid that
the state publishes without being able to say for sure if you
can teach that class.
Q. Okay. If there was -- you are not aware if there was a
technology teacher opening for the following school year?
A. I don't know specifically what technology means in this
case to be able to say whether or not there was an opening for
that position.
Q. If there was an opening for that position, would you as
the principal have been -- part of your job responsibilities
would be to find a person to teach that position that was
licensed for the position?
A. It was my duty as principal to place staff appropriately,
yes.
Q. And then would it be your duty as a principal if there was
an opening there and there was already a teacher there within
the corporation to teach that class, would you investigate that
teacher teaching that class if he was licensed for that class?
A. I don't understand, sir.
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Q. If there was an opening for a technology teacher, would it
be your duty that if there was a teacher within the corporation
that was already employed in the corporation that was qualified
for that class, would you consider that teacher to teach that
class if you had one there already with that license that
wanted to teach that class?
A. Again, it is hard for me to answer the question. I don't
understand.
Q. If there was a technology position open, a teaching
position for the following school year, and you had at Hanover
Central somebody that was licensed to teach that course and
would have taught that course, would you have had a duty as the
principal then to pursue that with that teacher?
A. Yes.
Q. Okay. This is not an admitted exhibit. It is Plaintiff's
Exhibit No. 82. Would you please describe that.
A. Okay. It is a message from --
MS. BUGALLA: What number? I'm sorry.
MR. VUKADINOVICH: It's 82. Eighty-two.
THE WITNESS: It is a message from me to Susan
Kounelis and Carol Kaiser regarding instructional technology
teacher.
Q. And what are you asking Miss Kounelis?
A. I'm asking her to jot down a reminder to create a posting
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for the above.
Q. Does that mean that there was going to be a position?
A. I would say yes.
Q. Okay. And then what was the date of that e-mail?
A. April 9.
Q. Of what year?
A. Of 2012.
Q. Okay. And is that actually about three weeks before you
gave me my decision that you were going to terminate my
employment?
A. That is one --
Q. I'm sorry?
A. It is several weeks, yes, before then.
Q. It was shortly before that though, correct?
A. Uh-huh. Yes.
MR. VUKADINOVICH: I move to admit Exhibit No. 82,
Your Honor.
MS. BUGALLA: No.
THE COURT: All right. Eighty-two is admitted.
Q. Am I a technology teacher?
A. I don't know.
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Q. You don't know -- I was under your supervision for the
school year, correct?
A. Yes.
Q. And you knew I was teaching high school and middle school
classes under your supervision, correct?
A. Yes.
Q. Okay. And you don't know what I was licensed to teach?
A. I do know what you were licensed to teach.
Q. What was I licensed to teach?
A. Drivers education and industrial arts under Rules 46, 47 I
believe.
Q. What about instructional technology?
A. I don't believe that was on your license.
Q. Did you check my personnel file?
A. No.
Q. Did you call Ms. Kaiser as the former superintendent and
ask her about what my qualifications were?
A. No.
Q. Do you remember during the testimony here when I submitted
a letter into evidence about when I went to a workshop and was
deemed the technology teacher? Do you remember that?
A. No.
Q. Okay. We'll move on from that right now. But you clearly
did not investigate as to whether or not I would be qualified
for that position, is that correct?
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A. I can't answer that question. It is assuming something I
don't agree with.
Q. I'm sorry?
A. You're assuming in your question something that I disagree
with.
Q. What is it that you disagree with?
A. Part of your question.
Q. What part of the question?
A. Could you repeat the question.
Q. Did you investigate what my qualifications were?
A. Yes.
Q. And did you determine that I was not qualified to teach
the technology classes the following school year?
A. Again, I'm not sure what you mean by "technology classes."
Q. This job that you were talking about here, the
instructional technology teacher position, that's the job I'm
talking about right there.
A. Okay. I don't recall that particular posting.
Q. Well, you don't deny that you sent that e-mail to Susan
Kounelis with carbon copy to Carol Kaiser, do you?
A. No.
Q. Now, I was -- was I RIF'd?
A. Yes.
Q. Under the corporation's guidelines for the -- under the
contract, would I have -- would the corporation have had to
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hire me for that job?
A. I don't know.
Q. This is No. 103 that has not been admitted. Would you
please describe that.
A. That looks like the front cover page that says "Master
Agreement." It goes on to say "between Hanover Organization of
Professional Educators and Hanover Community School
Corporation. January 1, 2008 to December 31, 2009."
Q. Was that in effect at the time that you made the decision
to terminate my employment?
A. My decision was preliminary.
Q. That's not what I asked you.
A. Well, again you are assuming --
MR. VUKADINOVICH: Your Honor, he is not answering my
question. I asked was that --
THE COURT: He had a question about your question.
He was unclear about something so just clarify it.
Q. Was this master agreement in effect at the time you made
the decision to terminate my employment?
MS. BUGALLA: Your Honor, I'm going to object because
the question assumes something that is not in evidence. It
assumes that Mr. Biggs made the decision to cancel
Mr. Vukadinovich's contract, and he did not make that decision.
THE COURT: Rephrase the question.
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Q. Are you familiar with what the requirements were if a
teacher is RIF'd from the corporation as to whether or not
there was any kind of a requirement that the corporation would
have to recall the teacher or give the teacher a job that is
open that the teacher is qualified for?
A. I want to answer your question, but I need some clarity on
it. Could you be more specific.
Q. Are you familiar -- as the principal, did you have to be
familiar with what the master agreement said?
A. Yes.
Q. And were you familiar with it?
A. Yes.
Q. Were you familiar with the provision on the policy about
when a teacher is RIF'd what the policy was for what the
corporation's responsibilities were to recall the teacher or to
give the teacher another available position if the position was
open? Are you familiar with that part of the policy, that
contract?
A. I'm familiar with part of what you said but not all.
Q. What is it that you're familiar with?
A. I'm familiar with the RIF process. I'm familiar with the
fact that teachers who are qualified to teach certain courses
who have been RIF'd may be called back if those courses are
then available the following year, having been cut the previous
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year. However, I'm not familiar with any process that places
teachers into those classes without proper certification.
Q. Now, you said the teachers may be called back. Is it they
may be called back or they must be called back under the
contract?
A. They must if they are qualified to teach those courses or
at least be given the option to come back. They don't have to.
MR. VUKADINOVICH: I'm gonna move to admit Exhibit
No. 103, Your Honor.
MS. BUGALLA: Well, Your Honor, the ongoing objection
that a collective bargaining agreement is not at issue in this
case, and so I question its relevance.
THE COURT: Sustained. I don't think it has any
relevance at all to the case. And it has the possibility that
it could confuse the issues to the jury. Whatever marginal
relevance it might have I think just came out in the
questioning with Mr. Biggs. To then introduce the entirety of
the collective bargaining agreement I think has very little
probative value and, again, has a danger of confusing the
issues for the jury. So it is sustained.
MR. VUKADINOVICH: Your Honor, could I respond?
THE COURT: Sure. Why don't you do it at sidebar?
MR. VUKADINOVICH: Your Honor, the letter --
THE COURT: At sidebar.
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MR. VUKADINOVICH: Oh, I'm sorry.
(Bench conference.)
MR. VUKADINOVICH: Your Honor, the letter that Ms.
Kaiser wrote to the school board recommending my termination
stated that it is consistent with the policy. It is right in
her letter to the School Board when she made the recommendation
that it is consistent with the master agreement with the
teachers union; that was part of the termination process.
THE COURT: Okay. And so what are you trying to
offer it to show?
MR. VUKADINOVICH: Because it shows that no matter
what he was gonna make sure that I wasn't gonna be able to come
back to Hanover to teach. No matter what the contract said,
yes or no, you are out of here because I'm retaliating against
you even though the contract --
THE COURT: I don't think -- you've just elicited
testimony from this witness along those lines what the contract
calls for. What I'm saying is that the totality of this
contract, which is about a 30-page document, is not germane to
this case. It's not relevant, and it has -- there's a very
real risk that this jury is gonna confuse the issues. In other
words, they're gonna think that this is a case about their
alleged violations of the collective bargaining agreement;
that's not what this case is about. That wasn't an allegation
in your complaint, or at least a claim in your complaint, and
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so I think it clutters the record and confuses the issues for
the jury. That's my ruling.
MR. VUKADINOVICH: Even about just putting that
particular one page in as opposed to the whole document?
THE COURT: I've ruled. You made your record.
(End of bench conference.)
Q. As the principal of the school and your familiarity with
what the obligations were of the corporation, was the
corporation required to hire me for a technology position that
was open the following school year that you refer to in that
e-mail?
A. I don't believe so.
Q. And why is that? If I was qualified, you don't believe
that the school should have hired me for that position?
A. Again, you're assuming something that I don't agree with,
and it is difficult to answer that question.
Q. If I was qualified for the position, should the school
have hired me for that position?
A. I can't guess.
Q. Pardon?
A. I cannot make a guess.
Q. I'm not asking you to guess. I'm asking you as the
principal should the school have been required to do that?
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A. I can't speculate.
Q. I'm not asking you to speculate. I'm asking as the
principal to answer the question.
A. It requires me to speculate, and I can't make a guess.
There's a lot of factors that deal with hiring, some that are
specific to license requirements, some that are specific to
interviews, and the best fit for the position. There's a lot
of different factors.
Q. Okay. When you say, "a lot of different factors," could
those factors also be if there was something going on that you
didn't like about the teacher that you just didn't want to let
that teacher have that job, does that also come into play as
those factors?
A. No.
Q. No?
A. (No audible response.)
Q. Okay. This exhibit has not been admitted. It is No. 118.
Could you please describe it.
A. You wanting me to describe it? I'm sorry. I'm reading it
at this moment.
THE COURT: Give him an opportunity to read the
document.
THE WITNESS: It looks like a definition printed
page. Looks like page 1 of 5. It says vaguely at the top,
Hanover Community Schools Bylaws and Policies. It looks like
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one such policy, specifically, administrative guideline.
Q. Are you familiar with that policy?
A. Having read over it briefly, I would say yes.
Q. All right. You see on the very bottom what it says there?
What's those two words there?
A. On the very bottom is a website link.
Q. The two words. They stand out.
A. Above that is the two words "due process."
Q. Okay. Are you familiar with that portion of the policy?
MS. BUGALLA: I need to interrupt, and I apologize.
What page are you looking at because what I'm looking at on
your exhibits is not the same as what's showing up, and I want
to make sure.
THE COURT: Will you show her the exhibit, so we are
all on the same page here.
MS. BUGALLA: Are you looking at the first page of
the exhibit?
(Document tendered.)
MS. BUGALLA: Your Honor, we don't have the first
page in the exhibit that Mr. Vukadinovich provided to us.
THE COURT: I have it here. He -- it may have just
not copied.
MS. BUGALLA: I'm just saying I just don't have the
first page.
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THE COURT: Well, what is the first page? Is the
first page the one that says, "Administrative Guidelines" on
the top?
MS. BUGALLA: Is that in your copy?
THE COURT: That's in my copy.
MS. BUGALLA: All right. Then it must not --
THE COURT: It is not in your --
MS. BUGALLA: It is not in our copy.
THE COURT: Take a moment to take a look at it so
that --
(Discussion held off the record between the parties.)
THE COURT: All right. You may proceed.
MR. VUKADINOVICH: Thank you.
Q. Are you familiar with the due process provision of the
corporation policy?
A. Not specifically with the letter of that particular
guideline, but I am familiar with the idea of due process, yes.
Q. I'm speaking in terms of the actual corporation policy.
Not just per se in general due process but what the corporation
policy was.
A. Not as much as I would like to be.
Q. And also should you be as the principal familiar with the
due process?
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A. I don't know.
Q. Now, when you were trained to be a principal did due
process come into the training? Any classes or anything like
that?
A. Due process certainly was part of the training, yes.
Q. What due process should I have been allowed with the
Hanover Community School Corporation?
MS. BUGALLA: Your Honor, I'm going to object. I
think that is asking this witness to make a legal conclusion
regarding one of the issues pending in this case.
THE COURT: Yeah, I agree. That's really a legal
conclusion that the Court will decide when I instruct the jury
on the meaning of that term.
MR. VUKADINOVICH: Very good.
Q. All right. I'm gonna draw your attention to the top where
it starts off, "Procedural due process." Have you ever read
that before --
A. No.
Q. -- as the principal at Hanover?
A. No.
Q. Do you feel as the principal of Hanover that you should
have been familiar with the corporation's due process policy?
A. You're asking something that I disagree with as part of
your question. In answer to that, I am familiar with due
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process. I'm not familiar with that particular statement and
policy.
Q. As the principal, don't you have to follow the
corporation's due process policy?
A. Yes.
Q. And yet you're not familiar with what the corporation's
due process policy was, correct?
A. Not correct.
Q. Not correct?
A. Correct.
Q. Correct that you are not familiar with it?
THE COURT: All right, guys. Come on. Start over
again 'cause we're on about our third "correct," and we don't
know which one is referencing what. So ask the question again.
Q. Okay. Did you know what the due process policy was,
particularly for your decision to terminate me, what due
process policy came into play?
MS. BUGALLA: Again, Your Honor, I'm going to object
because it assumes, once again, something that is not in
evidence. Mr. Biggs did not make the decision to end
Mr. Vukadinovich's contract, and he keeps saying that.
THE COURT: Well, okay. I'm gonna overrule the
objection. The witness can answer the question if he can. If
he can't, I'm sure he'll say he can't.
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Could you repeat the question?
Q. As the principal -- did you make a decision to terminate
my employment?
A. No.
Q. Did your letter say that you made a decision to terminate
my employment?
A. I made a preliminary decision.
Q. Did your letter state that to me?
A. That I made a preliminary decision, yes.
Q. So you did make a decision, is that correct?
A. No.
Q. Even though your letter said that you did?
A. No.
THE COURT: All right. Mr. Vukadinovich, it is
abundantly clear, he calls it a preliminary decision. You
called it a decision. The jury understands the distinction.
MR. VUKADINOVICH: Yes. Very good.
THE COURT: And they'll decide how important that is.
Q. Mr. Biggs, I'm gonna draw your attention to the actual
policy there. Could you please read that.
THE COURT: You need to scroll it down because it is
cut off on the screen there.
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THE WITNESS: Okay. Says, "Procedural due process
requires an established rule or standard, notice of facts of an
alleged violation and the applicable rule or standard
(accusation), and an opportunity to respond before a decision
is made."
Q. Okay. Now, do you agree that I was entitled to some kind
of due process in my termination?
A. Yes.
Q. Okay. And based on this policy here that you just read,
what was the established rule or standard?
A. I don't know.
Q. Now, in your letter -- what kind of facts did you give me
in the letter?
A. Without having it in front of me, I can't generalize
according to the number or kind or if any facts were in there.
Q. I believe this has been previously admitted as Plaintiff's
Exhibit No. 19.
THE COURT: I think that's right. I'll display it
for the jury.
THE WITNESS: I'm sorry. You're asking me for the
facts in this letter?
Q. Yes.
A. Okay. "You are hereby notified" -- I'm not sure how to
answer the question, sir, without just reading it.
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Q. The actual facts, what where the facts? Tell us what the
facts are about my termination.
A. That you are being notified of the preliminary decision to
decline the teaching contract at the end of the 2011-2012
school year. That the reason for this preliminary decision is
follows: That the teacher is subject to a justifiable decrease
in the number of teaching positions, more commonly called a
reduction in force, per IC 20-28-7.5-1(b)(3). You have a right
to request a private conference with the superintendent to
discuss the reasons for my preliminary decision.
Q. Okay. That will be fine there.
Now, did you ever hear anything about the -- Ms. Kaiser
informing the School Board in her recommendation letter the
things about my student enrollment declined over the years and
that my middle school Project Lead the Way classes were not
generating interest for the high school?
A. Yes.
Q. Okay. Well, are those facts?
A. Was her letter a fact, yes.
Q. The letter was a fact, correct?
A. The letter does exist.
Q. Okay. And were those facts that she said -- what she said
in the letter, was it a fact that my interest in my middle
school Project Lead the Way classes didn't create interest for
the high school Project Lead the Way classes, is that a fact?
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03-08-2016 Justin Biggs Testimony - Vukadinovich Trial

03-08-2016 Justin Biggs Testimony - Vukadinovich Trial

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