Deposition of Brandon Branch
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 1 of 17
Transcript of the Testimony of: Brandon Branch Date: February 26, 2013
Case: Lisa T. Jackson v. Paula Deen, et al. 4:12-CV-0139
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Torn Crites & Associates International, Inc. P.O. Box 9438 Savannah, Georgia 31412 Phone: 800-631-3480 Fax: 912-233-7777 [email protected] www.critesintl.com EXHIBIT
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 2 of 17 February 26, 2013
Brandon Branch Lisa T. Jackson V. Paula Deen, et at.
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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION LISA T. JACKSON, Plaintiff,
CIVIL ACTION NO.
vs. PAULA DEEN, PAULA DEEN 4:12-CV-0 139 ENTERPRISES, LLC, THE LADY & SONS, LLc, THE LADY ENTERPRISES, INC., EARL W. BUBBA HERS, and UNCLE BUBBA'S SEAFOOD and OYSTER HOUSE, INC.. Defendants.
Deposition of BRANDON BRANCH, taken by counsel for the Plaintiff, pursuant to notice and agreement, before Rachael Miller, Certified Court Reporter, at 218 West State Street, Savannah, Georgia, February 26. 2013. at 10:38 am.
U Associates International. Inc. Tom Crites & Astociates
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1 APPEARANCE OF COUNSEL: 2 3 4 5 6 I 8
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FOR If-I.E PLAiNTIFF: MATTHEW C BILLIPS, Esquire BUlips & Benjamin, LLP 3 10 Towercreek Parkway Suite 190 Atlaflta, Georgia 30339
770) 8590753
FOR THE DEFENDANTS: WILLIAM..FRANKUN, Esquire Oliver, Maner, LLP 218 West State Street Savannah, Georgia 31401 )912J236-3311
FOR THE DEFENDANTS: ANTHONY C LAKE, Esquire
Gillen, Withers & Lake, LLC 8 East Liberty Street Savannah, Georgia 31401 19121447-8400
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DISCLOSURE STATEMENT I 2 STATE OF GEORGIA 3 COUNTY OF CHATHAM: OPENING REMARKS AND STIPULATIONS - .6 4 Pursuant to ArbCIC 10. B. of the Rules 5 j 6 and Regulations of the Board of Court Reporting or 7 the Judicial Council of Georgia, 1 make the INDEX
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EXAMINATION By Mr. Billips
ATTESTATION • ERRATA.SHE:ET CERTIFICATE
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I am a Georgia Certified Court Reporter. lam not disqualified for relationship of interest under the provisions of O.C.G,A. 9l1-28(c).
Tom Crites & Associates International, 14 Inc. was contacted by S. Wesley Woolf, P.C. to 15 provide court reporting services for this 16 proceeding. 17 Tom Crites & Assodates International, 18 Inc. will not be taking this proceeding under any 19 contract that is prohibited by Georgia law. 20 ThIs, the 10th day of March, 2013. 21 22 23 24
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3 (Pages 6 to 91 Page 6 BRANDON BRANCH, 1 2 having been first duly sworn, was examined and 3 testified as follows: EXAMINATION 4 5 BY MR. BILLIPS: Ci. Please state your full legal name. 6 A. Phillip Brandon Branch. 7 8 0. And, Mr. Branch, where and in what 9 capacity are you presently employed? A. With Paula Deen Enterprises. 10 0. Okay. What do you do there? 11 A. I am Paula's assistant and creative 12 director for the company. 13 14 0. Okay. Tell me first about the creative IS director aspect of yourjob. What does that 16 entail? A. I oversee the magazine. I work with the 17 IS furniture line. Anything visual the public sees. I oversee the TV show and photo shoots. 19 0. And are you present at all of the lv 20 21 shows and photo shoots and things of that sort? 22 A Yes. For the most part 0. Okay. How long have you worked for Ms. 23 24 Deen? A. Nine years. 25
Page 8 I videos that have ever been put together? 2 A. Yes. 0. Okay. How many? 3 4 A Ijust know of one. Q. Okay. And was that the one that was the 5 6 subject of some litigation? 7 A. Yes. a. Okay. And did you see that video? Have a 9 you seen it? 10 A Yes. II Q. Were there - were there jokes and 12 language that were inappropriate for a 13 famHy-oriented show? 14 A. I guess it depends on the family. 15 0. 1 suppose it does. 16 MR. FRANKLIN: And what do you mean by a 17 family? IS MR. BIWPS: Excuse me? 19 MR. FRANKLIN: What do you mean by a 20 family? 21 MR. BIWPS: A family-oriented show. 22 MR. FRANKLIN: Okay, Once again. I 23 object to the form of family oriented Is that 24 husband and wife? Is that grandpa and grandma? 25 BY MR. fILLIPS:
Page 7 1 0. Okay. Are - so have you started 2 writing a tell-all book yet? 3 A No. 0. Do you have an agent? 4 MR. FRANKLIN: Are you soliciting? 5 MR. BILLIPS: No. 6 7 BY MR. BIWPS: 0. I do know one, so... 8 During the show - strike. The shows 9 10 are filmed, if I understand correctly, in front of 11 a live audience; is that right? A No. 12 0. They're not. So they're filmed and then 13 14 edited and then the shows are - are not live, 15 correct? 16 A. Correct 0. All right Does she ever show or film 17 18 shows in front of a live audience, to your 19 knowledge? 20 A. In the past she has. 21 0. Okay. As the creative director, did you 22 have any involvement in putting together an 23 outtake video? A. No. 24 0. All right A re you aware of any outtake 25
Page 9 I 0. Was it inappropriate for children? 2 MR. FRANKLIN: And once again. I don't 3 know what age children, but you can answer. These 4 are laers objecting talking back and forth. No S one listens to us. 6 THE WITNESS. I guess. 7 BY MR. BIWPS: Q. What kind ofjokes were on this outtake 8 9 video? 10 A 1 do not remember. 11 0. You don't. You have to see it to know. 12 conct? 13 A. Yes. 14 0. Were thereJokes about vaginas? IS A Yes. 16 0. Were there jokes about oral sex? A I don't recall that 17 18 (1 Do you recall any - Aft Deen engaging 19 in any depictions of oral sex with fruit? 20 A No. I don't recall that 21 0. Have you ever seen herdoso22 A No. 23 0. - on-. when filming her show? 24 ANo. 1 25 0. Okay. Did you review this - or who was
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Page tO responsible for putting this outtake video together? A. I do not know. 3 0. Would that not ordinarily be something 4 5 within your span of conlroll A. No. 6 C1 What if anc roiedo you have as 7 8 creative director with the actual show? MR, FRANKLIN: Theshowyoure talking 9 10 about? MR, BIWPS: The Paula Deen cooking Ii 12 show. MR. FRANKLIN: The whole shebang or are 13 4 you talking about a specific thing? MR. B1WPS: I've never watched her 15 16 show, so I'm going to have to learn from him. MR, FRANKLIN Okay. You're missing 17 8 some good television. 19 BY MR. BIWPS: 0. Okay. Does Paula Deen have more than 20 21 one 1V show? 22 A Na 23 0. Okay. Then when I refer to the Paula 24 DeenlVshow, do you know what rm talking about? 25 A. Yes, 2
A Yes. 1 2 0. And you haven't looked at that video in 3 how long? 4 A. At least three years. 0. Okay. Now, how familiar are - familiar 5 6 are you with members of the Deen family, other 7 than Paula? 8 A. Very familiar. 9 0. Okay. Are you —doyou consider 10 yourself to be close to them? II A Yes. 72 0. Do you think that you know them pretty 73 well? 14 A. Yes, 0. All right. How well do you know Bubba 15 16 Hiers? 77 A I would say pretty well. 0. Okay. Now, we've had testimony in this 18 19 case that you told an employee I think of-if 20 I'm correct of Uncle Bubba's that you had heard Mr. Hiers use the word nigger. 21 22 MR. FRANKLIN: Object to the form of 23 that. I believe it was Libby Summers who was not 24 an employee of Uncle Bubba's. 25 MR. BIWPS: Okay. Libby Summers, I
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Page Ii 0. What, if any, role do you have in the I 2 productIon, direction or anything else? 3 A. On the show I'm the prop stylist So I 4 choose the dishes, work with the clothing stylist, 5 do the flowers, do the food beauties, pick the 6 napkins, utensils. 7 0. Okay. And you're there for the filming 8 of the show? 9 A. Correct. 0. During the filming of the show, does Ms. 10 Deen use sexually suggestive language? Ii 12 A. No. 0. Does she ever tell jokes that are 13 14 sexually suggestive? A. Occasionally. 15 0. Okay. When you say occasionally, what 16 17 frequency do you mean? 18 A. 1 would say maybe once a year. 19 C1 Once a year. How many sexuay 20 suggestive jokes were there on this outtake video? 21 A. I don't remember. 22 0. Okay. Was it more than one? 23 A. I really don't remember. 24 0. So you just have no idea, you'd have to 25 see the video?
I don't remember where she worked. 2 BY MR. BILLIPS 3 CL Libby Summers - that you had told Libby 4 Summers you heard Uncle Bubba use the word nigger? 5 MR. FRANKLIN.' And I'll object to you 6 asking him to comment on the testimony of someone 7 else. Having said that, you can answer. 8 THE WITNESS: It never happened. 9 BY MR. BILUPS: 0. Never happened? 10 11 A. Never happened. 12 0. Has, to your knowledge, Uncle Bubba ever 13 used the word nigger? 14 A Not In my presence. 15 0. Okay. Would you be surprised to learn 16 that Mr. Hiers has actually admitted doing so at 17 Work In front of his managers? 18 MR, FRANKLIN: Object to the form of 19 that. I think it incorrectly characterizes 20 testimony saying managers, but you can answer. 21 BY MR. BIWPS 22 0. You can answer. A Repeat the question. 23 24 0. Would you be surprised to learn that Mr. 25 Hers has actually admitted to using the word
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Page 14 I nigger at work in front of his managerial - some 2 of his managerial staff? 3 A Yes 0. And do you know Libby Summers at all? 4 A. y, 5 0. How well do you know her? 6 A We worked together for maybe two years. 7 C). Okay. And what was her job? 8 A. She was food stylist 9 0, Okay. Is there any reason why you and 10 11 Ms. Summers would have been discussing Bubba 12 Hiers? MR. FRANKLIN: Objection, You're 13 14 assuming that there was such a discussion. MR. BILLIPS: No. I'm actually not 15 16 MR. ERANKUN.• Well, she says they've 17 talked about this doesn't mean there necessarily 18 was. MR. BIWPS: I didn't suggest by my 19 20 question that there was. MR. FRANKLIN: Okay. 21 22 MR. BILLIPS: I asked whether there was 23 any reason that there would have been. 24 MR. FRANKLIN: Okay. You can answer. 25 THE WITNESS: No.
I can answer. 2 THE WITNESS: No. 3 BY MR. BIWPS: 4 0. Okay. Is there any reason that Mr. 5 Gerard would have had that you are are of to communicate with you any - any reason within the 6 7 scope of any legal Issue that you can think of 8 that Mr. Gerard would have had to communicate with 9 you? 10 A. No. 0. Okay. Or for that matter for you to 11 12 communicate with Mr. Gerard. Would there have 73 been any reason for you to communicate with him on 14 any matters In the scope of his job as a lawyer? A. Yes. 15 0. Is there any reason for you to 16 17 communicate with Mr. Gerard regarding his scope as 18 a lawyer other than ln preparation foryour 19 deposition today? 20 MR, FRANKLIN: He has not - well, 21 object to the form of that. I think he said he's 22 done nothing in the preparation of the defense of 23 this lawsuit other than perhaps meeting with me. 24 BY MR. BIWPS: 25 0. Okay. What if anything, did you do to
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1 BY MR, B1LUPS: 1 prepare for your testimony today? 0. Okay. Ms. Summers 2 A. For - say that again. 2 MR. FRANKLIN: I object I don't know 3 0. What, if anything, did you do to prepare 3 4 how he would know if there's any reason if I call 4 yourself to give testimony in this deposition? S Joe or you call Joe. But having said that the A. Nothing. 5 6 objections there 6 0. Okay. MR. BILLIPS: It really is okay if you 7 7 MR. FRANKLIN: Well, other than - other B Just object to the form. 8 than 9 BY MR. BIWPS: 9 MR. BILLIPS: Other than meeting with 10 0. Now, have you had any role whatsoever in TO counsel. Ii assisting any - Ms. Deen or any of the Deen 71 MR. FRANKLIN: Apparently talking to me 12 companies with regard to anything having to do 12 means nothing. Thank you. I know where lam. 13 with this lawsuit 13 Chopped liver. 74 MR. FRANKLIN: Object to the Form. 14 BY MR. BIWPS: 15 BY MR, BIWPS: 15 0. Now, as Paula's assistant what do you 16 0. -other than appearing here today to 16 do? 17 give testimony? Ti A From waking her up in the morning to 18 A No. TB packing her clothes for a trip to traveling on a 19 0. Okay. Have you ever had any reason to 19 trip with her, overseeing her home, getting her 20 - do you know who Jim Gerard is? 20 from point A to B. 21 A Yes, 21 0. Okay. So you pretty much take care of 22 0. Okay. Have you ever had" reason to 22 every menial detail of her life? I'm not saying 23 consult with Jim Gerard on any matter relating to 23 it's limited to that but your job includes taking 24 your employment with Paula Deen? 24 care of the menial details of her life so she can 25 MR. FRANKLIN: Object to the form. You focus on whatever It is that she does? 125
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Lisa T. Jackson V. Paula Deen, et al 6Pages 18 to 21) Page 18 MR. FRANKLIN Object to the form to the 2 extent of menial. I'm not sure what that 3 encompasses or doesn't. If he understands, he can 4 answer. THE WITNESS: Yes. 5 6 BY MR. BILLIPS: 7 0. Do you know Lisa Jackson? 8 A. Yes. 9 0. Okay. And how well do you know Lisa
10 Jackson? A. We worked together for several years II 12 casual, not one-on-one. 0. Okay. How often would you interact with 13 74 her? A. Not often. 15 a. Did you go to Uncle Bubba's Seafood & 16 17 Oyster House very often? is A No. 0. Did you ever eat there? 19 A. Yes. 20 0. More than once? 27 22 A Yes. 23 0. Have you ever seen Mr. I -Hers in a state 24 of intoxication at the restaurant?
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THE WITNESS: Yes. 3 BY MR. BILUPS: 4 0. Okay. And has she ever confided in you 5 any concerns about her brother? 6 A No. 7 0. Has she ever indicated any concerns at 8 all about the fact that he is supervising 9 employees? 10 A No. 11 0. Would you consider yourself a loyal 12 employee of Ms. Deen? 13 A Yes. 14 a. Would you lie for her? A No. 75 76 Q. 1 suppose that's kind of a pointless 17 question, because if you were going to lie for 18 her... 19 MR. FRANKLIN: Object to your 20 editorialization. 21 BY MR. BILUPS: 22 a. Has anyone ever reported to you that 23 there were - there was any racial tension at 24 Uncle Bubba's? 25
A No.
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1 1 0. You are a - were you aware that Mr. Q. Has anyone - or are you aware that Mr. 2 Hiers watches pornography at the restaurant? 2 Hiers had at one point in time been in treatment 3 for cocaine and alcohol abuse? 3 A No. 4 4 0. Nobody has ever told you that had A. No. 0. Has Ms. Deen ever communicated to you 5 occurred or was occurring; Is that true? 5 A. True. 6 about any of the problems that had arisen at Uncle 6 7 7 Bubba's that resulted in a directive that he have Q. Okay. Ms. Deen has never in passing or 8 even in passing made any reference to Mr. Hiers 8 no managerial role in the restaurant? 9 engaging in inappropriate conduct of any sort is 9 A. No. 0. Does she talk to you about her problems? 10 that fair? TO 11 A. Uh-huh. She's not 1! MR. FRANKLIN: Object to the form of 12 that 12 MR. FRANKLIN: You have to answer BY MR. BILLIPS: 13 audibly. 13 14 0. Ms. Deen, does she talk to you about her 14 THE WITNESS: Yeah. No. She's never 15 problems? 75 mentioned that 16 BY MR. BIUJPS: 16 A. Yes. 17 0. Does she consider you a confIdant? 17 Q. Okay. Do you know who Barry Weiner is? A. Yes, 78 A. Yes. 18 MR. LAKE: Objection. Calls for 19 0. Is it Weiner or Weiner? 79 20 speculation. 20 A. Weiner. 21 21 BY MR. BILUPS: 0. And who Is Barry Weiner? 22 0. Does she behave toward you as if you are A. Paula's agent and business manager. 22 0. Okay. Is he an employee of Paula's or 23 a confidant? 23 24 do you know? MR. FRANKLIN , Once again, object to the 24 25 form. You can answer when we object That'sJust 125 A. I do not know, Tom Crites & Associates International, Inc. crltesintl.com
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Page 22 0. Do you know Karl Schumacher? 1 2 A Yes. 0. Has Mr. Schumacher ever spoken to you 3 4 about any problems that he felt existed with Mr. 5 Hers? 6 A No. 0. Has he ever communicated with you about 7 8 any concerns he had about Mr. Hiers or any other 9 members of the family taking money from Ms. Deen 10 to which they were not entitled 11 A No. 12 0. - or which they had not earned? 13 A No. 14 0. Okay. Has Mr. Schumacher ever IS communicated with you at all about anything 16 relating to the operation of the business? 17 A Na 0. Has Mr. Schumacher ever asked you to 18 79 pass messages or information along to Ms. Deen? A. Occasionally, yes. 20 21 0. What kind of thing would Mr. Schumacher ask you to pass along to Ms. Deen? 22 MR. FRANKLIN: Object to the form. 23 24 BY MR. BILIJPS: a. You can answer.
Page 24 0. Have you ever been involved in a lawsuit? A. No. 3 4 0. Ever sued anybody, ever been sued? 5 A. No. Q. Never tiled bankruptcy? 6 7 A No. 0. Are you married? 8 9 A. No. (1 Have you ever been arrested or otherwise 10 11 charged with a crime? 12 A No, 13 0. Without disclosing for the moment any 14 specifics, first have you ever spoken to Jim 15 Gerard? MR. FRANKLIN: Ever? 16 17 MR. BIWPS: Yeah. MR. FRANKLIN: Object to the form. 18 19 THE WITNESS: Yes. lye spoken to him. 20 BY MR. BIWPS: 27 0. Have you ever communicated with him via 22 email? 23 A No. I don't believe. 0. Okay. When you spoke to Mr. Gerard was 24 25 it about something relating to the corporation? 1
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Page 23 A, He would maybe give me a seared envelope 1 2 to hand to her. 0. Would he ever give you a verbal message? 3 4 A. No. 0. Okay. Now, have you ever been aware of 5 6 any complaints of harassment or unlawful 7 discrimination occurring within the Paula Deen 8 corporations, as Ill call the group of 9 defendants? 10 MR. FRANKLIN: Object to the form. You 11 can answer. 12 THE WITNESS: Ask me that one more time. 13 BY MR. BILLIPS: 14 0. Have you ever been aware of any 15 allegations of unlawful discrimination or 16 harassment, other than those brought by Ms. 17 Jackson? 18
A. No.
19 0. Have you ever felt - have you ever 20 yourself felt discriminated against for any 21 reason? A, No, 22 23 Q. Okay. Have you - have you ever given 24 testimony prior to today? A. No. 25
Page 25 I MR. FRANKLIN: Object to any question or 2 answer that would invade the attorney-client 3 privilege. 4 MR. BIWPS: I'm not invading the 5 privilege at present I'm establishing the 6 boundaries of the privilege. 7 BY MR. BIWPS: 8 0. Have you ever spoken to Mr. Gerard about 9 anything having to do with your employment or your 10 duties as an employee with the company? A. No. 1I 12 0. Have you ever spoken to him regarding 13 any matters, any legal issues affecting the 14 company? 15 A. No. a. Okay. Have you ever spoken to Mr. 16 17 Gerard? 18 MR. FRANKLIN; Once again, I'm going to 19 object. Whether hes spoken Invades the 20 attorney.dient privilege. If you inquire as to 21 what he spoke about 22 MR. BIWPS: The attorney-client 23 privilege - well, we can brief it If we have to. 24 MR. FRANKLIN: I think we maybe already 25 have.
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1 BY MR. BILLJFS THE WITNESS it could be various I 0. Mr. Branch. has Mr. Gerard ever advised 2 things. 2 3 you on any legal issues whatsoever? 3 BY MR. BILLIPS A. No. 4 4 0. Give me an example. C1 Okay. Has he ever questioned you on any 5 5 A She's not feeling great today. 6 legal issues whatsoever? (1 Doesn't seem very private or personal. 6 1 A No. 7 A She doesn't feel like going to a book 0. Has he ever questioned you regarding any 8 8 signing today. 9 of the claims of discrimination brought by Ms. 9 0. Okay. What is the most - what would 10 Jackson? 10 you consider to be the most private or personal 11 A. No. 11 thing that she's confided in you about? 12 0. Has anyone - other than Mr. Franklin 12 MR. FRANKLIN: Object to the form. How 13 today, has anyone ever asked you for Information 13 does he know what's the most private? 14 regarding any information you might know about Ms. 14 MR. BILUPS: I'm asking what he would 15 Jackson's claims? 15 consider the most private and personal thing. 16 A. No one's asked me. MR. FRANKLIN; Once again, I'll object 16 0. Okay. When Ms. - has anyone ever asked 17 17 to speculation. 18 you about any issues relating to Lisa Jackson at 18 THE WITNESS: I haven't a clue. 19 all? MR. B1LLIPS: Give it your best shot. 19 20 A. No one's questioned me. 20 MR. FRANKLIN: Object to the form. 21 Q. Okay. Have you ever volunteered 21 We're not here for best shots. 22 Information regarding Ms. Jackson? 22 THE WITNESS; I really can't give 23 A. No. 23 anything. 24 0. Okay. Have you ever made any complaints 24 BY MR. B1LLIPS: 25 to Ms. Deen or Mr. Hiers, anyone in the managerial 0. So y'aiI aren't- she doesn't really 25
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Page 27 I chain above Ms. Jackson with her? A. No. 2 0. Okay. Do you know any information that 3 4 might serve as the basis for a complaint about Ms. 5 Jackson? MR. FRANKLIN; With the exception - and 6 7 I object if it involves anything that may have 8 come up with discussions he has had with me. I'm 9 assuming you're not plumbing foi' that. tO MR. UIWPS: rm only asking ifhe has 11 personal knowledge 12 MR. FRANKLIN; Okay. Fine. MR. BILUPS: - of any misconduct or. 13 14 you know, anything of that sort that you believe 15 has been communicated by Ms. Jackson, THE WITNESS: No, 16 BY MR. BIWPS: 17 0. What does Ms. Deen confide in you about? 18 19 MR. FRANKLIN: Object to the form. 20 By MR. BILUPS: 0. You can answer. Does she tell you 21 22 private and personal things about herself? 23 A. Yes. 24 0. Such as? 25 MR. FRANKLIN: Oject to the form.
1 talk toyou about anything of a private or 2 personal nature? 3 MR. FRANKUN Object to the form. 4 Thats not what he said. 5 BY MR. BILUPS: 6 0. Other than I don't feet Pike going to a 7 book signing or I don't feel so well today, is 8 that right? 9 MR. FRANKUr& Object to the form. You 10 can answer. 11 THE WITNESS; l'mjust thinking. I 12 mean, there's - its been ten years rye known 13 her. [didn't think 14 BY MR. BIWPS: IS 0. In the ten years you've known her, you 76 can't think of a single example of anything other 17 than Is A. I mean there's - yes, there's more 19 things, but20 MR. FRANKLIN: Object to the form. 21 Object to the form. That's like asking every 22 conversation you had with someone over ten years 23 orovera week. 24 MR. BIUJPS: No. I'm asking him to 1 25 give mean example of one.
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MR, FRANKLIN: Object again to the form MR. FRANKLIN: My objection stands. 1 1 2 asking him sitting here. MR. BIWPS: Your objection is noted. 2 MR. BILUP5 My Ford, Counsel, 3 3 You can answer. MR. FRANKLIN: You don't have to call me 4 THE WITNESS: You know, she'll ask me do 4 5 your lord. Look, the way it works - let me say 5 you think I look fat in this outfit? Thafs a 6 something. 6 personal thing, 7 MR. BILUPS: You asked questions in 7 BY W. BIWPS: B exactly the same manner of the plaintiff during a Okay. Has she ever talked to you about 8 9 any concerns that she had regarding members of her 9 her deposition, okay, mostly without us trying to 10 step all over your record and make spurious 10 fniily, for example? It objections. So if you would like to object to the MR. FRANKLIN: Once again. I object to Ti form and asked and answered. 12 form12 MR. FRANKLIN: Ijust did, 13 MR. LAKE: Objection. Asked and 13 MR. BILUPS: - every time 14 answered. 14 MR. BIWPS: You can answer. 15 MR. FRANKLIN: Let mejust tell you 15 MR. FRANKLIN: Again. 16 something. 16 THE WITNESS: Repeat the question. 17 MR. BIWPS: - go ahead. I am 17 18 BY MR. BIWPS: 18 thoroughly familiar with the way It works. Q. Has she ever spoken to you about any MR. FRANKLIN: You ask the question, I 19 19 20 concerns that she has regarding any of the members 20 have an opportunity to object, and then he 21 of herfamilyl 21 answers. And that's the way it works and thafs MR. LAKE: Same objection. 22 the way ifs going to work. 22 MR. FRANKLiN: Objection to form. Same 23 MR. 811111'S: All right 23 24 objection. Any concerns. 24 MR. FRANKUN: I don't need a lecture THE WITNESS: Yes, she has. 25 from you on the rules of evidence or on anything 25 Page 31
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I else. This ain't my first trip to the rodeo and I BY MR. BIWPS. 2 hopefully won't be my last. 2 0. Okay. Tell me what— lets take them MR. B1WPS: You know what I don't 3 3 one at a time. What, if any, concerns has Ms. 4 think there is anybody In this room or in this 4 Deen expressed to you about her Sons? S building who has ever ridden anything in a rodeo. MR. FRANKLIN: Object to the form. Any 5 6 Let's just get off this - this issue. We're all 6 concerns. 7 experienced. We all know what we're doing. THE WITNESS: She would like more 7 MR. FRANKLIN: I don't need a lecture. 8 8 grandlcids. MR. BILUPS I don't need a speech. If 9 9 BY MR. BILLIPS: 10 you want to object to the form (1 Llh-huh. Does she have some reason to 10 MR. FRANKLIN: Ijust did. I I believe she's not going to have more grandkids - TI 12 MR. BIWPS: - object to the form 12 MR. FRANKLIN; Object to that You're 13 MR. FRANKLIN: Ijust did. 13 asking him for speculation. 14 MR. BIWPS: - without giving a 14 BY MR. BILUPS: 15 speech. 15 0. - or is It shejust wants more of them? 16 MR. FRANKLIN: Ijust did. Nowaskyour 16 MR. FRANKLIN: Object to the form. 17 next question. 17 BY MR. BIWPS: 18 18 BY MR. BILLIPS: 0. You can answer the question. 19 0. Now, Mr. Branch, is the only thing Paula 19 A. Shejust wants more. 20 Deen has ever talked to you about concerning her 20 0. Okay. Anything else? 21 Sons IS her desire for more grandchildren? 21 MR. FRANKLIN: Object to the form. A. No. 22 22 THE WITNESS: No. 23 23 BY MR. BIILIPS: 0. What else has she talked to you about 24 0. That's the only thing she ever talked to 24 concerning 25 you about her— her sons; Is that correct? 1 25 MR. FRANKLIN: Object to the form. Tom Crites & Associates International, Inc. crltesintL corn
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I MR. FRANKLIN: Object again to the form. BY MR. BPLUPS I 2 BY MR. BILUPS: 0. - her sons? 2 3 0. You can answer. A She would like for Bobby to settle down 3 4 MR. FRANKLIN: Can P have a standing 4 and find a wire. 5 objection? I don't want to waive something by not 0. Okay. Has she ever expressed any 5 6 objecting to ft. 6 concerns about whether Bobby is gay? MR. BIWPS: You may have a standing 7 MR. FRANKLIN: Object to that That Is 7 8 objection to every question I ask. 8 outrageous. That has absolutely - that's an MR. FRANKLIN: Every time you open your 9 9 Insulting question and you did it yesterday. 10 mouth I can have a standing objection without MR. BILLJPS: Why? Why is it insulting? 10 Ii making it? ljust want to make the record clear. MR. FRANKLIN: What on earth does that 11 MR. BIWPS: You may. 12 12 have to do with anything involved in this case? MR, FRANKLIN: Then it will be a 13 13 You asked Dustin that 14 standing objection on form unless 1 elaborate on 14 MR. BIWPS Yes. 15 that MR. FRANKLIN: - yesterday. And now 15 16 MR. BIWPS: That's 16 you're asking - that is Insulting. Its 17 MR. FRANKLIN: I'm not here trying to be Improper. 17 18 an obstructionist. MR. BIWPS: Why is it insulting? 18 MR. BILUPS: That's perfectly fine. 19 MR. FRANKLIN: Fm not going to —if 19 20 BY MR. BPLLIPS: 20 you cant figure that out, then you've got a 0. What other concerns, if any, has Ms. 21 problem, my friend. What does someone's sexual 21 22 Deen expressed about her sons? 22 orientation in the Deen family have to do with 23 A. I can't think of any other things she's 23 this? 24 expressed about them other than just love. 24 MR. BIWPS: Well, you know, it depends 0. Okay. What if any. concerns has Ms. 25 on whether I t goes to his relationships with other 25
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Page 35 I witnesses, other employees, other managers. It 2 goes to bias. There's a whole lot of ways where 3 it might MR. FRANKLIN: Welt we'll see where 4 S this goes and I don't think you're going to like 6 it 7 BY MR. BILUPS: C1 Has Ms. Deen ever expressed any concerns B 9 about whether Bobby is gay? 10 MR. FRANKLIN: And objection. 17 BY MR. BIWPS: 12 0. You can answer. 13 A No. 14 0. Okay. Do you have any idea whether 15 Bobby is gay? MR. FRANKLIN: And objection. 16 MR. LAKE: Objection. Il MR. FRANKLIN: Once again, this is 78 19 outrageous. 20 BY MR. BILLIPS: 21 Q. You can answer. A. No. 22 0. Okay. What else has Ms. Deen 23 24 expressed - what other concerns has she expressed 25 to you about her sons?
1 Deen expressed about her brother? A Nothing really. 2 Q. Okay. Did she telIyouwfen he stole 3 4 $30,000 From thefrjointlyowned restaurant? A. No. 5 6 0. Were you aware that he had taken money 7 to which he was not entitled from the restaurant? 8 A. No. 0. Is this the first you're hearing of 9 10 that? II A. Yes. 12 Cl. Does she ever talk to you about money 13 issues? A. Yes. 14 Q. Okay. Now, one allegation in this case 15 16 is that P. Jackson was present during planning 17 the wedding. And I don't remember who It was for 18 whether It was Bubba's wedding or whose. Were you 19 involved in the planning of any weddings A. Yes. 20 21 0. - with Ms. Jackson? 22 A. Yes. 23 0. Okay. Whose wedding was It? A. Bubba's. 24 0. Bubbas. Okay. That s what I was 25
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 12 of 17 Brandon Branch Lisa T. Jackson v. Paula Deen, et al.
February 26, 2013
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ATTESTATION
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CERTIFICATE
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I. the undersigned, have read the 3 4 foregoing transcript and with the exception of S any corrections specified on the attached 6 correction sheet attest it constitutes a true and 7 correct transcription of my testimony given at the 8 time and place specified therein. 9 10 11 12 (Signed): Brandon Branch 13 14 15 WITNESS: 16 17 18 19 DATE20
3 STATE OF GEORGIA 4 COUNTY OF CHATHAM: 5 I hereby certify that the foregoing 6 7 transcript was taken down, as stated in 8 the caption and the questions and 9 answers thereto were reduced to 10 typewriting under my direction; that the ii foregoing pages 1 through 47 represent a 12 true, complete, and correct transcript 13 of the evidence given upon said hearing. 14 and I further certify that I am not of kin or counsel to the parties in the 16 case; am not in the regular employ of 17 counsel for any of said parties; nor am 18 Tin anywise interested in the result of said case. 20 This, the 10th day of March, 2013.
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RACHAEL MILLER. RPR, CSR, CCR 2807
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1 ERRATA SHEET 2 STATE OF GEORGIA 3 COUNTY OF CHATHAM) 4 I wish to make the following changes for the following reasons: 5 6 PAGE LINE CHANGE:_________________ 7 8 REASON:________________ 9 - CHANGE:_________________ 10 REASON: 11 - CHANGE:___________________ 12 REASON:________________ 13 CHANGE'_______________ 14 REASON:__________________ 15 16 17
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(Signed) Brandon Branch
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 13 of 17
February 26, 2013
Brandon Branch Lisa T. Jackson v. Paula IDeen, et al.
49 A absolutely 34:8 abuse 19:3 43:2,5 ACTION 1:5 actual 10:8 address 44:21 admitted 13:16,25 advance 40:18 advised 26:2 age 9:3 agent 7:4 21:22 agreement 1:18 ahead 32:17 ain't 33:1 alcohol 19:3 43:1 43:2,13,17 alcoholic 43:16 allegation 37:15 allegations 23:15 annual 41:9 answer 9:3 13:7 13:20,22 14:24 18:1 16:4 19:25 21:12 22:26 23:1125:2 27:21 29:10 30:3,15 31:18 35:12,21 36:3 answered 30:12 30:14 answers 32:21 48:9 ANTHONY 2:21 anybody 24:4 33:4 Anything's 40:12 anywise 48:18 Apparently 17:11 APPEARANCE 2:1 appearing 15:16 approved 39:18 arisen 19:6 arrangements 3917 40:1 arrested 24:10 Article 5:5 asked 14:22 22:18 26:13,16,17 30:12,13 32:7 34:1344:20 asking 13:6 27:10 28:14 29:21,24 31:13 32:2 34:16 aspect 6:15
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Brandon Branch Lisa T. Jackson v. Paula Deen, et al.
February 26, 2013
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 15 of 17
February 26, 2013
Brandon Branch Lisa T. Jackson v. Paula Deen, et a).
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Brandon Branch Lisa T. Jackson v. Paula Deen, et al.
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Brandon Branch Lisa T. Jackson v. Paula Deen, et al.
February 26, 2013 53
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Transcript of the Testimony of: Brandon Branch Date: February 26, 2013
Case: Lisa T. Jackson v. Paula Deen, et al. 4:12-CV-0139
As
Torn Crites & Associates International, Inc. P.O. Box 9438 Savannah, Georgia 31412 Phone: 800-631-3480 Fax: 912-233-7777 [email protected] www.critesintl.com EXHIBIT
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 2 of 17 February 26, 2013
Brandon Branch Lisa T. Jackson V. Paula Deen, et at.
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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION LISA T. JACKSON, Plaintiff,
CIVIL ACTION NO.
vs. PAULA DEEN, PAULA DEEN 4:12-CV-0 139 ENTERPRISES, LLC, THE LADY & SONS, LLc, THE LADY ENTERPRISES, INC., EARL W. BUBBA HERS, and UNCLE BUBBA'S SEAFOOD and OYSTER HOUSE, INC.. Defendants.
Deposition of BRANDON BRANCH, taken by counsel for the Plaintiff, pursuant to notice and agreement, before Rachael Miller, Certified Court Reporter, at 218 West State Street, Savannah, Georgia, February 26. 2013. at 10:38 am.
U Associates International. Inc. Tom Crites & Astociates
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 3 of 17 Februa ry 26, 2013
Brandon Brancli Lisa T. Jackson v. Paula Deep, et al.
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1 APPEARANCE OF COUNSEL: 2 3 4 5 6 I 8
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FOR If-I.E PLAiNTIFF: MATTHEW C BILLIPS, Esquire BUlips & Benjamin, LLP 3 10 Towercreek Parkway Suite 190 Atlaflta, Georgia 30339
770) 8590753
FOR THE DEFENDANTS: WILLIAM..FRANKUN, Esquire Oliver, Maner, LLP 218 West State Street Savannah, Georgia 31401 )912J236-3311
FOR THE DEFENDANTS: ANTHONY C LAKE, Esquire
Gillen, Withers & Lake, LLC 8 East Liberty Street Savannah, Georgia 31401 19121447-8400
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DISCLOSURE STATEMENT I 2 STATE OF GEORGIA 3 COUNTY OF CHATHAM: OPENING REMARKS AND STIPULATIONS - .6 4 Pursuant to ArbCIC 10. B. of the Rules 5 j 6 and Regulations of the Board of Court Reporting or 7 the Judicial Council of Georgia, 1 make the INDEX
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8 following disclosure.
EXAMINATION By Mr. Billips
ATTESTATION • ERRATA.SHE:ET CERTIFICATE
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I am a Georgia Certified Court Reporter. lam not disqualified for relationship of interest under the provisions of O.C.G,A. 9l1-28(c).
Tom Crites & Associates International, 14 Inc. was contacted by S. Wesley Woolf, P.C. to 15 provide court reporting services for this 16 proceeding. 17 Tom Crites & Assodates International, 18 Inc. will not be taking this proceeding under any 19 contract that is prohibited by Georgia law. 20 ThIs, the 10th day of March, 2013. 21 22 23 24
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3 (Pages 6 to 91 Page 6 BRANDON BRANCH, 1 2 having been first duly sworn, was examined and 3 testified as follows: EXAMINATION 4 5 BY MR. BILLIPS: Ci. Please state your full legal name. 6 A. Phillip Brandon Branch. 7 8 0. And, Mr. Branch, where and in what 9 capacity are you presently employed? A. With Paula Deen Enterprises. 10 0. Okay. What do you do there? 11 A. I am Paula's assistant and creative 12 director for the company. 13 14 0. Okay. Tell me first about the creative IS director aspect of yourjob. What does that 16 entail? A. I oversee the magazine. I work with the 17 IS furniture line. Anything visual the public sees. I oversee the TV show and photo shoots. 19 0. And are you present at all of the lv 20 21 shows and photo shoots and things of that sort? 22 A Yes. For the most part 0. Okay. How long have you worked for Ms. 23 24 Deen? A. Nine years. 25
Page 8 I videos that have ever been put together? 2 A. Yes. 0. Okay. How many? 3 4 A Ijust know of one. Q. Okay. And was that the one that was the 5 6 subject of some litigation? 7 A. Yes. a. Okay. And did you see that video? Have a 9 you seen it? 10 A Yes. II Q. Were there - were there jokes and 12 language that were inappropriate for a 13 famHy-oriented show? 14 A. I guess it depends on the family. 15 0. 1 suppose it does. 16 MR. FRANKLIN: And what do you mean by a 17 family? IS MR. BIWPS: Excuse me? 19 MR. FRANKLIN: What do you mean by a 20 family? 21 MR. BIWPS: A family-oriented show. 22 MR. FRANKLIN: Okay, Once again. I 23 object to the form of family oriented Is that 24 husband and wife? Is that grandpa and grandma? 25 BY MR. fILLIPS:
Page 7 1 0. Okay. Are - so have you started 2 writing a tell-all book yet? 3 A No. 0. Do you have an agent? 4 MR. FRANKLIN: Are you soliciting? 5 MR. BILLIPS: No. 6 7 BY MR. BIWPS: 0. I do know one, so... 8 During the show - strike. The shows 9 10 are filmed, if I understand correctly, in front of 11 a live audience; is that right? A No. 12 0. They're not. So they're filmed and then 13 14 edited and then the shows are - are not live, 15 correct? 16 A. Correct 0. All right Does she ever show or film 17 18 shows in front of a live audience, to your 19 knowledge? 20 A. In the past she has. 21 0. Okay. As the creative director, did you 22 have any involvement in putting together an 23 outtake video? A. No. 24 0. All right A re you aware of any outtake 25
Page 9 I 0. Was it inappropriate for children? 2 MR. FRANKLIN: And once again. I don't 3 know what age children, but you can answer. These 4 are laers objecting talking back and forth. No S one listens to us. 6 THE WITNESS. I guess. 7 BY MR. BIWPS: Q. What kind ofjokes were on this outtake 8 9 video? 10 A 1 do not remember. 11 0. You don't. You have to see it to know. 12 conct? 13 A. Yes. 14 0. Were thereJokes about vaginas? IS A Yes. 16 0. Were there jokes about oral sex? A I don't recall that 17 18 (1 Do you recall any - Aft Deen engaging 19 in any depictions of oral sex with fruit? 20 A No. I don't recall that 21 0. Have you ever seen herdoso22 A No. 23 0. - on-. when filming her show? 24 ANo. 1 25 0. Okay. Did you review this - or who was
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Brandon Branch Lisa T. Jackson v. Paula Deen, et al. 4Pages 10 to 13)
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Page tO responsible for putting this outtake video together? A. I do not know. 3 0. Would that not ordinarily be something 4 5 within your span of conlroll A. No. 6 C1 What if anc roiedo you have as 7 8 creative director with the actual show? MR, FRANKLIN: Theshowyoure talking 9 10 about? MR, BIWPS: The Paula Deen cooking Ii 12 show. MR. FRANKLIN: The whole shebang or are 13 4 you talking about a specific thing? MR. B1WPS: I've never watched her 15 16 show, so I'm going to have to learn from him. MR, FRANKLIN Okay. You're missing 17 8 some good television. 19 BY MR. BIWPS: 0. Okay. Does Paula Deen have more than 20 21 one 1V show? 22 A Na 23 0. Okay. Then when I refer to the Paula 24 DeenlVshow, do you know what rm talking about? 25 A. Yes, 2
A Yes. 1 2 0. And you haven't looked at that video in 3 how long? 4 A. At least three years. 0. Okay. Now, how familiar are - familiar 5 6 are you with members of the Deen family, other 7 than Paula? 8 A. Very familiar. 9 0. Okay. Are you —doyou consider 10 yourself to be close to them? II A Yes. 72 0. Do you think that you know them pretty 73 well? 14 A. Yes, 0. All right. How well do you know Bubba 15 16 Hiers? 77 A I would say pretty well. 0. Okay. Now, we've had testimony in this 18 19 case that you told an employee I think of-if 20 I'm correct of Uncle Bubba's that you had heard Mr. Hiers use the word nigger. 21 22 MR. FRANKLIN: Object to the form of 23 that. I believe it was Libby Summers who was not 24 an employee of Uncle Bubba's. 25 MR. BIWPS: Okay. Libby Summers, I
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Page Ii 0. What, if any, role do you have in the I 2 productIon, direction or anything else? 3 A. On the show I'm the prop stylist So I 4 choose the dishes, work with the clothing stylist, 5 do the flowers, do the food beauties, pick the 6 napkins, utensils. 7 0. Okay. And you're there for the filming 8 of the show? 9 A. Correct. 0. During the filming of the show, does Ms. 10 Deen use sexually suggestive language? Ii 12 A. No. 0. Does she ever tell jokes that are 13 14 sexually suggestive? A. Occasionally. 15 0. Okay. When you say occasionally, what 16 17 frequency do you mean? 18 A. 1 would say maybe once a year. 19 C1 Once a year. How many sexuay 20 suggestive jokes were there on this outtake video? 21 A. I don't remember. 22 0. Okay. Was it more than one? 23 A. I really don't remember. 24 0. So you just have no idea, you'd have to 25 see the video?
I don't remember where she worked. 2 BY MR. BILLIPS 3 CL Libby Summers - that you had told Libby 4 Summers you heard Uncle Bubba use the word nigger? 5 MR. FRANKLIN.' And I'll object to you 6 asking him to comment on the testimony of someone 7 else. Having said that, you can answer. 8 THE WITNESS: It never happened. 9 BY MR. BILUPS: 0. Never happened? 10 11 A. Never happened. 12 0. Has, to your knowledge, Uncle Bubba ever 13 used the word nigger? 14 A Not In my presence. 15 0. Okay. Would you be surprised to learn 16 that Mr. Hiers has actually admitted doing so at 17 Work In front of his managers? 18 MR, FRANKLIN: Object to the form of 19 that. I think it incorrectly characterizes 20 testimony saying managers, but you can answer. 21 BY MR. BIWPS 22 0. You can answer. A Repeat the question. 23 24 0. Would you be surprised to learn that Mr. 25 Hers has actually admitted to using the word
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Page 14 I nigger at work in front of his managerial - some 2 of his managerial staff? 3 A Yes 0. And do you know Libby Summers at all? 4 A. y, 5 0. How well do you know her? 6 A We worked together for maybe two years. 7 C). Okay. And what was her job? 8 A. She was food stylist 9 0, Okay. Is there any reason why you and 10 11 Ms. Summers would have been discussing Bubba 12 Hiers? MR. FRANKLIN: Objection, You're 13 14 assuming that there was such a discussion. MR. BILLIPS: No. I'm actually not 15 16 MR. ERANKUN.• Well, she says they've 17 talked about this doesn't mean there necessarily 18 was. MR. BIWPS: I didn't suggest by my 19 20 question that there was. MR. FRANKLIN: Okay. 21 22 MR. BILLIPS: I asked whether there was 23 any reason that there would have been. 24 MR. FRANKLIN: Okay. You can answer. 25 THE WITNESS: No.
I can answer. 2 THE WITNESS: No. 3 BY MR. BIWPS: 4 0. Okay. Is there any reason that Mr. 5 Gerard would have had that you are are of to communicate with you any - any reason within the 6 7 scope of any legal Issue that you can think of 8 that Mr. Gerard would have had to communicate with 9 you? 10 A. No. 0. Okay. Or for that matter for you to 11 12 communicate with Mr. Gerard. Would there have 73 been any reason for you to communicate with him on 14 any matters In the scope of his job as a lawyer? A. Yes. 15 0. Is there any reason for you to 16 17 communicate with Mr. Gerard regarding his scope as 18 a lawyer other than ln preparation foryour 19 deposition today? 20 MR, FRANKLIN: He has not - well, 21 object to the form of that. I think he said he's 22 done nothing in the preparation of the defense of 23 this lawsuit other than perhaps meeting with me. 24 BY MR. BIWPS: 25 0. Okay. What if anything, did you do to
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1 BY MR, B1LUPS: 1 prepare for your testimony today? 0. Okay. Ms. Summers 2 A. For - say that again. 2 MR. FRANKLIN: I object I don't know 3 0. What, if anything, did you do to prepare 3 4 how he would know if there's any reason if I call 4 yourself to give testimony in this deposition? S Joe or you call Joe. But having said that the A. Nothing. 5 6 objections there 6 0. Okay. MR. BILLIPS: It really is okay if you 7 7 MR. FRANKLIN: Well, other than - other B Just object to the form. 8 than 9 BY MR. BIWPS: 9 MR. BILLIPS: Other than meeting with 10 0. Now, have you had any role whatsoever in TO counsel. Ii assisting any - Ms. Deen or any of the Deen 71 MR. FRANKLIN: Apparently talking to me 12 companies with regard to anything having to do 12 means nothing. Thank you. I know where lam. 13 with this lawsuit 13 Chopped liver. 74 MR. FRANKLIN: Object to the Form. 14 BY MR. BIWPS: 15 BY MR, BIWPS: 15 0. Now, as Paula's assistant what do you 16 0. -other than appearing here today to 16 do? 17 give testimony? Ti A From waking her up in the morning to 18 A No. TB packing her clothes for a trip to traveling on a 19 0. Okay. Have you ever had any reason to 19 trip with her, overseeing her home, getting her 20 - do you know who Jim Gerard is? 20 from point A to B. 21 A Yes, 21 0. Okay. So you pretty much take care of 22 0. Okay. Have you ever had" reason to 22 every menial detail of her life? I'm not saying 23 consult with Jim Gerard on any matter relating to 23 it's limited to that but your job includes taking 24 your employment with Paula Deen? 24 care of the menial details of her life so she can 25 MR. FRANKLIN: Object to the form. You focus on whatever It is that she does? 125
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Lisa T. Jackson V. Paula Deen, et al 6Pages 18 to 21) Page 18 MR. FRANKLIN Object to the form to the 2 extent of menial. I'm not sure what that 3 encompasses or doesn't. If he understands, he can 4 answer. THE WITNESS: Yes. 5 6 BY MR. BILLIPS: 7 0. Do you know Lisa Jackson? 8 A. Yes. 9 0. Okay. And how well do you know Lisa
10 Jackson? A. We worked together for several years II 12 casual, not one-on-one. 0. Okay. How often would you interact with 13 74 her? A. Not often. 15 a. Did you go to Uncle Bubba's Seafood & 16 17 Oyster House very often? is A No. 0. Did you ever eat there? 19 A. Yes. 20 0. More than once? 27 22 A Yes. 23 0. Have you ever seen Mr. I -Hers in a state 24 of intoxication at the restaurant?
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THE WITNESS: Yes. 3 BY MR. BILUPS: 4 0. Okay. And has she ever confided in you 5 any concerns about her brother? 6 A No. 7 0. Has she ever indicated any concerns at 8 all about the fact that he is supervising 9 employees? 10 A No. 11 0. Would you consider yourself a loyal 12 employee of Ms. Deen? 13 A Yes. 14 a. Would you lie for her? A No. 75 76 Q. 1 suppose that's kind of a pointless 17 question, because if you were going to lie for 18 her... 19 MR. FRANKLIN: Object to your 20 editorialization. 21 BY MR. BILUPS: 22 a. Has anyone ever reported to you that 23 there were - there was any racial tension at 24 Uncle Bubba's? 25
A No.
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1 1 0. You are a - were you aware that Mr. Q. Has anyone - or are you aware that Mr. 2 Hiers watches pornography at the restaurant? 2 Hiers had at one point in time been in treatment 3 for cocaine and alcohol abuse? 3 A No. 4 4 0. Nobody has ever told you that had A. No. 0. Has Ms. Deen ever communicated to you 5 occurred or was occurring; Is that true? 5 A. True. 6 about any of the problems that had arisen at Uncle 6 7 7 Bubba's that resulted in a directive that he have Q. Okay. Ms. Deen has never in passing or 8 even in passing made any reference to Mr. Hiers 8 no managerial role in the restaurant? 9 engaging in inappropriate conduct of any sort is 9 A. No. 0. Does she talk to you about her problems? 10 that fair? TO 11 A. Uh-huh. She's not 1! MR. FRANKLIN: Object to the form of 12 that 12 MR. FRANKLIN: You have to answer BY MR. BILLIPS: 13 audibly. 13 14 0. Ms. Deen, does she talk to you about her 14 THE WITNESS: Yeah. No. She's never 15 problems? 75 mentioned that 16 BY MR. BIUJPS: 16 A. Yes. 17 0. Does she consider you a confIdant? 17 Q. Okay. Do you know who Barry Weiner is? A. Yes, 78 A. Yes. 18 MR. LAKE: Objection. Calls for 19 0. Is it Weiner or Weiner? 79 20 speculation. 20 A. Weiner. 21 21 BY MR. BILUPS: 0. And who Is Barry Weiner? 22 0. Does she behave toward you as if you are A. Paula's agent and business manager. 22 0. Okay. Is he an employee of Paula's or 23 a confidant? 23 24 do you know? MR. FRANKLIN , Once again, object to the 24 25 form. You can answer when we object That'sJust 125 A. I do not know, Tom Crites & Associates International, Inc. crltesintl.com
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Page 22 0. Do you know Karl Schumacher? 1 2 A Yes. 0. Has Mr. Schumacher ever spoken to you 3 4 about any problems that he felt existed with Mr. 5 Hers? 6 A No. 0. Has he ever communicated with you about 7 8 any concerns he had about Mr. Hiers or any other 9 members of the family taking money from Ms. Deen 10 to which they were not entitled 11 A No. 12 0. - or which they had not earned? 13 A No. 14 0. Okay. Has Mr. Schumacher ever IS communicated with you at all about anything 16 relating to the operation of the business? 17 A Na 0. Has Mr. Schumacher ever asked you to 18 79 pass messages or information along to Ms. Deen? A. Occasionally, yes. 20 21 0. What kind of thing would Mr. Schumacher ask you to pass along to Ms. Deen? 22 MR. FRANKLIN: Object to the form. 23 24 BY MR. BILIJPS: a. You can answer.
Page 24 0. Have you ever been involved in a lawsuit? A. No. 3 4 0. Ever sued anybody, ever been sued? 5 A. No. Q. Never tiled bankruptcy? 6 7 A No. 0. Are you married? 8 9 A. No. (1 Have you ever been arrested or otherwise 10 11 charged with a crime? 12 A No, 13 0. Without disclosing for the moment any 14 specifics, first have you ever spoken to Jim 15 Gerard? MR. FRANKLIN: Ever? 16 17 MR. BIWPS: Yeah. MR. FRANKLIN: Object to the form. 18 19 THE WITNESS: Yes. lye spoken to him. 20 BY MR. BIWPS: 27 0. Have you ever communicated with him via 22 email? 23 A No. I don't believe. 0. Okay. When you spoke to Mr. Gerard was 24 25 it about something relating to the corporation? 1
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Page 23 A, He would maybe give me a seared envelope 1 2 to hand to her. 0. Would he ever give you a verbal message? 3 4 A. No. 0. Okay. Now, have you ever been aware of 5 6 any complaints of harassment or unlawful 7 discrimination occurring within the Paula Deen 8 corporations, as Ill call the group of 9 defendants? 10 MR. FRANKLIN: Object to the form. You 11 can answer. 12 THE WITNESS: Ask me that one more time. 13 BY MR. BILLIPS: 14 0. Have you ever been aware of any 15 allegations of unlawful discrimination or 16 harassment, other than those brought by Ms. 17 Jackson? 18
A. No.
19 0. Have you ever felt - have you ever 20 yourself felt discriminated against for any 21 reason? A, No, 22 23 Q. Okay. Have you - have you ever given 24 testimony prior to today? A. No. 25
Page 25 I MR. FRANKLIN: Object to any question or 2 answer that would invade the attorney-client 3 privilege. 4 MR. BIWPS: I'm not invading the 5 privilege at present I'm establishing the 6 boundaries of the privilege. 7 BY MR. BIWPS: 8 0. Have you ever spoken to Mr. Gerard about 9 anything having to do with your employment or your 10 duties as an employee with the company? A. No. 1I 12 0. Have you ever spoken to him regarding 13 any matters, any legal issues affecting the 14 company? 15 A. No. a. Okay. Have you ever spoken to Mr. 16 17 Gerard? 18 MR. FRANKLIN; Once again, I'm going to 19 object. Whether hes spoken Invades the 20 attorney.dient privilege. If you inquire as to 21 what he spoke about 22 MR. BIWPS: The attorney-client 23 privilege - well, we can brief it If we have to. 24 MR. FRANKLIN: I think we maybe already 25 have.
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1 BY MR. BILLJFS THE WITNESS it could be various I 0. Mr. Branch. has Mr. Gerard ever advised 2 things. 2 3 you on any legal issues whatsoever? 3 BY MR. BILLIPS A. No. 4 4 0. Give me an example. C1 Okay. Has he ever questioned you on any 5 5 A She's not feeling great today. 6 legal issues whatsoever? (1 Doesn't seem very private or personal. 6 1 A No. 7 A She doesn't feel like going to a book 0. Has he ever questioned you regarding any 8 8 signing today. 9 of the claims of discrimination brought by Ms. 9 0. Okay. What is the most - what would 10 Jackson? 10 you consider to be the most private or personal 11 A. No. 11 thing that she's confided in you about? 12 0. Has anyone - other than Mr. Franklin 12 MR. FRANKLIN: Object to the form. How 13 today, has anyone ever asked you for Information 13 does he know what's the most private? 14 regarding any information you might know about Ms. 14 MR. BILUPS: I'm asking what he would 15 Jackson's claims? 15 consider the most private and personal thing. 16 A. No one's asked me. MR. FRANKLIN; Once again, I'll object 16 0. Okay. When Ms. - has anyone ever asked 17 17 to speculation. 18 you about any issues relating to Lisa Jackson at 18 THE WITNESS: I haven't a clue. 19 all? MR. B1LLIPS: Give it your best shot. 19 20 A. No one's questioned me. 20 MR. FRANKLIN: Object to the form. 21 Q. Okay. Have you ever volunteered 21 We're not here for best shots. 22 Information regarding Ms. Jackson? 22 THE WITNESS; I really can't give 23 A. No. 23 anything. 24 0. Okay. Have you ever made any complaints 24 BY MR. B1LLIPS: 25 to Ms. Deen or Mr. Hiers, anyone in the managerial 0. So y'aiI aren't- she doesn't really 25
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Page 27 I chain above Ms. Jackson with her? A. No. 2 0. Okay. Do you know any information that 3 4 might serve as the basis for a complaint about Ms. 5 Jackson? MR. FRANKLIN; With the exception - and 6 7 I object if it involves anything that may have 8 come up with discussions he has had with me. I'm 9 assuming you're not plumbing foi' that. tO MR. UIWPS: rm only asking ifhe has 11 personal knowledge 12 MR. FRANKLIN; Okay. Fine. MR. BILUPS: - of any misconduct or. 13 14 you know, anything of that sort that you believe 15 has been communicated by Ms. Jackson, THE WITNESS: No, 16 BY MR. BIWPS: 17 0. What does Ms. Deen confide in you about? 18 19 MR. FRANKLIN: Object to the form. 20 By MR. BILUPS: 0. You can answer. Does she tell you 21 22 private and personal things about herself? 23 A. Yes. 24 0. Such as? 25 MR. FRANKLIN: Oject to the form.
1 talk toyou about anything of a private or 2 personal nature? 3 MR. FRANKUN Object to the form. 4 Thats not what he said. 5 BY MR. BILUPS: 6 0. Other than I don't feet Pike going to a 7 book signing or I don't feel so well today, is 8 that right? 9 MR. FRANKUr& Object to the form. You 10 can answer. 11 THE WITNESS; l'mjust thinking. I 12 mean, there's - its been ten years rye known 13 her. [didn't think 14 BY MR. BIWPS: IS 0. In the ten years you've known her, you 76 can't think of a single example of anything other 17 than Is A. I mean there's - yes, there's more 19 things, but20 MR. FRANKLIN: Object to the form. 21 Object to the form. That's like asking every 22 conversation you had with someone over ten years 23 orovera week. 24 MR. BIUJPS: No. I'm asking him to 1 25 give mean example of one.
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MR, FRANKLIN: Object again to the form MR. FRANKLIN: My objection stands. 1 1 2 asking him sitting here. MR. BIWPS: Your objection is noted. 2 MR. BILUP5 My Ford, Counsel, 3 3 You can answer. MR. FRANKLIN: You don't have to call me 4 THE WITNESS: You know, she'll ask me do 4 5 your lord. Look, the way it works - let me say 5 you think I look fat in this outfit? Thafs a 6 something. 6 personal thing, 7 MR. BILUPS: You asked questions in 7 BY W. BIWPS: B exactly the same manner of the plaintiff during a Okay. Has she ever talked to you about 8 9 any concerns that she had regarding members of her 9 her deposition, okay, mostly without us trying to 10 step all over your record and make spurious 10 fniily, for example? It objections. So if you would like to object to the MR. FRANKLIN: Once again. I object to Ti form and asked and answered. 12 form12 MR. FRANKLIN: Ijust did, 13 MR. LAKE: Objection. Asked and 13 MR. BILUPS: - every time 14 answered. 14 MR. BIWPS: You can answer. 15 MR. FRANKLIN: Let mejust tell you 15 MR. FRANKLIN: Again. 16 something. 16 THE WITNESS: Repeat the question. 17 MR. BIWPS: - go ahead. I am 17 18 BY MR. BIWPS: 18 thoroughly familiar with the way It works. Q. Has she ever spoken to you about any MR. FRANKLIN: You ask the question, I 19 19 20 concerns that she has regarding any of the members 20 have an opportunity to object, and then he 21 of herfamilyl 21 answers. And that's the way it works and thafs MR. LAKE: Same objection. 22 the way ifs going to work. 22 MR. FRANKLiN: Objection to form. Same 23 MR. 811111'S: All right 23 24 objection. Any concerns. 24 MR. FRANKUN: I don't need a lecture THE WITNESS: Yes, she has. 25 from you on the rules of evidence or on anything 25 Page 31
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I else. This ain't my first trip to the rodeo and I BY MR. BIWPS. 2 hopefully won't be my last. 2 0. Okay. Tell me what— lets take them MR. B1WPS: You know what I don't 3 3 one at a time. What, if any, concerns has Ms. 4 think there is anybody In this room or in this 4 Deen expressed to you about her Sons? S building who has ever ridden anything in a rodeo. MR. FRANKLIN: Object to the form. Any 5 6 Let's just get off this - this issue. We're all 6 concerns. 7 experienced. We all know what we're doing. THE WITNESS: She would like more 7 MR. FRANKLIN: I don't need a lecture. 8 8 grandlcids. MR. BILUPS I don't need a speech. If 9 9 BY MR. BILLIPS: 10 you want to object to the form (1 Llh-huh. Does she have some reason to 10 MR. FRANKLIN: Ijust did. I I believe she's not going to have more grandkids - TI 12 MR. BIWPS: - object to the form 12 MR. FRANKLIN; Object to that You're 13 MR. FRANKLIN: Ijust did. 13 asking him for speculation. 14 MR. BIWPS: - without giving a 14 BY MR. BILUPS: 15 speech. 15 0. - or is It shejust wants more of them? 16 MR. FRANKLIN: Ijust did. Nowaskyour 16 MR. FRANKLIN: Object to the form. 17 next question. 17 BY MR. BIWPS: 18 18 BY MR. BILLIPS: 0. You can answer the question. 19 0. Now, Mr. Branch, is the only thing Paula 19 A. Shejust wants more. 20 Deen has ever talked to you about concerning her 20 0. Okay. Anything else? 21 Sons IS her desire for more grandchildren? 21 MR. FRANKLIN: Object to the form. A. No. 22 22 THE WITNESS: No. 23 23 BY MR. BIILIPS: 0. What else has she talked to you about 24 0. That's the only thing she ever talked to 24 concerning 25 you about her— her sons; Is that correct? 1 25 MR. FRANKLIN: Object to the form. Tom Crites & Associates International, Inc. crltesintL corn
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I MR. FRANKLIN: Object again to the form. BY MR. BPLUPS I 2 BY MR. BILUPS: 0. - her sons? 2 3 0. You can answer. A She would like for Bobby to settle down 3 4 MR. FRANKLIN: Can P have a standing 4 and find a wire. 5 objection? I don't want to waive something by not 0. Okay. Has she ever expressed any 5 6 objecting to ft. 6 concerns about whether Bobby is gay? MR. BIWPS: You may have a standing 7 MR. FRANKLIN: Object to that That Is 7 8 objection to every question I ask. 8 outrageous. That has absolutely - that's an MR. FRANKLIN: Every time you open your 9 9 Insulting question and you did it yesterday. 10 mouth I can have a standing objection without MR. BILLJPS: Why? Why is it insulting? 10 Ii making it? ljust want to make the record clear. MR. FRANKLIN: What on earth does that 11 MR. BIWPS: You may. 12 12 have to do with anything involved in this case? MR, FRANKLIN: Then it will be a 13 13 You asked Dustin that 14 standing objection on form unless 1 elaborate on 14 MR. BIWPS Yes. 15 that MR. FRANKLIN: - yesterday. And now 15 16 MR. BIWPS: That's 16 you're asking - that is Insulting. Its 17 MR. FRANKLIN: I'm not here trying to be Improper. 17 18 an obstructionist. MR. BIWPS: Why is it insulting? 18 MR. BILUPS: That's perfectly fine. 19 MR. FRANKLIN: Fm not going to —if 19 20 BY MR. BPLLIPS: 20 you cant figure that out, then you've got a 0. What other concerns, if any, has Ms. 21 problem, my friend. What does someone's sexual 21 22 Deen expressed about her sons? 22 orientation in the Deen family have to do with 23 A. I can't think of any other things she's 23 this? 24 expressed about them other than just love. 24 MR. BIWPS: Well, you know, it depends 0. Okay. What if any. concerns has Ms. 25 on whether I t goes to his relationships with other 25
Page 37
Page 35 I witnesses, other employees, other managers. It 2 goes to bias. There's a whole lot of ways where 3 it might MR. FRANKLIN: Welt we'll see where 4 S this goes and I don't think you're going to like 6 it 7 BY MR. BILUPS: C1 Has Ms. Deen ever expressed any concerns B 9 about whether Bobby is gay? 10 MR. FRANKLIN: And objection. 17 BY MR. BIWPS: 12 0. You can answer. 13 A No. 14 0. Okay. Do you have any idea whether 15 Bobby is gay? MR. FRANKLIN: And objection. 16 MR. LAKE: Objection. Il MR. FRANKLIN: Once again, this is 78 19 outrageous. 20 BY MR. BILLIPS: 21 Q. You can answer. A. No. 22 0. Okay. What else has Ms. Deen 23 24 expressed - what other concerns has she expressed 25 to you about her sons?
1 Deen expressed about her brother? A Nothing really. 2 Q. Okay. Did she telIyouwfen he stole 3 4 $30,000 From thefrjointlyowned restaurant? A. No. 5 6 0. Were you aware that he had taken money 7 to which he was not entitled from the restaurant? 8 A. No. 0. Is this the first you're hearing of 9 10 that? II A. Yes. 12 Cl. Does she ever talk to you about money 13 issues? A. Yes. 14 Q. Okay. Now, one allegation in this case 15 16 is that P. Jackson was present during planning 17 the wedding. And I don't remember who It was for 18 whether It was Bubba's wedding or whose. Were you 19 involved in the planning of any weddings A. Yes. 20 21 0. - with Ms. Jackson? 22 A. Yes. 23 0. Okay. Whose wedding was It? A. Bubba's. 24 0. Bubbas. Okay. That s what I was 25
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ATTESTATION
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CERTIFICATE
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I. the undersigned, have read the 3 4 foregoing transcript and with the exception of S any corrections specified on the attached 6 correction sheet attest it constitutes a true and 7 correct transcription of my testimony given at the 8 time and place specified therein. 9 10 11 12 (Signed): Brandon Branch 13 14 15 WITNESS: 16 17 18 19 DATE20
3 STATE OF GEORGIA 4 COUNTY OF CHATHAM: 5 I hereby certify that the foregoing 6 7 transcript was taken down, as stated in 8 the caption and the questions and 9 answers thereto were reduced to 10 typewriting under my direction; that the ii foregoing pages 1 through 47 represent a 12 true, complete, and correct transcript 13 of the evidence given upon said hearing. 14 and I further certify that I am not of kin or counsel to the parties in the 16 case; am not in the regular employ of 17 counsel for any of said parties; nor am 18 Tin anywise interested in the result of said case. 20 This, the 10th day of March, 2013.
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RACHAEL MILLER. RPR, CSR, CCR 2807
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1 ERRATA SHEET 2 STATE OF GEORGIA 3 COUNTY OF CHATHAM) 4 I wish to make the following changes for the following reasons: 5 6 PAGE LINE CHANGE:_________________ 7 8 REASON:________________ 9 - CHANGE:_________________ 10 REASON: 11 - CHANGE:___________________ 12 REASON:________________ 13 CHANGE'_______________ 14 REASON:__________________ 15 16 17
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(Signed) Brandon Branch
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Brandon Branch Lisa T. Jackson v. Paula IDeen, et al.
49 A absolutely 34:8 abuse 19:3 43:2,5 ACTION 1:5 actual 10:8 address 44:21 admitted 13:16,25 advance 40:18 advised 26:2 age 9:3 agent 7:4 21:22 agreement 1:18 ahead 32:17 ain't 33:1 alcohol 19:3 43:1 43:2,13,17 alcoholic 43:16 allegation 37:15 allegations 23:15 annual 41:9 answer 9:3 13:7 13:20,22 14:24 18:1 16:4 19:25 21:12 22:26 23:1125:2 27:21 29:10 30:3,15 31:18 35:12,21 36:3 answered 30:12 30:14 answers 32:21 48:9 ANTHONY 2:21 anybody 24:4 33:4 Anything's 40:12 anywise 48:18 Apparently 17:11 APPEARANCE 2:1 appearing 15:16 approved 39:18 arisen 19:6 arrangements 3917 40:1 arrested 24:10 Article 5:5 asked 14:22 22:18 26:13,16,17 30:12,13 32:7 34:1344:20 asking 13:6 27:10 28:14 29:21,24 31:13 32:2 34:16 aspect 6:15
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37:15 48:16,19 casual 18:12 CCR 48:24 celebrity 42:14 CERTIFICATE 3:16 Certified 1:18 5:9 certify 46:6,14 chain 27:1 change 43:10 47:7 47:9,11,13,15,17 47:19 changes 47:5 characterizes 13:19 charge 39:12,13 39:20 charged 24:11 charity 44:8 Chatham 5:3 45:7 45:8 47:3 48:4 children 9:1,3 choose 11:4 Chopped 17:13 CMI.. 1:5 claims 26:9,15 clear 36:11 close 12:10 clothes 17:18 clothing 11:4 clue 28:18 cocaine 19:3 cold 42:24 Colorado 42:13 come 27:8 comment 13:6 communicate 16:68,12,13,17 communicated 19:5 22:7,15 24:2127:15 companies 15:12 company 6:13 26:10.14 complain 44:17 complaint 27:4 complaints 23:6 26:24 complete 48:12 compound 43:5 concerning 33:20 33:24 concerns 20:5,7 22:8 30:9,20,24 31:3,6 34:6 35:8
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35:24 36:21,25 concluded 45:15 conduct 21:9 confidant 19:17 19:23 confide 27:18 confided 20:4 28:11 consider 12:9 19:17 20:11 28:10,15 constitutes 46:6 consult 15:23 contacted 5:14 contract 5:19 control 10:5 conversation 29:22 cooking 10:11 corporation 24:25 corporations 23:8 correct 7:15,16 9:12 11:9 12:20 31:25 41:7 46:7 48:12 correction 46:6 corrections 46:5 correctly 7:10 CouncIl 5:7 counsel 1:17 2:1 17:10 32:3 48:15 48:17 counties 45:8 County 5:345:8,8 47:3 48:4 court 1:1,18 5:6,9 5:15 creative 6:12,14 7:21 10:8 crime 24:11 Crites 5:13,17 CSR 48:24 current 44:21 D D 3:2 4:2,2 5:1 dance 39:5 DATE 46:19 day 5:20 40:17 48:20 days 38:24 39:5 Deen 1:7,7 6:10 6:24 9:18 10:11 10:20,24 11:11 12:6 15:11,11,24
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Brandon Branch Lisa T. Jackson v. Paula Deen, et al.
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e50 19:5,14 20:12 21:7 22:9,19,22 23:7 26:25 27:18 31:4 33:20 34:22 35:8,23 36:22 37:138:2,6,9 39:8,23 40:14,21 41:1,9.2142:25 42:2543- 12,25 Deens 43:16 defendants 1:11 2:12,20 23:9 defense 16:22 degree 41:17 depends 8:14 34:24 depictions 9:19 deposition 1:16 16:1917:432:9 45:15 DESCRIPTION 4:3 design 42:13 desire 33:21 detail 17:22 details 17:24 direction 11:2 48:10 directive 19:7 director 6:13.15 7:2110:8 disclosing 24:13 disclosure 5:6 discriminated 23:20 discrimination 23:7,15 26:9 discussed 38:2 40:23 41:1 discussing 14:11 discussion 14:14 41:4,5 discussions 27:8 39:2340:20 dishes 11:4 disqualified 5:10 DISTRICT 1:1,2 DIVISION 1:3 doing 13:16 33:7 40:15 dress 38:22 dressed 38:12,15 dresses 38:17 drink 43:25 duly 6:2 Dustin 34:13
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Brandon Branch Lisa T. Jackson v. Paula Deen, et a).
51 kids 42:2 8:129:1 21:9 include 41:13 45:6 kin 48:15 kind 9:8 20:16 Includes 17:23 22:2143:23 Income 41:8 know 7:8 8:4 9:3 Incorrectly 13:19 9:11 10:3,24 Indicated 20:7 12:12,1514:4,6 Information 22:19 15:3,4,2017:12 26:13,14,22 27:3 18:7,921:1724 Inquire 25:20 21:2522:126:14 insulting 34:9,10 27:3,14 28:13 34:16,18 Interact 18:13 30:4 33:3,7 34:24 39:4 40:3 Interest 5:11 interested 48:18 knowledge 7:19 13:12 27- 11401 International 5:13 5:17 41:3 Intoxication 18:24 known 29:1215 Invade 25:2 L Invades 25:19 Invading 25:4 L 5:1 Involved 24:1 LADY 1:8,8 34:1237:19 Lake 2:21,22 40:20 19:19 30:13,22 Involvement 7:22 35:17 45:12 39:16 language 8:12 Involves 27:7 11:11 Issue 16:7 33:6 law 5:19 Issues 25:13 26:3 lawsuit 15:13 26:6,1837:13 16:23 24:2 44:18 lawyer 16:14,18 lawyers 9:4 learn 10:16 13:15 Jackson 1:4 18:7 13:24 18:10 23:17 leave 42:8,19,20 26:10,18,22 27:1 Lecture 32:24 33:8 27:5,15 37:16,21 1eft42:22 38:2 39:24 40:21 legal 6.6 16:720:1 41:244:4,7 25:13 26:3,6 Jackson's 26:15 let's 31:2 33:6 44:11 Libby 12:23,25 Jim 15:20,23 13:3,3 14:4 24:14 41:24 45:2 Liberty 2:23 job 6:15 14:8 lie 20:14,17 16:14 17:23 life 17:22,24 40:1544:13 limited 17:23 Joe 15:5,5 Lindley 41:24 Johnston 45:2,3 line 6:18 47:6 Lisa 1:4 18:7,9 jointly-owned 37:4 26:18 39:22 jokes 8:11 9:8,14 40:23 9:16 11:13,20 listens 9:5 Judicial 5:7 litigation 8:6 little 39:2 K live 7:11,14,18 liver 17:13 Karl 22:1
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Brandon Branch Lisa T. Jackson v. Paula Deen, et al.
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Case 4:12-cv-00139-WTM-GRS Document 146-7 Filed 04/17/13 Page 17 of 17
Brandon Branch Lisa T. Jackson v. Paula Deen, et al.
February 26, 2013 53
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