In 2012, Celebrity Chef Paula Deen was sued by a former employee for sexual/racial harassment. For Deen, the deposition she filed in May, 2013, proved to be the worst mistake of her life.

Interrogated by Matthew C. Billips, the attorney for the plaintiff, Lisa Jackson, Deen responded as follows:

Q.  Are you aware of [your brother, Earl “Bubba” Hiers] admitting that he engaged in racially and sexually inappropriate behavior in the workplace?

A.  I guess. Q.  Okay.

A.  If I was sitting here I would have heard it.

Mistake #13:  She admits once again to having been apprised of her brother’s offensive behavior.

Earl “Bubba” Hiers

Q.  Okay.  Well, have you done anything about what you heard him admit to doing?

A.  My brother and I have had conversations.  My brother is not a bad person.  Do humans behave inappropriately?  At times, yes. 

I don’t know one person that has not.  My brother is a good man.  Have we told jokes?  Have we said things that we should not have said, that–yes, we all have.  We all have done that, every one of us.

Mistake #14:  She admitted to having talked with her brother about his offensive behavior–but she did not say she did anything to stop it or punish him for it.

Q.  You said you have had such conversations with [your brother]. When did you do so?

A.  When Karl told me he was stealing, I addressed that with Bubba.

Q.  And as a result of Mr. Hiers stealing, he received a pay increase and the money he had taken was recharacterized as wages, is that correct?

A.  I don’t know how it was settled.  I know that Karl was paying Lisa Jackson more than my brother was being paid, so if there was a salary increase, it would have been long overdue.

Mistake #15:  She admitted that even though she learned that one of her employees was stealing from her, she had nevertheless retained him. 

Speaking of her employee, Karl Schumacher, Deen said:

A.  Karl is the most judgmental person I know.  And out of every team member on our team, he is certainly the most prejudice.

Mistake #16:  She admitted that she had retained an employee who was openly prejudiced toward a wide range of people.

MackWorks, a business consulting firm, conducted an investigation of Uncle Bubba’s, which was owned by her brother, Earl “Bubba” Hiers. A

.  I didn’t read the report.

Q.  Okay.  And what, if any, investigation have you done to determine if it is your brother who is lying, as opposed to Miss Jackson and Mr. Schumacher and the people at MackWorks?

A.  I know my brother.  I know his character.  If I ask him something, he would not lie to me, nor would I to him.  There was nothing to investigate.

Mistake #18:  After an independent consulting firm gives her a scathing report about her brother’s restaurant, she didn’t read it.  

Mistake #19:  She admitted she didn’t read it.

Mistake #20:  She admitted she took no action to discover the truth for herself: “There was nothing to investigate.”

* * * * *

The media has focused its attention on Deen’s admission to having used the “N-word.”

  But clearly she was running a dysfunctional operation–replete with alcoholism, racial prejudice, sexual harassment and theft.

Much has been made of Deen’s serving as an ambassador of Southern culture and cooking.

But if only some of the accusations made against her hold up, she must also serve as an ambassador of a South decent Americans want to forget–and forever put behind them.

That was definitely an era when blacks knew their place–which was as slaves in the kitchens or fields of the Southern planter class who owned them.

According to Jackson, those are the days Deen would love to return to.

Deen has given lip service to knowing that the days of Southern racism are past.  But according to the complaint filed against her by her former employee, Lisa Jackson, that past remained very much alive:

• Requiring black employees to use separate bathrooms and entrances from whites.
• Holding black employees to “different, more stringent standards” than whites.
• Allowing her brother, Earl “Bubba” Hiers, to regularly made offensive racial remarks.
• Allowing Hiers to make inappropriate sexual comments.
• Allowing Hiers to force the plaintiff, Lisa Jackson, to look at pornography with him.
• Allowing Hiers to often violently shake employees.
• Allowing Hiersto come to work in “an almost constant state of intoxication.”
• Enabling Hiers’ behavior by ignoring Jackson’s efforts to discuss his behavior.
• Holding “racist views herself.”

Many of Deen’s supporters have claimed she is the victim of anti-Southern prejudice. But the truth appears that only in the South could she have run so gigantic and lucrative an empire for so long in such prejucial and dysfunctional fashion.

The wonder is not that the Food Network refused to renew her contract after June, 2013.  The wonder is that she has managed to stay in business this long.

There are many lessons to be learned from the deposition Paula Deen gave in May, 2012, during a lawsuit filed against her for sexual/racial harassment lawsuit.

Interrogated by Matthew C. Billips, the attorney for the plaintiff, Lisa Jackson, Deen responded as follows:

Q.  Now, does [your brother’s] sense of humor include telling jokes about matters of a sexual nature?

A.  We have all told off-colored jokes.

Q.  Okay.  Does his sense of humor include telling jokes of a racial nature?

A.  I’m sure those kind of jokes have been told.  Every man I’ve ever come in contact with has one.

Mistake #3:  Deen acknowledged that off-color jokes were told in her workplace, and that she was clearly aware of it.

Mistake #4:  Deen made light of the telling of jokes that the vast majority of employers would not tolerate in their workplaces.

Q. Okay.  Miss Deen, have you told racial jokes?

A.  No, not racial.

Q.  Okay, have you ever used the N-word yourself?

A.  Yes, of course.

Mistake #5:  She knew that the charge of racial discrimination stood at the very heart of the lawsuit facing her. 

Yet, when asked if she had ever used the “N-word,” she replied, “Yes, of course,” as if this were the most natural thing in the world.

Q.  Okay.  In what context?

A.  Well, it was probably when a black man burst into the bank that I was working at and put a gun to my head.

Q. Okay, and what did you say?

A.  Well, I don’t remember, but the gun was dancing all around my temple.  I didn’t…feel real favorable towards him.

Q.  Okay.  Well, did you use the N-word to him as he pointed a gun in your head at your face?

A.  Absolutely not.

Q.  Well, then, when did you use it?

A.  Probably in telling my husband.

Mistake #6:  What is discussed between husband and wife is protected legally as marital privilege.  Her attorney should have objected and told her not to answer the question. 

If she had not admitted to using it privately with her husband, she might not have been asked if she had used it since then.

Q, Okay.  Have you used it [the “N-word”] since then?

A.  I’m sure I have, but it’s been a very long time.

Mistake #7:  Having admitted she used it in the past, she compounds her mistake by admitting she had used it since. 

Mistake #8:   There is an entirely legal way to avoid incriminating oneself–and being prosecuted for perjury.  It’s contained in the words: “Not that I can recall.”

Q. Can you remember the context in which you have used the N-word?

A.  No.

Q.  Has it occurred with sufficient frequency that you cannot recall all of the various context in which you’ve used it?

A.  No.

Q.  Well, then tell me the other context in which you’ve used the N-word.

A.  I don’t know, maybe in repeating something that was said to me.

Q.  Like a joke?

A  No, probably a conversation between blacks.  I don’t–I don’t know.

Mistake #9:  The vast majority of restaurant kitchens are staffed by blacks or Hispanics, whose exchanges are often obscene and homophobic. 

If Deen had said she had quoted such a conversation between employees, she could have legitimately claimed she did so entirely for the sake of accuracy. 

She could have blamed them for using the N”-word,” and cast herself strictly in the role of reporter.

Q.  Okay.

A.  But that’s just not a word that we use as time has gone on.  Things have changed since the 60s in the South.  And my children and my brother object to that word being used in any cruel or mean behavior.

Q.  Okay.

A.  As well as I do.

Q.  Are you aware that your brother has admitted to using that word at work?

A.  I don’t know about that.

Mistake #10:  She had previously admitted to attending her brother’s deposition, where he admitted to, among other offenses, using the N-word in the workplace. 

So this is a direct contradiction of her earlier admission.

Q  Okay.  Now, if you had learned of Mr. Hiers engaging in racially or sexually inappropriate behavior in the workplace, what, if any, actions would you have taken?

A.  I certainly would have addressed it.

Mistake #11:  Previously she had been asked: “Did any of the things that your brother admitted to doing, including…using the N-word in the workplace, did any of that conduct cause you to have any concerns about him continuing to operate the business?” 

And she had replied: “No.”  So this amounts to yet another contradiction.

Q.  Have you ever addressed Mr. Hiers’ racially or sexually inappropriate conduct?

A. No.

Mistake #12:  She admitted to having learned about her brother’s use of the “N-word” in the workplace–and then admitted to having never addressed it.

Q.  And you are aware of his admitting to engaging in racially and sexually inappropriate  behavior in the workplace in his deposition in this case?

A.   No.

Mistake #12:  This directly contradicts her previous admission that she had learned of his engaging in such behavior during his deposition.

The purpose of this blog is to highlight the ways public and private bureaucracies actually operate–as opposed to how they usually want others to believe they operate.

Occasionally, a case comes along that is so filled with blatant violations of law and common sense that it offers a road map of what others should do to avoid similar disaster.

Such a case is that of celebrity chef Paula Deen.

On April 3, Uncle Bubba’s Seafood and Oyster House closed without warning.

The Savannah, Georgia, restaurant lay at the center of the infamous Paula Deen lawsuit.

And, in keeping with the mistreatment she had long tolerated against her employees, Deen closed Uncle Bubba’s without a trace of class.

Yes, Paula Deen thought so little of her employees that she didn’t even tell them beforehand.  She let them show up to work, only to find kitchen appliances being removed from the restaurant.

Employees collected their severance checks in the parking lot.

Insead, the restaurant posted the following announcement on its Facebook page:

“Since its opening in 2004, Uncle Bubba’s Oyster House has been a destination for residents and tourists in Savannah, offering the region’s freshest seafood and oysters.

“However, the restaurant’s owner and operator, Bubba Heirs, has made the decision to close the restaurant in order to explore development options for the waterfront property on which the restaurant is located.

“At this point, no specific plans have been announced and a range of uses are under consideration in order realize the highest and best use for the property.

“The closing is effective today, Thursday, April 3, 2014. Employees will be provided with severance based on position and tenure with the restaurant.

“All effort will be made to find employees comparable employment with other Savannah restaurant organizations.” 

In 2013, Deen became the subject of nationwide controversey when Lisa Jackson, a former employee of Uncle Bubba’s, filed a sexual/racial harassment lawsuit against her.

In a deposition, Deen was asked if she had used the word “nigger” and she replied: “Of course.”

Suddenly, she lost her cooking show on the Food Network.  Several of his business partners–including Sears, JC Penney and Kmart–also gave hr the heave-ho.

The lawsuit was eventually dismissed, but, by then, the damage was done.

Commentators focused obsessively on Deen’s admission that she used the word “nigger.”  Entirely ignored was the longtime mistreatment she had allowed to be dished out to her employees.

Paula Deen

Deen, her brother Earl “Bubba” Hiers, her company, and the corporations that operated a pair of restaurants she owns in Savannah, Georgia, were sued by former employee Lisa Jackson.

A complaint filed in the U.S. District Court for the Southern District of Georgia in November, 2012, claimed that Jackson was subjected to “violent, sexist, and racist behavior” during her five years’ employment by Deen.

It was for that reason that she left Uncle Bubba’s Oyster House, which was run by Hiers, in August, 2010.

Jackson’s complaint alleged that:

• Black employees were required to use separate bathrooms and entrances from whites.
• Black employees were held to “different, more stringent standards” than whites.
• Hiers regularly made offensive racial remarks.
• Hiers made inappropriate sexual comments.
• Hiers forced Jackson to look at pornography with him.
• Hiers often violently shook employees.
• Hiers came to work in “an almost constant state of intoxication.”
• Dean enabled Hiers’ behavior by ignoring Jackson’s efforts to discuss his behavior.
• Deen “holds racist views herself.”

The allegation that black employees were ordered to use separate bathrooms and entrances harkens back to the ugly days of the pre-civil rights South.

That was an era where most blacks knew their place–or were murdered by the Ku Klux Klan.

In May, 2013, Deen gave her own deposition in the case.

She denied many of the allegations against Hiers-–but ended up admitting that she was aware of his offensive behaviors:

Q.  Okay.  Are you aware–-you were here during your brother’s deposition, right?

A.  Yes.

Q.  So you are aware of the things that he’s admitted to?

A.  Absolutely.

Q.  Did any of the things that your brother admitted to doing, including reviewing–-reviewing pornography in the workplace, using the N-word in the workplace, did any of that conduct cause you to have any concerns about him continuing to operate the business?

A.  No.  My brother and I, 25 years ago…each started a business and we each had $200 to start that business. 

My brother built the most successful long-service business in Albany, Georgia, with his $200.  My brother is completely capable unless he’s being sabotaged.

Mistake #1:  Deen acknowledged that, if she hadn’t known about her brother’s behavior prior to his deposition, she was present during this and thus learned about it then.

Mistake #2:  Deen acknowledged that even after she officially became aware of his behavior, she did not feel there was any reason to sever him from the company.

Celebrity Chef Paula Deen, her brother Earl “Bubba” Hiers, her company, and the corporations that operate a pair of restaurants she owns in Savannah, Georgia., are being sued by former employee Lisa Jackson.

A complaint filed in the U.S. District Court for the Southern District of Georgia in November, 2012, claimed that she was subjected to “violent, sexist, and racist behavior” during her five years’ employment by Deen.

In the deposition she filed in May, 2013, she proved to be her own worst enemy.  Consider the following:

Speaking of her employee, Karl Schumacher, Deen said:

A.  Karl is the most judgmental person I know.  And out of every team member on our team, he is certainly the most prejudice.

Q.  Prejudice against who?

A.  You name it.

Q.  African-Americans?

A.  Gays, you name it. If you drink, you’re a bad person.  If you use four-letter words, you’re a bad person.  If you don’t think like he thinks, you’re a bad person.

Q.  Is he–?

A.  He is a one-man jury.

Stupid Mistake #16:  She admits that she had retained an employee who was openly prejudiced toward a wide range of people: “Gays, you name it.”

Q.  Is he prejudice against African-Americans?

A.  I–no, I don’t–no, I would say the answer to that one would be no.

Stupid Mistake #17:  Having already admitted the Schumacher was “a one-man jury” and “the most prejudice” of her employees, Deen suddenly claims he isn’t prejudiced against blacks. 

MackWorks, a business consulting firm, conducted an investigation of Uncle Bubba’s, which is owned by her brother, Earl “Bubba” Hiers.

Q.  Okay.  And in order to determine that it was the opinion of these high-priced consultants that Miss Jackson had been the victim of discrimination sufficient to give her cause to file an EEOC [U.S. Equal Employment Opportunity Commission] all you would have had to do was read that report, correct?

A.  I didn’t read the report.

Q.  Okay.  And what, if any, investigation have you done to determine if it is your brother who is lying, as opposed to Miss Jackson and Mr. Schumacher and the people at MackWorks?

A.  I know my brother.  I know his character.  If I ask him something, he would not lie to me, nor would I to him.  There was nothing to investigate.

Stupid Mistake #18:  After an independent consulting firm gives her a scathing report about her brother’s restaurant, she doesn’t read it. 

Stupid Mistake #19:  She admits she didn’t read it.

Stupid Mistake #20:  She admits she took no action to discover the truth for herself: “There was nothing to investigate.”

* * * * *

I have not searched through the entire deposition as given by Paula Deen.  But the portion I have reviewed convinces me this was a lawsuit–and a disaster–waiting to happen.

The media has focused its attention on Deen’s admission to having used the “N-word.”  But clearly she was running a dysfunctional operation–replete with alcoholism, racial prejudice, sexual harassment and theft.

Much has been made of Deen’s serving as an ambassador of Southern culture and cooking.  But if only some of the accusations made against her hold up, she must also serve as an ambassador of a South decent Americans want to forget–and forever put behind them.

That was definitely an era when blacks knew their place–which was as slaves in the kitchens or fields of the Southern planter class who owned them.

According to Jackson, those are the days Deen would love to return to.

As proof, she cited an exchange that occurred when she was appointed by Deen to handle the catering and staff for Bubba’s wedding in 2007.

When she asked Deen what the servers should wear, Deen allegedly replied:

“Well what I would really like is a bunch of little niggers to wear long-sleeve white shirts, black shorts and black bow ties, you know in the Shirley Temple days, they used to tap dance around.

“Now, that would be a true Southern wedding wouldn’t it? But we can’t do that because the media would be on me about that.”

Deen has given lip service to knowing that the days of Southern racism are past.  But according to the complaint filed against her by her former employee, Lisa Jackson, that past remains very much alive:

• Requiring black employees to use separate bathrooms and entrances from whites.
• Holding black employees to “different, more stringent standards” than whites.
• Allowing her brother, Earl “Bubba” Hiers, to regularly made offensive racial remarks.
• Allowing Hiers to make inappropriate sexual comments.
• Allowing Hiers to force the plaintiff, Lisa Jackson, to look at pornography with him.
• Allowing Hiers to often violently shake employees.
• Allowing Hiersto come to work in “an almost constant state of intoxication.”
• Enabling Hiers’ behavior by ignoring Jackson’s efforts to discuss his behavior.
• Holding “racist views herself.”

Many of Deen’s supporters have claimed she is the victim of anti-Southern prejudice.

But the truth appears that only in the South could she have run so gigantic and lucrative an empire for so long in such prejucial and dysfunctional fashion.

The wonder is not that the Food Network refused to renew her contract after June, 2013.  The wonder is that she has managed to stay in business this long.

Celebrity Chef Paula Deen, her brother Earl “Bubba” Hiers, her company, and the corporations that operate a pair of restaurants she owns in Savannah, Georgia, are being sued by her former employee Lisa Jackson.

A complaint filed in the U.S. District Court for the Southern District of Georgia in November, 2012, claimed that she was subjected to “violent, sexist, and racist behavior” during her five years’ employment by Deen.

There are many lessons to be learned from the deposition Deen gave in the case in May.  Such as:

Q, Okay.  Have you used it [the “N-word”] since then?

A.  I’m sure I have, but it’s been a very long time.

Stupid Mistake #7:  Having admitted she used it in the past, she compounds her mistake by admitting she had used it since. 

Stupid Mistake #8:   There is an entirely legal way to avoid incriminating oneself–and being prosecuted for perjury.  It’s contained in the words: “Not that I can recall.”

Q. Can you remember the context in which you have used the N word?

A.  No.

Q.  Has it occurred with sufficient frequency that you cannot recall all of the various context in which you’ve used it?

A.  No.

Q.  Well, then tell me the other context in which you’ve used the N word.

A.  I don’t know, maybe in repeating something that was said to me.

Q.  Like a joke?

A  No, probably a conversation between blacks.  I don’t–I don’t know.

Stupid Mistake #9:  The vast majority of restaurant kitchens are staffed by blacks or Hispanics, whose exchanges are often obscene and homophobic.  If Deen had said she had quoted such a conversation between employees, she could have legitimately claimed she did so entirely for the sake of accuracy.  She could have blamed them for using the  N-word, and cast herself strictly in the role of reporter.

Back to the deposition:

Q.  Okay.

A.  But that’s just not a word that we use as time has gone on.  Things have changed since the 60s in the South.  And my children and my brother object to that word being used in any cruel or mean behavior.

Q.  Okay.

A.  As well as I do.

Q.  Are you aware that your brother has admitted to using that word at work?

A.  I don’t know about that.

Stupid Mistake #10:  She had previously admitted to attending her brother’s deposition, where he admitted to, among other offenses, using the N-word in the workplace.  So this is a direct contradiction of her earlier admission.

Q  Okay.  Now, if you had learned of Mr. Hiers engaging in racially or sexually inappropriate behavior in the workplace, what, if any, actions would you have taken?

A.  I certainly would have addressed it.

Stupid Mistake #11:  Previously she had been asked: “Did any of the things that your brother admitted to doing, including…using the N word in the workplace, did any of that conduct cause you to have any concerns about him continuing to operate the business?”  And she had replied: “No.”  So this amounts to yet another contradiction.

Q.  Have you ever addressed Mr. Hiers’ racially or sexually inappropriate conduct?

A. No.

Stupid Mistake #12:  She admitted to having learned about her brother’s use of the N-word in the workplace–and then admitted to having never addressed it.

Q.  And you are aware of his admitting to engaging in racially and sexually inappropriate  behavior in the workplace in his deposition in this case?

A.   No.

Stupid Mistake #12:  This directly contradicts her previous admission that she had learned of his engaging in such behavior during his deposition.

Q.  Are you aware of Mr. Hiers admitting that he engaged in racially and sexually inappropriate behavior in the workplace?

A.  I guess.

Q.  Okay.

A.  If I was sitting here I would have heard it.

Stupid Mistake #13:  She admits once again to having been apprised of her brother’s offensive behavior.

Q.  Okay.  Well, have you done anything about what you heard him admit to doing?

A.  My brother and I have had conversations.  My brother is not a bad person.  Do humans behave inappropriately?  At times, yes.  I don’t know one person that has not.  My brother is a good man.  Have we told jokes?  have we said things that we should not have said, that–yes, we all have.  We all have done that, every one of us.

Stupid Mistake #14:  She admits to having talked with her brother about his offensive behavior–but she did not say she did anything to stop it or punish him for it.

Q.  You said you have had such conversations with [your brother]. When did you do so?

A.  When Karl told me he was stealing, I addressed that with Bubba.

Q.  And as a result of Mr. Hiers stealing, he received a pay increase and the money he had taken was recharacterized as wages, is that correct?

A.  I don’t know how it was settled.  I know that Karl was paying Lisa Jackson more than my brother was being paid, so if there was a salary increase, it would have been long overdue.

Stupid Mistake #15:  She admits that even though she learned that one of her employees was stealing from her, she had nevertheless retained him.

The purpose of this website is to highlight the ways public and private bureaucracies actually operate–as opposed to how they usually want others to believe they operate.

Occasionally, a case comes along that is so filled with blatant violations of law and common sense that it offers a road map of what others should do to avoid similar disaster.

Such a case is that of celebrity chef Paula Deen.

Paula Deen

Let’s start at the beginning.

Deen, her brother Earl “Bubba” Hiers, her company, and the corporations that operate a pair of restaurants she owns in Savannah, Georgia, are being sued by former employee Lisa Jackson.

A complaint filed in the U.S. District Court for the Southern District of Georgia in November, 2012, claimed that she was subjected to “violent, sexist, and racist behavior” during her five years’ employment by Deen.

Jackson’s complaint describes her as a “white female” who has biracial nieces.

It was for that reason that she left Uncle Bubba’s Oyster House, which was run by Hiers, in August, 2010.

Jackson’s complaint alleges the following:

• Black employees were required to use separate bathrooms and entrances from whites.
• Black employees were held to “different, more stringent standards” than whites.
• Hiers regularly made offensive racial remarks.
• Hiers made inappropriate sexual comments.
• Hiers forced Jackson to look at pornography with him.
• Hiers often violently shook employees.
• Hiers came to work in “an almost constant state of intoxication.”
• Dean enabled Hiers’ behavior by ignoring Jackson’s efforts to discuss his behavior.
• Deen “holds racist views herself.”

The allegation that black employees were ordered to use separate bathrooms and entrances harkens back to the ugly days of the pre-civil rights South.  That was an era where most blacks knew their place–or were murdered by the Ku Klux Klan.

In May, 2013, Deen gave her own deposition in the case.  She denied many of the allegations against Hiers-–but ended up admitting that she was aware of his offensive behaviors:

Q.  Okay.  Are you aware–-you were here during your brother’s deposition, right?

A.  Yes.

Q.  So you are aware of the things that he’s admitted to?

A.  Absolutely.

Q.  Did any of the things that your brother admitted to doing, including reviewing–-reviewing pornography in the workplace, using the N word in the workplace, did any of that conduct cause you to have any concerns about him continuing to operate the business?

A.  No.  My brother and I, 25 years ago…each started a business and we each had $200 to start that business.  My brother built the most successful long-service business in Albany, Georgia, with his $200.  My brother is completely capable unless he’s being sabotaged.

Stupid Mistake #1:  Deen acknowledged that, if she hadn’t known about her brother’s behavior prior to his deposition, she was present during this and thus learned about it then.

Stupid Mistake #2:  Deen acknowledged that even after she officially became aware of his behavior, she did not feel there was any reason to sever him from the company.

Getting back to Deen’s deposition:

Q.  Now, does his sense of humor include telling jokes about matters of a sexual nature?

A.  We have all told off-colored jokes.

Q.  Okay.  Does his sense of humor include telling jokes of a racial nature?

A.  I’m sure those kind of jokes have been told.  Every man I’ve ever come in contact with has one.

Stupid Mistake #3:  Deen acknowledged that off-color jokes were told in her workplace, and that she was clearly aware of it.

Stupid Mistake #4:  Deen made light of the telling of jokes that the vast majority of employers would not tolerate in their workplaces.

Then came–for Deen–the most deadly part of the deposition:

Q.  Okay.  Miss Deen, have you told racial jokes?

A.  No, not racial.

Q.  Okay, have you ever used the N word yourself?

A.  Yes, of course.

Stupid Mistake #5:  She knew that the charge of racial discrimination stood at the very heart of the lawsuit facing her.  Yet, when asked if she had ever used the N-word, she replied, “Yes, of course,” as if this were the most natural thing in the world.

Q.  Okay.  In what context?

A.  Well, it was probably when a black man burst into the bank that I was working at and put a gun to my head.

Q. Okay, and what did you say?

A.  Well, I don’t remember, but the gun was dancing all around my temple.  I didn’t…feel real favorable towards him.

Q.  Okay.  Well, did you use the N word to him as he pointed a gun in your head at your face?

A.  Absolutely not.

Q.  Well, then, when did you use it?

A.  Probably in telling my husband.

Stupid Mistake #6:  What is discussed between husband and wife is protected legally as marital privilege.  Her attorney should have objected and told her not to answer the question.  If she had not admitted to using it privately with her husband, she might not have been asked if she had used it since then.