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