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Keebaugh v. Int'l Bus. Machines Corp.

IBM's CEO May Be Deposed After Other Executives Show She Has Non-Duplicative Information

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ORDER   On January 31, 2020, Defendant International Business Machines Corporation (“IBM” or “Defendant”) filed a letter motion objecting to Plaintiff Terry Keebaugh’s (“Plaintiff”) request to depose Defendant’s Chief Executive Officer (“CEO”) Ginni Rometty (“Rometty”) and Chief Human Resources Officer (“CHRO”) Diane Gherson (“Gherson”) prior to deposing other witnesses. (Docket No. 55). On February 5, 2020, Plaintiff filed a letter in response, arguing that Rometty and Gherson have relevant knowledge concerning the alleged “discriminatory plan that led to plaintiff’s firing,” and that Defendant did not offer any evidence rebutting this fact or that otherwise militates in favor of delaying their depositions. (Docket No. 56). I. BACKGROUND 1. Facts Plaintiff commenced employment with IBM in 1984 as a marketing representative, and eventually rose through the ranks to the position of Client Director. (Docket No. 1

13, 20). Despite strong work performance from 2007 until 2015, Plaintiff was terminated on November 30, 2016 at the age of 55. (Id.

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