EXHIBIT IV

Good Cause Summary below was submitted by E. Denise Caldon in Fourth Motion

in Fulton County Superior Court and includes Excerpts and full Deposition of
Regent Doreen Stiles Poitevint, former Vice Chair of the BOR Committee on
Organization and Law, resulting in Deposition becoming Open Record.
Four Responses in Opposition - authorized by Attorney General Sam Olens resulted in four Denials by Judge Doris L. Downs, Fulton County Superior Court, to
Motions filed by E. Denise Caldon requesting the lifting of the Protective Order (s) to
which she never consented contrary to repeated false statements by The Attorney
Generals Office.
The Deposition of Regent Poitevint confirms repeatedly the misrepresentation of fact,
RICO (racketeering) practices and breach of legal due process to USG faculty, staff
and students in over thirty public higher education institutions by the Board of Regents
of the University System of Georgia and not addressed by Attorney General Sam
Olens.
Regent Doreen Stiles Poitevint states in her Deposition that she did not even know
she was the Vice Chair of the BOR Organization and Law Committee in November
2008 two years earlier than her Deposition on 8 February 2010.
EXCERPTS:
Q: So do you have knowledge of why Ms. Caldon departed employment from Macon
State College?
A: Only after our committee meeting because I dont remember hearing the case
discussed.
Q: And specifically, are you referring to the meeting when Ms. Caldons application
for a review was to come up and be heard or addressed?
A: Yes.
Pgs. 14-17

Q: But you dont recall that Ms.the matter of Ms. Caldons appeal came up at that
meeting?
A: No.
Q: Is that correct?
A: Its correctA phone call was made to me by Ms. Caldon.she said, .do
you remember the case that came up in the Organization and Law meeting or
something. And I said, No, I dont..
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Q: I understood you to say that the knowledge you have about Ms. Caldons
employment situation and her appeal from the termination was gained by you after the
committee meeting was closed on or about November the 10th of 2008?
A: Well, to tell you the truth, Im not sure about where the information came from.
Q: But youre not sure how you know what you know?
A: No, and I feel sure it was through updates on the case.

Pgs. 18-21

Q: Do you have any knowledge, Ms. Poitevint, of the allegations in our lawsuit, in this
lawsuit that Ms. Caldon brought?
A: No, I really dont.

Q: You dont know why she is challenging her termination in court?

A: No really.
Q: Are you familiar with the Georgia Whistleblower Act at all?
A: I have heard of it. So far as specifics, no.
Q: Okay. Have you ever been involved in a Board of Regents matter or meeting where
the topic of the Georgia Whistle Blower Act came up in connection with an employee
termination, or maybe there was perhaps a concern whether an employee who was
being terminated was being fired in violation of the Act?
A: Its very hard for me to because I am familiar with the term, as to whether
something like that had come up with had come up that I was involved with the
Board. Im sorry.
Q: Im just wondering, as you sit here today, are you able to recall ever having a
discussion about the Georgia Whistle Blower Act.
A: No specific discussion whatsoever.

Pgs. 18-21

Q: And some of these questions, I know, may sound silly, but what is the role of the
Board of Regents in reviewing applications for review by university system employees
who have appealed their terminations?
A: We are not where those go in the very beginning. Our legal department will look
over those.
Q: Okay. When you say were not involved in the very beginning, our legal department
looks over those, Im not sure I know what you mean.
A: Burns Newsome and Kimberly Ballard-Washington look over documents, look
over the cases.

Q: Okay. As you understand it, the purpose of Mr. Newsomes review is to determine
whether there is any validity to the appeal?
Ms. Hyman: I object.
Q: Is there any preliminary opinion or conclusion or assessment that the Legal Affairs
Office provides before the matter is formerly heard by the Board of Regents?
A: I would think so.
Q: So is it fair to say then that most of the time the Board of Regents is going to be
interested in ascertaining why a particular employee who is appealing a termination
was terminated?
A: Possibly.
Pgs. 23-29
Q: And are there any printed guidelines or rules regarding how reviews of employment
terminations are to be conducted?
A: Not that Ive ever seen.

Page 33

Pgs. 35-37

Page 39

Q: And are these meetings these applications for review and employment appeals,
are they brought up and handled at a at one of these eight meetings or so?
A: For all the Regents to participate in? No.
Q: Is there an agenda thats usually followed for these meetings?
A: We have a sheet that will be handed out to us that will have the cases
down. But nothing about the case will be brought up until the person
whos handling that case will visit with people about that.

Q: And then is there a review of any documents or evidence by the Board of

Regents?
A: Do you mean physical documents?
Q: Yes, maam.
A: No.
Q: Why not?
A: Well, I think that time restraints is one of the main problems right
there.
Q: Do the Regents review the applications for review that are submitted by
the employees?
A: No.
Q: Why not?
A: I think just like I said time restraints.

Q: So then it usually is the case or frequently is the case then that no physical
documents are reviewed by the Board of Regents in connection with employee
applications for review?
A: I cant think of a single incident where that is the case on anything that I have
been involved with. I cant answer for any prior time to that.
Page 41
Q: Okay. Usually documents themselves are not reviewed when the matter comes up?
A: No physical documents.
Q: Okay. So its just discussion?
A: Discussion
Q: So no evidence is reviewed?
A: Evidence meaning?
Page 42
Q: Statements, documents, files
A: No, but I think if
Q: --- letters, emails.
A: No, .

Page 42

Q: I asked this before, and I just want to make sure I understand. So you, in typical
review matter, you will not have been provided with the employees application for
review itself and whatever attachment the employee has put together; is that correct?
A: No. No. And I guess if I would feel nothing is being withheld from me.
Q: It sounds like the answers not much other than what the lawyer can tell you; is
that correct?
A: Right. A review of the information is given to us.
Q: Is there a record of the vote about how to handle a particular appeal?
A: ..Can I tell you whether that is regarded (recorded?) in stone, no, I cant.

Pgs. 44-45
Q: Okay. And so you dont know whether there is any to the extent there are

votes, and it sounds like there are, are the votes recorded anywhere?
A: I cant answer that.
Page 51

Page 52

Q: Is there any kind of standard that the Board of Regents employs in its review of
employee termination decisions?
A: Im so sorry to be taking so long with this, but, no, there is no written anything.
Q: But what Im wanting to know, is there any document that is generated that
contains the Boards decision with respect to a particular appeal and perhaps the
reason for its decision?
A: Not that I am aware of, but I feel sure that theres some notation somewhere, but
not any that Im aware of.
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Pgs. 56-57

Q: But as we sit here today, you dont and I think the meeting minutes reflect your
presence at that meeting on that date, but your testimony is you dont recall ever sitting
in a Board of Regents meeting and hearing any appeal of Ms. Caldons matter?
A: No, I dont.
Q: And you dont know whether the matter was heard or not. Youre not in a position
to know that?
A: No, I dont.

Page 63

Pg. 69

Pg. 69

Q: Does this look, though, like a form you are familiar with that would layout an
agenda for items to be reviewed by your committee?
A: The document that I get is a sheet that will have the case number and the
individuals or individual involved, and that will be it.
Q: So the official meeting minutes, Ms. Poitevint, reflect your presence, input and
voting with respect to matters A through H on this form, correct?
A: Correct.
Q: Okay. One of which was the matter of Ms. Denise E. Caldons application for
review concerning her termination?
A: Correct.
Q: Okay. But your testimony is you dont recall her matter coming up at all in the
November 10, 2008 meeting?
A: No, I dont. .
Q: Have you ever spoken to any other Regent who can attest that Ms.
Caldons matter was heard and was properly handled through the proper
Board of Regents policies and procedures on November 10th?
A: No. Im sorry. I havent.

Pg, 79
Q: Okay. Do you know what to the extent that Ms. Caldons matter did come up and
was duly handled by the Board of Regents, do you know what documents, materials
and information were reviewed by the Board?
A: No, I dont.

Pgs. 82-83

Q: Youre not aware of any investigation or assessment into whether or not into
Mr. Bells conduct or misconduct or anything like that?
A: No.

Q: And are you sure -- werent you the chair of that committee back in November
2008?
A: I thought I just became the vice chair ---

Pgs. 82-83

Q: Could you have been the vice chair back in November of 08?
A: (Witness shaking head negatively.)
Q: Tell me again when you began being the chair.
A: Well, I looked down at this. I thought I just became the vice chair
Q: Could you have been the vice chair back in November of 08?
A: Thats what it says on this, but I dont think so.
Q: Thats why I was asking.
A: I dont think so.

Pgs. 82-83

Q: Okay. So youre not in the position to know whether or not the denial of Ms.
Caldons application for review was the appropriate action for the Board of Regents to
take?
A: No. Im sorry. Im not.
Q: Ms. Caldon makes the statement about Mr. Bells mental decline. Im wondering if
reading that now perhaps refreshes your recollection that youve seen this document at
some point in time.
A: No, I havent.

Q: But seeing this here doesnt

A: No.
Q: - refresh your recollection that youve seen this before?
A: No, not at all.
Pgs. 84 - 89

Q: Okay. Is it concerning for the Board of Regents where you have an administrative
assistant to the president whos been at the school for some 15 years reporting that her
supervisor, the president of the college, is experiencing a mental decline?
A: Would that be of concern to me?
Q: Yes, maam.
A: I would take everything into consideration, yes, I would.

Q: But really the question was, as a Regent, not you as a human being, as a Regent I
assume that would be something that would be concerning?
A: Yes.
Q: Do you know whether that matter was discussed -- I take it you dont
A: No, I dont.
Q: And on the second page, Ms. Poitevint, it indicates Dr. Bells own daughters and
son have called me both at home and at the office for two years regarding their strong
concern for their fathers increasing psychological health decline. And the question is
the same. Is it is that a matter of concern to you as a Regent?
A: I think it would be a matter of concern. I definitely do.
Q: Ms. Caldon reports that while working for Mr. Bell Dr. Bell, I was put in a
position of covering up countless and inappropriate auditor sensitive discrepancies.
And, again this is coming from an employee whos been there a long time. Is that
something thats concerning to you as a Regent?
A: Yes, its of a concern to me.
Q: Has the Board of Regents ever looked into or any committee organized by the Board
of Regents ever looked into any of these matters relating to Dr. Bell?
A: No, not that I am aware of at all.

FULL DEPOSITION OF REGENT DOREEN STILES POITEVINT BELOW:

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