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00001 1 in the united states district court for the middle district of ...

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00020<br />

1 one. She went to Dr. Peterman with her concerns.<br />

2 I don't know any specific statements that Dr.<br />

3 Peterman made because I was not <strong>in</strong> that meet<strong>in</strong>g when she<br />

4 went to her.<br />

5 Q. Fair enough. Did she state what her concerns were <strong>for</strong><br />

6 <strong>the</strong> untenured teachers?<br />

7 A. Just that <strong>the</strong>re has been <strong>court</strong> cases that say you can't<br />

8 teach Creationism. So she was concerned if this is<br />

9 com<strong>in</strong>g, <strong>the</strong>n you have some untenured teachers that would<br />

10 be teach<strong>in</strong>g it. She was concerned <strong>for</strong> -- I don't<br />

11 know -- I don't know if I want to say <strong>for</strong> <strong>the</strong>ir jobs.<br />

12 Younger teachers and putt<strong>in</strong>g <strong>the</strong>m <strong>in</strong> that position I<br />

13 guess.<br />

14 Q. You said that Bert said we need to keep on our guard?<br />

15 A. Yes. Someth<strong>in</strong>g to that effect, yeah.<br />

16 Q. Sure. Did she say anyth<strong>in</strong>g else that elaborated on that<br />

17 po<strong>in</strong>t?<br />

18 A. Not that I can recall.<br />

19 Q. Did Bert ever show you a memo reflect<strong>in</strong>g --<br />

20 A. No.<br />

21 Q. -- her conversation?<br />

22 A. No. I have seen it recently. But not at that time, I<br />

23 didn't, no.<br />

24 MS. PENNY: Off <strong>the</strong> record.<br />

25 (J. Miller Deposition Exhibit 1 was marked.)

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