Katrina L. Webster v. Thomas W. Harker, Acting Secretary of the Navy, et al.

The questioned presented are: 1. Defendant’s Counsel stopping a deposition to direct a deponent [CAPT Patrick Croley] to change his testimony to hide discrimination, should be sufficient grounds for a ruling of discrimination in Petitioner’s favor, or at the very least, to withstand summary judgement (see ECF 71, p. 4,1st paragraph)? a. If the District Court Judge was aware of the Equal Employment Opportunity Commission’s (EEOC’s) Office of Federal Operations (OFOs) Sua Sponte Decision (appendix G) and case No. 20-0610, ECF 1, that the Navy Captain Patrick Croley (identified in question “a” above, had breached the Confidentiality of pro se Petitioner’s EEO activity, shouldn’t this have been sufficient to withstand granting of summary judgment to the Defendant? 2. Moreover, in the same OFO decision, if the Judge was aware that the EEOC OFO has found that pro se Petitioner was discriminated on the basis of Reprisal, shouldn’t this have been sufficient to find discrimination in pro se Petitioner’s favor or at the very least, been sufficient to survive summary judgment? 3. Agency Attorney Kevin Keefe’s use of Lexis Nexis to research and disseminate Plaintiff and her husband’s Protective EEO Activity to SSP Management and Board of Directors is sufficient to withstand granting summary judgement to Defendant, and consistent with the OFO’s 14 February 2020 Sua Sponte Decision (see Pl.’s Opposition to M.T.D. at ECF 70, page 30; “security clearance issue”). 4. Denied a copy of Defendant’s deposition of Petitioner’s witness’ testimony. Since this deposition was with taxpayers’ money, should plaintiff be permitted a copy free of cost. The deponent was Plaintiffs witness who provided testimony on Petitioner’s behalf that would have withstood summary judgment and was damaging to Defendant’s case. 5. Should an affidavit from the agency’s former Human Resource Director, clearly identifying discrimination in the agency, be sufficient to withstand a decision of summary judgment in Defendant’s favor? 6. Is it legal for the Judge to outright “deny” Plaintiffs cross motion for summary judgment without making a ruling on its merits?