More on Varian's hostile work environment:
FALCON: Second paragraph says "this really began to escalate circa February 20 -- one week after Mike and I had a stormy meeting with Britt in which Mike made it clear that he felt I had systematically singled him out for harassment and was continuing to do so." This is your statement that you put in this note, your thoughts, your reflections?
POWELL: I'm saying I believe I wrote this, but I don't know what I did with it. It might have been something for my own knowledge, I just wanted to document what was going on. I -- I -- you know, I have a recollection of what happened, but yes.
FALCON: Is there some reason that you didn't include that statement or the effect of that statement in your declaration that you filed, or you signed and had filed with the court in this case, appears here in your deposition as Exhibit 1?
POPPE: Objection, vague, compound and argumentative. I don't know what you mean by the effect of the statement.
FALCON: That Mike felt that he was being systematically singled out for harassment.
POPPE: I know what statement you're referring to, I don't know what you mean by the effect of the statement.
POWELL: Well, the memos -- it's consistent with what Mike wrote to Britt that we just looked at and which I believe everyone had seen. So, yeah.
FALCON: Yeah, you did -- is there a reason you didn't include this in your declaration?
POWELL: No, I don't even remember this. No, I -- statement, you mean.
FALCON: Yes.
POWELL: No, there is no reason.
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