ML062000352

Transcript of Individual

ML062000352
Person / Time
Site:	Salem, Hope Creek
Issue date:	05/28/2004
From:	NRC/OI
To:
References
1-2003-045, FOIA/PA-2005-0194
Download: ML062000352 (88)

Text

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF INVESTIGATIONS INTERVIEW IN THE MATTER OF:

INTERVIEW OF Docket No. 1-2003-045 (CLOSED)

Friday, May 28, 2004 DNNS Conference Room NRC Region I Office 475 Allendale Road King of Prussia, PA The above-entitled interview was conducted at 9:10 a.m.

BEFORE:

Information in is rei

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0 j*mjfpriior Special Agent: Jeffrey Teator inaccordance v*h Act, exemption: p-i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

2 APPEARANCES:

On Behalf of the Witness, Jeffrey Keenan, Esq.

Assistant General Solicitor PSEG Services Corporation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

3 1 P-R-O-C-E-E-D- I-N-G-S 2 9:10 a.m.

3 SR. SPECIAL AGENT TEATOR: Today's date 4 is May 2 8 th. The year is 2004. My name is Jeffrey 5 Teator. I'm a senior special Agent with the United 6 States Nuclear Regulatory Commission, Office of 7 Investigations. It's approximately 9:10 in the 8 morning.

9 This morning I'm interviewing(

10 .The interview's taking place in the DNNS 11 Conference Room, NRC Region I Offices in 475 12 Allendale Road, King of Prussia, Pennsylvania.

13 prior to going on the 14 record, did I present you with my credentials?

15 NYs 16 SR. SPECIAL AGENT TEATOR: Did I explain 17 to you this is a voluntary interview?

18 Yes, you did.

19 SR. SPECIAL AGENT TEATOR: Okay.

20 Knowing it's voluntary, do you wish to go forward?

21 Yes, I Will.

22 SR. SPECIAL AGENT TEATOR: All right.

23 Do you have any objection this morning to providing

/

24 sworn testimony?

25 an No, not at all.

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4 1 SR. SPECIAL AGENT TEATOR: Raise your 2 right hand please?

3 Whereupon, 5 was called as a witness and, having been first duly 6 sworn, was examined and testified as follows:

7 EXAMINATION 8 SR. SPECIAL AGENT TEATOR: Thanks.

9 \you're being interviewed today as a 10 potential subject in this investigation, and I'll 11 explain what I mean by that, in that I'm conducting 12 an investigation into whether Kim Harvin's position 13 was eliminated down at Salem Hope Creek because she 14 engaged in NRC protected activity.

15 I'm also investigating whether Kim 16 Harvin's last date at the site was moved up from 17 April 1 6 th to March 2 8 th because she engaged in such 18 protected activity.

19 Now from what I understand, you were 20 involved in a meeting and discussion that occurred 21 on March 18, 2003, where there were discussions, 22 decisions made, a direction given to move up Ms.

23 Harvin's last day at the site.

24 So because of your, from what I 25 understand now, and we're going to get to it during NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 the interview, but from what I understand, because 2 based on your involvement in that meeting and 3 discussion, that's why you're a potential subject in 4 this investigation.

5 Okay.

6 SR. SPECIAL AGENT TEATOR: 400w) you're 7 represented by counsel today. Counsel, if you could 8 identify yourself please, and explain your 9 representation?

10 MR. KEENAN: Yes. My name is Jeff 11 Keenan. I'm Assistant General Solicitor with PSEG 12 Services. I'm representin and PSEG Nuclear 13 in a dual capacity.

14 I've reviewed this information and in 15 particular the discussions on March 18 th, and I 16 don't have reason to believe there's a conflict of 17 interest nor a violation of 10 CFR 50.7. Obviously, 18 that's the NRC's -- is going to evaluate that and 19 reach their conclusions.

20 But that we are participating on a 21 voluntary nature and we appreciate the chance to 22 provide the testimony.

23 We would also like to review the 24 25 transcript at a mutually convenient time when the transcript's available.

A

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6 1 SR. SPECIAL AGENT TEATOR: Okay..

2 is that your understanding of Jeff's representation?

3 Yes, it is.

4 SR. SPECIAL AGENT TEATOR: Okay. I have 5 a few follow-up questions for you.

6 7 SR. SPECIAL AGENT TEATOR: Does your 8 employer require you to have an attorney present 9 when you're interviewed by the NRC Office of 10 Investigations?

11 No, it does not.

12 SR. SPECIAL AGENT TEATOR: Were you in 13 any way threatened with any type of adverse action 14 by your employer if you did not request counsel to 15 represent you during this interview?

16 No, I wasn't.

17 SR. SPECIAL AGENT TEATOR: Do you 18 understand you have a right to a private interview 19 by me if you wanted one?

20 ýw ý Yes.

21 SR. SPECIAL AGENT TEATOR: Knowing all 22 this, do you wish to go forward with counsel 23 present?

24 Yes.

25 SR. SPECIAL AGENT TEATOR: Okay. All .-1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 right. NNWW can you give me your date and place 2 of birth please?

3 4

5 SR. SPECIAL AGENT TEATOR: Okay, and 6 your Social Security number?

7 8 SR. SPECIAL AGENT TEATOR: And your home 9 address please?

10 11 12 SR. SPECIAL AGENT TEATOR: That's down 13 this way sort of, right?

14 ) It's about a hour and a 15 half up the road?

16 SR. SPECIAL AGENT TEATOR: Is it?

StYes.

17 18 SR. SPECIAL AGENT TEATOR: Okay. How 19 far from Newark?

20 Depends upon what you mean.

21 Time or miles?

22 SR. SPECIAL AGENT TEATOR: Miles.

23 24 SR. SPECIAL AGENT TEATOR: South? Is it 25 south of Newark?

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16. 1 [-**,,*** *Yes.

2 SR. SPECIAL AGENT TEATOR: Okay. All 3 right. Your home phone number please?

4 5 SR. SPECIAL AGENT TEATOR: Have you ever 6 served in the United States military?

7 1i hhae not.

8 SR. SPECIAL AGENT TEATOR: Okay. Have 9 you attended college?

10 Yes.

11 SR. SPECIAL AGENT TEATOR: Which school?

12 S so ---

13 SR. SPECIAL AGENT TEATOR: What year?

14 15 SR. SPECIAL AGENT TEATOR: What was your 16 degree in?

17 -

18 SR. SPECIAL AGENT TEATOR: Bachelor of -

19 20.

21 SR. SPECIAL AGENT TEATOR:

22 Further degrees?

23 Not completed.

24 SR. SPECIAL AGENT TEATOR: Who do you 25 currently work for? Which company?

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9 I . PSEG Services Corporation.

2 SR. SPECIAL AGENT TEATOR: Can you 3 explain the relationship with your employer with 4 PSEG Nuclear please?

5 2 PSEG Services Corporation 6 is the support centralized services company that 7 provides functional support like Human Resources, 8 IT, financial accounting to each of the operating 9 companies, PSEG Power being one of the operating 10 companies.

11 SR. SPECIAL AGENT TEATOR: For the 12 record, that's an announcement here at Region I, and 13 the court reporter can please not record that in the 14 transcript. All right, and your current job title 15 please?

16 17 18 SR. SPECIAL AGENT TEATOR: In the 19 Services Corporation?

20 Correct.

21 SR. SPECIAL AGENT TEATOR: Okay, and who 22 do you report to?

23 24 ~N 25 SR. SPECIAL AGENT TEATOR: How long have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

10 1 you been in your current position?

2/

4 SR. SPECIAL AGENT TEATOR: Were you 5 employed by PSEG prior to that?

6 7 SR. SPECIAL AGENT TEATOR: Okay, in what 8 capacity?

9 4was a-10 12 SR. SPECIAL AGENT TEATOR: Okay, in that 13 job, did you have any involvement with the nuclear 14 business unit?

15 No, none whatsoever.

16 SR. SPECIAL AGENT TEATOR: Okay. So in 17 18 19 ,* PSEG Power at the time.

20 SR. SPECIAL AGENT TEATOR: Okay.

21 Going into the Services 22 Corporation is a recent change.

23 SR. SPECIAL AGENT TEATOR: Let's -- can 24 you break that down for me?

25 Sure.

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11 1 SR. SPECIAL AGENT TEATOR: When that 2 change occurred?

3 )When I joined in this 4 capacity, I joined PSEG Power. As of April 12 h of 5 this year, there was a reorganization involving 6 Human Resources, where Human Resources was brought 7 into the Services Corporation as a centralized 8 functional group.

9 So I became an employee of the Services 10 Corporation at that time, but serving in the same 11 capacity as I was serving in when I came over in 12 13 SR. SPECIAL AGENT TEATOR: Okay. So 14 u were hired to work in PSEG Power?

15 correct.

16 SR. SPECIAL AGENT TEATOR: Was the 17 Nuclear Business Unit part of that organization?

18 It did not officially 19 report to my boss at that time, who wasN 20 . It was loosely connected. It reported to 21 the Chairman and Chief Executive Officer of PSEG.

22 SR. SPECIAL AGENT TEATOR: Okay. Can 23 you tell me your supervisory responsibility over the 24 HR unit at the site? That would be 25 and ~ i(h  ?

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12 1 *Well, the HR people at the 2 nuclear site basically report to me. They did 3 report to me back in IM 4 SR. SPECIAL AGENT TEATOR: Okay. So 5 that reporting chain has remained the same as 8/02?

6 )Yes, it has.

7 SR. SPECIAL AGENT TEATOR: Okay. All 8 right, thanks. That will help me later on.

9 Okay.

10 SR. SPECIAL AGENT TEATOR: All right.

11 So you came on in *nto your current, I'm going 12 to just call it "work area"?

13 That's correct, sure.

14 SR. SPECIAL AGENT TEATOR: I feel like 15 I'm in your plant. All right, again that's just an 16 announcement here in Region I. we'll 17 get back to the questioning here.

18 When you came on in. in your 19 current capacity, supervising the site HR people 20 down at Salem Hope Creek, at any point after that 21 were there any type of concerns brought to your 22 attention regarding Kim Harvin, and how she 23 conducted herself down at the site, interacting with 24 people, doing personal business on company time, 25 anything like that? Was anything like that brought -' (,.

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13 1 to your attention? If so, when and who?

2 No, I wouldn't say anything 3 like that was brought to my attention. I began to 4 learn who the people were, and Kim Harvin had, I 5 guess, a loose connection with or relationship with 6 the Human Resources Group, because of her role as 7 Culture Transformation Manager, I believe it was.

8 So I sort of knew her name, but I really 9 had no idea what she did or what that meant. There 10 was no such title in the company that I was aware 11 of.

12 SR. SPECIAL AGENT TEATOR: But at some 13 point did your site HR people, in the form of A 14 .. (ph) would be 15 another one that worked down there?

16 \Yes, but I don't know her.

17 SR. SPECIAL AGENT TEATOR: Did any of 18 those individuals or anyone else in your reporting 19 chain at the site raise concerns to you regarding 20 the way Kim Harvin, and I'm going to be general 21 here, conducted herself down here?

22 I came to know her name.

23 SR. SPECIAL AGENT TEATOR: Sure.

24 '-.And obviously without 25 remembering any specifics, I mean Kim's name sort ofX'7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

14 1 was a name that, more so than other names, I just 2 came to know.

3 Maybe it was because of her role as an 4 organization development person, and the kinds of 5 things that she perhaps got involved with, in terms 6 of employees and things that we would have 7 considered to be the purview of Human Resources.

8 But nothing of a particular nature, nothing specific 9 like an event or a specific issue that I could 10 recall.

11 SR. SPECIAL AGENT TEATOR: Anything 12 improper regarding her conduct down there?

13 - No, not improper. I 14 wouldn't use the term "improper."

15 SR. SPECIAL AGENT TEATOR: Go ahead and 16 tell me if you had some --

17 Difficult personality at 18 times.

19 SR. SPECIAL AGENT TEATOR: Go ahead.

20 Tell me about that, and who you heard that from and 21 the basis for that?

22 I'm not sure I could assign 23 it to any one individual that I heard it from.

24 SR. SPECIAL AGENT TEATOR: What was the 25 general --

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15 1 Well probably from the 2 Human Resources Department. People, you know 3 *se -** people who may have --

4 you know, who are the people down at nuclear? I 5 knew no one for all intents and purposes.

6 I knew -ilTMIt

/IC 7I I'd never been there, 8 basically never even saw these people for all 9 intents and purposes.

10 SR. SPECIAL AGENT TEATOR: Okay.

11 In the general course of 12 conversation, I would say, you know, Kim's name 13 would have sort of surfaced, and somewhere along the 14 line, someone would have mentioned to me --

15 Again, I'm not quite sure who was the 16 first person to mention her name to me or in what 17 context, but it would have been something along the 18 lines of "You know, Kim works here in this like OD 19 capacity. She came out of (ph) 20 group."

21 I had no idea what that meant, because 22 there was no such thing in the company that I was 23 aware of.

24 SR. SPECIAL AGENT TEATOR: Right.

25 I mean, generally I was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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16 1 sort of -- that was it. Sort of general knowledge, 2 if you will. General understanding of people on the 3 site, particularly those related to HR.

4 Who's doing what in HR? I needed to 5 find out what was going on in the Human Resources 6 Department, or the Human Resources function.

7 SR. SPECIAL AGENT TEATOR: Right. You 8 made a comment that leads me to believe Kim was 9 doing something outside normal HR-type work?

10 "Well, she wouldn't have 11 been doing normal HR work. She shouldn't have been 12 doing normal HR work, because she wasn't part of the 13 Human Resources Department.

14 SR. SPECIAL AGENT TEATOR: Okay. Maybe 15 I took you wrong then, what you said. You made a 16 moment, something outside of normal HR activity. I 17 didn't know if you were going somewhere with that.

18 )No, I wasn't. I think I 19 might have been referring to her role as an 20 organization development consultant. Despite 21 whatever her title was, as she called herself, would 22 have been someone who would have functioned in the 23 capacity of looking at organization structure, 24 organization effectiveness, organization efficiency.

25 To an extent, that's the purview of the"-'

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17 1 Corporate Human Resources Group or the, I guess they 2 call themselves Organization Development in Newark, 3 unde She was an extension or came 4 from that group.

5 Nowhere else in the company would a 6 position like that have existed. So there wouldn't 7 have been an OD person in any other business unit, 8 certainly not that I was aware of.

9 So I was curious as to well what does 10 she do there, because this doesn't exist any place 11 else.

12 SR. SPECIAL AGENT TEATOR: Okay, right.

13 And exploring your curiosity, what did you find out?

14 W That she tended to speak to 15 employees sort of on a general basis. She was 16 involved in the Gallup survey; she was involved in a 17 variety of other survey activities or survey-type 18 activities.

19 Gallup was the one I heard of the most, 20 where she would gather information, kind of get a 21 sense of what was the morale, what was the general 22 tone at the site, and work wit -and the 23 senior team and doing something with that.

24 Now that always perplexed the Human 25 Resources people, because they would have thought NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 that was their purview, to a degree.

2 SR. SPECIAL AGENT TEATOR: Right. Did 3 you come to find that she was -- that -had 4 asked for her services for the entire year of 2002?

5 At some point did you become aware that he had 6 specifically --

7 Yes. I became aware of the 8 fact that somewhere along the line, and it preceded 9 me, so I'm not quite sure I know exactly what the 10 genesis of this was, that she was -- services like 11 hers out of the OD Group were asked for.

12 It was supposed to be a -- I call it a 13 "limited duration assignment." Whether that was a 14 year or two years, I'm not quite sure. I know she 15 was going to be there for most of 2002, if not all 16 of 2002.

17 And beyond that, I wasn't sure. I just 18 that would be something that )ould have 19 told us when this thing no longer had a usefulness 20 to the nuclear business.

21 We would probably, as normally would 22 happen, be told "I no longer have a need for this 23 job. There's no real reason why this should exist,"

24 perhaps because there was an organization structure 25 change, or there were other services of a like /(

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19 1 nature to be provided by someone else, as would 2 normally have occurred in an organization.

3 SR. SPECIAL AGENT TEATOR: Okay. At 4 some point did you have such a discussion withg IC-5 about that?

6 No. I never -- actually, I 7:-

7 never really spoke to all that much.

8 SR. SPECIAL AGENT TEATOR: Okay. So if 9 you could just share with me -- you took over your 10 position in It's pretty late in the 11 2002 time period. What was -- and if we could focus 12 on Kim Harvin if we could.

A

• sure.

13 14 SR. SPECIAL AGENT TEATOR: When you acme 15 and took your present position in*i what was 16 your understanding of the duration of her work down 17 there at Salem Hope Creek? What was explained to 18 you regarding the expectation of her duration --

19 )Oh, not very much at all.

20 It was just that she was there. It was probably an 21 assignment of some temporary nature, and then we 22 would be told when, you know, when it was over, in a 23 sense. Pretty much that was it.

24 SR. SPECIAL AGENT TEATOR: That's it.

25 My involvement with Kim --

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20 1 I hadn't even met Kim at that point in time.

2 SR. SPECIAL AGENT TEATOR: Okay.

3 So all I knew that there 4 was a person in a role, a role that didn't exist 5 anywhere else in PSEG that I was aware, outside of 6 Corporate Human Resources, sort of embedded within 7 the operating company, which was something of an 8 anomaly. It just didn't exist anywhere else.

9 So it sort of got my curiosity up. I 10 got an answer that she was there sort of as an 11 extension ofV4 11group, pretty much 12 end of the story.

13 SR. SPECIAL AGENT TEATOR: Moving 14 towards the end of calendar year 2002, was 15 information brought to your attention later on in 16 the year of '02 regarding her status at the site, 17 whether we continue into '03 and/or beyond that?

18 No, I probably didn't know 19 or I wasn't told specifically anything other than 20 what I just pretty much said. I mean, I sort of 21 came by that information as a piece of general 22 information about what's going on, who does what, 23 who's who and trying to find out what I was 24 responsible for and who was doing what down there.

25 I essentially had the directive from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 )"Get the Human Resources function for 2 all of Power, which included nuclear." It didn't 3 report to him. HR was sort of came under my 4 umbrella, and "Get your arms around it."

5 I was assigned a project virtually from 6 Day 1, which was called the development of a chapter 7 in a playbook that we were working on, and that 8 chapter was called "Organizational Effectiveness."

9 So everything under the HR umbrella was something I 10 needed to look at.

11 SR. SPECIAL AGENT TEATOR: All right.

12 Still talk about --

13 . Specifically on Kim Harvin?

14 SR. SPECIAL AGENT TEATOR: Right.

15 'I had no discussions, for 16 the most part, with anybody, certainly not of a 17 specific nature, that related to either her, her 18 behavior or her assignment or the length of that 19 assignment.

20 SR. SPECIAL AGENT TEATOR: Would that 21 include 1 You would not have had such 22 discussions with her in 2002 either?

23 )No, not on a specific 24 basis. I probably did ask "What does Kim do 25 there," and she explained to me she came to nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

22 1 probably at the request.of I believe, out of 2 group, and she was there to, you 3 know, provide some OD type of support and services.

4 Bu this wasn't a permanent role. This was a role 5 that was going to end at some point in time.

6 SR. SPECIAL AGENT TEATOR: Let's talk 7 about that a little bit.

8 Sure.

9 SR. SPECIAL AGENT TEATOR: Tell me more 10 about it being not a permanent role down there?

11 1 There was no such job in 12 the company. Those jobs, OD consultant jobs, and 13 let's call it that, regardless of what she called 14 herself, OD consultant jobs existed in one place and 15 one place only, and that was in the corporate -- I 16 believe it's called the Organization Development 17 Group, under 18 SR. SPECIAL AGENT TEATOR: Right.

19 That's in Newark. There 20 were no other jobs there. So it was sort of let me 21 provide a service to the Nuclear Business Unit. For 22 some reason, I don't know the reason whyk =

23 requested that.

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23 1 frame around it. What the time frame was, I didn't 2 know. I wasn't told that. I wasn't there at the 3 outset of this assignment, so I wasn't there as far 4 as what specific details were put around it.

5 For all I knew, it was going to end at 6 the end of that year, the end of the following year.

7 SR. SPECIAL AGENT TEATOR: You didn't 8 know?

9 1 didn't know.

10 SR. SPECIAL AGENT TEATOR: Okay, and no 11 one discussed that with you?

12 MNR 0 13 SR. SPECIAL AGENT TEATOR: All right.

14 When you came on -- I keep saying you came on. You 15 had been with the company, but when you came to your 16 - position in. were you. made aware that 17 there was a downsizing plan for down at the nuclear 18 site?

19 There were discussions --

20 there were always discussions about the possibility 21 of restructuring or downsizing.

22 SR. SPECIAL AGENT TEATOR: But this one 23 actually did happen. They had a downsizing in early 24 2003.

25 Were you -- which one were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 you referring to?

2 SR. SPECIAL AGENT TEATOR: You had the 3 Business Services people; some of them were let go.

4 You had some of the IT people.

~Yes.

5 6 SR. SPECIAL AGENT TEATOR: Towards the 7 end of that late winter, early spring, Kim Harvin 8 was let go.

9 ) Yes. Yes, I was aware of 10 the IT-Business Services downsizing.

11 SR. SPECIAL AGENT TEATOR: Okay. Why?

12 Why were they downsized? Do you know?

13 Part of the reason, I 14 believe, is that some of those services that were 15 provided, again, as embedded services within 16 Nuclear, were being transferred to the Services 17 Corporation, the Corporate IT Group.

18 When that has happened, not just in 19 Nuclear but elsewhere in the company, some of the 20 jobs that were embedded in the operating company 21 disappear, because they're already covered in the 22 corporate function up in Newark. So some of those 23 jobs would have gone away.

24 SR. SPECIAL AGENT TEATOR: Okay. Were

//

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1 downsizing in early '03?

2 Certainly on the periphery, 3 yes.

4 SR. SPECIAL AGENT TEATOR: Do you recall 5 Kim Harvin's name being mentioned at all as part of 6 that downsizing?

7 I couldn't honestly tell 8 you I remember her name specifically being 9 mentioned, but I'm not sure that it wouldn't have 10 been. Not specifically, no.

11 SR. SPECIAL AGENT TEATOR: Right.

12 . There was no specific 13 conversation about Kim Harvin being downsized at 14 that point in time, that I recall.

15 SR. SPECIAL AGENT TEATOR: All right.

16 Let's move on a little bit then, okay? At some point 17 were you made aware that a decision had been made to 18 eliminate her position down there at the site?

19 Ys 20 SR. SPECIAL AGENT TEATOR: How did you 21 become aware of that and when?

22 1., 1_. When. It probably was in 23 the early part of '03. I had known for a while that 24 was going to be retiring, and somewhere in C--

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26 1 I think it may have been 2 I'm not quite sure who may have -- it 3 may have been said that, you know, the OD 4 role doesn't really need to exist. It was really 5 created for purposes, I think, more of supporting 6 'in his capacity as and it was created as 7 a permanent job to support the business unit per se.

8 So we didn't create a job that was sort 9 of like a manager of HR, that supported the site, 10 that supported the business unit.

11 This is a job that was created, or a 12 role that was created, I think, more by - as 13 sort of an individual kind of one-off support 14 service to him, in the area of organization 15 development, that was deemed not to be needed, once 16 he left. Because it served his purposes. It didn't 17 necessarily serve a larger purpose.

18 SR. SPECIAL AGENT TEATOR: Do you know 19 whose decision it was to eliminate that position?

20 Probabl 21 SR. SPECIAL AGENT TEATOR: You're not 22 sure, though?

23 I'm not entirely sure, but 24 since it reported to it probably would have 25 beený' Uecision. That's how it would have NEAL R.GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 been conveyed to us.

2 SR. SPECIAL AGENT TEATOR: Do you 3 remember how it was conveyed to you? You mentioned 4

5 Well, probably eitherm 6 you know,

-- y have heard from"* because 7 my interaction with was minimal. We didn't 8 talk very much.. spoke sort of to me through 9

10 So he may have told '4 may have 11 told and either ay have told me first

-. 12 oril told me first. I couldn't recall exactly.

13 SR. SPECIAL AGENT TEATOR: Let me just 14 turn the tape off for a minute. It's 9:25.

15 (Off the record.)

16 ý,SR. SPECIAL AGENT TEATOR: It's about 17 9:37. We're back on the record. When you were made 18 aware, in early '03, that Kim Harvin's position had 19 been eliminated, what was your understanding of the 20 basis for why that occurred?

21 ) Well, it hadn't been 22 eliminated yet. There was talk about -- at some 23 point this probably would come to an end, so that 24 when left, there wouldn't be a need to carry 25 on something that I think, created for his NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

28 1 own particular purposes.

2 Again, to reiterate what I said, since 3 it was not a job, certainly one that I understood 4 would have existed there kind of on a regular, 5 permanent basis, because it didn't existed. That 6 wasn't sort of a structure in our organization.

7 But that seemed logical to me to have a 8 job that was created for an individual or by an 9 individual for what I would call special purpose, 10 whatever purpose that was going to be to serve, that 11 it would be logical to eliminate that job when the 12 individual left that role.

13 SR. SPECIAL AGENT TEATOR: Okay. So 14 when discussions are first occurring about the 15 potential to eliminate her position, your 16 understanding it is becaus it was a job, a 17 function for jspecifically for him. Because 18 he was leaving, that function would no longer be 19 necessary.

20 L Yes, exactly.

21 SR. SPECIAL AGENT TEATOR: All right, 22 okay. But at some point, the actual decision was 23 made, she's done. Her position is eliminated.

24 -'Yes. At some point, the 25 decision was made. The-job will be eliminated.

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1 We'll eliminate it and then we would pick a date.

2 SR. SPECIAL AGENT TEATOR: Okay. So 3 let's talk about the decision's been made to 4 eliminate the position, not discussion about it, all 5 right? So we're moving on a little bit.

• • ) Sure.

6 7 SR. SPECIAL AGENT TEATOR: Just a 8 little.

• Okay.

9 10 SR. SPECIAL AGENT TEATOR: But these 11 things are important. When that decision was made, 12 what was your understanding of the basis for that 13 final decision that hey, her position is going to be 14 eliminated? Ic-15 Pretty much the same thing.

16 When was going to leave PSEG, there wouldn't 17 have been a reason to have it. His successor, if he 18 felt that he needed a position like that, could have 19 created it, could have asked for the same thing.

20 But at that point in time, we didn't 21 need to have it, felt there was no need to carry it 22 over, especially since it was certainly my 23 understanding, I believe it was a lot of people's 24 understanding, that this was created, sort of again, 25 I'll use the term "special purpose, limited NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 duration, temporary assignment," whatever you want 2 to call it. To suggest that there was a time frame 3 around this thing. It wasn't something that could 4 have gone on in perpetuity.

5 SR. SPECIAL AGENT TEATOR: Okay.

6 0 ay.

7 SR. SPECIAL AGENT TEATOR: Who else had 8 that understanding? You said you and other people 9 were --

10 g Oh, I think Owl 11 12 SR. SPECIAL AGENT TEATOR: Okay. Do you 13 recall --

.14 (Within the HR community. I 15 mean, certainly everybody, I think, saw it that way.

16 SR. SPECIAL AGENT TEATOR: About the 17 nuclear business, you mean? Not*w

• but maybe -- C 18 I mean, would you interact with other senior level 19 people down there?

20 ( °)To a slightly greater 21 degree. My interaction with the rest of the nuclear 22 management team at that point in time was somewhat 23 minimal, because of the way the structure kind of 24 worked.

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31 1 Resources and I worked with the rest of the business 2 unit.

3 But I would have to speculate to say 4 that, you know, I knew for a fact that they knew 5 that this was a temporary assignment, because I'm 6 not sure --

7 SR. SPECIAL AGENT TEATOR: I'm not going 8 to ask you to speculate in that area. I'm going to 9 ask you a question.

10 During any discussions you would have 11 had with the senior managers down at the site, in 12 early '03, do you recall them discussing the fact 13 that Kim Harvin's position was going to be 14 eliminated?

15

• I don't recall having a 16 discussion with any of them about Kim Harvin.

17 SR. SPECIAL AGENT TEATOR: At all? My 18 question was specific as to a discussion they had, 19 if they had a discussion with you about her position 20 being eliminated?

21 No. I mean, I can't recall 22 a conversation where I would have had that 23 discussion anyway.

24 SR. SPECIAL AGENT TEATOR: Okay. After 25 the decision has been made to eliminate her  ;

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32 1 position, Kim gets a - meets with her 2 February 26, 2003, and gives her the 45-day letter, 3 and Kim signs the acknowledgment she got the letter, 4 and I guess the separation package.

5 Uh-huh.

6 SR. SPECIAL AGENT TEATOR: Okay. Now at 7 that point, from what I understand, and correct me 8 if I'm wrong, Kim Harvin's put in a pool where she's 9 eligible for other positions in the company; is that 10 correct?

11 Yes. That's what the 45-12 day letter says, yes.

13 SR. SPECIAL AGENT TEATOR: Okay. Now in 14 late February '03, did your responsibility change at 15 all, as far as your working with the people down at 16 the site?

17 No.

18 SR. SPECIAL AGENT TEATOR: Okay. A 19 change in --

20 ) In any way? No. I was 21 still responsible for Human Resources, they still 22 reported to me, and that was pretty much it.

23 SR. SPECIAL AGENT TEATOR: Okay. Now 24 did you -- from what I understand, there was a particular job of, offered to Kim Harvin, a client-..-"U 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 consultant. It was about an year job. I 2 can't remember the exact title. An HR client 3 consultant position?

4 That's the title of a job, 5 yes.

6 SR. SPECIAL AGENT TEATOR: Okay. Do you 7 remember such a position being offered to Kim after 8 she had been informed her position was going to be 9 eliminated?

10 .* ) No, it was not offered to 11 her within the Nuclear Business Unit.

12 SR. SPECIAL AGENT TEATOR: Okay. Why 13 not?

14 1 don't --

15 SR. SPECIAL AGENT TEATOR: My 16 understanding it was. There was a job offered to 17 her, and I thought it was down at the Nuclear 18 Business Unit?

19 Well, it was --

20 MR. KEENAN: Well, the question would 21 need foundation as to, having knowledge of 22 that.

23 SR. SPECIAL AGENT TEATOR: I thought I 24 asked a foundation question.

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J4 1 knowledge of that.

2 SR. SPECIAL AGENT TEATOR: Do you have 3 any knowledge of Kim being offered an HR client 4 position down in the Nuclear Business Unit, after 5 she had been informed her position was eliminated?

6 No 7 SR. SPECIAL AGENT TEATOR: Okay. Was 8 Kim considered, like everyone else who had been let 9 go during that time period, was she going to be 10 considered for all the jobs she was qualified for?

11 V-) Yes.

12 SR. SPECIAL AGENT TEATOR: Okay. Were 13 you part of any discussion where any open jobs would 14 not be made available to her for any particular 15 reason?

16 Only those for which she 17 wouldn't have been qualified, as would normally be 18 the case.

19 SR. SPECIAL AGENT TEATOR: Does any one 20 come to mind? Any particular job come to mind, 21 where she wasn't qualified for it? Or maybe she 22 expressed an interest in?

23 No. I don't recall her 24 expressing interest in a particular job that we then 25 had a discussion about her being qualified or not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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35 1 being qualified for.

2 SR. SPECIAL AGENT TEATOR: Okay, all 3 right. It's almost 9:45. We're going to take a 4 short break.

5 (Whereupon, a short recess was taken.)

6 SR. SPECIAL AGENT TEATOR: It's 7 approximately 9:53 in the morning, and I'm I

8 continuing the interview of .

9 I want to move on to discussing Kim Harvin's last 10 day at the site being moved up from April 16, 2003 11 until late March 2003, okay?

12 Okay.

13 SR. SPECIAL AGENT TEATOR: Were you part 14 of any discussions in March 2003 surrounding the 15 moving up of her last day on site?

16 _ BUVYs 17 SR. SPECIAL AGENT TEATOR: Can you tell 18 me when the first discussion occurred, and who was 19 present?

20  : I think the first 21 discussion occurred around the 1 8 th. { -

22 myself,we had an off-site meeting, an 23 HR off-site meeting.

24 SR. SPECIAL AGENT TEATOR: Now where was 25 that? /

/

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36 1 Hamilton Park, New Jersey.

2 A question was brought up, I think, if I recall 3 correctly, sort of in the context, at least in one 4 regard, something that Kim was supposed to be doing.

5 A project, an Inspection project of some sort, I 6 think.

7 She was going to go out and basically --

8 I'm not sure I know the exact nature of the task she 9 was going to preform, but the word "inspection" 10 sticks in my mind. She was going to represent PSEG.

11 Well shortly thereafter, she wouldn't have been a 12 PSEG employee.

13 So I think mw)and I and( had a 14 conversation around -- well that doesn't seem to be 15 a very appropriate thing to do, to represent to 16 someone outside of PSEG, with a person who is no 17 longer going to be here because her job was 18 eliminated, was going to do an inspection or 19 whatever the task was, representing herself as a 20 PSEG employee when she wasn't going to be a PSEG 21 employee.

22 In addition to that, I think one of us 23 probably asked the others, is there any reason why 24 we can't do what we sometimes and often do, which is 25 move up the date that someone leaves the property. -- /

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37 1 They don't -- they're not precluded from 2 the benefits and the entitlements that they have 3 during the 45-day period. It's just that they get 4 the date moved up because there's no need for that 5 person to be on site.

6 So if Kim was going to be continuing to 7 represent herself during the 45-day period as an 8 employee who someone, particularly outside, would 9 have perhaps understood or misunderstood to be 10 something that would have continued on, we didn't 11 want that to happen, because that would have -- we 12 didn't think that was appropriate.

13 SR. SPECIAL AGENT TEATOR: Okay.

14 4) So we just said "Is there a 15 need for Kim to be here? Is she working on anything 16 that is, you know, that has to be closed out?"

17 Usually it's something that either has to be closed 18 out; you're transitioning into something else, which 19 is why you're asked to stay.

20 Otherwise, quite often we'll just say 21 "Look. We'll provide you with all the support 22 services. Get on with your life, your job search 23 and whatever."

24 SR. SPECIAL AGENT TEATOR: Okay. Let's 25 break this down a little bit if we could.

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39 1 It would have gone beyond 2 the April 1 6 th date, andwe said "Well, that's sort 3 of highly inappropriate for her to be representing 4 herself, particularly to some outside person or 5 entity, as an employee of PSEG, when in fact she's 6 not."

7 SR. SPECIAL AGENT TEATOR: Okay. So 8 that's talking about after her last day?

9 That's talking about what 10 led to our discussion, in part, around why would we 11 say to Kim -- I mean, there's really no need for you 12 to be here, so that Kim wouldn't engage in projects 13 of that sort, where she'd represent herself either 14 internally or externally to somebody, as an employee 15 who's continuing on.

16 SR. SPECIAL AGENT TEATOR: Right. But 17 that's really not HR's decision. She's still 18 working for at that point. Were you 19 getting direction fro 'that "I don't need her 20 here any more? HR, do what you need to do?" Did 21 that direction come frord 22 No, not specific direction.

23 No, I wouldn't say specific direction.

24 SR. SPECIAL AGENT TEATOR: How about 25 non-specific?

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40

1. - Anything you got -- from 2 "yes. No. I mean we -- I didn't have a 3 direct conversation with him. We would have said if 4 you have a project that needs to be closed out, a 5 matter of transition from her to somebody else of 6 something that was being handled and it wasn't, HR 7 often makes the decision, or at least recommends to 8 management, why does the person stay on site, in the 9 location.

10 Because it's often detrimental to the 11 morale of the individual or it's embarrassing to the 12 individual, or somewhat detrimental, in our opinion, 13 to the morale of people around that individual, who 14 say "We know someone. They're leaving. It's hard 15 to come to work knowing the person you're sitting 16 next to or you're leaving," and we try to separate 17 those two things.

18 So it's in the normal course of making a 19 determination, as to whether or not somebody needs 20 to be there during the 45-day period. We look at 21 whether or not there's some critical work to be 22 concluded. There was none, as far as I was aware 23 of.

24 SR. SPECIAL AGENT TEATOR: And what you 25 just said, is that based just on this sidebar /4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

41 1 discussion you had on the 1 8 th of March?

2 I think the sidebar 3 discussion focused on that as one of the points.

4 I'm not quite sure exactly what the rest of the 5 conversation was all about. It was a relatively 6 brief conversation, as I recall. I mean, it didn't 7 go on for more than 10, 15 minutes.

8 SA We concluded that' ould go back, 9 talk to. about the conversation he should have 10 with Kim about leaving at the date that was chosen, 11 March 2 8 th. Is that the date?

12 SR. SPECIAL AGENT TEATOR: That's 13 actually her last day on site.

14 out leaving, you know, as 15 of March 2 8 th. i mean, not needing to be on site 16 beyond March 2 8 th.

17 SR. SPECIAL AGENT TEATOR: Do you recall 18 there being any discussion from m about Kim 19 Harvin moving into a new office over that previous 20 weekend? Do you recall that being brought up or 21 discussed at all?

22 Ww No, I don't.

23 SR. SPECIAL AGENT TEATOR: Okay. What 24 other reasons were or discussion occurred about 25 moving up her last day? Was there any other reasons NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 discussed for doing that, other than what you've 2 already said?

3 No, none that I recall.

4 SR. SPECIAL AGENT TEATOR: So the site 5 visits issue was one of them. Normal HR type of --

6 Nothing more to do. No 7 need to sit around. Those are the kinds of 8 conversations we would have around these kinds of 9 situations.

10 SR. SPECIAL AGENT TEATOR: Okay. Were 11 there any discussions about her temporary living 12 expense claims?

13 Yes.

14 SR. SPECIAL AGENT TEATOR: During that 15 meeting?

16 Oh, I couldn't recall if it 17 was during that meeting.

18 SR. SPECIAL AGENT TEATOR: During that 19 time period?

20 . Could have been, yes.

21 SR. SPECIAL AGENT TEATOR: Okay. Tell 22 me what you know of that --

23 1 know that aWNd 24 mentioned to me that she was, she had seen a couple 25 of expense reports that had some rather odd --

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43 1 that's my word -- sort of expense items, one of 2 which, as I recall, I think an airline ticket 3 expense that had no receipt, a fairly significant 4 expense.

5 I don't remember the exact dollar 6 amount, but it wasn't a small item obviously. It 7 was a -- she had attended some meetings, some 8 conference, put in her expense report, and said "no 9 receipt."

10 aid she was looking at a couple 11 of things like that, and I said "That's kind of odd.

12 I find it odd that someone would, you know, kind of 13 lose a receipt for an airline ticket."

14 That's not something you'd normally 15 misplace or not have available to you, and she said 16 there were a couple of other things like that, where 17 there were fairly significant expenses for which 18 there was a waiver required to get the expense 19 reimbursed.

20 SR. SPECIAL AGENT TEATOR: Was there --

21 do you recall there being any discussion from. )

22 to and/or you that -- I mean, was Kim looking 23 for another job, trying to hang on, or trying to 24 look more towards her future.

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44 1 at all? I mean, trying to hang on at the site, be 2 retained here? Do you recall that discussion 3 occurring during this March 18"' meeting?

4 I remember a discussion; 5 I'm not sure if it occurred at the March 18t 6 meeting. I mean, it was a discussion about Kim sort 7 of wanting to try to stay more where she was than 8 try to, you know, pursue her future outside.

9 General conversation.

10 SR. SPECIAL AGENT TEATOR: With who?

I mean, probably the same 12 group of people. Those are the kinds of 13 conversations we would have normally had about what 14 was going on.

15 SR. SPECIAL AGENT TEATOR: All right.

16 During this March 18 th discussion, was there 17 direction given to, specific direction given to, 18 to have Kim off-site, have her last day be 19 that Friday, March 2 1st? Do you recall that 20 direction being given?

21 I remember him being given 22 specific direction to have her leave earlier than 23 the April 1 6 th date. Whether it was the 21"* or the 24 28th, I don't recall.

25 But I know we did have a specific to do *i\

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45 1 for him, go talk to about having her leave 2 earlier rather than later.

3 SR. SPECIAL AGENT TEATOR: What was he 4 to talk to, about regarding that? Get 5 okay --

6 ThautlI as supposed to 7 have that conversation. Not us. It wasn't going to 8 come from us. It was supposed to come fromv 9 xyou need to talk to Kim about 10 the date to be moved up, because you're not- doing 11 anything with it. There's no reason to have her 12 remain on site, as there often isn't with people in 13 that situation. But you need to have the 14 conversation with her, as opposed to it coming from 15 us."

16 SR. SPECIAL AGENT TEATOR: From my 17 understanding, it did not occur like that. i 18 did not have that conversation with her, from what I 19 understand up to this point. Was that your 20 understanding?

21 No .) All I know is that she 22 was told. I'm not quite sure by whom or exactly 23 what point in time?

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46 1 that Kim needed to focus on getting a new job, 2 moving on with her future, but not getting a new job 3 in the Nuclear Business Unit?

4 There was certainly 5 conversation around Kim needs to move on with her 6 life and get a job.

7 I wasn't aware that there was any job, 8 specific job at the Nuclear Business Unit for which 9 she was qualified or for which she had applied.

10 But I don't remember 4 )saying there 11 is no job for her here regardless. I don't remember 12 that.

13 SR. SPECIAL AGENT TEATOR: "Here" being 14 where?

15 "Here" being NBU.

16 SR. SPECIAL AGENT TEATOR: Right. Do 17 you recall W saying during the March 1 8 th 18 meeting, or on another occasion, and you can tell me 19 when, that she wanted Kim Harvin relieved of all her 20 duties, so she could focus on her future?

21 i1 Again, could have been part 22 of the March 1 8 th discussion. If it wasn't, I 23 couldn't tell you when else that would have 24 occurred. But that sort of would have been part of 25 that same conversation around not really having A NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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47 1 duties; I mean, having to free her up from sitting 2 there doing, I'm not quite sure, anything.

3 You know, whatever project Kim decided 4 she was going to engage in, this outside project I 5 referred to, was what Kim was doing. We didn't 6 assign her to something. She wouldn't have been 7 assigned to something during the 45-day period, the 8 45-day period not being for that purpose.

9 The 45-day period being for things, 10 clearing up things that are outstanding from 11 previous responsibilities, and then using for 12 purposes of pursuing your next job.

13 Whether that job would have been 14 internal or external, you know, wouldn't have made a 15 difference to us. Pursue your next opportunity.

16 SR. SPECIAL AGENT TEATOR: What about if 17 she were given that assignment to go inspect another 18 plant, before she was told that her job was 19 eliminated? What would happen in that situation, 20 from an HR standpoint, from your standpoint?

21 This is with regard to any 22 kind of a situation like this? Is that why you're 23 asking the question?

24 SR. SPECIAL AGENT TEATOR: Well, let's 25 talk about Kim. From my understanding, she was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 given the approval byll to go on this site 2 visit, that I believe is what you were discussing 3 here. She was given the approval from to do 4 this.

5 1 mean we would have said 6 if a person is going to go beyond the date of their 7 employment, their legitimate employment, to be doing 8 something representing the company beyond that 9 point, would not have been appropriate.

10 We certainly would have strongly advised 11 the manager to kind of re-look at that and probably 12 pull back from it, to say you don't have somebody 13 out there representing, especially perhaps dealing 14 with an external entity or person, representing 15 themselves to be an employee of the company when 16 they're not an employee of the company.

17 SR. SPECIAL AGENT TEATOR: We're going 18 to turn over to Side B. It's almost 10:15.

19 (Tape change) 20 SR. SPECIAL AGENT TEATOR: Okay. It's 21 still almost 10:15. I've turned over to Side B.

22 Did you have such a discussion witl 23 about that very issue which you described?

24 (1,No, I don't recall having a 25 direct conversation with a.....--bja out this at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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49 1 all.

2 SR. SPECIAL AGENT TEATOR: Do you know 3 if'had such a conversation wit 4 ) I couldn't tell you if she 5 had a direct conversation with him.

6 SR. SPECIAL AGENT TEATOR: O0 7 Id He worked for you in your management chain.

8 Do you know if he had such a conversation wit l 9 surrounding that?

10 He may very well have.

11 SR. SPECIAL AGENT TEATOR: Do you recall 12 him sharing a conversation like that with you?

13 Again, it's hard to recall 14 exactly, sort of specifically the exact moment or 15 the exact event of having come by way of that 16 information, coming to know that that was something 17 that we were looking at.

18 Because obviously I knew that we were 19 looking at it, but exactly how it was conveyed to 20 me, communicated to me and by whom, and exactly 21 when, I couldn't recall that.

22 SR. SPECIAL AGENT TEATOR: Okay. Let's 23 talk about for a minute, if we could. Did 24 ad"ever make a statement to you, to the effect of 25 she was nudging"" to make a decision on whether NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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50 1 to keep Kim or not? Now we're back to the 2 discussion on eliminating her position, not 3 accelerating her out.

4 So we're back to the first part. Did 5

6 Why to nudg into making a decision o n 7 whether to keep Kim Harvin?

8 Yes. I mean, 4 had 9 said to me that a decision had to made about this 10 position, given the fact that it was a position tha t 11 wasn't permanent.

12 You would normally have asked that 13 question. Jrelationship with Was a 14 little bit more operational than mine was. She had 15 more of a direct working relationship. and I 16 didn't speak very much, but may have had that 17 conversation.

18 I came to know that -- I mean, we were 19 looking at having a decision made with regard to 20 Kim's position, because as I said before, it was 21 sort of what I called a special purpose position 22 that Jhad requested when was there.

23 C, When

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51 1 further need, and we don't have this position 2 anywhere else, then this is a position that should 3 go away. This is a function that should go away."

4 SR. SPECIAL AGENT TEATOR: Right. So 5 did tell you that she had those discussions 6 wit 7 ) Again, I can't recall a 8 specific conversation, but obviously I sort of came 9 to know that that was an issue that was being looked 10 at, the elimination of that role.

11 SR. SPECIAL AGENT TEATOR: All right.

12 Let's go back to the moving up of her date, okay?

13 The direction is given to (,to move up her 14 date from April 1 6 th, and you don't recall whether 15 you heard it being March 21't or March 28 th, right?

16 Right.

17 SR. SPECIAL AGENT TEATOR: What's your 18 next involvement, or knowledge of that occurring, 19 that plan moving forward, that work occurring to 20 make that happen?

21 . I probably called the 22 next week and said "You know, where does it stand?"

23 to make sure he carried through on the to-do.

24 SR. SPECIAL AGENT TEATOR: Do you have 25 any specific recollection of doing that, or what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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52 1* O told you it had been communicated to 2 Kim or it had not been communicated to Kim?

3 >1 specifically would recall 4 talking to ýabout, again, just the follow-up to 5 an item that had to be taken care of. I couldn't 6 tell you what day I may have called him.

7 And exactly what he said to me in that 8 conversation, I don't remember. But at some point, 9 I knew that there was a date picked. Whether that 10 was the 2 8 th or it was going to be the 21st, I don't 11 remember.

12 But there was -- yes, she was going to 13 be leaving, Towards the end of this month, this 14 month being March of '03, right?

15 SR. SPECIAL AGENT TEATOR: Yes, '03.

16 '03. That concluded the 17 matter as far as I was concerned. He did what he 18 was supposed to have done. As far as I was aware, 19 he spoke to was supposed to have 20 spoken to Kim.

21 A conversation took place with Kim. Kim 22 was aware of the fact that the date was March 2 8 th, 23 because there was no particular need for her to stay 24 on beyond that.

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53 1 right. At any point were you made aware -- you came 2 to your position in Power, PSEG Power, i 3 , right?

4 Uh-huh.

5 SR. SPECIAL AGENT TEATOR: At any point 6 after that, were you made aware that Kim Harvin had 7 brought concerns to senior management at the site, 8 regarding a perception that production is being 9 emphasized over safety, that the way the site was 10 being managed-was a nuclear safety concern, that 11 there were non-concern decisionmaking, decisions 12 being made in the operating of the units. Were you 13 ever made aware that she made those type of concerns 14 to senior Management?

15 The only and the first time 16 I knew that she had said anything was when I saw a 17 copy of the letter that she had written to.

18 '7(ph), and I forget the exact date of that.

19 But prior to that --

20 SR. SPECIAL AGENT TEATOR: That's March 21 -- I think it's March 2 6 th, actually. I think 22 that's the date in the letter. March 26, '03.

23 Right.

24 SR. SPECIAL AGENT TEATOR: When did you 25 see that letter? How long after -- because that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

54 1 the date of the letter t_._

2 Shortly after that, a month 3 after it. It probably wasn't shortly after that, 4 meaning, you know, a couple of days after that.

5 It somehow, a copy eventually found its 6 way to me, but I couldn't tell you whether it was a 7 month or six weeks or -- it certainly wasn't two or 8 three days, but within the next week.

9 SR. SPECIAL AGENT TEATOR: Okay. It's 10 your testimony --

11 And I don't remember it 12 being time-stamped, so I couldn't tell you exactly 13 what -- I just remember seeing a copy of the letter.

14 SR. SPECIAL AGENT TEATOR: So your 15 testimony is that's the first time you were made 16 aware that Kim had raised concerns down at the site?

17 Yes.

18 SR. SPECIAL AGENT TEATOR: By what was 19 written in the letter by her?

20 Yes.

21 SR. SPECIAL AGENT TEATOR: Okay, all 22 right. Let's go back to talking --

23 As I recall. I can't 24 recall another event that, prior to the letter, that 25 would have taken place, where I would have been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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• 55 1 apprised of or told about anything she raised in 2 that regard. That was sort of the first time I 3 think I had any knowledge that she had such a claim 4 against the company.

5 SR. SPECIAL AGENT TEATOR: Right.

6 Because of that claim, that's why we're here today.

7 R ght.

8 SR. SPECIAL AGENT TEATOR: Okay. The 9 decision, though, to accelerate her last day at the 10 site, move up her last day at the site, were you 11 part of that decisionmaking process, where' 12 ý_as told to make that happen?

13 Yes. I would say yes.

14 SR. SPECIAL AGENT TEATOR: Is there 15 anything you can offer, any type of documentation, 16 anything, that would show that that direction was 17 given ton March 18, 2003?.

18 Anything you could think of, a follow-up 19 e-mail to him; a note in your diary; something that 20 you would have done to show that that direction was 21 given to .)!*n March 1 8 th?

22 ,0 Not in any written form. I 23 mean --

24 SR. SPECIAL AGENT TEATOR: Any kind of 25 form. I'm looking for anything.

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56 1 *Just a phone conversation 2 that -- I mean, I know I had a conversation with 3 him. I don't know if I would have left him a 4 voicemail, or if I talked directly to him. I 5 couldn't recall that specifically.

6 But I know, you know, I would have 7 followed up the following week, to say "Where does 8 it stand? What's the status?"

9 SR. SPECIAL AGENT TEATOR: That's the 10 phone conversation which you just mentioned, would 11 have been the follow-up call?

12

-. *Yes. I think, but I 13 wouldn't have -- I don't remember writing something 14 down or making a note.

15 SR. SPECIAL AGENT TEATOR: How about an 16 e-mail, maybe to, to anyone, that's 17 going to show that that direction was given on the 18 18 19 I mean, none that I have found --

20 21 SR. SPECIAL AGENT TEATOR: The dates --

22 frankly, the date's very important. It is.

23 Right.

24 SR. SPECIAL AGENT TEATOR: Anything you 25 could think of?

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57 1 \No. I mean, I'd have to --

2 I've looked at my e-mails. I keep a lot of e-mail 3 correspondence in folders and --

4 SR. SPECIAL AGENT TEATOR: Yes, me too.

5 Nothing. Trash? Did you look in your trash? Not 6 your trash can, but your computer trash? I'm 7 picking your brain, frankly.

8 Noll- No. Yes. No, I didn't go 9 back to look through trash. Quite frankly, I'm not 10 sure I know how.

11 SR. SPECIAL AGENT TEATOR: You click on 12 your trash icon and get it.

13 ) I'm not technologically 14 astute. If it's not there, I have to ask my 15 secretary to find it.

16 SR. SPECIAL AGENT TEATOR: All right.

17 Might there be something that you gave to your 18 secretary to show that direction was given?

19 . Probably not. I wouldn't 20 necessarily have given her something. I may have --

21 if I had it -- if there was any form of 22 documentation, it may have been an e-mail because I 23 couldn't get him on the phone, but I don't recall 24 and I don't have a copy of an e-mail. -1

/ I 25 SR. SPECIAL AGENT TEATOR: And you've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

58 1 looked through your e-mails to --

2 ** Yes, I have.

3 SR. SPECIAL AGENT TEATOR: Okay.

4 .i But, you know, those -- I 5 mean, correspondence like that, it would have just 6 been a substitute for a phone call. I'm not sure I 7 would have kept it.

8 SR. SPECIAL AGENT TEATOR: Right, I 9 know. I'm asking, just to --

10 I'm not sure -- I can't 11 tell you I remember writing an e-mail.

12 SR. SPECIAL AGENT TEATOR: Okay, all 13 right. Well, if you could think of anything that 14 would show, other than your testimony. I have a 15 copy o0 schedule that shows there's a 16 meeting in, Hamilton Park Conference Center on March 17 1 8 th 18 1 have that too.

19 SR. SPECIAL AGENT TEATOR: Okay. You 20 - have that on your calendar?

21 Yes.

22 SR. SPECIAL AGENT TEATOR: Do I have 23 that, Jeff?

24 MR. KEENAN: I don't think we have that, 25 but we'd be glad to provide it.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

59 1 SR. SPECIAL AGENT TEATOR: I'd like to 2 get that. Yes, that's good.

3 MR. KEENAN: Sure.

4 SR. SPECIAL AGENT TEATOR: And, the 5

• calendar of March '03 shows "Hamilton Park 6 Conference Center, 9:00 to 1:00 p.m., arbitration 7 prep for *I" "Mj HR conference."- Then it 8 says "4:00-to 5:00 p.m., discussion of meeting on 3/20 with Does that --

10 We were going to meet 11 afterwards. I think we -- again, we had the 12 conversation sort of as a sidebar, as opposed to 13 waiting until the end of the day.

14 SR. SPECIAL AGENT TEATOR: Okay.

15 So the 4:00 to 5:00 -- I 16 think we both wrote down. I'm trying to recall what 17 I saw on my calendar. We may have both written down 18 4:00 to 5:00, because that was sort of the plan.

19 We got there, I mean, at a break,O 20 I got together, 1nd and you know, it took us 15 21 minutes or whatever. We had a conversation. So we 22 didn't need a formal meeting per se. So we didn't 23 do the 4:00 to 5:00.

24 That was just sort of the placeholder 25 that we had, you know, once we finish the meeting, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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60 1 let's address the issue. Time permitted otherwise.

2 SR. SPECIAL AGENT TEATOR: So then I 3 want to understand this fully. So going into that 4 day, there was already discussions surrounding have 5 to meet to discuss Kim Harvin?

6 There was obviously a -- I 7 don't know whether it was a question or an issue, 8 that said, you know, we need to make a decision on a 9 date, or something along those lines.

10 So we were all going to be in the same 11 place at the same time. It's easy to do this sort 12 of face-to-face, .then it is trying to get everybody 13 on the telephone. We'll all be at this meeting.

14 SR. SPECIAL AGENT TEATOR: Right.

15 L70-0--" So let's set aside some 16 time and talk about, you know, whether withe --

17 what we need to do withiW what we need to say 18 toQ was going to talk to about, you 19 know, having Kim leave sooner.

20 We don't need -- I mean, there's no 21 project. Again, I think it was partly prompted by 22 this, whatever this project was that she was going 23 to go off and do, and we said, "we" being probably 24 the three of us at least, you know, that's the sort 25 of thing we don't need someone doing.

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61 1 It doesn't work for the company. Any 2 reason why Kim ought to be here beyond then? Does 3 she need to stay here until April 16.h?

4 If she's -- you know, it's sort of 5 interesting. If she's going to sign up for things 6 she ought not to sign up for, because she's no 7 longer going to be an employee past April 1 6 th, 8 there's no need to have somebody on the property 9 doing that, representing PSEG, when they're not 10 going to be an employee past April 1 6 th 11 SR. SPECIAL AGENT TEATOR: Okay. So how 12 far in advance was this discussion on the 1 8 th 13 planned?

14 MWell, it could have been 15 the day before. I mean, I don't believe it was -- I 16 don't recall it being sort of weeks before that. It 17 was, you know, could have been a spur of the moment.

18 We're all going to be there. Why don't 19 we make sure we just get together? We'll all see 20 each other. Do it face-to-face, take care of it.

21 It will take us 15 minutes, as opposed to a day and 22 a half trying to round up everybody.

23 SR. SPECIAL AGENT TEATOR: "We all" 24 meaning you,

'lb 25 myself an .

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62 1 SR. SPECIAL AGENT TEATOR: All right.

2 Yes.

3 SR. SPECIAL AGENT TEATOR: And 4 calendar talks about a discussion of a meeting, of a 5 March 2 0 th meeting with Did you meet 6 with n the 2 0 th of March?

7 0.

8 SR. SPECIAL AGENT TEATOR: Do you know 9 if did?

10 I couldn't tell you. I 11 don't know.

12 SR. SPECIAL AGENT TEATOR: Okay. I'm 13 going to take a short break. It's almost 10:30.

14 (Off the record.)

15 SR. SPECIAL AGENT TEATOR: Okay, we're 16 back on. It's 10:30. Jeff, you were going to --

17 you offered off the record to try and find out who 18 set up this March 18th meeting, and something on 19 their calendar may show who did it and when it was 20 made?

21 MR. KEENAN: Yes. The company will be 22 glad to stipulate, to provide the information 23 relative to the origin of the March 1 8 th meeting, in 24 terms of who organized it, who created -- whatever 25 we have with respect to the computer records we'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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63 1 provide the NF*C.

2 SFL. SPECIAL AGENT TEATOR: Okay. )

3 from what I uniderstand, there was a meeting with 4 0 )n the 2 0 th of March, 2003, anl:

and *metw 5 Do you recall 6 you on Nthe result of that meeting?

- I'm sure he must have.

7 8 SR SPECIAL AGENT TEATOR: Do you have 9 any specific r ecollection of what he told you?

10 No. I mean, I couldn't 11 tell you sort of without speculating on exactly what 12 he would have said.

13 SR . SPECIAL AGENT TEATOR: I don't want 14 you to do that " When -- after Kim had been told her 15 position was e liminated on February 2 6 th, were there 16 any complaints or concerns brought to your attention 17 by your site HR people, regarding Kim's emotional 18 state down at the site, and how it was affecting 19 others?

20 ) I understood Kim to be 21 upset, but any:body who was told their job is 22 eliminated is upset.

23 SR SPECIAL AGENT TEATOR: Sure.

24 So I wouldn't have 25 necessarily co asidered it to be out of the ordinary.

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64 1 How it was affecting others is one of the reasons 2 why we ask people to leave sooner, rather than 3 later, because we feel it does affect other people 4 who, you know, have relationships with this 5 individual or feel badly for them.

6 It tends to get disheartening if not 7 disruptive, so we try to move the person along 8 obviously.

9 SR. SPECIAL AGENT TEATOR: Do you recall 10 there being any specific concerns brought to your 11 attention by your site HR people, regarding Kim's 12 emotional state and how it was affecting others at 13 the site?

14- I couldn't tell you a 15 particular, you know, reaction that someone had, or 16 a particular state of mind that she was in, no.

17' SR. SPECIAL AGENT TEATOR: So0ly or 18 dididn't share anything with you regarding how 19 Kim Harvin was affecting others at the site? And if 20 the answer is no, that's fine. I'm just asking you 21 if--

22 No.

23 SR. SPECIAL AGENT TEATOR: I'm just not 24 getting a clear answer. I don't think you're 25 evading me, but I don't -- 7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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65 1 No. I just remember sort 2 of that the normal kind of conversation is, you 3 know, she's upset. I can understand that. I can 4 appreciate being upset.

5 SR. SPECIAL AGENT TEATOR: Right, right.

6 But did either" or share with you that 7 "Hey, people at the site are telling us that the way 8 Kim's acting is, people are uncomfortable with it.

9 She's emotional. They don't know how to deal with 10 it or handle it." Did oraybring that to 11 your attention?

12 I They may have, but I can't 13 tell you, you know, specifically a conversation that 14 they had in any specifics, or reaction from either 15 her or from someone around her to me.

16 SR. SPECIAL AGENT TEATOR: Okay. After 17 Kim is -- her last day is March 2 8 th, okay? Do you 18 know who took over her work or continued her work 19 after she left the site?

20 NAs far as I am aware, there 21 was no specific continuation of her work. I can't 22 honestly tell you I knew exactly everything she was 23 doing, you know, what project or projects she may 24 have been working on.

25 So I don't know who would have taken it f NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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66 1 over. I don't believe there was anything that HR.

2 took over, of what she did. I'm not sure I knew 3 exactly what she did do. So I couldn't tell you who 4 may have taken something over.

5 SR. SPECIAL AGENT TEATOR: Do you know 6 if the site hired any consultants to fill her role 7 or function after she left, cultural change/OD-type 8 consultants? Do you know if that occurred after she 9 left?

10 I know we continued with 11 the Gallup people, but that had been there for a 12 while. She wasn't -- she didn't do the Gallup 13 survey per se.

14 SR. SPECIAL AGENT TEATOR: But Gallup 15 was there already? Was there somebody new brought 16 in to fill the role that she had while she was 17 employed there?

18 . No, not that I am aware of.

19 Consultants, no. Facilitator, you call it what you 20 want. But she had a couple -- from what I 21 understand, she had a couple of different hats down 22 there.

23 She did a lot of different things. No, 24 I don't remember any specific consultant or outside 25 person or company or anything else. 7,./

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67

1. Okay. I'd like to show you 2 a document and ask you about it. I'm going to let 3 you look at this off the record, but for the record, 4 it's a cover sheet of a fax, and the cover sheet is 5 "To 6 I guess that's you, , "from0 .

7 AIMI , dated April 14, '03 and it's regarding Kim 8 Harvin." I'm going to go off the record and you 9 could take a chance to review the cover sheet, and 10 there's a few pages attached to it, and you can 11 review those too if you want. But I'm going to ask 12 you mainly about the cover sheet. It's about 10:37.

13 (Off the record.)

14 SR. SPECIAL AGENT TEATOR: It's about 15 10:45. We're back on the record after a short 16 break. After reviewing this document,1U"a is 17 there something you want to add from your previous 18 testimony?

19.Yes. I just recalled 20 something that you asked me about, did we bring any 21 consultant or person in to do the work that Kim had 22 been doing.

23 There was no direct connection was far 24 as I am concerned, but there was a person, a 25 consultant by the name of *F-' jiwho. M NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

68 1 "WWWWWz*brought in to do some work with, I 2 believe, it was the Chemistry Group,*a'and 3 I'm not quite sure who the others were.

4 1. It was portrayed to me as a project that 5 would be undertaken to satisfy some IMPO (ph) 6 qualification requirement, and that this individual, 7 _.... .i.,,; was a consultant who had extensive 8 knowledge of the nuclear industry, and could help 9 them with this.

10 I know I had asked-1 I said 11 "Is there really an IMPO qualification issue, 12 because I don't want doing a project that has 13 no value to the company."

14 SR. SPECIAL AGENT TEATOR: Right.

15 lHe said "No, it has to do 16 with some IMPO qualification." At that point, I 17 wasn't really all that familiar with what IMPO 18 qualifications they were talking about. I took his 19 word for it.

20 So this fellow came in 21 and did what ultimately amounted to sort of culture 22 survey. The reason I know that is because he gave a 23 presentation to myself,Iand a fellow by name of 24 (ph), who is .. e.

25 ON.". I don't even know why ', N_ Mswas NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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69 1 invited to the presentation. Neither did he.

2 went through his --

3 this was a pieliminary sort of presentation or 4 readout of what he had found so far. About 45 5 minutes into that presentation, I said "Time out."

6 I said "What you're doing here is like -- it's a 7 culture survey; is that correct?" He said "Yes."

8 I said "What you've done is you've sort 9 of validated some of the things that we know about 10 the culture we have, which were general things like 11 -- we do a thing called Circumplex which kind of 12 looks at or defines culture in general, which is a 13 culture that is passive or active, general terms 14 like that.

15 I said "We do something in conjunction 16 with our leadership development program, which gives 17 as much sort of a picture of culture as we need. We 18 don't need to continue this sort of thing. It's a 19 waste of time, it's a waste of money. discontinue 20 what you're doing."

21 SR. SPECIAL AGENT TEATOR: So you had 22 the power and authority to shut that type of thing 23 down right then and there?

24 Because it came through 25 Human Resources. It turned out it was really a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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70 1 Human Resources project. It was a culture survey 2 project, and I told )to just cease and desist 3 because we had already done this.

4 SR. SPECIAL AGENT TEATOR: OKay. Why 5 was it portrayed -- if you know. Why was it 6 portrayed to you that this guy's work was needed 7 down there was part of an IMPO qualification?

8 ) I don't know specifically.

9 I think it had something to do with the IMPO -- I 10 guess they have specifications related to leadership 11 and management and supervisory skills.

12 That's what this sort of really related 13 to. There was something in an IMPO report, which I 14 had never seen, that they were talking about as the 15 basis for this.

16 It was presented to me, or at least my 17 understanding it was a technical requirement that 18 was being satisfied, when in fact it turned out to 19 be sort of a qualitative requirement.

20 But he was not brought in to do 21 something specifically, as far as I'm aware, that 22 Kim Harvin was doing per se.

23 SR. SPECIAL AGENT TEATOR: Okay, all 24 right.

I'.

25 But you asked that question NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

JPI,'I ) A-AA3rJQ 1A1ACWLhMt'Trnh1fnf% 1)nAn=3n A4 71 1 about consultants. He was a consultant.

2 SR. SPECIAL AGENT TEATOR: Any others?

3 Any other type of consultant work that was performed 4 after she left, that may -- that involved the same 5 type of work, culture-type work, survey-type work?

6 Only the work we do 7 throughout Power, for leadership development.

8 SR. SPECIAL AGENT TEATOR: Anything new, 9 I guess?

10 No, nothing new that I can 11 recall. This was the only other thing that sort of 12 happened, after her, after Kim left.

13 SR. SPECIAL AGENT TEATOR: Let's get 14 back to talking about this fax. Again, the fax is 15 dated April 14, 2003. It's To K from Ireads I wanted you 17 to have a copy of - (ph) memo of October. 31, 18 2001,1" 2001 is underlined.

19 "Please note that it was considered a 20 'rotational' assignment. There was no guarantee of 21 employment beyond 2002." Do you know why you 22 received this, the purpose of this, what caused this 23 to be sent?

24 !1111 We probably, "we" being 25 and I, probably askedý you know, we all../`

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72 1 sort of generally understand that this is a 2 temporary or rotational or limited duration. This 3 was a limited duration project.

4 Is there anything that shows us that? I 5 mean, "Do you recall something being said, something 6 written down?"

7 I think he produced this from his file, 8 and said 1, who had left Nuclear before I 9 got to Power, or right around the time I got to 10 Power, obviously had this -- this was in the file 11 from him, from t $I ) basically saying "This 12 is a rotational assignment," which validated our 13 position on it being temporary. Rotational 14 assignments are by definition temporary.

15 SR. SPECIAL AGENT TEATOR: So I guess my 16 question is, why would you need that validated?

17 Kim's already gone at that point. She's been gone 18 two plus weeks.

19 What caused this to be sent to you?

20 What brought it up? Why? I don't understand why.

21 She's already gone.

22 I don't recall exactly why.

23 SR. SPECIAL AGENT TEATOR: DidisU,/end 24 it up to you, based on a directive you gave him, 25 specific directive? //

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73 1 I may have asked him the 2 question, do you have any, you know, documentation 3 that shows that we are in fact and indeed correct 4 with regard to our having treated this as a 5 rotational or temporary assignment.

6 He discovered this, and that validated 7 the position we took and answered the question. Why 8 I would have asked the question --

9 SR. SPECIAL AGENT TEATOR: That's what I 10 want to get at. I don't understand why. I'd like 11 for someone to explain that.

12 I'm not sure I remember 13 exactly what was said or asked or going on.

14 SR. SPECIAL AGENT TEATOR: Other than 15 you or who might be able to speak 16 to why this was sent up to you and' )

17 ) I don't know. I mean, it's 18 just the three of us that I can speak, sort of speak 19 for. I can speak for myself.

20 SR. SPECIAL AGENT TEATOR: Speak for 21 myself. But if there's anybody else who you know 22 was involved in causing this having to be sent up, 23 or be reviewed or --

24 i No, I can't. I mean, just 25 among the three of us, the question would have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

1 . . -

74 1 arisen, and exactly what the basis for the question 2 was, I don't remember.

3 SR. SPECIAL AGENT TEATOR: Let's talk 4 about for a minute. Do you know who 5 .1141ýL2'is?

6 DO I know who 7 is? Yes.

8 SR. SPECIAL AGENT TEATOR: Okay. Were 9 you present for any discussions where he discussed 10 Kim Harvin's, the elimination of her position or her 11 last day being moved up from April 16th?

12 I don't remember him having 13 a conversation with me. I may have kept him posted 14 on the goings-on, as I would normally have done.

15 But conversations that he had, sort of directed to 16 me?

17 SR. SPECIAL AGENT TEATOR: Were you 18 present for, were you present for any such 19 conversations? So you recall being present for any 20 such conversations?

21 )No. But I would have kept 22 him informed of what happened in general.

23 SR. SPECIAL AGENT TEATOR: Okay. Do you 24 recall being present for any discussions whereI 25 would have commented on Kim Harvin's work NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

75 1 down at the site, or job performance down there, 2 whether she was any value at the site, anything 3 along those lines that you recall?

4 No, definitely not.

5 SR. SPECIAL AGENT TEATOR: Why do you 6 say "definitely not"?

7 Because I don't recall 8 14Maving a conversation like that at 9 all. He would have had conversations about people's 10 performance, particularly in -- you know, if it was 11 a critical role, or they were performing a critical 12 project, I would have had that conversation, 13 probably along those lines with him.

-14 But I never remember -- I don't remember

.15 having any conversation with about 16 Kim's performance, any project that she was working 17 on, or anything else of the like.

18 SR. SPECIAL AGENT TEATOR: Okay. Was 19 this ever brought to your attention, and the 20 question's going to be that Kim felt she may have 21 been blackballed from the Nuclear Business Unit or 22 PSEG? Did anyone ever tell you that Kim thought or 23 felt she had been blackballed?

24 No, no.

25 SR. SPECIAL AGENT TEATOR: At some point NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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76 1 you were made aware of *.th ,etter; is that )

2 correct?

4 SR. SPECIAL AGENT TEATOR: And what was 5 in the letter?

6 Ys 7 SR. SPECIAL AGENT TEATOR: And were you 8 tasked with reviewing or investigating any of the 9 concerns or issues raised in that letter?

10 I wasn't tasked with 11 anything of that nature.

12 SR. SPECIAL AGENT TEATOR: I think I'm 13 almost finished here. It's about five of 11:00.

14 I'm going to take a quick break and look over my 15 stuff. You guys do the same. If there's something 16 you want to add, please do so, and we'll come back 17 on in a few minutes.

18 (Whereupon, a short recess was taken.)

19 SR. SPECIAL AGENT TEATOR: Okay. It's 20 about two minutes before 11:00. I have a follow-up 21 question, and then Jeff, if you want to go over 22 something with your client, and I may ask some 23 questions after you finish with that.

24 But' did(I .ever say to you 25 that it was her objective to get Kim Harvin out of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

77 1 the organization? Did she ever make such a 2 statement to you or a statement to that effect?

3 Not that specific statement 4 like that that I recall, no.

5 SR. SPECIAL AGENT TEATOR: Anything 6 along lines? Do you recall her saying anything 7 along those lines to you?

8 No. Again, I mean, the

/

9 issue of we have a person who is in a temporary or 10 rotational assignment.

11 Do we need that person there, which to 12 me is a legitimate HR question? Do we need that 13 function being performed?

14 If not, let's make the right decision as 15 far as removing that positoin, that function, and 16 unfortunately that individual, any individual, from 17 the organization.

18 There's a lack of value or redundancy 19 or, you know, just an inefficiency that should be 20 corrected. That's part of what we do, I think.

21 SR. SPECIAL AGENT TEATOR: But to answer 22 my direct question?

23 No.

24 SR. SPECIAL AGENT TEATOR: Right. Jeff, 25 is there something you want to go over with your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

78 1 client, and if you do, please go ahead. I'm 2 finished with my questioning right now. But go 3 ahead.

4 MR. KEENAN: Yes. I'll just add for the 5 record, N we understand -- I understand that 6 you attended a meeting where Kim Harvin showed up in 7 the February '03 time period.

8 Can you share with us what occurred in 9 that meeting and your understanding of Kim's 10 presence at that meeting?

11 Sure. The meeting was 12 February of '02. It was what's called the Annual 13 Leadership Conference that- Ihas held 14 for the last couple of years, to which he invites 15 somewhere about 80 to 85 of the top managers of 16 Power.

17 MR. KEENAN: Is that February of '02 or 18 '03?

19 I February of '03, I'm sorry.

20 MR'. KEENAN: Go ahead.

21 The meeting was limited in 22 terms of its attendance, because we were having a 23 particular keynote speaker.

24 It happened to be (ph),

25 and it was not known to the general list of invitees NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

79 1 who was going to be there, because we wanted it to 2 be a surprise. It was a pretty important keynote 3 speaker for us.

4 So we only invited certain people. Kim 5 Harvin was not on the invitation list, as she didn't 6 hold a position of management authority, and wasn't 7 the level thatýý,)would have invited to this 8 particular meeting.

9 Kim showed up uninvited, and I thought 10 that was rather odd, and a number of people 11 commented, including .nd(MM "What is Kim 12 doing here?" I said "I have no idea what Kim is 13 doing here.

14 Someone must have invited her that 15 didn't have the authority to invite her, but it's 16 rather odd that somebody shows up a meeting like 17 this when they're not invited."

18 There was only a brief exchange between 19 her and I, not on that particular note, but I just 20 thought it was very strange that she would have 21 appeared some place where the president and COO of 22 Power invites people specifically, specifically did 23 not invite her, but she saw fit to show up 24 uninvited, and just sat there for the two days.

25 We did not take any action to remove her NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

80 1 from the meeting. I think that would have been 2 embarrassing and inappropriate. But she stayed in 3 the meeting for the full two days, day and a half, 4 as a completely uninvited guest.

5 So I could never figure out exactly what 6 her motivation was for doing that. Just sort of 7 point -- it pointed out to me that, I mean, here was 8 a person that did what she wanted to do, in ways 9 that were not necessarily sanctioned by the company, 10 because to show up at this kind of a meeting would 11 have taken a fair amount of nerve to do so.

12 MR. KEENAN: And you're sure she was 13 there, based on she also asked a question oflz 14 -Is that what you recall?

15 N Oh yes, she did ask a 16 question. There were relatively few people who did 17 ask him a question, because he didn't have very much 18 time for questions. But I think she was -- the 19 first, one of the first, if not the first person to 20 ask a question of him.

21 So she certainly did stand out in the 22 crowd, and brought even more attention to herself, 23 for having been there uninvited, by asking the 24 question of 25 MR. KEENAN: How do you know she wasn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

81 1 invited by, say, 2 **How do I know she wasn't 3 invited b:7 I don't know who invited her. I 4 can only assume that she was invited by someone like 5 )or showed up on her own, because I know that 6 she was not on the list. I helped prepare the list.

7 MR. KEENAN: Okay. All right.

8 SR. SPECIAL AGENT TEATOR: Let me -- and 9 don't take this the wrong way, but I watch you, and 10 sometimes when you say things about Kim, it seems 11 like you didn't like her.

12 That's my impression. If that's true, I 13 want to explore that a little bit, and if there is a 14 business/job performance reason for that, I'd like 15 to open that to.

16 I'd be happy to. Well 17 perhaps it 'would be useful to understand the 18 relationship between Kim and I, because it was very 19 limited.

20 The first time I met Kim was October of 21 '02, so shortly after I had joined Power. There was 22 a meeting that I had asked for, that I didn't 23 directly participate in for the whole day. It was 7

24 all the training people from both Power and Nuclear.

25 We were looking at two or our main NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

82 1 leadership development programs, the Supervisory 2 Academy and what we called Leadership in the 21"*

3 Century, which is a manager-director level program.

4 The purpose of that was to sort of help 5 me get my arms around what we did in the area of 6 leadership development. That was one of the 7 mandates I had from to do these 8 things on an across-the-board basis, so that Nuclear 9 wasn't doing its own thing and FASL (ph) wasn't 10 doing its own thing. But that we had Power, 11 integrated Power-level programs.

12 So I had brought people -- I had not met 13 any of these people from Nuclear at that point in 14 time. I had two people from Power. Their names 15 were and..

16 They worked on my -- worked 17 for me at that time. was from the 18 Services Corporation. She was in the Leadership 19 Development area.

20 The people from Nuclear were-0I 21 who was the then-head of; 22 were the two people who 23 worked for him in the Technical Training Group down 24 at Nuclear, and Kim Harvin.

• I I -

I-25 We sort of all introduced ourselves NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

83 1 around the table as we got started. My purpose in 2 being there was to kind of scope out sort of the 3 philosophy of Leadership Development that Power was 4 looking to put in place.

5 What my purpose was for getting 6 everybody together, what I wanted them to look at 7 with respect to this mandate I had from AIW, to 8 make sure we were looking at the right things, the 9 right types of things in these two programs.

10 I didn't know Kim to invite her or not 11 invite her. She came with the rest of the group.

12 It was obvious to me that she came not by 13 invitation.

14 SR. SPECIAL AGENT TEATOR: Why? Why was 15 that obvious to you?

16 . Because they didn't sort of 17 treat her like they treated the others. The 18 conversation around -- these three people from 19 within the Training Group itself. She was not in 20 the Training Group.

21 There would have been no reason why she 22 would have necessarily have been invited, because I 23 said specifically the training people who were 24 responsible for the Academy; she was not.

25 The training people who were responsible NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

84 1 for the Leadership Development activities up in 2 Newark, those were the people I want in the room.

3 I'd like to meet them all and kind of get this all 4 started.

5 In laying out sort of my philosophy and 6 purpose and everything, I mean she asked me a couple 7 of questions, and I don't remember the exact nature 8 of the questions. But they were, you know, we just 9 talked.

10 Some of what she was aiming to get at 11 was "Well, we in Nuclear are responsible for these 12 things. We in Nuclear have been responsible for 13 these things. In a sense, why are you taking this 14 responsibility?"

15 I reiterated that it was mandate 16 to me, who was the -- yas the head of Power, 17 and 0 s ultimately going to have.

18 responsibility for all of these business units under 19 the Power umbrella, and he already had mandated to 20 me in this, in the context of this organization 21 effectiveness project, to look at, as one of the 22 things, leadership development across all of Power.

23 It didn't -- it didn't appear to me that 24 that was something that she quite agreed with. The 25 meeting went on. They went back to their respective NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

85 1 jobs and, you know, and started to produce some 2 work.

3 She did not produce anything specific.

4 I did not ask her to produce anything specific. I 5 didn't know what her role was at that point in time.

6 It turned out that she had introduced herself as the 7 Manager of Cultural Transformation, which didn't 8 mean anything to me at that moment, but I realized 9 later on there's no such role here.

10 Subsequent to that, and I believe it was 11 December of '02, I was down at the Nuclear Training 12 Center to follow-up or close out that particular 13 session of the Supervisory Academy. There's what 14 they call a readout to the SLT, the Senior 15 Leadership Team.

16 While down there, Kim and I had a 17 conversation. Obviously the 'question of my 18 responsibility over these things was something that 19 bothered here.

20 There was another meeting. I don't 21 believe she was in the meeting, but it was among the 22 same people who had met in Newark back in October, 23 to talk about the same subject, what's our progress, 24 where are we at?

25 Afterwards, Kim came out of another NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON. r)C Pr,nnnfli.1n U.. .,

86 1 office and said to me "By the way, I spoke to 2 and he confirms that yes, in fact, you are 3 responsible for these programs. So, you know, 4 whatever help I can give you, I'd be happy to give 5 you.1" 6 This had sort of a continuing debate, in 7 a sense, between her and I. It was like "I'm just telling you what as told me is my 9 mandate as the and I

10. wasn't quite sure exactly why she was taking the 11 position she was taking, as a person in a role that 12 was somewhat temporary by definition, that was 13 organization development and had no responsibility 14 that I can determine, over the kinds of things that 15 *had hired me to do.

16 There was a bit of, sort of I'll call it 17 kind of irritation and tension between the two of 18 us, so much so that at this meeting I just described 19 a moment ago, where she showed up uninvited, the 20 only comment she made to me was "Well, I hope 21 there's nothing personal between you and I."

22 I said "Kim, there's never been anything 23 personal between you and I. It's all been business.

24 You know, you've chosen to see things the way you've 25 seen them, and I've chosen to see things the way NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

87 1 I've seen them. I can't help it that you didn't see 2 things the way I was told they should have been seen 3 by 4 That pretty much shaped our 5 relationship, and that was pretty much the basis her 6 and I had any sort of dialogue, throughout the 7 entire time that she worked for the company.

8 SR. SPECIAL AGENT TEATOR: Okay. Did 9 you have other interactions with her like that, from 10 that point forward?

1 There may have been a phone 12 call or two, but my conversations and interactions 13 with Kim were extremely limited.

14 There was nothing that she was doing 15 that sort of spilled over into what I did, 16 particularly after we got the issue of leadership 17 development and the responsibility for it cleared 18 up, which she reluctantly, clearly reluctantly 19 agreed was my responsibility. But that's kind of 20 shaped the relationship I had with her.

21 SR. SPECIAL AGENT TEATOR: Okay. Is 22 there anything more you want to add about your 23 relationship with her? I mean, I asked the 24 question, because I got a sense of something.

25  : No, it was -- just that we NEALR. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

88 1 didn't have a close relationship. We didn't speak 2 very much at all, certainly not frequently. I mean, 3 there was very few conversations. The couple of 4 conversations are really the ones I just relayed to 5 you.

6 I didn't really know what she did ever.

7 I couldn't quite sit here and articulate precisely 8 what she did down at Nuclear.

9 SR. SPECIAL AGENT TEATOR: Did you ever 10 ask *what she did?

11 explained somewhere 12 along the line I'm sure that she was in an OD, 13 organization development-type capacity, consultant 14 to him, you know, something that one creates out of 15 one's own need, and doesn't really have a particular 16 structure.

17 Rotational assignments oftentimes are 18 like that. You put a person to a task, for which 19 they may have a unique skill or you think they have 20 a unique skill. But it's not a defined kind of 21 role. You do things as you see fit.

22 SR. SPECIAL AGENT TEATOR: Right.

23 Anything more?

24 25 SR. SPECIAL AGENT TEATOR: Jeff?

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89 1 MR. KEENAN: Nothing further.

2 SR. SPECIAL AGENT TEATOR: I don't have 3 anything to add. I appreciate your time.

4 You're welcome.

5 SR. SPECIAL AGENT TEATOR: It's 11:10.

6 If you come up with something regarding the March 7 1 8 th, please share it with Jeff so that I get it.

8 We're off the record.

9 (Whereupon, at .11:10 a.m., the interview 10 was concluded.)

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