Deposition Summary of Richard Perkins in Tiffany Lipkovich vs Wayne County et al.

This deposition summary is about Richard Perkins in the case of Tiffany Lipkovich vs Wayne County et al. Perkins was a corporal with the office of the Wayne County and had held that position since April 13th, 1992. He was involved with the workers union and was given the position of Chief Steward of Division One. Perkins had acquaintance with the plaintiff and was present during her interview with the internal affairs. Read on to learn more about Perkins' involvement in the case.

Summary Deposition
Tiffany Lipkovich vs Wayne County et al.
Deposition summary
Of
Richard Perkins
Taken on August 3, 2011
PAGE: LINE SUBJECT/EXHIBIT SUMMARY
Examination by Mr. Whitfield
4:4 20:25 Identification of the defendant The name of the defendant is
Richard Edward Perkins III
and has never been known by
any other name.
5:6 4:18 Employment Details The defendant was the
corporal with the office of the
Wayne County and had held
that position since April 13th
1992. The current
responsibilities of the
defendant included providing
security and supervising the
inmates within the jail. The
Defendant had worked
previously in various fast food
restaurants and warehouse. He
even provided his services to a
fax distribution and copier
company where he did
deliveries. Afterwards he was
working in the tech service
where he repaired copiers and
fax machines. After the
aforementioned jobs the
defendant moved to the
county. After coming to the

county the defendant worked
with a company called
Hovinga Business Systems
where she worked as a
technician. The defendant was
originally hired as an officer
and promoted to the position
of a corporal after fifteen
years of service.
6:13 19:25 Involvement with the workers
Union
The defendant worked as a
union representative. He was
given the position of Chief
Steward of Division One and
had worked in that position for
a couple of years. The
Defendant stated that she did
not consider her involvement
with the Union at the same
time of holding the position of
the corporal at the sheriff’s
office to be dual employment.
She further added that she
received payment for
providing his services at the
Sheriff’s office and also
received stipend for providing
his service to the Union. The
Defendant stated that she was
holding the position of
alternate Steward prior to
being promoted the position of
Chief Steward and had been
involved in the grievance
process for a period more than
three years. The Defendant
stated that she was thorough
with the grievance procedure
and had played the roles of
taking the complaints of the
members, conveying the same
to the management and
thereafter presenting the same
to the union. The Defendant
stated the role of the internal
affairs is to investigate
complaints as the same is a

part within the Sheriff’s
department. The defendant
stated that she had been
involved with the Internal
Affairs interview and handled
approximately forty
complaints.
14:16 25:9 Acquaintance of the
Defendant with Tiffany
Lipkovich
The Defendant stated he had
met the plaintiff at the
interview stage prior to the
Internal Affairs. The
defendant was notified that the
plaintiff was to be interviewed
by the internal affairs. It is to
be mentioned that the
defendant had no idea why he
had been called for the
interview. According to the
defendant the interview lasted
for half an hour. There was
another member present in the
interview room, Claire Carter.
It can be noted that prior to
interview of the plaintiff by
Clare Carter the defendant had
asked the plaintiff on the way
from Division one to internal
affairs whether the plaintiff
had any knowledge about
what the interview was about
and the plaintiff state no
PAGE:LINE EXHIBIT/SUBJECT SUMMARY
24:18-28: 20 Exhibit five Perkins posed question that he
did not have any knowledge
about the drugs which have
been allegedly provided to the
inmates and he also did not
have any gain from the
relationship with inmates. The
questions which Perkins asked
Tiffany with respect to the
interview were the questions

which Perkins wanted to put
on record. Perkins believed
that tiffany had no previous
disciplinary records. Perkins
said her that he does not have
the power to determine a 30
day chance agreement.
28:21-33:10 Statement made to Tiffany and
Carter
Perkins did not make
statement to her that she
would be provided with a less
severe punishment but Perkins
did talk to her. Perkins made a
statement about situation
where the employees had been
terminated for less significant
actions as well as those
situations where termination
did not take place for a serious
offence. Perkins has no record
or transcript of such interview
with her. Perkins was just
discussing things with carter.
Two stewards from the other
divisions were present in the
meeting. Perkins provided
them with the fact that the
decision cannot be taken until
proper discussion with the
management is done.
33:11-37:7 Hearing from management Perkins provided that he did
here back from the
management in relation to the
decision who was probably the
second vice president and who
also was in-charge of handling
the grievance dispute. This
person was identified as
Debbie Martin. Perkins
provided that Ms Martin is the
vice president of the
association. Perkins gas no
other discussion with Ms.
Martin in relation to the
Tiffany case and there was no
record found about that either
37:16-40:1 Discussion outside meeting Perkins has no discussion in

with Ms. Martin and grievance
procedure
relation to the tiffany case
with Ms Martine outside.
Perkins assumed that the
grievances would have to be
prepared. Perkins agrees that
the process is conducted by
the union on behalf of the
union member. Perkins
concedes that the process has
to be determined based on
what has occurred. Perkins did
not have the belief that it was
a tree step process until
referred to the collective
bargaining agreement. The
union has to submit the
grievances to the labor
relations. It was also conceded
by Perkins that it is up to the
union to decide which of the
cases are to be arbitrated.
Perkins was not privy to
information required to
prepare grievances for the
labor relations
40:10-47:2 Arbitration Perkins has the knowledge
that the arbitration conducted
in step five of the grievance
procedure. Perkins knows that
the process of arbitration is
not automatic. Perkins has
never handled any grievance
at the arbitration stage. The
grievance process is handled
by the bargaining agent after a
certain step. Perkins has no
knowledge that what happens
in a stage 4 step. Perkins
provides that stewards are not
a part of the process. Perkins
did not have knowledge about
the outcome of the interview
always. Perkins signed the
document which prevented the
arbitration.