Stacy Sawin Deloitte Facts

Case 1:16-cv-00827-CMH-MSN Document 95 Filed 05/09/17 Page 1 of 18 PageID# 1544
FILED
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGII^ HAY - 9 P U: 21
Alexandria Division
ERK US DISTRICT COURT
UEXANDRIA, VIRGINIA
RANJITH KEERIKKATTIL,
Plaintiff,
V. Case No: l:16-cv-827-CMH-MSN
STACY SAWIN, etal.
Defendants.
PLAINTIFF'S OPPOSITION TO DEFENDANTS^

MOTION FOR SUMMARY JUDGEMENT
Plaintiff, Ranjith Keerikkattil, hereby submits his Opposition to Defendants' Motion for
Summary Judgment (ECF No. 75) filed by Defendants Deloitte LLP, Deloitte Consulting LLP
and Deloitte Services LP (collectively referred as "Defendants").
INTRODUCTION
Here we have Defendants represented by former Defendant Eric Janson once again lying
that "Plaintiff Ranjith Keerikkattil is a vexatious litigant who was banned from the University of
Maryland after he stalked one of its students." Defendants' Memorandum (ECF No. 76) at 1.
Absent litigation privilege, Defendant's statements would be defamation per se. Defendants
themselves admit that Plaintiff graduated with "his bachelor's degree in applied mathematics
from the University of Maryland in 2010". See ECF No. 76 at 4. As for their lie that Plaintiff is
"banned" from University of Maryland, Plaintiff has and continues to attend alumni events at the
University as late as a few weeks ago. Similarly, their claim that Plaintiff stalked someone is
frivolous as well and cannot point to any rulings or findings of fact to substantiate this.
Defendants attempt to label Plaintiff as a vexatious litigant bystating:
Plaintiff has sued virtually every person and institution associated with this litigation,
including Deloitte and five of its professionals including Stacy Sawin, the Deloitte
employee he currently stands accused of criminally stalking; the Washington, D.C.
Metropolitan Police and two of its employees who arrested him; the U.S. Attorney for
Washington, D.C. and the Assistant U.S. Attorney initially assigned to prosecute him; the
attorneys representing Ms. Sawin; Ms. Sawin's father; and one of the undersigned
attorneys for Deloitte.
Id.
However, they have provided no rulings or findings of fact from any of the cases to prove
their frivolous claim that Plaintiffs assertions were frivolous or vexatious. See Keerikkattil v.
Shealy, et al. No. 24C16002306 (Md. Cir. Ct.) and Keerikkattil v. Stargel, et ai. No. 16-CV-
00857 (D.D.C.). However, the Court may take judicial notice of the fact that Eric Janson was
hired by Deloitte based on Stacy Sawin's insistence, was also her former counsel', extensively
lobbied Deloitte to hire his mistress Meredith CampbelP as Ms. Sawin's counsel and went as far
as contacting an Assistant U.S. Attorney and demanded that he should bring criminal charges
against Plaintiff to silence him in this litigation^. Mr. Janson should be ashamed of himself for
stooping to such lows. Plaintiffs work has only started in holding these crooks and criminals
accountable under the law.
PRELIMINARY STATEMENT
Defendants' Motion for Summary is a web of delusion and outright lies that paints a false
picture of the actual facts that lead to Plaintiffs unlawful termination from Deloitte. As Plaintiff
would be explaining in detail in this motion, there are multiple "genuine issues of material facts"
in the Statement of Material Facts proffered by the Defendants and hence summary judgment
must be denied.
' Am. Compl., Ex. R.

Âm. Compl., Ex. S.
ECF No. 67-2.
Stacy Sawin, one of Plaintiffs former colleagues at Deloitte Consulting LLP lied to her
employer about her interactions with Plaintiff in order to "protect" herself and so that "Deloitte
fires him[PlainitfJ]". Deloitte assigned a Talent (HR) Senior Manager Alicia Carberry, who is
better known at the firm for sleeping around with Deloitte partners (such as Kelly Mire"*) than for
her investigative skills and had a discriminatory animus towards Plaintiff from the beginning.
After interviewing both Plaintiffs superiors Ritesh Verma and Bheeshma Tumati well as his
colleagues Laura Amster and Julie Gi Kim, and being unable to find any evidence to substantiate
Ms. Sawin's frivolous claims, Ms. Carberry lied to Derick Masengale (the individual who had
the power to hire and fire Plaintiff) that Plaintiff lied to her and demanded that he be terminated.
At the same time, Ms. Carberry lied to Deloitte leadership that she did not find any
explicit/vulgar text messages and sexting apps such as Snapchat on Ms. Sawin's Deloitte phone,
a conduct that violates Deloitte's policies and would have subjected Ms. Sawin to termination.
FACTUAL BACKGROUND
Plaintiff, Ranjith Keerikkattil ("Mr. Keerikkattil") started his employment with Deloitte
Consulting LLP ("Deloitte Consulting") on November 10, 2014 as a Senior Consultant within its
Federal Information Management Service Line headed by Defendant Derick Masengale. He had
no supervisory role and no other Deloitte employee reported to him. (Keerikkattil Decl. (Ex. A) ^
1.)
Mr. Keerikkattil met Stacy Sawin ("Ms. Sawin") for the first time on March 4, 2015 at
Information Management Sip'n'Share, a networking event held at Deloitte. She contacted him
the next day via e-mail. (Keerikkattil Decl. f 2. and Ex. 1)
On April 14, 2015, Ms. Sawin after getting fired from her project with Bureau of
Engraving & Printing ("BEP") and security clearance denied contacted him via e-mail asking for
" Am. Compl., %68.

help finding a project, Ritesh Verma ("Mr. Verma"), a Director with Deloitte Consulting was
looking for a Business Technology Analyst ("BTA") to assist him for a proposal effort. Mr.
Keerikkattil provided a list of available BTAs to Mr. Verma. He eventually made the decision to
hire Ms. Sawin on the FPS proposal effort (Keerikkattil Decl. f 3. and Ex. 2). Mr. Keerikkattil
was never Ms. Sawin's manager or supervisor. Both of them reported to Bheeshma Tumati ("Mr.
Tumati"), a Senior Manager with Deloitte Consulting who worked under Mr. Verma.
On May 30, 2015, Mr. Keerikkattil sent Ms. Sawin a polite letter via e-mail titled "FPS
Future Guidance and Cease & Desist Letter" expressing his desire to have no direct involvement
with her on the FPS proposal effort. (Keerikkattil Decl. f 10. and Ex. 7)
On June 1, 2015 at 3:50 PM, Ms. Sawin sent a text message to Vikram Rajan stating "I'm
taking actions to protect myself because he sent me a cease and desist letter and eluded to me
asking him to lie to my manager". See Ex. B at DELOITTE008670. Most outrageously at 8:48
PM, Ms. Sawin sends a text message to Sam Magier that states, "Thanks Sam! This guy is quite a
piece of work. I hope Deloitte fires him". Id. This removes any questions on what Ms. Sawin's
intent were - to fabricate lies about Plaintiff to get him fired from Deloitte.
Ms. Sawin also contacts her Deloitte Counselor Kash Tajammul and lies to him that Mr.
Keerikkattil brought her on to the CMS proposal because he was interested her. She also lied that
Mr. Keerikkattil told her that she is no longer needed on the proposal because she did not accept
his gifts. See Ex. C at DELOITTE006680. Mr. Keerikkattil never ever told Ms. Sawin that she is
no longer needed on the CMS proposal. It is obvious that she was trying to manufacture a sexual
harassment and retaliation scenario. Mr. Tajammul reports and restates Ms. Sawin's lies to
Monique Mignon, a Deloitte Talent/HR employee. Id.
On June 3, 2015, Ms. Sawin sends Leslie Moore Garcia, a Deloitte HR employee an e-
mail containing the following hyperlink: https://casetxt.com/case/keerikkattil-v-hrabowski. This
was intentionally done to portray Mr. Keerikkattil in a negative light at the beginning of the
investigation with the intent to have him fired, something that she had desired. See Ex. D at
DEL01TTE005387. Ms. Sawin also writes up a document titled "The interactions Between Stacy
Sawin and Ranjith Keerikkattil" with multiple false and defamatory statements and calls it the
most important document and submits it to Deloitte HR. See Ex. E at DELOITTE008867.
Stacy Sawin also cleverly deleted and altered selected text messages and apps from her
Deloitte corporate phone. This became known During Deloitte's investigation when a text
message that stated, "Stacy 1 want to eat you" sent from Vikram Rajan to Stacy Sawin was
missing from the text messages obtained from her phone. However, Vikram Rajan vividly
recalled sending her that text message. See Ex. F at DEL01TTE008846. In fact, even Deloitte's
own eDiscovery Litigation Analyst, Aleta Jacobson clearly points to deletion of text messages by
Stacy Sawin. See Ex. G at DELOITTE005563.
Based on Ms. Sawin's lies, Deloitte HR interviewed Mr. KeerikkattiPs superiors and
subordinates for any improper behaviors or communications from Mr. Keerikkattil towards Ms.
Sawin. After interviewing his superiors Ritesh Verma and Bheeshma Tumati, as well as his
colleagues Laura Amster and Julie Gi Kim, Deloitte was unable to find any improper behavior
from Mr. Keerikkattil towards Ms. Sawin. See Ex. H at DELOITTE008776-78, 6777-81, 6771-
74 and 6775-76. After failing to find any improper conduct, Alicia Carberry who from the
beginning wanted to fire Mr. Keerikkattil lied to Derek Masengale that Mr. Keerikkattil should
be fired for lying to her. She even prepared the script for Derek Masengale. See Ex. I at
DEL01TTE008747-48.
Alicia Carberry also ensured that Mr. Keerikkattil's complaint against Ms. Sawin gets
resolved in her favor. Despite the fact that Deloitte's own eDiscovery Litigation Analyst stated
that Stacy Sawin may have deleted text messages and apps, Ms. Carberry and her subordinate
Leslie Moore Garcia made no efforts to retain her corporate phone or laptop hard drive, or to
recover these deleted messages and apps. Instead they lied to Deloitte leadership stating that they
did not recover any explicit text messages, lync messages or e-mails. See Ex. J at
DELOITTE005721. This is in stark contrast to her conduct towards Mr. Keerikkattil where she
immediately confiscated his corporate phone and laptop and specifically instructed to Deloitte IT
that these devices should be preserved. See Ex. K at DELOITTE005366. Despite the fact that
Deloitte's eDiscovery Litigation Analyst found Snapchat installed in her corporate phone, which
is a direct violation of APR 208.007, Ms. Carberry and her subordinate Leslie Moore Garcia
reported to Deloitte leadership that Ms. Sawin did not violate any Deloitte policies. APR 208.007
states that installing, using or downloading any unauthorized software, applications or
technology services is prohibited. See Ex. F at DELOITTE008850. Mr. Keerikkattil's claim that
Ms. Sawin was fired from her Bureau of Engagement & Printing ("BEP") project due to failure
to obtain security clearance was also found to be true. Id; see also Ex. L at DELOITTE005340.
Deloitte and Ms. Carberry always had a strong preference for Ms. Sawin, a female over
Mr. Keerikkattil, a male. Upon Ms. Sawin's insistence^, Deloitte Defendants' hired Eric J. Janson
and his law firm Seyfarth Shaw LLP to defend against Plaintiffs anticipated Federal lawsuit. Ms,
Sawin, Deloitte Defendants and Mr. Janson concocts a plan to accuse Plaintiff of stalking Ms.
Sawin and then use the stalking claim to threaten and intimidate Plaintiff. Together, they submit
a document with multiple false statements about Plaintiff to DC MPD First District Police
Station with the intend of bringing frivolous criminal stalking charges against him.
^ Both Ms. Sawin and Mr. Janson graduated from Lehigh University and knew each other
through their alma mater. See Am. Compl., Exs. G & S.
Ms. Sawin and Mr. Janson tlien file a frivolous and defamatory Civil Restraining Order
("CRO") petition in D.C. Superior Court that gets summarily dismissed. After failing the CRO
petition, Ms. Sawin and Mr. Janson attempt a second bite at the apple by filing a Civil Protection
Order ("CPO") petition in D.C. Superior Court. Mr. Janson insisted that Deloitte Defendants
specifically hire Meredith S. Campbell ("Ms. Campbell"), his intimate friend from Lehigh days^
and her law firm Shulman, Rogers, Gandal, Pordy and Ecker P.A. ("SRGPE"). Mr. Janson also
obtained funding for Ms, Campbell and SRGPE from Deloitte for representing Ms. Sawin in the
CPO proceeding. Michael J. Lichtenstein, General Counsel for SRGPE has already admitted that
Deloitte under Mr. Janson's direction has been paying SRGPE's (and his paramour's) legal bills
for representing Stacy Sawin. See ECF No. 67-1.
Mr. Janson also used his influence with the United States Attorney's Office for the
District of Columbia to initiate and sustain a meritless misdemeanor prosecution against Plaintiff.
Any doubts regarding this were cleared when on September 8, 2016 Mr. Janson, as Deloitte's
agent personally appeared in D.C. Superior Court and demanded to John Giovannelli, an AUSA
that he should bring felony criminal charges to threaten and intimidate Plaintiff from pursuing
this case. Plaintiffs claims are corroborated by Allison Baker Shealy, an SRGPE attorney and
Deloitte funded counsel for Ms. Sawin who witnessed Mr. Janson's tortious interactions with Mr.
Giovannelli. See ECF No. 67-2.
PLAINTIFF'S STATEMENT OF MATERIAL FACTS IN DISPUTE
1. Plaintiff and Ms. Sawin knew each other and were friends on Facebook before working
together on the CMS FPS proposal. On April 14, 2015, Ms. Sawin after getting fired from
her project with Bureau of Engraving & Printing ("BEP") and security clearance denied
^ Mr, Janson and Ms. Campbell both graduated from Lehigh University in 1998. See Am.
Compl., Ex. S. After Lehigh, Ms. Campbell went to Harvard Law and Mr. Janson ended up at
bottom-tier George Mason Law.
contacted Plaintiff via e-mail asking for help finding a project. Ritesh Verma ("Mr.
Verma"), a Director with Deloitte Consulting was looking for a Business Technology
Analyst ("BTA") to assist him for a proposal effort. Mr. Keerikkattil provided a list of
available BTAs to Mr. Verma. He eventually made the decision to hire Ms. Sawin on the
FPS proposal effort. Mr. Keerikkattil was never Ms. Sawin's manager or supervisor. Both
of them reported to Bheeshma Tumati ("Mr. Tumati"), a Senior Manager with Deloitte
Consulting who worked under Mr. Verma. All of the work Ms. Sawin performed was
assigned by Mr. Tumati and Mr. Verma. (Keerikkattil Decl. ^3. and Ex. 2). (Dispute D's
SOF1|4,5.)
2. Defendants' claim that Plaintiff was "evasive and uncooperative" (Carberry Decl. ^ 16.) is
completely false. Alicia Carberry's meeting notes show that Plaintiff had answered all her
questions, gave her "3 zip files" that had all the "emails related to Stacy". See Ex. D to
Carberry Decl. (Dispute D's SOF ^ 16.)
3. Defendants specifically stated that "Plaintiff denied having sent Ms. Sawin a text saying
she was "slim and sexy," denied that he had communicated with Ms. Sawin after sending
her the "cease and desist" email, and denied that Ms. Sawin had ever asked him to keep
his communications with her strictly professional". (Carberry Decl. Tf 16). However,
Alicia Carberry's interview notes (Ex. D to Carberry Decl.) contradict this. According to
her notes, with respect to the so called "slim and sexy" text message, Plaintiff had stated
"I think I know what this is about. There was one time when we were in McLean and 1
think I upset her because she misunderstood me and thought I made a fat comment. I sent
her a text later that said sorry if I hurt her feelings that I didn't mean to." With respect to
Defendants' claim that Plaintiff denied that he had communicated with Ms. Sawin after
sending her the "cease and desist" email, Ms. Carberry's notes state,"well maybe once to
make sure that she didn't have any questions related to the email her sent." Besides Ms.
Carberry's notes does not contain the question - "Has Ms. Sawin had ever asked Mr.
Keerikkattil to keep his communications with her strictly professional?". Plaintiffs
answers to Ms. Carberry is consistent with his testimony under oath as well as supporting
evidence (Keerikkattil Decl. ^5, 10. and Ex. 3). Taken together Alicia Carberry's
statement that Plaintiff lied to her is in itself a big lie. (Dispute D's SOF ^ 16,17,18.)
4. Despite the fact that Plaintiff was truthful to Ms. Carberry, she lied to Deloitte leadership
and Derick Masengale (the individual who had the power to terminate Plaintiff) that
Plaintiff lied to her and should be terminated. She even prepared the termination script for
Mr. Masengale detailing what he should tell Plainitff while terminating him. See Ex. I at
DELOITTE008747-48. In addition, Alicia Carberry and her deputy Leslie Moore Garcia
interviewed Plaintiffs superiors Ritesh Verma and Bheeshma Tumati, as well as his
colleagues Laura Amster and Julie Gi Kim, all of who testified that they did not witness
any improper behavior from Mr. Keerikkattil towards Ms. Sawin, See Ex. H at
DELOITTE008776-78, 6777-81, 6771-74 and 6775-76. Hence the only way for Ms.
Carberry to maliciously fire Plaintiff was to lie that he lied to her. (Dispute D's SOF %
20,21.)
5, Stacy Sawin filed the complaint with Deloitte not because she was concerned about any
non-work related text messages or interactions. In fact, more than 90% of all text
messages sent/received by Ms. Sawin on her Deloitte corporate phone had nothing to do
with her work at Deloitte. See Ex. B. In addition, these text messages show that Ms.
Sawin frequently attended non-work related events with her Deloitte employees. The only
reason why Ms. Sawin filed a complaint with false statements against Plaintiff was
according to her own words, to "protect" herself after Plaintiff sent her the cease and
desist letter on May 30, 2015 as she stated in a text message to Vikram Rajan and so that
"Deloittefires hitn[Plainitff]" as she stated in a text message to Sam Magier. See Ex. B
at DELOITTE008670. (Dispute D's SOF ^ 5,6,10,11.)
6. Stacy Sawin lied to her Deloitte Counselor Kash Tajammul that Mr. Keerikkattil brought
her on to the CMS proposal because he was interested her. She also lied that Mr.
Keerikkattil told her that she is no longer needed on the proposal because she did not
accept his gifts. See Ex. C at DELOITTE006680. Mr. Keerikkattil never ever told Ms.
Sawin that she is no longer needed on the CMS proposal (Keerikkattil Decl. ^ 10. and Ex.
7). In addition, Ms. Sawin was hired on the CMS proposal because she contacted Plaintiff
asking for help and Plaintiff forwarded her name to Ritesh Verma who chose to hire her
(Keerikkattil Decl. f 3. and Ex. 2). Mr. Tajammul reported and restated Ms. Sawin's lies
to Monique Mignon, a Deloitte Talent/HR employee. See Ex. C at DELOITTE006680.
Also, in order to portray Plaintiff in a negative light to have him fired, Ms. Sawin lied to
Deloitte investigators that Plaintiff had stalked a student at University of Maryland See
Ex. D at DELOITTE005387. However, Ms. Sawin has never complained to Deloitte that
Plaintiff had stalked her. (Dispute D's SOF ^ 11,12,13,14,15.)
7. Alicia Carberry's investigation of Plaintiffs complaint against Ms. Sawin is laughable at
best. Plaintiff had complained, among others, that (i) "Stacy Sawin uses her Deloitte
issued corporate mobile phone/Lync to exchange text messages/IM's that not only are
unrelated to legitimate business needs but also are sexually explicit or inappropriate"; and
(ii) "Stacy Sawin uses her Deloitte issued corporate mobile phone for purposes not only
10
are irrelevant to Deloitte's legitimate business needs but also are inappropriate such as
dating and/or pornography". Ms. Carberry had already made up her mind to exonerate
Ms. Sawin from the beginning and the sham investigation was just to cover her butt in the
case of any litigation. In support of this:
a) Ms. Carberry gave Ms. Sawin advance notice so that she could delete all the explicit
messages and apps such as OkCupid from her phone as well as compromising IM's and
e-mails from her laptop. On the other hand, she forcibly confiscated Plaintiffs laptop and
phone from him. In other words, Ms. Carberry enabled Ms. Sawin to destroy inculpatory
evidence while denying Plaintiff the ability to present inculpatory evidence.
b) Deloitte's eDiscovery Litigation Analyst Aleta Jacobson found Snapchat, a wildly
popular sexting app installed in Ms. Sawin's Deloitte corporate phone, which is a direct
violation of APR 208.007, which prohibits the "Installing, using or downloading any
unauthorized software, applications or technology services." See Ex. F at
DELOITTE008850. Despite conclusive evidence, Ms. Carberry and her subordinate
Leslie Moore Garcia reported to Deloitte leadership that Ms. Sawin did not violate any
Deloitte policies.
c) Defendants never performed any forensic analysis to determine which all apps were
deleted from Ms. Sawin's Deloitte phone. This would have uncovered the truth that Ms.
Sawin used dating apps such as OkCupid on the phone in violation of APR 208.007. Mr.
Keerikkattil has testified at his deposition as well as sworn under oath that he had
witnessed dating apps on Ms. Sawin's Deloitte corporate phone. Ms. Carberry instead
reported that she did not find any dating apps on Ms. Sawin's phone.
d) Defendants withheld sexually explicit MMSs identified by Ms. Jacobson from
II
production to Plaintiff. Ms. Jacobson had stated in that she had recovered both SMSs and
MMSs. As an example, Ms. Sawin sent the following text message to Vikram Rajan on
6/17/2015 at 6:32:46AM, "Woke up a bit b4 I actually was actually getting out of bed and
realized that I had nothing on below the waist ... http://m.imgur.com/gallery/JZ85Pgu"
(Ex. B at DELOITTE008660), The sexually explicit MMS along with other would have
clearly proven that Ms. Sawin violated Deloitte's Code of Conduct. Defendants also
withheld 579 explicit emails in the "naughty" list (Ex. G at DELOITTE005563) identified
by Ms. Jacobson from production. Despite uncovering sexually explicit MMSs and e-
mails, Ms. Carberry and Ms. Garcia (Ms. Carberry's Deputy) notified Deloitte leadership
that they uncovered no explicit messages or e-mails.
(Dispute D's SOF ^ 22,25,26.)
8. Plaintiff testified during his deposition about explicit text messages as well as Snapchat
and OkCupid apps on Ms. Sawin's Deloitte corporate mobile phone (PI. Dep.at 132-140.)
Plaintiff has also certified under oath in his declaration that he had witnessed explicit text
messages as well as Snapchat and OkCupid apps on Ms. Sawin's Deloitte corporate
mobile phone (Keerikkattil Decl. 111 •) (Dispute D's SOF f 23,24,25,26.)
LEGAL STANDARD
L Summary Judgment
Summary judgment is appropriate only if the record shows that "there is no genuine issue
as to any material fact and that the moving party is entitled to a judgment as a matter of law."
Fed. R. Civ. P. 56(c); see also Anderson v. Liberty Lobby, Inc., All U.S. 242, 247-48 (1986);
Evans v. Techs. Apps. & Serv. Co., 80 F.3d 954, 958-59 (4th Cir.1996). The party seeking
summary judgment has the initial burden to show the absence of a genuine issue of material fact.
12
Celotex Corp. v. Catrett, All U.S. 317,325 (1986), A genuine issue of material fact exists "if the
evidence is such that a reasonable jury could return a verdict for the nonmoving party."
Anderson, Ml U.S. at 248. Once a motion for summary judgment is properly made and
supported, the opposing party has the burden of showing that a genuine dispute exists.
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586-87 (1986). The facts shall
be viewed, and all reasonable inferences drawn, in the light most favorable to the non-moving
party. Anderson, All U.S. at 255; see also Lettieri v. Equant Inc., 478 F.3d 640, 642 (4th
Cir.2007). To defeat a properly supported motion for summary judgment, the non-moving party
"must set forth specific facts showing that there is a genuine issue for trial." Id. at 248. Whether
a fact is considered "material" is determined by the substantive law, and "[o]nly disputes over
facts that might affect the outcome of the suit under the governing law will properly preclude the
entry of summary judgment." Id.
IL Title VII Discrimination
Title VII prohibits an employer from (i) discriminating against an employee on the basis
of sex, and (ii) retaliating against an employee for complaining about prior discrimination or
retaliation. 42 U.S.C. §§ 2000e-2(a)(l), 2000e-3(a). In order to survive summary judgment,
plaintiff must first establish a prima facie case of unlawful discrimination. See Reeves v.
Sanderson Plumbing Prod, Inc., 530 U.S. 133, 142 (2000); Texas Dept ofCommunityAffairs v.
Burdine, 450 U.S. 248, 252-53 (1981). In order to establish a primafacie case of discriminatory
adverse employment action under Title VII, a plaintiff must either produce "direct evidence" of
discrimination or satisfy the burden shifting rubric established in McDonnell Douglas Corp. v.
Green, 411 U.S. 792 (1973). Direct evidence of discrimination is "a set of facts which would
enable the fact-finder to conclude, in the absence of any further explanation, that it is more likely
13
than not that the adverse employment action was the product of discrimination." Ennis v. Nat'!
Ass'nofBus. & Educ. Radio, Inc., 53 F,3d 55, 58 (4th Cir. 1995). To establish aprimafacie case
under McDonnell Douglas, a plaintiff must prove that he: (I) he is a memberof a protected class;
(2) he suffered adverse employment action; (3) he was performing his job duties at a level that
met his employer's legitimate expectation at the time of the adverse employment action; and (4)
the position remained open or was filled by similarly qualified applicants outside of the protected
class. See McDonnell Douglas, 411 U.S. at 802. If the plaintiff chooses to proceed under this
burden shifting framework and establishes a prima facie case, the burden of production then
shifts to the employer to articulate a legitimate, non- discriminatory justification for its allegedly
discriminatory action. Burdine, supra, 450 U.S. at 253. If the employer carries this burden, the
plaintiff then must establish that the neutral reasons offered by the employer were not its true
reasons, but were a pretext for discrimination. See Burdine, 450 U.S. at 256 ("[Plaintiff] may
succeed in this either directly by persuading the court that a discriminatory reason more likely
motivated the employer or indirectly by showing that the employer's proffered explanation is
unworthy of credence."). "The final pretext inquiry merges with the ultimate burden of
persuading the court that [the plaintiff] has been the victim of intentional discrimination, which at
all times remains with the plaintiff." Merritt v. Old Dominion Freight Line, Inc., 601 F.3d 289,
294 (4th Cir. 2010) (internal citations omitted). See also Reeves v. Sanderson Plumbing Prods.
Inc., 530 U.S. 133 (2000) (a Title VII plaintiff must prove an employer's reasons were not true or
"unworthy of credence."); EEOC v. Navy Federal Credit Union, 424 F.3d 397, 405 (4th Cir.
2005).
ARGUMENT
L Plaintiff has provided sufficient evidence from which a jury could reasonably
14
conclude that he was discriminated
Under McDonnell Douglas, a plaintiff demonstrates a prima facie case of sex
discrimination by showing that (1) he is a member of a protected class; (2) he suffered adverse
employment action; (3) he was performing his job duties at a level that met his employer's
legitimate expectation at the time of the adverse employment action; and (4) the position
remained open or was filled by similarly qualified applicants outside of the protected class. See
McDonnell Douglas, 411 U.S. at 802.
Sex is a protected class under the Civil Rights Act of 1964. Mr. Keerikkattil has suffered
adverse employment action in the form of termination by Deloitte. Mr. Keerikkattil was
performing his job duties that exceeded his employer's expectations based upon his DPME
performance rating as well as the communication from his Counselor Mehran Tamami'. Mr.
Keerikkattil's position remained opened and a job listing with Mr. Keerikkattil's same Title
(Senior Consultant, Deloitte Consulting LLP) and Job Description (SAS Developer, Arlington
VA) appeared on Deloitte's Careers web site within 2 business days from his unlawful
termination^. Therefore, Mr. Keerikkattil has met all the requirements to demonstrate a prima
facie case of sex discrimination \xndQT McDonnell Douglas.
Plaintiff has already proven that Deloitte's proffered reasons for his termination were false. It
is abundantly clear that Alicia Carberry lied to Deloitte leadership to get Plaintiff fired. PI SOF in
Dispute 3-4. A "failure to conduct what appeared to be a fair investigation of the violation
that purportedly prompted adverse action may support an inference of pretext. See Trujillo v.
PacifiCorp, 524 F.3d 1149, 1160 (10th Cir. 2008). At the same time, Alicia Carberry turned a
blind eye to Stacy Sawin's violations of Deloitte policies and instead lied to Deloitte leadership
' Am. Compl., Ex. B.

®Am. Compl., Ex. V.
15
that Ms. Sawin did not violate any Deloitte policies to save her job. PI SOF in Dispute ^ 7. There
is absolutely no question that Alicia Carberry and her deputy Leslie Moore Garcia both females
discriminated against Plaintiff, a male compared to Stacy Sawin, afemale.
Since Mr. Keerikkattil has successfully made a prima facie case of sex discrimination and has
proven with sufficient evidence that Deioitte's asserted justifications were false, a reasonable
trier of fact could conclude that he was unlawfully discriminated by Deloitte. Reeves v.
Sanderson Plumbing Prods., Inc., 530 U.S. 133, 148 (2000) ("[A] plaintiffs prima facie case,
combined with sufficient evidence to find that the employer's asserted justification is false, may
permit the trier of fact to conclude that the employer unlawfully discriminated."). Therefore, Mr.
Keerikkattil has proven a valid claim for sex discrimination under McDonnell Douglas burden-
shifting framework.
II. Plaintiff and Ms. Sawin are similarly situated under Title VII
Deloitte Defendants claim that Plainitff and Ms. Sawin are not similarly situated because
according to them Plaintiff "was a Senior Consultant in Deioitte's Information Management
Service Line" and "Ms. Sawin was a Business Technology analyst, a more junior role."
Defendants' Memorandum (ECF No. 76) at 13. However, Defendants' do not offer any evidence
to show that Plaintiff was Ms. Sawin's supervisor or that his duties were substantially different
from that of Ms. Sawin's.
Deloitte Consulting LLP has three tiers of employees:
(i) Partners & Directors - Partners own shares of the firm and Directors are non-equity
partners. Partners and Directors are elected by existing Partners and Directors.
(ii) Managers - Managers report to Partners and Directors and supervise regular
employees.
16
(iii) Non-managerial employees - These employees have no supervisory responsibilities
and include the titles of Senior Consultants, Consultants and Business Technology
Analysts.
Plaintiff like Ms. Sawin as a regular non-managerial employee of Deloitte Consulting LLP had
no supervisory responsibilities as Deloitte Consulting Director Ritesh Verma clearly stated,
"Ranjith not responsible for anyone else". See Ex. H at DELOITTE008777
"'[T]o be similarly situated the employees must have been disciplined by the same
supervisor.'" Jones v. Giant ofMd, LLC, No. DKC-08-304, 2010 WL 3677017, at *8 (D. Md.
Sept. 17, 2010) (quoting McDougal-Wilson v. Goodyear Tire and Rubber Co., 427 F. Supp. 2d
595, 610 (E.D.N.C. 2006)). Within Deloitte Consulting, employees (or practitioners in Deloitte
lingo) are hired and fired by Service Line leaders. Plaintiff and Ms. Sawin were both hired by
Defendant Derek Masengale as the Service Line Leader for Deloitte's Information Management
Service Line. Similarly, the decision to terminate Plaintiffs employment was made by Mr.
Masengale. See Am. Compi, Ex. K. Hence, Plaintiff and Ms. Sawin are similarly situated under
Title VII.
CONCLUSION
For the foregoing reasons. Plaintiff Ranjith Keerikkattil respectfully requests that this Court
deny Defendant's Motion for Summary Judgment.
CERTIFICATION PURSUANT TO LOCAL CIVIL RULE 83.1M(2)
I declare under penalty of perjury that:
No other attorney has prepared, or assisted in the preparation of this document.
17
Ranjith Keerikkattil
Executed on: May 9,2017
Dated: May 9,2017 Respectfully submitted,
4707 Grand Bend Drive
Catonsville, MD 21228
rkeerikkattil@gmail.com
Tel: (443) 690-1031
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 9^'^ day of May 2017, Plaintiffs Opposition to
Defendants' Motion for Summary Judgment was served by First Class Mail Postage Prepaid to:
Christine M. Costantino
Eric J. Janson
Nicholas H, De Baun
Seyfarth Shaw LLP
975 F Street, N.W.,
Washington, DC 20004
Phone: (202) 463-2400
Fax: (202) 641-9232
ccostantino@seyfarth.com
ejanson@seyfarth.com
ndebaun@seyfarth.com
Counselfor Defendants Deloitte LLP, Deloitte Consulting LLP, Deloitte Services, LP
18
Case 1:16-cv-00827-CMH-MSN Document 95-1 Filed 05/09/17 Page 1 of 28 PageID# 1562
Exhibit A
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
RANJITH KEERIKKATTIL,
Plaintiff,
V. Case No: l:16-cv-827-CMH-MSN
STACY SAWIN,etal.
Defendants.
DECLARATION OF RANJITH KEERIKKATTIL
RANJITH KEERIKKATTIL, under penalty of perjury, affirms as follows:
1. I started my employment with Deloitte Consulting LLP ("Deloitte Consulting") on

"November 10, 2014 as a Senior Consultant within its Federal Information Management
Service Line headed by Defendant Derick Masengale. I had no supervisory role and no
other Deloitte employee reported to me.
2. I met Stacy Sawin ("Ms. Sawin") for the first time on March 4, 2015 at Information
Management Sip'n'Share, a networking event held at Deloitte. She contacted me the next
day via e-mail. See Ex 1.
3. On April 14, 2015, Ms. Sawin after getting fired from her project with Bureau of
Engraving & Printing ("BEP") and security clearance denied contacted me via e-mail
asking for help finding a project. Ritesh Verma ("Mr. Verma"), a Director with Deloitte
Consulting was looking for a Business Technology Analyst ("BTA") to assist him for a
proposal effort. I provided a list of available BTAs to Mr. Verma. He eventually made the
decision to hire Ms. Sawin on the FPS proposal effort. See Ex. 2. I was never Ms.
Sawin's manager or supervisor. Both of us reported to Bheeshma Tumati ("Mr. Tumati"),
a Senior Manager with Deloitte Consulting who worked under Mr. Verma. Mr. Verma
and Mr, Tumati also hired Laura Amster and Julie Gi Kim on to the proposal effort based
on Ms. Sawin's recommendation.
4. On April 23 2015, Ms. Sawin invited me to her apartment to work at cafe in her
apartment complex. 1 never asked me her to invite me to her apartment complex or to
work there.
5. On May 6, 2015 afternoon, Ms. Sawin and I along with a couple of our colleagues
worked out of Deloitte's Tysons Comer office. After working into the late evening, our
Manager Bheeshma Tumati invited our team including Ms. Sawin and I for a happy hour
at Gordon Biersch in Tysons Comer Mall. I said to the team that I would be shopping in
the mall as we departed out of Gordon Biersch. Ms. Sawin requested me to drop her in
DC or Rosslyn and asked me to let her know when I'm done with my shopping. I
proceeded to shop at Barnes & Nobles and Macys. Ms. Sawin proceeded to shop at some
other stores. While I was at Macy's waiting for the fitting rooms to be free, I received a
text message from Ms. Sawin stating "I'm making moves" and "I'm in express". I replied
to her that "Now I'm in macy's". Subsequently Ms. Sawin came over towards Macy's.
We met in front of Macy's and proceeded towards the parking lot. While we were
walking Ms. Sawin told me that she was shopping for a formal dress for a concert she
was going to attend later that week. While we were driving back, we had a casual chat
about non-work related matters. Ms. Sawin and I were friends on Facebook that time. I
told her that she looked different in her Lehigh University graduation picture. For some
reason, Ms. Sawin believed that she looked fatter and uglier than in her graduation
picture and was unhappy. I told her that I did not mean that. I subsequently dropped her
in Washington D.C. After I got home I sent a text message clarifying that I didn't mean
that she was fat and ugly. In order to make sure that she didn't feel hurt and to cheer her
up I texted, "I'm sorry Didn't mean to hurt you" and "You're cute slim and sexy!". She
replied, "It's okay". The next day 1ran into her near the cafeteriaon the fourth floor. She
said, "It's all good" with respectto the previous night's misunderstanding. See Ex 3.
6. On May 10, Ms. Sawin sent me an invite on Linkedln. See Ex 4.

7. On May 13, 2015 evening, Ms. Sawin and I were working together at Deloitte Arlington
office. Ms. Sawin asked me if I was attending the Asian Business Resource Group
("ABRG") happy hour at Cafe Asia in Arlington, VA. I informed her that I did not know
about the event and can attend. Ms. Sawin and I carpooled from Deloitte office to Cafe
Asia. While we were entering Cafe Asia, we were greeted by Neel Sanghvi, a BTA at
Deloitte. Subsequently, 1 had a chat with Mr, Sanghvi when he stated that another
Deloitte BTA Vikram Rajan had a romantic interest in Ms Sawin. Ms. Sawin had
introduced me to Mr. Rajan before. Mr. Sanghvi also alleged that I had a romantic
interest in Ms. Sawin. I did not respond to his frivolous accusation. However, I informed
Ms. Sawin about Mr. Sanghvi's allegations via Lync message. See Ex 5.
8. On May 28, 2015, Ms. Sawin and I attended an Armed Forced Business Resource Group
("AFBRG") event at Deloitte office. The event was a book signing event with Gayle
Tzemach Lemmon, author of "Ashley's War". See Ex 6. The conversation between Ms.
Sawin and I involved her stating that both her "grandpas" served in the military and she
continued talking about her grandparents. Ms. Sawin also stated that her racist white
grandparents on her father's side did not talk to her grandparents on her mother's side for
a long time because they were of Japanese Origin.
9. On May 29, Ms. Sawin and I attended ABRG Asian Pacific Heritage Month event at
Deloitte office. The conversation primarily involved Ms. Sawin talking about her
Memorial Day long weekend hanging out with her Lehigh University friends. It was
nothing related to the CMS proposal work.
10. Based on the text messages I received from Ms. Sawin, it appeared to me that Ms. Sawin
had completely misunderstood the nature of our relationship. So, on May 30, 2015, I
wrote a letter to her expressing my desire to stay away from her, not to contract me
regarding FPS proposal effort and directed her to contact Mr. Tumati or Mr. Verma. See
Ex 7. I never attempted to retaliate against her and never told her that she is no longer
needed on the FPS proposal effort. I also sent her a follow-up note asking her if she had
any questions regarding my e-mail.
11. From early April thru end of May, 2015, I witnessed Stacy Sawin using her Deloitte
corporate phone to send explicit text messages as well as explicit images using Snapchat.
I also saw OkCupid app on her Deloitte corporate phone and had once even told her that
installing dating apps violates Deloitte's policies.
12. On June 10, 2015 at 3 PM, 1 was asked to meet Alicia Carberry, a Senior Manager with
Deloitte Talent (HR). Ms. Carberry's behavior was hostile towards me. It appeared as if
she had already made up her mind to fire me. She also forcibly took away my laptop
despite me stating that I would like to send her further documents in support of my
answers.
13. Deloitte Defendants tried their best to withhold responsive documents about
investigations conducted by them. They delayed the production of these responsive
records by more than 79 days. Finally, on March 24, 2017 following a motion to compel,
they produced responsive documents related to these investigations. These documents
conclusively proved that Alicia Carberry lied to Deloitte leadership that I lied to her,
turned a blind eye towards Ms. Sawin's multiple violations of Deloitte policies and asked
her deputy Leslie Moore Garcia to report to Deloitte Talent Leadership that Ms. Sawin
did not violate any Deloitte policies.
14.1 also informed Deloitte Defendants that 1 would like to correct/supplement my

deposition transcript based on recently discovered information pursuant to Fed R. Civ.
P. 30(e) within 30 days of its publication. Deloitte Defendants refused to allow me to
correct/supplement my deposition transcript. Hence my depositions transcript is
inaccurate and does not reflect answers that are to the best of my current knowledge.
Dated: April 21,2017

Catonsville, Maryland
EXHIBIT 1 TO KEERIKKATTIL DECLARATION

From: Sawin, Stacy (US - Arlington)

Sent: Thursday, March 05, 2015 3:25 PM
To: Keerikkattil, Ranjith (US - Arlington)
Subject: IM All Hands Follow-up
Hi Ranjith,
It was nice meeting you yesterday at the IM All Hands Event. Thank you for offering to send me information about SWAT
Proposal Training and SAS Training. I am actively seeking ways to learn more about Deloitte and IM topics, so I truly
appreciate your willingness to advice and help me.
Best Regards,
Stacy
Stacy Sawin
Business Technology Analyst
Deloitte Cosulting LLP
Tel/Direct: +1 571 841 77841 Mobiie: +1 503 380 3915
Ssawin@deloitte.com I www.deloitte.com
corisider Ihe eiii/ircjnrnent before pfiritino

EXfflBIT 2 TO KEERIKKATTIL DECLARATION

Keerikkattil, Ranjith

Sent: Tuesday, April 14, 2015 10:56 AM
To: Sawin, Stacy (US - Arlington); Keerikkattil, Ranjith (US - Arlington)
Subject: Conversation with Sawin, Stacy (US - Arlington)
Sawin, Stacy (US - Ariington) {10:30 AM]:
Hi Ranjith! How are you doing?

Keerikkattii, Ranjith (US - Ariington) [10:30 AM]:
Hey Good. How are you?
How's your BEP engagement going?
Are you still in Rosslyn?

Sawin, Stacy (US - Arlington) [10:31 AM]:
I'm doing well. However, I'm no longer part of the BEP engagement, which is actually why I wanted to reach out to
you. I'm between projects and have a bit of extra time. Is there anything I can help you with?
I'm involved with a proposal on the CMS account. We need support on creating architecture diagrams, meeting
minutes, doing research online and things like that. Not sure if you are interested. It's a SAS based analytics
platform we are proposing.
Are you currently looking for a project or waiting to be on-boarded to a different one?
That sounds like something I would like to be involved with. Is there anything I get started on for the CMS
proposal and/or materials to familiarize myself with the account? Also, I am currently looking for a project.
Are you free around 12 today? I'm going for lunch with a consultant in IM. May be we can join us. We can talk
then.
I know a specialist master who wants a BA/BTA for one of the CMS projects
I need to ask him if he needs an experienced hire with CMS experience or not
I wish I could but I already have a lunch meeting. I'm free anytime after 1:15PM though, if you have any availability
later in the day
Keerikkattii. Ranjith (US • Arlington) [10:55 AM]:
Okay. Let me see. I have a 3-4 and am meeting with my counselor at 5:30. So let's see 4. I'll ping you

Sent: Monday, April 20, 2015 8:12 PM
Subject: RE: Hi
Hi Ranjith,
Thank you for sending methe Visio diagranfis. Ido have Visio installed on my laptop andam happy to get started.
Best Regards,
Stacy
From: Keerikkattil, Ranjith (US - Arlington)

Sent: Monday, April 20,2015 8:04 PM
To: Sawin, Stacy (US - Arlington)
Subject: RE: Hi
You can re-use components from the attached Visio diagrams for our diagram than startingfrom scratch. Do you have
Visio installed on your Deioitte laptop? Ifnot search for Visio on DeloitteNet and you'll find the instructions to install
from there.
Deioitte Consulting LLP
1919 North Lynn Street, Arlington, VA, 22209
Tel/Direct: +1 571 882 5816 | Mobile: +1 571 317 9772 | Fax: +1 855 344 9721
rkeerikkattil@deloitte.com | www.cleloitte.com
Piease considei' the environsrssnt before printing.

Cc: Keerikkattil, Ranjith (US- Arlington)
Subject: Re: Hi
Sure. I'll review it and get back to you by tomorrow.
Thanks!
Deioitte Consulting LLP
1919 North Lvnn Street, Arlington. VA. 22209
Tel/Direct: +1 571 882 5816 I Mobile: +1 571 317 97721 Fax: +1 855 344 9721
rkeerikkattil@deloitte.com I www.deloitie.com
Please consider the environment before printing.
On Apr 20, 2015, at 4:34 PM, Sawin, Stacy (US - Arlington) <ssawin@deloitte.com> wrote:
Hi Ranjith,
Attached are my first draft of the meeting minutes and a picture of the solution framework. Iwould
greatly appreciate your feedback on the minutes, since it was my first time taking meeting notes. Please
let me know how I can modify them to meet the proposal team's needs.
Best Regards,
Stacy

Sent: Monday, April 20,2015 2:33 PM
To: Sawin, Stacy (US- Arlington)
Subject: RE: Hi
Cool. That works!
Deloitte Consulting LLP
1919 North Lynn Street, Arlington, VA,22209
rkeerikkattil@cleloitte.com I www.deloitte.com
Pleajir' oonsicisr Umf^-nvironrnsnj uefurij prirning.
From: Sawin, Stacy (US- Arlington)

To: Keerikkattil, Ranjith (US- Arlington)
Subject: RE: Hi
Sure! Since we used my computer for the Google Hangout, I handwrote a large majority of the meeting
notes. I will type them up later this afternoon and send them over, in addition to the solution pictures.

To: Sawin, Stacy (US- Arlington)
Subject: RE: Hi
Can you send me the draft notes and the solution picture when you get a chance?
rkeerikkattil@deloitt6.com | www.deloitte.com
Pisa5s conainer ihe onvironrvian? before pnritirin^

Sent: Sunday, April 19, 2015 6:15 PM
Subject: Re: Hi
You are confirmed for tomorrow. Plan to get there a bit early. If you don't find Ritesh or
Bheeshma from Deloitte, tell the receptionist that you have a meeting with Andrew Horton.
Again, call me if you find any issues.
2
1919 North Lvnn Street. Arlington. VA. 22209
Tel/Direct: +1 571 882 5816 I Mobile: +\ 571 317 97721 Fax: +1 855 344 9721
rkeerikkattil@deloitte.com I www.deloitte.com
On Apr 19, 2015, at 12:37 PM, Keerikkattil, Ranjith (US - Arlington)

<rkeerikkattil@DEL01TTE.com> wrote:
Stacy,
Thank you for your interest in knowing more about the solution. The attached
documents should give you an overview. The first attachment is an overview of
the current solution. The second one is our proposed solution framework. We
need to finalize the products (see below table) that best meets the requirements for
this framework. That's what the meeting tomorrow is about. The third deck talks
about our current proposal team. I'll be in Rosslyn on Tuesday and we can discuss
further.
Area
FPS.1.0 Technology
GDir Proposed Tech Component
Rationale
Data Integration
Sqoop
Sqoop, SAS DI Studio/Dataflux
Sqoop for loading data into Cloudera
SAS DI Studio/Dataflux included in current CPI license
SAS DI Studio integrates well with SAS Decision Manager
SAS DI Studio can incorporate SAS code in workflows (Re-using IBM

SAS code)
Data Warehousing
Hortonworks
Cloudera/Teradata (Leveraging IDR)

Execution of the post-pay models on Teradata (DDR) (because that is where

theyears and years of claims datalives now), and move pre-pay model execution
over on to Cloudera (this follows along a little more closely to what Bheeshma
was talking to when the four of us talked last Friday)
Leveraging Cloudera for storing new unstructured data sources added in

addition to the current ones.
Business Rules Development
Custom code
SAS Business Rules Manager
In-database execution of business rules
SAS has provided quals in both conmiercial and federal space
Better integration with the rest of the SAS suite.
Model Development
Custom code
SAS Enterprise Miner
Included in current CPI license
Models developed in Enterprise Miner can be executed in-database
Easy to use GUI interface for Model Developers
Model Management
No solution
SAS Model Manager
In-database execution of models
Business Rules Execution
No solution
SAS Business Rules Manager

SAS Scoring Accelerator for Hadoop/ SAS Scoring Accelerator for Teradata
Pushes SAS code/PMML/DS2 to run in-database within Hadoop
Faster business rules execution than FICO Blaze
Model Execution
No solution except running custom code in Hadoop
SAS Model Manager

SAS Scoring Accelerator for Hadoop/ SAS Scoring Accelerator for Teradata
Pushes SAS code/PMML/DS2 and EM models to run in-database within

Hadoop
Reduces model execution time
Alert Generation
Custom code written in CLIPS
SAS FCM/SAS custom code for additional functionalities
SAS FCM and SNA are part of CPFs SAS FF license
Additional customizations can be done with SAS code
SAS FCM integrates with most of the commercial case management tools
Please do not share these without informing us.
Once you get to the General Dynamics office at 3060 Williams Dr, please go
towards the reception on the ground floor and they'll sign you in. You can contact
me at 571-317-9772 if you have any questions or run into any issues.
Tel/Direct: +1 571 882 5816 I Mobile: +1 571 317 9772 I Fax: +1 855 344 9721
rkeerikkattil@deloitte.com<mailto:rkecrikkatdl@deloitte.com> I
www.deloitte.coni<http://www.deloitte.com/>

Sent: Sunday, April 19, 2015 12:14 PM

Cc: Verma, Ritesh (US - Arlington)
Subject: RE: Hi
Thank you for the meeting invitation and details. I am looking forward to learning
more about the proposal, helping with meeting notes and translating diagrams.
Also, if it's not too inconvenient, I would appreciate it if you could send me notes
from prior meetings. I would like to further my understanding of the current state
of the proposal and how I should structure my notes.
Thanks!
Stacy

Sent: Sunday, April 19,2015 11:41 AM
Cc: Verma, Ritesh (US - Arlington)
Subject: RE: Hi
Will confirm by tonight.
You would need to get to 3060 Williams Drive, Fairfax, VA 22031. I'm out of
state tomorrow and will be dialing in. if you don't drive you can take the Orange
Line from our Rosslyn office to Dunn Loring Merrifield Metro Station and take a
quick Uber/Cab.
We would need your help with taking down the meeting minutes and translating
the diagrams during white-boarding into Visio.
I'm also copying Ritesh, the PPD on the proposal effort.
You can charge the time spent on this as well as the cab to CMS10457-BP-LP-
1000 CMS B&P 10316609-FPS
Tel/Direct: +1 571 882 5816 I Mobile: +1 571 317 9772 I Fax: +1 855 344 9721
rkeerikkattil@deloitte.com<mailto:rkeerikkattil@deloiite.com> I
www.deloitte.com<littp://www.deloitte.com/>

Sent: Friday, April 17, 2015 6:06 PM
Subject: RE: Hi
Hi, the best number to reach me at is 5033803915. Also, I am available. Keep me

6
posted.
Sent from my Verizon Wireless 4G LTE smartphone
Original message
From: "Keerikkattil, Ranjith (US - Arlington)"
<rkeerikkattil @DEL01TTE.com<mailto:rkeerikkattil @DELOITTE.com»
Date: 04/17/2015 6:03 PM (GMT-05:00)
To: "Sawin, Stacy (US - Arlington)"
<ssawin@deloittc.com<niailto:ssawin@deloitte.com»
Subject: Hi
Stacy,
What's the best number to reach you? Also are you free on Monday from 9-2? I
may need your help if Nick/Conor (BTA's in my account) have conflicts.
Thanks!
Tel/Direct: +1 571 882 5R16<iel !-H%20571 %20882%205816> IMobile: +1 571
317 Q772<rel:+1 %20571 %2Q317%209772>l Fax: +1 855 344
9721<tel:+l%20855%20344%209721>
rkcerikkattil@deloitte.com<mailto:rkecrikkattil@deloitte.coni> i
www.deloitte.com<http://www.deloitte.com/>

<1769-2014.pdf>
<FPS - Frame-work for Solutions Discussion_v4.pptx>
<CMS FPS2 All Hands Status Meeting 04_09_15 v3.pptx>
<FPS2 Solution Framework Meeting Minutes Outline.docx>
<Solution Framework picl.jpg>
EXHIBIT 3 TO KEERIKKATTIL DECLARATION

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EXfflBIT 4 TO BCEERIKKATTIL DECLARATION

Gmail - Ranjith,please add me to your Linkedin network
Ranjith K <rumbc1@gmail.com>
M Gmail
Ranjith, please add me to your Linkedin network
1 message
Stacy Sawin <member@linkedin.com> Sun, May 10, 2015 at 9:10 PM

Reply-To: Sksawin@aol.com
To: Ranjith Keerikkattil <rumbc1@gmall.com>
Unlffidfl3.
Stacy Sawin Hi Ranjith,
I'd like to connect with you on Linkedin.
Stacy Sawin
Federal Business Technology Analyst at Deloitte
Accept View Profile
You are receiving Invitation emails. Unsubscribe

Thisemail was intended for Ranjith Keerikkattil (Senior Consultant at Deloitte). Learn why we included
this.
Ifyou need assistance or have questions, please contact Linkedin Customer Service.
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I of I
EXfflBIT 5 TO BÊRIKKATTIL DECLARATION

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From; Keerikkattil, Ranjith (US - Arlington)

Sent: Sunday, May 31,2015 10:31 PM
Cc: Keerikkattil, Ranjith (US - Arlington)
Subject: FPS Future Guidance and Cease & Desist Letter
Importance: High
Dear Ms. Sawin,
As partof my changing priorities, Iwould not bedirectly involved with you in any actual/perceived administrative role
including but not limited to FPS. Please work with Ritesh Verma and/or Bheeshma Tumati to determine thesupport they
need from you with respectto FPS. I have already sent you a samplee-mail for reference. Please do not involve me in
requesting time off from your project with respect to FPS. Please check your service hours summary and Inform Ritesh
Verma ifyou are close to enough hours fora PE so that you are duly recognized foryour contributions. Iwould be more
than happy to share any information regarding your performance to date, to the best ofmy knowledge, information
and/or belief, within my possession orcontrol, if requested by a third-party fact finder. Please let me know if you have
any questions or concerns regarding the above by COB tomorrow. Also, please refrain from contacting meexcept for
legitimate business needs of Deloitte LLP.
Sincerely,
1919 North LynnStreet, Arlington, VA, 22209
Tel/Direct: +1 571 882 5816 | Mobile: +1 571 317 97721 Fax: +1 855 344 9721
rkeerikkattil@cleloitte.com I www.deloiHe.com
oonsiori ihe betor-;- prinijrK^
CONFIDENTIALIPr' NOTICE; This e-rnaii message, including any attachments, is for the sole use of the intended recipient(s)
and may contain confidential and privileged information orotherwise be protected by law. Any unauthorized review, use,
disciosure ordistribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and
destroy all copies of the original message.
Exhibit C
From: Garcia, Leslie Moore (US - Hermitage)
To: Caras, Sarah (US - Arlington)
Sent: 6/2/2015 2:04:00 PM
Subject: RE: TR Incident
Sarah,
Thank you for sending this over. I will reach out toKash and Stacy to let them know I will look into this.
Leslie Moore Garcia, PHR, SHRM-CP
Specialist Federal Practice. Talent Relations
Deloitte Services LP
Tel/Direct: +1 615 882 7129 | Mobile: +1 615 785 0173
lesliegarcia@deloitte.com | www.deloitte.com
From: Caras, Sarah (US - Arlington)

Sent: Tuesday, June 02,2015 1:13 PM
To: Mignon, Monique (US- Arlington)
Subject: TR Incident
Hi Monique,
Please let me knowif I should be forwarding this to Alicia or a TR inbox.
Thanks,
Sarah
Date: 6/2/15
BA Name: Sarah Caras
Source ofInformation from Reporter : phone conversation

Reporter Name ;Kash Tajammul (Stacy Sawin's counselor)
Reporter RC: 40672- Federal IM
Complainant Name: Stacy Sawin
Complainant RC: 40672- Federal IM
Subject Name: Ranjith Keerikkattil
Subject RC: 40672- Federal IM
Case Detail; Stacy was asked to work on aCMS proposal by Ranjith. He recently expressed that he brouglit her
onto the proposal team because he was interested in her. At that time, she told her she wanted to keep their
relationship professional only. Soon after, he vacationed and brouglit her back gifts from his trip. She did not accept
the gifts and reiterated that she wanted to keep their relationship professional. Since that discussion, he has since told
her that she is nolonger needed on the proposal team.
Exhibit D

To: Garcia, Leslie Moore (US - Hermitage)
Sent: 6/3/2015 1:30:13 AM
Subject: talent concernfollow-up
Attachments: FPS Future Guidance and Cease &Desist Letter; FPS; Fwd: One or More of Your GovWin IQ
Opportunities Has Been Updated; RE: FPS Business Intelligence Support; RE: introduction; RE:
StacySawin - 5/14 Towson Meeting; text between Ranjith and Vikrann onStacy's Phone,png;
Text_Screenshots.zip
Hi Leslie,
Thank you tortaking the time to speak with me about my talent concern with Ranjith Keerikkattil. The following
information was requested during ourconversation, please see the list below.
Attached isa zip file titled Text Screenshots, which contains all ofthetexts sent between me and Ranjith.
The Neel's full name isNeel Sanghvi. Ranjith also mentioned thatMaher Ashraf was a part of the conversation at
the ABRG Happy Hour on May 13th.
Theattached email Introduction is an email thread between Brian Hankin and I, regarding my future involvement
with the proposal.
The attached email titled FPS Business Intelligence Support isthe email thread between Satya Settipalli, regarding
my future involvement with the FPS proposal.
Theemails FPS and FPSFuture Guidance and Cease &Desist Letter where sent byRanjith on May 31
The following is a link to the court case pertainingto Ranjith: https://casetext.com/case/keerikkattil~v-hrabowski
Theattached email Fwd: One More of Your GovWin IQ Opportunities HasBeenUpdated wasforwarded to me
by Ranjith and regards the release of the RFP.
My last day doing official work for the proposal wasMay 11 thougli I did attend a Proposal Happy Houron
May 15 Thiswas organized by Ranjith and took place at Rasika. Bheeshma Tumati, Ranjith Keerikkattil, Brain
Hankin, Satya Settipalli, Laura Amster, and I attended this happy hour.
Attached is a screenshot from my phonetitled "text between Ranjith and Vikram on Stacy's Phone ".
) The attached email titled Stacy Sawin -5/14 Towson Meeting is partof the email thread thatoccurred regarding my
attendance at the Towson meeting. The conversation between Kyle Matisand Ranjith is not included, because I was
not cc 'ed in the conversation.
Please let me know if there is any additional information I can provide you with now or moving forward.
Best Regards,
Stacy
Stacy Saw in
BusinessTeclinotogy Analyst
Tel/Direct: +1 571 841 77841Mobile: +1 503 380 3915
Ssawin@cl6loitte.com| www.deloitte.com
Plecjsrj coiwidfei the eciviforirnenil befc>fe psirBlno.
Exhibit E
To: Turcott. Jerry (US - Arlington)
Sent: 6/4/2015 2:14:59 PM
Subject: security discussion follow-up
Attachments: FPS Future Guidance and Cease &Desist Letter; FPS; Fwd: One or More ofYour GovWin IQ
Opportunities Has Been Updated; lync message.jpg; RE: FPS Business Intelligence Support; RE:
introduction; RE: Stacy Sawin - 5/14Towson Meeting; Stacy and Ranjith Timeline.docx;
Text_Screenshots.zip; Texts from Ranjith to Vikram on Stacy's Phone.zip

Sent: Thursday, June 4. 2015 6:14:58 PM
To: Turcott, Jerry (US - Arlington)
Hi Jerry,
Thanl< you for tailing the time to meet with me. Attached are all of the documents Isent to Leslie. The most helpful
will probably be the word document "Stacyand Ranjith Timeline".
Thank You Again,Stacy
The Interactions between Stacy Sawin and Ranjith Keerikl<atti

March; Stacy and Ranjith metat an IM Sip n Share, where Stacy expressed in interest in learning more
about Information Management.
March 17*''; Ranjith and Stacy met for 30 minutes atCaffe Aficionado and discussed the IM service line,
SAS, and Deloitte
March 19*'': Following Ranjith's recommendation, Stacy attended the ABRG Proposal 101 training, where
the two discussed proposal opportunities at Deloitte
April 14"^; Ranjith and Stacy met at Caffe Aficionado to discuss her potential involvement on the CMS
FPS proposal
April 20*''; Stacy attended her first proposal meeting, FPS2 Technical Solutioning meeting (9-2PM)
April 23'**; Ranjith requested thatStacy meet with him that night to do work for the proposal. Stacy had
already committed to attending a BTAAC event at BuffaloBilliards, ending at 8;30PM. Ranjith offered to
meet Stacy in DC near Buffalo Billiardsand suggested that they find a place nearby to work, which Stacy
agreed to. After arriving at Buffalo Billiards, Ranjith suggested that they work at a coffee shop near U
Street, which would require them to drive. Ranjith then proceeded to drive Stacy around DC for over an
hour, before taking Stacy back to the Buffalo Billiards area. They then worked at a Panera until it closed
around 10PM. With work still unfinished, Stacy suggested that they work in the cafe in her apartment
complex, which is open 24-hours a day. Ranjith then drove them to Stacy's apartment building where
they worked in the cafe for a few more hours. During this time, Ranjith requested a tour of the
apartment complex, which Stacy gave despite initial reservations.
May 1®' or 2nd: Ranjith had requestedthat Stacy meet with him to finalize the meeting notesthat she
had taken at prior FPS meetings. He then told her that he would meet her at her apartment complex at
10AM on Sunday, May 3'^
May S'*": Ranjith and Stacy worked onfinalizing the meeting minutes she had taken at a prior FPS
meeting. Though this regularly took Stacy 1 hours to do on her own, it took Stacy and Ranjith over 4
hours to complete this task, as a result of what seemed like attempts on Ranjith's part to stall the
process. During this time, Ranjith excessively quizzed Stacy on her understanding of the different
technical components of the proposal, asked questions pertaining to her career ambitions, and
questions about her personal life. He also instigated having both breakfast and at sit-down lunch with
Stacy during this meeting and appeared to expense both meals.
May 5*''; Ranjith andStacy attendedan FPS meeting in Towson, which wentfrom 10;30AM to ~5PM.
Ranjith provided transportation for Stacy, who does not own a car. While traveling to the meeting,
Ranjith and Stacy had discussed getting dinner after the meeting. When the meeting ended and Stacy
invited coworker Bheeshma to join her and Ranjith for dinner, Ranjith became visibly upset. He then
insisted that Stacy get a margarita with him after dinner. Stacy then expressed multiple times that she
was very tired and was really looking forward to going home as soon as possible. However, she did
formally reject Ranjith's plan, out of fear that it would negatively affect involvement on the proposal
moving forward. Stacy and Ranjith proceeded to get an appetizer and margaritas. When Ranjith asked if
Stacy wanted to split the bill, Stacy gave him her personal credit card. Ranjith then said that he wouldn't
let her paywith a personal credit card and proceeded to payfor the meal, with what Stacyassumed was
his Deloitte corporate card.
May 6*'': After a long working session for theFPS Proposal, Stacy, Ranjith, Bheeshma, and Laura got
dinner in the Tyson Mall. Once the dinner concluded, Stacy said that she would liketo do some shopping
at Barnes and Nobles. As Laura and Bheeshma departed, Ranjith said that he was interested in checking
out books at Barnes and Nobles, instead of going home as he had originally planned. Uncomfortable by
this change in Ranjith's plan, Stacy said that she would instead be shopping at women's clothing stores.
Ranjith then proceeded to follow Stacy as she shopped for clothing for approximately 3 hours, excluding
the time she was able to evade him by changing stores. Ranjith then insisted that he drive Stacy back to
her apartment. Worried about offending Ranjith and thus hurting her role on the proposal, Stacy
accepted this car ride.
During this car ride, Ranjith commented on Stacy's current physical appearance in comparison to her
pictures on Facebook. He went into detail about the swimsuit she wears, her appearance in her profile
picture, and her weight. Stacy expressed how these observations upset her and explained how Ranjith
had been rude and inappropriate. After dropping Stacy off at her apartment, Ranjith texted Stacy saying
"I'm sorry © I didn't mean to hurt you. That was poor choice of words to convey what I wanted to. And
you're cute slim and sexy. Big time. Sorry again! Good night".
May 10*'' (Sunday); Ranjith requested that Stacy meet with him to take a phone call. After declining to
meet in the reception area of her apartment, Stacy met with Ranjith at the Rosslyn office. It shortly
became evident that her attendance was not needed for the 30 minute conversation that occurred
between Ranjith and Bheeshma. Stacy was then prompted to work with Ranjith for 4 hours, though she
was able to offer limited support. At this time, Stacy asked whether or not her attendance was needed
at the FPS proposal meeting occurring May 11^^. Ranjith highly recommended thatStacy attend. Stacy
then proceeded to send an email to Bheeshma requesting that he contact Kyle Matis, a senior
consultant that Stacy reports to on her main project. Kyle had previously requested that he receive
email verification from proposal leaders whenever Stacy needed to work outside of Rosslyn.
May 11*'': During the drive home from the FPS meeting inTowson, Ranjith expressed explicit interestin
having a relationship Stacy. At this time he stated that Stacy was brought on to the proposal at his
request, which he made in hopes to get closer to Stacy. He said there was no real need for her efforts
and that much of the work she had been doing he would have done himself under normal
circumstances. He also said that he had been purposefully scheduling time with her to do work on
weekends, in order to spend time with her outside of a work setting. This conversation occurred at the
beginning of a ~2 hour car ride, which made Stacy feel like she was unable to address the situation.
May 12*^*: Stacy requested that Ranjith email Kyle, since Bheeshma had not responded to her email
request. Ranjith then proceeded to email Kyle on Stacy's behalf, verifying that he had requested that she
attend the meeting in Towson. Later that day, Kyle sent an email to Ranjith requesting that they discuss
Stacy's availability and what her role in the proposal would be moving forward. Ranjith notified Stacy of
this email and worked with her to craft a response.
May 13*'': At an ABRG Happy Hour, Ranjith made unwanted advances towards Stacy. These included
touching Stacy's shoulder, back, and giving her a hug. Ranjith's intentions are captured in a Lync
conversation at10;58PM that night, where he told Stacy "Nee! came over and told me he saw me hitting
on you and knows that Vikram is also hitting on you. That's why Iasked you before". In a prior
conversation, Ranjith had asked about her relationship with Vikram. Stacy had disclosed that she was
seeing Vikram, though she and Vikram were not inan official relationship.
Stacy proceeded to have a conversation with Ranjith, during which sheexplained how Ranjith had put
her in a bad situation, which felt similar toa quid pro quo situation. She said that as a young female in
the workplace she isvulnerable and that he needsto be cognizant ofthe factthat he is ina role of
authority over her in regards to the proposal.
May 14*^ Ranjith sent Stacy a picture of adrink with the caption "My fourth drink tonight/ CMS RADV
Happy Hour". This prompted the following text conversation:
Stacy: Ranjith I really need for you to back off

Ranjith: what happened?Just texting right? Did something happen today?
Stacy: I'm just uncomfortable with our situation
Ranjith: Does that mean Ishouldn't text you?
Stacy: Not if it's not work related
Ranjith: I'm sorry Ididn't mean to hurt you in any way
IVlay 15**': Ranjith sent Stacy thefollowing via text: "I was so hurt yesterday night that Ihad decided not
to talk to you. That's why Ididn't text you and ask Laura to. I'm not going to hang out with you until FPS
is over since you're worried about quid pro quo issues. Iwas even thinking of canceling the happy hour
today"
May 19: Ranjith reached out to Stacy to ask ifshe would be attending a FPS proposal meeting on May
21^^ Before Stacy could decline the meeting invite, Bheeshma included Stacy's name on a list ofpeople
attending, Ranjith then offered to lie on Stacy's behalf, as shown in the followingtext conversation:
Ranjith: "Don't think you have to tell Bheeshma. I'll tell him you got an urgent meeting that you couldn't
reschedule or something like that"
Stacy: "No need to make something up. I wasn't planning on going because you said it would be too
technical. Also, I haven't receivedanythingfrom Bheeshma or Mitch. From now on, I need to give my
managers more than two days' notice, especially before Memorial Day weekend."
Laterthat afternoon, Ranjith set up a Level setting meeting with Stacy at 6PM. During this meeting,
Stacy expressed that she felt that Ranjith took advantage of her willingness to work hard and desire to
help the proposal. As an individual with onlya few months or working experience,Stacy trusted that
Ranjith's requests were necessary and did not openly question what seemed like an excessive amount of
1 on 1 meetings, coffees, and meals. Stacy also said that Ranjith had failed to separate his professional
needs and personal wants, which was unprofessional and unacceptable.
Ranjith apologized for not making a clear distinction between personal and professional meetings. He
said that he had realized that he and Stacy had a lot of coffees and mealstogether and said that he had
chosen to payfor these expenses himselfand at times had been using his personal credit card, which
made Stacy more uncomfortable.
Ranjith requested that Stacy delete the text messages in her phone, so that they wouldn't get into
trouble with Deloitte. Ranjith then proceeded todelete their text conversation in his phone, though
Stacy did not delete the messages In her phone. The meeting ended with Ranjith agreeing to only
contactStacy for matters regarding FPS, to not make direct decisions on her behalf, and to not make
requests without full disclosure of the proposal's needs.
-May 26"^: Ranjith said that be bought Stacy abottle of alcohol while in Brazil for Memorial Day
Weekend. Unsure about what to do, Stacy began ignoring Ranjith's Lync messages at this time. Later
that night, Stacy blocked Ranjith on Facebook.
May 30: The followingtext conversation took place;
Ranjith (3:02PM): Hey! How's your weekend going? Doing anything fun?
Ranjith (3:02PM): Are youfree tomorrow night?
Ranjith (3:03PM): Nothing related to FPS. To make sure Iclarify
Stacy (3:43PM): Ireally appreciate the clarification given our recent history. Iwould like to keep our
relationship strictly professional though. Ihope I'm notbeing too blunt. I'm happy to talk about this in
person in more detail if you'd like.
Ranjith (3:52PM): Sure. Let's grab a drink tomorrow nightlike 8:30?I'm witha friend from LA. Will be
hanging out with him tilltomorrow evening."
Stacy (9:34PM): Idon't think suggesting thatwe grab drinks tomorrow is an appropriate response to
what Ijust said"
Ranjith (10:08PM): Okay. Sorry. Iwas responding to talk aboutin person
Stacy (10:15PM): Idon'tthink you're getting itthough. That's notappropriate
Ranjith (10:21PM): No Iget it. No need of meeting.
May31: At7:54PM, Ranjith sent an emailto Stacy requestingthat she contact Ritesh to determine ifshe
would be needed for future proposal efforts. Later that night, Stacy logged onto her work computer and
Ranjith sent her a Lync message, asking if she had seen his email. Stacy did not respond and logged off
ofher work computer shortly after. At 10:31, Ranjith thensentStacy thefollowing email;

Sent: Sunday, May 31, 2015 10:31 PM
To; Sawin, Stacy (US - Arlington)
Cc: Keerikkattil, Ranjith (US - Arlington)
Subject: FPS Future Guidance and Cease & Desist Letter
Importance: High
Dear Ms. Sawin,
As part ofmy changing priorities, Iwould not be directly involved with you in any actual/perceived
administrative role including but not limited to FPS. Please work with Ritesh Verma and/or Bheeshma
Tumati to determine thesupport they need from you with respect to FPS. Ihave already sent you a
sample e-mail for reference. Please do not involve me in requesting time off from your project with
respect to FPS. Please check your service hours summary andinform Ritesh Verma ifyou are close to
enough hours fora PE so that you are duly recognized foryour contributions. Iwould be more than
happy toshare any information regarding your performance todate, tothe best of my knowledge,
information and/or belief, within my possession orcontrol, if requested by a third-party fact finder.
Please let me know if you have any questions orconcerns regarding the above by COB tomorrow. Also,
pleaserefrain from contacting me exceptfor legitimate business needsof Deloitte LLP.
Sincerely,
This email was thenfollowed by two texts from Ranjith to Stacy, asfollows:
Ranjith (10:34PM): Please check your email and refrain from contacting me
Ranjith (10:35PM): Thank you and bye!
June 1:Alarmed bethe wording in Ranjith's communications the day prior, Stacy called herDeloitte
counselor Kash to describe thesituation between her and Ranjith. Kash and Stacy agreeing that the
situation was serious and to involve Talent and the proposal PPD Ritesh. For moral support, Stacy
contacted her dad. Stacy's dad discovered that there were previous allegations ofRanjith stalking a
UMD student, who he had previously worked with. He subsequently accused the female of harassment.
These previous accusation In conjunction with Ranjith's "Cease and Desist Letter" led Stacy to believe
she may need legal coverage moving forward.
Later thatafternoon, Ranjith sentStacy a Lync message saying thatheassumed thatStacy did not have
anyquestions regarding his email. He then said good luck andgoodbye. Uncomfortable with the
situation and unsure about the legal implications ofa response, Stacy chose to ignore Ranjith's message.
Exhibit F
Raniith KeerikkattiKs Allegations as noted in the email entitled
"Talent Meeting FoIIow-Up" on June 12.2015
Talent Meetim
1. Stacy Sawin has maintained and continues to maintain non-professional relationships with
Deloitte employees, including but not limited to, with Vikram Rajan who had invited her for dates
in the past.
a. What Information do we currently know? When did we receive it, from whom and in
what form did we receive it.
i. So both Stacy and Vikram have verbally told Leslie Garcia that they are seeing
each other socially outside of work.
ii. Conversation with Stacy took place via the phone on 6.2.2015 and the
conversation with Vikram took place via the phone on 6.23.2015.
iii. Leslie Garcia confirmed that Stacy and Vikram do not work on the same
engagement and/or firm initiatives (e.g. proposal/FPI/RFP) nor do they directly
report to each other in any capacity. Both Stacy and Vikram are both Business
Technology Analysts (BTA) within Federal Deloitte Consulting LLP. Stacy is
aligned to the Federal Technology Information Management service line and
Vikram is aligned to the Federal Technology System Integration service line.
iv. Stacy admitted to Leslie on 6.22.2015 that she has other friendships with
Deloitte colleagues that include but are not limited to, Thor Schumacher,
Federal Technology System Integration BTA
b. What questions do we still need to ask and to whom we need to ask them?
i. N/A
c. What Deloitte policies apply? APR 216 Nepotism
i. "The U.S. Firms prohibit situations where a Related Person either directly or
indirectly: Manages, supervises, reviews or evaluates work performed by another
Related Person, or Is responsible for, has Influence on, or has control of related
confidential Information pertaining to the recruitment, hiring, admission, retention,
evaluation, assignment, management, supervision, compensation, payment,
training, transfer, promotion, demotion, discipline, termination or any other action
that may result in the reward or disadvantage of another Related Person.
ii. For other situations involving Related Persons not expressly prohibited under this
policy, the applicable U.S. Flrm(s) may review, evaluate and determine the
appropriateness of all such situations and take any steps, in their discretion, to
address any situations that (a) have the potential for creating an adverse Impact
on the relevant operations or the workplace, (b) create problems of safety, security
or morale, or (c) create either an actual conflict of interest or the appearance of a
conflict of Interest."
2. Stacy Sawin frequently invites Deloitte employees to her apartment.

i. Based onthe image and preservation ofStacy's Deloitte issued PDA, we have
been able to confirm via textmessages thatfellow Deloitte colleagues have in
fact been to Stacy's home.
ii. Stacy has confirmed with Leslie via a phoneconversation on 6.22,2015 that Thor
Schumacher had been to her home to do laundry.
b. Whatquestionsdo we still need to askand to whom we need to askthem?
i. N/A
c. What Deloitte policies apply? N/A
3. Stacy Sawin uses her Deloitte Issued corporate mobile phone/Lync to exchange text
messages/IM's that not only are unrelated to legitimate business needs but also are sexually
explicit or inappropriate.
a. What Information do we currently know? When did we receive it,from whom and in
i. Based on the information received from the image and preservation ofStacy's
Deloitte issued PDA on 6.18,2015 from Aleta Jacobson, we have been unable to
confirm that any explicit text messages or pictures where sent or received to
Stacy.
i. We need to ask AletaJacobson ifshe is able to recover text messages to and
from Vikram Rajan on Stacy's PDA prior to IVlay 14, 2015.
ii. Question to OGC: Do we need to check her Deloitteemail and Lync to
determine if she has sent or received any explicit email messages or Lync
messages?
iii. Can Aleta check apps (e.g. Snapchat, OkCupid) on Stacy's Deloitte issued PDA for
explicit material?
c. What Deloitte policies apply?
i. APR 208 Electronic Communications:
1. .001 "The Systems and Electronic Communications are considered to
be the property of the U.S. Firms, unless otherwise provided by law.
While incidental and occasional personal use of the Systems is
permitted In accordance with this policy, a User waives any claims to
privacy as It relates to the use of the Systems and to the Electronic
Communications. If a personal Electronic Communication Is Intended
to be truly "confidential" or "privileged", alternative means of
transmission should be used."
2. .007 Other Prohibited Activities: "Installing, using or downloading any
unauthorized software, applications or technology services."
4. Stacy Sawin uses her Deloitte issuedcorporate mobile phone for purposes not only are
irrelevant to Deloitte's legitimate business needs but also are inappropriate such as dating
and/or pornography.
a. What Information do we currently know?When did we receive it, from whom and in
i. Based on the information receivedfrom the image and preservation of Stacy's
Deloitte issued PDA on 6.18.2015 from Aleta Jacobson, we have been unable to
confirm that any explicittext messages or pictures where sent or received to
Stacy.
i. We need to ask Aleta Jacobson ifshe is able to recovertext messages to and

from VIkram Rajan on Stacy's PDA prior to May 14, 205.
ii. Question to OGC: Dowe need to check her Deloitte email and Lync to
determine ifshe has sent or receivedany explicit email messages or Lync
messages?
iii. Can Aleta check apps (e.g. Snapchat, OkCupid) on Stacy's Deloitte issued PDA for
explicit material?
i. APR 208 Electronic Communications:
permitted In accordance with this policy, a User waives any claims to
Communications. If a personal Electronic Communication Is intended
A. What is Stacy's relationship with other Deloitte co-workers and specifically Vikram Rajan? Does
she maintain relationships with other Deloitte employees beyond "professional relationships"?
i. So both Stacy and Vikram have verbally told Leslie Garcia that they are seeing
ii. Conversation with Stacy took place via the phone on 6.2.2015 and the
iii. Leslie Garcia confirmed that Stacy and Vikram do not work on the same
aligned to the Federal Technology Information Management service line and
Vikram is aligned to the Federal Technology System Integration service line.
iv. Stacy admitted to Leslie on 6.22.2015 that she has other friendships with
Deloitte colleagues that include but are not limited to, Thor Schumacher,
Federal Technology System Integration BTA
i. N/A
c. What Deloitte policies apply? APR 216 Nepotism
i. "The U.S. Firms prohibit situations where a Related Person either directly or
Related Person, or Is responsible for, has influence on, or has control of related
confidential information pertaining to the recruitment, hiring, admission, retention,
training, transfer, promotion, dennotion, discipline, termination or any other action

policy, the applicable U.S. Firm(s) may review, evaluate and determine the
address any situations that (a) have the potential for creating an adverse Impact
conflict of interest."
B. Has Stacy brought Deloitte employees to herapartment before? Who all, how many times and for
what reason? I'm pretty sure the answer is yes forVikram Rajan and Thor Schumacher. So it's more
of a confirmation as well as identifying who else and how many times.
ii. Based on the image and preservation of Stacy's Deloitte issued PDA, we have
been able to confirm via text messages that fellow Deloitte colleagues have in
fact been to Stacy's home. Stacy has confirmed with Leslie via a phone
conversation on 5.22.2015 that Thor Schumacher had been to her home to do
laundry.
iii. N/A
c. What Deloitte policies apply? N/A
C. Has Stacy used her Deloitte issued corporate mobile phone/Lync to exchange text messages/IM's
that not only are unrelated to legitimate business needs but also are sexually explicit or
inappropriate? The text messages I've seen on her Deloitte mobile phone like "I want to eat you
Stacy" from Vikram Rajan does not appear like a Deloitte business related text message to me.
a. What Information do we currently know? When did we receive it, from whom and in what
form did we receive it.
i. Based on the information received from the image and preservation of
Stacy's Deloitte issued PDAon 6.18.2015 from Aleta Jacobson, we have
been unable to confirm that any explicit text messages or pictures where
sent or received to Stacy.
ii. Based on the information received from the image and preservation of
Stacy's Deloitte issued PDA on 6.18.2015 from Aleta Jacobson, we were
unable to verify that a text from Virkam stating "I want to eat you Stacy"
was sent to Stacy's Deloitte PDA via text.
iii. Vikram informed Leslie via a phone conversation on 6.23.2015 that he was
aware of a text message mentioned in the documentation that was taken
out of context. Vikram told Leslie his and Stacy's conversation was taken
out of context and was purely a PG conversation. Vikram said the text was;
"Stacy I want to eat you." Vikram said the context of the text was he was
very hungry and sent Stacy the text, saying "Stacy I want to eat you."
iv. Vikram indicated to Leslie that hisfriends ali give him a hard time because
he sendssilly random textsto everyone not just Stacy. He said it was not a
meaningful text. It was a dumb text.
V. Vikram said he does takeefforts to make surethat he does notsend any
inappropriate messages to Stacy because he knows she is using a combined
personal and work phone.
vt. Leslie asked if he had record of the text. Vikram said he does not have
record of the text. He thinks it is something to do with his phone settings.
Vikram alsosaid he does not believe that Stacy would have anything on her
phone that would be anything like that. Vikram said it would be very
peculiar, if she did.
iv. We need to ask Aleta Jacobson ifshe is able to recover text messages to and
from Vikram Rajan on Stacy's PDA prior to May14, 205.
V. Question to OGC: Dowe need to check her Deloitte email and Lync to
messages?
vi. Can Aleta check apps (e.g. Snapchat, OkCupid) on Stacy's Deloitte Issued PDA for
explicit material?
vii. APR 208 Electronic Communications:
While Incidental and occasional personal use of the Systems Is
permitted In accordance with this policy, a (yser waives any claims to
Communications. If a personal Electronic Communication is Intended
D. IsStacy'sstatement madeto me that Vikram Rajan had Invited her for dates true? If so, do they
still interact and what is the nature of that relationship?
a. What Information do we currently know? When did we receive it, from whom and
in what form did we receive it.
iii. So both Stacy and Vikram haveverbally told Leslie Garcia that they are seeing
iv. Conversation with Stacy took place via the phone on 6.2.2015 and the
V. Leslie Garcia confirmed that Stacy and Vikram do not work on the same
aligned to the Federal Technology Information Managementserviceline and

Vikram Is aligned to the Federal Technology System Integration service line,
vi. N/A
d. What Deloitte policiesapply? APR 216 Nepotism
I. "The U.S. Firms prohibit situations where a Related Person either directly or
Related Person, or Is responsible for, has influence on, or has control of related
confidential information pertaining to the recruitment, hiring, admission, retention,
training, transfer, promotion, demotion, discipline, termination or any other action
policy, the applicable U.S. Firm(s) may review, evaluate and determine the
address any situations that (a) have the potential for creating an adverse impact
conflict of interest."
E. Does Stacy use her Deloitte corporate mobile phone for purposes that not only are Irrelevant to
Deloitte's legitimate business needs but also inappropriate such as dating apps (for example
OkCupid)?
d. What Information do we currently know? When did we receive it, from whom and in what
form did we receive it.
viii. Based on the information received from the image and preservation of Stacy's
Stacy.
e. What questions do we still need to ask and to whom we need to ask them?
ix. We need to ask Aleta Jacobson if she is able to recover text messages to and
from Vikram Rajan on Stacy's PDA prior to May 14, 205.
x. Question to OGC: Do we need to check her Deloitte email and Lyncto
messages?
xi. Can Aleta check apps (e.g. Snapchat, OkCupid) on Stacy's Deloitte issued PDA for
explicit material?
f. What Deloitte policies apply?
xii. APR 208 Electronic Communications:
While Incidental and occasional personal use of the Systems Is
permitted in accordance with this policy, a User waives any claims to
privacy as it relates to the use of the Systems and to the Electronic
Communications. If a personal Electronic Communication Is Intended

Raniith Keerikkattil's email entitled
"Stacy Sawin; Litigation Hold Notice for Documents and Electronic Data" on June 22.2015
Stacy Sawtn
1. Any allegations ofviolations ofDeloitte's policies made by Stacy Sawin and/or Ranjith
Keerikkattil in written or oral form.
a. Code of Ethics and Professional Code of Conduct
2. Any and all documents relating toany investigation conducted by Deloitte LLP in relation toany
allegations made byStacy Sawin and/or Ranjith Keerikkattil.
3. Any and all communications between Stacy Sawin and Ranjith Keerikkattil including
communications where both parties have been copied.
4. Any and all communications between Stacy Sawin and Vikram Rajan, a Business Technology
Analyst at Deloitte Consulting, including but not limited to any sexually explicit text messages
and IM's exchanged between them.
5. Any and all documents relating toStacy Sawin's dismissal from the U.S. Bureau of Engraving and
Printing engagement while being employed with Deloitte LLP, Including but not limited todrug
test results and/oradmissions made ofcontrolled substance usage.
a. On Friday, June 12,2015 Alicia connect with Buddy White (FedSec Sr. Manager)
regarding Stacy's clearance:
"In Dorothy's absence Ireached outto Buddy White and he provided me thefollowing
update on Stacy's clearance.
"Stacy was processed through 0PM and was not successful. She does not have any
clearance noted atthis time. We believe that Stacy is currently pending a suitability of
access with Treasury."
Thanks!
Alicia"
Stac/s Clearan.
A. Any allegations ofviolations ofDeloitte's policies orconcerns made by you against me.
a. Code of Ethics and Professional Code of Conduct
B. Any and all communications between you and me including communications where weboth
have been copied.
CONFIDENTIAL
DELOITTE008849
C. Any and all communications between you and Vikram Rajan, a Business Technology Analyst at
Deloitte Consulting, including but not limited to any sexually explicit text messages and IM's
exchanged such as "I want to eat youStacy" on May 5, 2015.
I. Based onthe information received from the image and preservation ofStacy's
Stacy.
ii. Based on the information received from the image and preservation ofStacy's
Deloitte issued PDA on 6.18.2015 from Aleta Jacobson^ we were unableto verify
that a text from Virkam stating "I want to eat you Stacy" was sent to Stacy's
Deloitte PDA via text
iii. Vikram informed Leslie via a phone conversation on 6.23.2015 Vikram
iv. that the statement "I want to eat you Stacy" was a random text message due to
the fact he was hungry.
xiii. We need to askAleta Jacobson ifshe is able to recovertext messagesto and
from Vikram Rajan on Stacy's PDA prior to May14, 205.
xiv. Question to OGC: Do we need to checkher Deloitte email and Lync to
determine ifshe hassent or received any explicit email messages or Lync
messages?
XV. Can Aleta check apps (e.g. Snapchat, OkCupid) on Stacy's Deloitte issued PDA for
explicit material?
xvi. APR 208 Electronic Communications:
permitted in accordance with this policy, a User waives any claims to
privacy as it relates to the use of the Systems and to the Electronic
Communications. If a personal Electronic Communication is Intended
2. .007 Other Prohibited Activities: "Installing, usingor downloading any
B. Any and all documents relating to yourdismissal from the U.S. Bureau of Engraving and Printing
engagement while being employed with Deloitte.
a. On Friday, June 12,2015 Alicia connect with Buddy White (FedSec Sr. Manager)
regarding Stacy's clearance:
"In Dorothy's absence Ireached out to Buddy White and he provided methe following
update on Stacy's clearance.
"Stacy was processed through 0PM andwas notsuccessful. She does not have any
clearance notedat thistime. We believe that Stacy iscurrently pending a suitability of
access with Treasury."
Thanks!
Alicia"
Stacy's Oearan.
C. Information contained within "Snapchat", "OkCupid" and any other non—employment related
apps that are installed in your Deloitte corporate phone.
D. Any and all communications between you and Thor Schumacher, Business Technology Analyst,
Deloitte Consulting (to whom you had askedto take his clothes awayfrom yourapartment on
May 28, 2015 at the Deloitte Arlington Office's 15th floor lounge).
E. Any and all communications between you and other male Deloitte employees who have visited
your apartment or whose residence you've visited.
F. Your Deloitte timesheets from February 27, 2015 onwards.
G. Any and all documents relatingto your illegal drug use historyincluding but not limited to
declarations madeto U.S. Bureau of Engraving and Printing, Deloitte, Lehigh University and
Lakeridge HighSchool, LakeOswego, OR.
Exhibit G
From: Jacobson, Aleta (US - Hermitage)
To: Carberry, Alicia (US - Arlington)
Lipskar, Leah Bensen (US - New York); Garcia, Leslie Moore (US - Hemiitage)
Sent: 6/26/2015 4:19:29 PM
Subject: RE: Mobile Device Collection (Sawin, Stacy)
Attachments: Add PST in Outlook 2013 or 2010 with Plctures.docx; ssawin_Contacts.csv;
ssawln_mms_hlstory.csv: ssawin_sms_history.xlsx
Hi Ahcia,
The Snapcliat app is installed on her phone, OkCupid is not. I looked to see ifI could dig any data out of the
snapchat app, but it's all garble and is not anything that makes sense outside ofthe app.
In investigated further into why texts from Vikram don't show up earlier than 5/12/15. They actually do, but they 're
all group texts. Ifyou look in the SMS spreadsheet (not the MMS spreadsheet -where gioup texts would normally
be) and do a search for "Vikram " prior to 5/12, he's on a lot oftexts, but with a different number. I had to look into
what this was. Stacy had an app on her phone called GroupMe. It'san app designed for group texts but sends them
as SMS messages. On the spreadsheet, ifyou search for one of the phone numbers in the GroupMe texts, they all
correspond to numbers in her contacts spreadsheet. Each group created in GroupME is assigned its own phone
number. That said, you can see the rest of the texts by doing asearch on Vikram's name. It is not possible to know-
all the members in each group.
It appears that they texted through GroupMe until May 12 ^^ând then the two texted directly to each other's phone
numbers. Other possibilities are that Stacy deleted prior texts from Vikram and the were written over (which makes
them unrecoverable). Or, they could have texted througli another app -there are many that do not use SMS or MMS
and the phone does not log the texts. I did not see any apps for this installed on her phone, but it could have been
removed.
The only Lync conversation she saved v/as dated yesterday. (As mentioned in my other email, Lync conversations
aren't automatically saved -the user must manually save tliem and they go into a"conversation history "folder in
Outlook.) I saved it in a PDF and is in the shared folder:
WWuspscforensics 1WCarberi-y SHARE
Also mthe shared folder, are her emails. 579 messages were found containing words from our standard "nauglity "
hst In the email folder on the share, there is alog file. Ifyou scroll to the bottom ofthat file, you '11 see the hits for
each word. Ifyou need to narrow your search and eliminate any ofthose words (some can be vague), let me know.
You '11 need to mount the PST file in Outlook to view her emails. I've attached procedures for mounting aPST in
Outlook, should you need it.
CONFIDENTIAL DEL01TTE005563
I ve shared the folder with those copied on this email.Please let me know if anyone has issues accessing the share
and if there are any other questions I can answer. I'm happy to help.
Thank you.
Aleta Jacobson
AssociateeDiscovery Litigation Analyst
rrs eDiscovery and Investigation COE | Information Security, Risk SCompliance (IRC)
Office: 615-882-6512: Cell: 615-603-0621
aleiacobson@deloitte.com Ivww.deloitte.com
From: Carberr>', Alicia (US - Arlington)

Sent; Friday, June 26, 2015 10:48 AM
To: Jacobson, Aleta (US - Hermitage)
Cc: Lipskar, Leah Bensen (US - New York); Garcia, Leslie Moore (US - Hermitage)
Subject: RE: Mobile Device Collection (Sawin, Stacey)
It just dawned on me that Stacy didn't start with Deloitte till Febniary 8, 2015 so we can use that as the starting
point. ®
Thanks,
Alicia
Alicia Carberry
Senior Manager, Talent Relations
Tel/Direct: +1 571 8828942| Fax: +1 202379 25431 Mobile: +1 4109265720
acarberrv@deloitte.com Ivww.deloitte.com
Exhibit H

Sent: 7/2/2015 8:11:50 AM
Subject: Questions about FPS - Ritesh Verma - Ranjitli/Stacy
Link to meeting notes: ^Questions about FPS - Ritesh Verma - Raniith/Stacv
Questions about FPS - Ritesh Verma - Ranjith/Stacy

Wednesday, June 3. 2015
2:31 PM
Meeting Date: 6/3/2015 2:30 PM

Location: Lync Meeting (connection details below)
Link to Outlook Item: dick here
Invitation Message
Participants
lH Garcia. Leslie Moore (US - Hermitage) (Meeting Organizer)
lH Verma. Ritesh (US - Arlington)
Notes
Who is the proposal team? He was a involved - pre-posal submitting to

(re-competed)
Dan Krevis 8 &0 and Brien Lorenze (FAS)
Ritesh is leading technology
Bheeshma
Brian Hankin
Ranjith on a project he leads CMS back

Others in
Daren
Srivasal
Ranjith pulled in 6 - 8 weeks ago
Smaller team because it is Technical piece and in pre propasai
Stacy's role help with meeting minutes and to keep them coordinate action
items
o Ranjith pulled her in. Ritesha was mentioning pulling in junior staff
Ranjith no someone so he reach out and got her involved
o Ranjith not responsible for anyone else
o He said he knew of someone who was looking for an opportunity to get
engaged
o There is an email trail of this
What are Ranjith's responsibilities on the proposal? He joined the firm about 3
months ago and has worked at CMS - he brings knowledge of the current
environment and knowledge of the tool
Is he leading any of the proposal work streams? Significant contributor regarding

- main contributor Bheeshma. Ranjith takes his directions from Bheeshma
Who reports to him? From tech team Bheeshma, Ranjith, and Stacy - she most
like was asked from. Believe that Bheeshma
She was involved Mid April. Probably 10 hours a week about 60 hours total.
Would they have had to work on weekends or late evening. There was one
weekend call. Maybe one or two evening. No need for any weekend
collaboration work.
Is Stacy still currently working on the pre=proposal - yes she has been it is
coming out later in the month. As far as he is concerned she is on the team.
Has Ranjith mentioned her involvement going forward.
No they have not had any involvement.
Is Ranjith Key to the pre-proposal - Bheeshma

He knows of one happy hour but Stacy,
GDIP is the prime - one in Fairfax and in Towson,
Typically everyone drives to meeting and they would help drive.
Yesterday, 12:30 PM ET conference call he had a call with Kash and Sarah
Caras. Said Stacy is his counselee she is relatively new to the firm. Rajesh had
expressed personal interest, told him he she wanted it to be a professional
relationship, he had come back with letter to tell her to stop contacting him
He mentioned to her that her services were no longer needed on FPS.
Her role has changed since she started on the proposal she has completed
some flows her role continues to evolve.
Ranjith - works on CMS - RADVLAC - Sally D'iamato - he does not lead any
work stream - Ahshok Subramiman.
CreaTed with Microsoft OneNote 2013.

Sent: 7/7/2015 7:49:39 AM
Subject: Privileged and Confidential - Prepared at the request of OGC - Talent Discussion
Link to meeting notes: >Priviieqed and Confidential- Prepared at the request of OGC - Talent Discussion
Privileged and Confidential - Prepared at the request of OGC

Talent Discussion
Monday, June 15. 2015
8:58 AM
Meeting Date: 6/15/2015 10:00 AM
Link to Outlook item: click here
invitation Message
Participants
lI Garcia. Leslie Moore (US - Hemnitage) (Meeting Organizer)
lD Tumati. Bheeshma (US - Arlington) (Accepted in Outlook)
lD Carberrv. Alicia (US - Arlington) (Accepted in Outlook)
Notes
As a matter of Introduction: Leslie Garcia, I am part of the Federal Practice Talent Relations team. I work with
Alicia Carberry my Sr. Manager who is on the phone with us today.
House Keeping Items:
Wanted to let you know the conversation we are having today Is as confidential as possible
What you tell me is confidential and would only be discussed on a need to know basis outside this call with
possible my leadership and possibly the Office of General Council.
I ask that you do the same because I am conducting an investigation and do not want any potential future
conversations I might have to be jeopardized and not discuss the details of our conversation withothers including
your peers, any individuals we might discuss or your leadership
Also Deloitte has a zero tolerance policy for retaliation. Deloitte is committed to maintaining a working
environment that promotes ongoing and open communication among their personnel. Individuals must not be
subjected to harassment. Intimidation, threats, discrimination, or any form of reprisal, because they have filed a
complaint or assisted or participated in an investigation. We take all reports of retaliation or possible retaliation
very seriously.
i asked Bheeshma: Have you worked on a CMS proposal? Yes
I asked Bheeshma: Which one? FPS and before that UCM worked with CMS leadership - FPs Frua
Solutions Architecture Leader
I asked Bheeshma: Who have you worked withon this FPS proposal?
Dan Crevis - Project
Brian Lorenze - Leading FPS Proposal
Ritesh Verma - CMA Based Leaders
Brad Eskins LCSP
CMS Leaderships asked them to do FSP- huge proposal had done pre RFP proposal for last 8 to 9 months
Considered a strategic
He has worked with multiple people - worked withthe Prime - worked with
Ranjith Keerikkattil - prior experience - asked to work with him by Ritesh
Stacy Sawin - BTA
Laura Amster -
Have notworked with Laura and Stacy ina long timethey worked with them about a week- should have
been in the March or April - especially during the Story boarding - needed to some
He asked - Riteshgave him Ranjith and Ranjith brought Stacy and Laura they are federal IM resources
They only worked for a week
Ranjithis someone that he worked withfor some time
Iasked Bheeshma: Were youinvolved in the decision to bring Stacyon the proposal? Bheeshma reached
out to a BTA at census - she was not available so he asked Ranjith if he knew of anyone and he brought in.
Ranjith had met them at an IM Meeting prior.
They only worked for a few days.
Ranjith worked with them. Stacy did a great job on doing the meeting min. and story board
She attended two meeting in Fairfax and two others in Towson.
The meeting had a number of partners and others Sr Manager - Brian Hankin pursuit, Susan seacrest Sr
Manager with GDIT. Darren Srivisal SM
I asked Bheeshma: Do to know who assigned Stacy her work? Stacy was pull in by Ranjith - asked Riteshto
find BTAs. Ritesh reached out to Ranjith. He reached out to Stacy and said Stacy wanted to support the
proposal. Attend the meeting inFairfax. Good listen taking not learning, continue. On a day to day basis
would yousay Ranjith would say Ranjith gave Stacy hertasks - He said yes. Bheeshma would coordinate
with Ran then he would with S and La
Iasked Bheeshma: Did anyoneever requests Stacy be removed from the proposal? No, she was only pulled
3 - 4times she does not have more to contribute on a Tech level. Only maybe 7 days overall. He has not
seen her more than 7 days. Not a full time role at all. For no one was it
I asked Bheeshma: Was there a need for the team members to work during the weeks? Do you know where
these meetings took place? What happened GDIT asked for Stay board session on Monday so on Friday
theystarted working on it. Some of the team members may have worked that meeting - still working he pre
RFP- so they wanted to make sure ready. I can be in April - May time frame. Itwas in Month of May 2nd
week weekend before May 11th.
Do youknow ifStacy or Ranjith worked on thatweekend. Not sure. Got some slide but frtey did notmeet
the markso Bheeshma had to work Saturday or Sunday, On Sunday around noon 05/10/15 Ranjith sent his
the invite. Were there meeting GDIT meeting. Were in the afternoon.
All
asked Bheeshma: Have there been any offsite meetings and or dinners?
I asked Bheeshma: When and where have those occurred? May 11 5:30 - 6:00 - meet in in Towson.
All four went to meeting. Think that Stacy drove. Bheeshma and Ranjith both drove. Not sure how
Stacy or Laura.
The very first meeting , Stacy took a taxi,
Then Bheeshma dropped Stacy at the Mclean office after, not sure why. Itwas just he and Stacy.
She attended another meeting in Fairfax.
Do you know if Stacy and Ranjith rode together. Yes. Theytold him the live inthe same area and they
drove together to Towson meeting. Believe it was the May 11th meeting.
They
Kelsey Hale, On Friday they worked inMcLean office (raj, K, St, Laura,) Ranjith coordinated with
Stacy and Laura on 9th.
Thinks that ttiey drove in the car. Believed
I asked Bheeshma: How all attended the meetings?
I asked Bheeshma: How did you get to the dinner? No other Dinner.
No need for the team to get together for any for any other business requirements. There was no need
for the team to get together after that time frame.
Bheeshma
After that Ranjith, Stacy or Laura were not involved in any sub sequent meeting
No one else.
Stacy asked him to send her mgr email.
After that she had a delivery project.
After May 11 he does
Would Ranjith - he does not think so.
Did anyone ever ask to remove form the p
No but he sent an email to say she was doing a good.
I asked Bheeshma: Did you ever intend any other offsite meetings.
I asked Bheeshma: Are you aware of how any other team member's transportation?
I asked Bheeshma: Was there a need for the team members to work late evenings? Do you know where
these meetings took place? Do you recall Stacy mentioning that she was working late?
I asked Bheeshma: Do you have any knowledge of anyone having a friendships outside of the proposal?
No, friendships in the, any dating dinner or weekends, no
I asked Bheeshma: Have you ever witnessed any inappropriate communications or behaviors between
colleagues on the proposal? No definitely not.
I asked Bheeshma: Are you aware of anyone wanting to ask someone on a date or pursue a relationship?
No I asked Bheeshma: Do you have any firsthand knowledge, have you ever witnessed any Inappropriate
communication, behavior, or any type of touching between Ranjith Keerikkattil and Stacy Sawin? No. They
seem to be any other regular IM resources, they seem to know each other as IM resources in the since
nothing un normal
I asked Bheeshma: Is there anything else that you think I should have asked or that you would liketo tell me
that you would thinkis relevant to our conversation? No, I do not see in un normal behavior, especially. He
had not worked with Ranjith before, introduced by CMS leaves.
In tum he brought on Stacy and Laura, over a span of time. Stacy may have spent not more than 40 hours
Laura 24 hours.
Ranjith has been working on and off 4 - 5 hour a week for the last 8
Have you interacted with Ranjith at all since 5/11? His family is moving to India, moving to USI, so been
busy
Maybe sent an email or something like that but also been busy with work.
After May 11th, heforgot onething the Leadership, Brian Hankin gave a dinner/happy hour Radhika Rest in
DC
Ranjith, Brian, Stacy, Bheeshma, Julie, Laura andSatya- Hedrove from and he dropped them at the metro
went with
He was about to leave and ran into Ranjith in lobby. Why
No plans to go
Created with Microsoft OneNote 2013,

Sent: 7/7/2015 7:43:19 AM
Subject: Privileged and Confidential - Prepared at the request of OGC - Talent Discussion - Julie Gi Kim
Ranjith/Stacy
Link to meeting notes: ^Privileged and Confidential - Prepared at the request of OGC - Talent Discussion - Julie Gi Kim
- Raniith/Stacv
Privileged and Confidential - Prepared at the request of OGC -

Talent Discussion - Julie Gi Kim - Ranjith/Stacy
Friday, June 12, 2015
12:02 PM
Link to Outlook Item: click here
Invitation Message
Participants
tl Garcia. Leslie Moore (US - Hermitage) (Meeting Organizer)

tl Kim. Julie Gi (US - Arlington)
Notes
Thank you for taking the call with me today
I asked Julie: Are you in a private place where we can have a private conversation? Julie said:
As a matter of introduction: Leslie Garcia, I am part of the Federal Practice Talent Relations team.
I have some housekeeping items I would like to discuss.
Wanted to let you know the conversation we are having today is as confidential as possible
conversations I might have to be jeopardized and not discuss the details of our conversation with others Including
your peers, any individuals we might discuss or your leadership
environment that promotes ongoing and open communication among theirpersonnel. Individuals must not be
subjected to harassment, intimidation, threats, discrimination, or any form of reprisal, because they have filed a
complaint or assisted or participated inan investigation. We take all reports of retaliation or possible retaliation
very seriously.
I asked Julie: Do you have any questions about that? Julie said: No
I asked Julie: How long have you been with Deloitte? Julie said: been with Deloitte about 2 months
I asked Julie: What Is your role? Julie said: she is a consulting in IM techno
I asked Julie: What engagement is she currently staffed on?: Julie said: Navy - data Lead consultant
I asked Julie: Have you worked on a CMS proposal? Julie said: yes, very briefly
0 I asked Julie: Which one? She will go back and find out. FPS.
1asked Julie; Who all have you worked with on this proposal? She was approached by Ranjith and found
out later that Stacy Sawin referred her to Ranjith and Ranjith reached out to her. And worked with Laura who
she referred to the group. Afterthat got on a callthey were meeting in McLeanand they were meeting with
another Sr. Manager. Another time she had a meeting with Ranjith and Stacy. They met in the Rosslyn first
floor and they decided to go to the hotel restaurant at Rosslyn to have lunchand discuss the proposal.
I asked Julie: How are the team dynamics on the proposal? Julie said: To be honest thinkit was okay did
not feel anything unusual, just starting off as well. Seems like everyone on the call she was on were helping
each other out.
I asked Julie: Have there been any offsite meetings and or dinners? Julie said: I was invited for a dinner
on Am St. Rasika (sp.), but I could not join because I had company coming over.
I asked Julie: When you meet for lunch how did you get there? Julie said: The Meridian has a restaurant
that is connected from the 4th floor there in Rosslyn so they walked.
I asked Julie: Have you ever witnessed any inappropriate communications or behaviors between
colleagues on the proposal? No that she is aware of. She did not notice anything inappropriate.
I asked Julie: Do you have any firsthand knowledge, have you ever witnessed any inappropriate
communication, behavior, or any type of touching (holding hands, putting had on back or shoulder) between
Ranjith Keerikkattil and Stacy Sawin? Julie said: No I never noticed anything
I asked Julie: Did Stacy ever tell you how she began work on proposal. Julie said: no.
I asked Julie: Is there anything else that you think I should have asked or that you would like to tell me that
you would think is relevant to our conversation? Julie said: Laura Amster might know better, Laura was
present for the meeting and the happy hour as well. I had very limited interaction.
I thanked Julie for the call and reminded Julie about the confidentiality that we discussed and the No
Retaliation Policy.
Created Microsoft OneNote 2013.

Sent: 7/7/2015 7:42:37 AM
Subject: Privileged and Confidential - Prepared at the request of OGC -Talent Discussion - Laura Anreter
Ranjith/Stacy
Link to meeting notes: )Privileaed and Confidential - Prepared at the request of OGC -Talent Discussion - Laura
Amster - Raniith/Stacv
Privileged and Confidential - Prepared at the request of OGC

-Talent Discussion - Laura Amster - Ranjith/Stacy
Friday, June 12. 2015
11:16 AM
Link to Outlook Item: click here
invitation Message
Participants
lD Garcia. Leslie Moore (US - Hermitage) (Meeting Organizer)
lH Amster. Laura (US - Arlington)
Notes
Thank you for taking the call with me today
I asked Laura: Are you in a private place where we can have a private conversation? Laura said: Yes
I am looked
As a matter of introduction: Leslie Garcia, I am part of the Federal Practice Talent Relations team.
House Keeping Items:
Wanted to let you know the conversation we are having today is as confidential as possible
conversations I might have to be jeopardized and not discuss the details of our conversation with others
including your peers, any individuals we might discuss or your leadership
environment that promotes ongoing and open communication among their personnel. Individuals must not be
subjected to harassment, intimidation, threats, discrimination, or any form of reprisal, because they have
filed a complaint or assisted or participated in an investigation. We take all reports of retaliation or possible
retaliation very seriously.
I asked Laura: Do you have any question about that? Laura said: No she is fine
I asked Laura: How long have you been with Deloitte? Laura said: I joined 30th of March,
I asked Laura: What is your role? Laura said: I am a consUtant
I asked Laura: What engagement is she currently staffed on?: Laura said: I am at BEP Bureau of Engraving
Printing her 2nd day on site. Not assigned to any project before that. Assisted with a potential proposal worked
for the or four days someone asked her to join
I asked Laura: Have you worked on a CMS proposal? Laura said: Yes that was the proposal, a colleague that I
started with reached out to me and asked to join. I worked on some architecture. It was actually a pre-proposal
I asked Laura: Which one? It was for FPS. Fraud Prevention System
I asked Laura: How did you get involved in the proposal? Laura said: Julie G. Li pinged her about it but she
did not work with her on it. She gave her name to the others working on the proposal.
I asked Laura: Who all have you woi1<ed with on this proposal? Laura said:
Stacy Sawin
Bheeshma Tumati Sr Manager
Laura said: she did almost all of her work with Ranjith and Stacy
1asked Laura: How would you categorize the team dynamics on the pre-proposal work? Laura said From her
perception it was fine, she was very new so they needed to explain things to her and it was a good collaboration
I asked Laura: Have there been any offsite meetings and or dinners? Laura said: She attended on dinner after
they did the presentation to the client. A week or two after the presentation to the client it was a happy hour but it
was a dinner at a restaurant.
I asked Laura: When and where have those occurred? Laura said: I do not remember the exact date of the
dinner but it was in downtown DC at Rathika
I asked Laura: How ail attended the meetings? Laura said: Stacy, Ranjith, Bheeshma, Brian Senior
manager, another person cannot remember his name, she met him at the dinner, she believes her was a
manager.
How we you invited to the dinner - Ranjith sent an invite:
1asked Laura: How did you get to the dinner? Laura said: I asked Laura: She rode with Bheeshma and
Ranjith to the dinner. Stacy was going to ride but was somewhere else so she did not ride there. But she
and Stacy got a ride back from to the Metro Ranjith and Bheeshma in the front seat and she and Stacy in the
back seat.
Did youever intend any otheroffsite meeting . She was invited but she called into the Lync.
Are you aware of how any other team members transportation? Laura said:
Iasked Laura who assigned herthe work to do on the proposal: Laura said: Ranjith told hershe would working on
the diagram. Bheeshma was there too and so He may have also told her about it Shedoes not know who saidit
first.
I asked Laura: Have you everwitnessed any inappropriate communications or behaviors between colleagues on
the proposal? Laura said: no
Do you have any knowledge of anyone having a friendships outside of the proposal. Well Ido not know, but I
think Ranjith and Stacywere talking about some activities, They did participate in other things an knew each other
before. Seems like ttey had participated In sometNng before. Do you recall any of these conversations. These
were on the first day she was there. They were sitting at tablediscussing it. Stacy had started on the proposal
before hand. She was there before doing notes or something.
Iasked Laura: Do you haveanyfirsthand knowledge, haveyou ever witnessed any inappropriate commurHcation,
behavior, or any type of touching between Ranjith Keerikkattil and Stacy Sawin? Laura said: No, not really but just
the first day, they were meeting, Stacy said she had to do some shopping. She thought Stacy he was le thatwas
the only thing strange, butnever noticed any touching at all not even once. After they were done for the first day
they went to a little restaurant inthe Tysons mall, orderappetizer and drinks. Stacy mentioned she hadto but
something for herfather and all of a sudden he decided to go with her. Becausethey knew each otherbefore
thought itwas weird. What was Stacy's reaction? Notsure of it. Notsure If she said anything she justsaid
goodbye to her
When youworked about 4 days, maybe less. With the group for the 1st and second day she was mostly with
Stacy because Ranjith and Bheeshma went to work on something else anotherroom. Her last day she called in
and was taking notes.
Do happen to knowwho assigned Stacy her work. She said she did not know?
When youwere at the meeting do you know how Stacy got to the meeting. Do not rememberhow she got there.
Ranjith had pinged her earlier that day, buthe said that he and Stacy were going to ride together. But Idid not
ride because I was not in Rosslyn that day.
I asked Laura: Is there anything else that you think I should have asked or that you would like to tell me that you
would think is relevant to our conversation? Laura said: uhhm ... I do not know not if it, one time I ran into Ranjith
inRosslyn asked ifhe knew when the propwas going to start and theywerewaiting . Iwentto an event lastweek,
they talked he asked ifshe had seen Stacy because she was there? He asked her ifshe knew where Stacy was
because he knew she was there? Not sure of the exactly what the wording was. Before she had run into him she
saw her by the food. She pointed out to him where she had seen her earlier but not sure it that is where she was.
What event was that after party after impactday. Itwas in a space at the Zoo indowntown DC. He repeated that
when he found out about the proposal he was going to let Stacy and I know.
I thanked Laura for the call and reminded Laura about the confidentiality that we discussed and the No Retaliation
Policy
Created -with Microsoft OneNote 2013,
Exhibit I
Carberry, Alicia (US - Arlington)

To: Masengale, Derick (US - Arlington)
Lipskar, Leah Bensen (US - New York); Garcia, Leslie Moore (US - Hermltaqe)
Sent: 6/18/2015 6:52:40 PM
Subject: Privilege and Confidential: Talking Points for Discussion with Ranjith
Attachments: Ranjith Keerikkattil 396081 Separation Memo.docx
Derick:
Iwanted to provide you the talking points for our discussion with Ranjith tomorrow at 9:00 am ET. Your part is
highliglited in red 1will let you know if he responds and states he is unavailable; otherwise, Iwill call you first and
we will call Ranjith directly.
IPc have deiermified Ihat you M'ere not honest duringyour interview last Wednesday and as a result ^ye have made
the decision to separate you for cause ejyective today. We do not tolercuwe individuals making false statemefits cmd
impeding our investigations. Alicia is on the line to share with you the information regarding vour separation memo
and other benefits.
If he tries toargue orifresistance occurs, please say;

"The decision to separate is final."
Alicia's part
\ou will receive aseparation memo shortly by email to your personal email account and by certified mail to your
home address. I will go througli the memo briefly with you now ifyou like? Ifyou have any additional questions
le^rdingyour benefits, I can reach out to 800-Deloitte directly and speak with abenetlts specialist.
Ifhe argues or goes back about the separation or investigation, Alicia can respond:
As Derick has previously stated, the decision to separate is final. While we do not retaliate against individuals
who willingly participate inan investigation, we do not tolerate those who are untiaithful and create obstacles
or roadblocks in our investigative process.
Potential Questions Ânswers for Alicia to responded to:
IfRanjith claims that this is retaliation for him making aallegations against Stacy:
This decision has nothing to do with your allegations about Stacy. We will continue to look into your
allegations that you raised. Your failure to cooperate and be taithful is a serious offense and violates our
code of ethics and professional conduct. (APR 205)
IfRanjith asks what Stacy said in the investigation;

We cannot share what she or anyone else involved in the investigation said.
IfRanjith asks what will happen toStacy:

Because of the privacy ofpersonnel decisions, we cannot share with you any information about Stacy.
IfRanjith says he wants to talk to a lawyer;

You are always entitled to seek legal advice. If your attorney has questions about the separation
process, we would be happy to put him/her in contact with someone in OGC.
IfRanjith asks what to do about his PDA and otlier firm property:
We will need to collect your PDA and any other Deloitte property. We will send you apre-paid box to
youi home for you to return the equipment. You will no longer have access to our systems or the buildine
aftertoday. ^
Thanks,
Alicia
Alicia Car berry
Deloitte Services, LP
1919 North Lynn Street.Arlington, VA 22209
Tel/Direct; +1 571 882 8942 | Fax; +1 202 379 25431 Mobile: +1 410 926 5720
acarbeny@d6loitt6.com (www.d6loitte.com
coi'siJe! tfif- i!;vsronrnei-it befors piiraing.
CONFIDENTIAL
DELOITTE008748
Exhibit J

To: Freeman, Teresa (US - McLean)
Sent: 7/13/2015 6:51:18 PM
Subject: FW: Mobile Device Collection (Sawin, Stacy)
Teresa,
Alicia asked me to let you know I had reviewed Stacy Sawin's emails to determine if she had sent or received any
with explicit language or content. There were no emails containing explicit content or language.
Thank you,
Senior Specialist Federal Practice. Talent Relations
Tel/Direct: +1 615 882 7129 | Mobile: +1 615 785 0173
les(legarcia@cle!oitte.com iwww.deIoitte.com

Sent: Monday, June 29, 2015 4:41 PM
To: Carberiy, Alicia (US - Arlington); Lipskar, Leah Bensen (US - New York)
Subject: RE: Mobile Device Collection (Sawin, Stacy)
I went througli all ofthe emails last niglit. There were no explicit emails or Lync messages on Stacy's hard drive.
Senior Specialist Federal Practice. Talent Relations
Tel/Direct; +1 615 882 7129 | Mobile: +1 615 785 0173
!es|jegarcia@deloitte.conr> Iwww.deloitte.com
Exhibit K
From: Carberry, Alicia (US - Arlington)

To: Garcia, Leslie Moore (US - Hermitage); Samuel, Rajiv (US - Hyderabad)
CC: Lipskar, Leah Bensen (US - New York)
BCC: Carberry, Alicia (US - Arlington)
Sent: 6/19/2015 10:02:54 AM
Subject: RE: 396081 - Ranjith Keerikkattil
Per Leslie's request below, please deactivate Ranjith's account effective immediately.
Thank you,
Alicia
Alicia Carberry
Tel/Direct: +1 571 882 8942 | Fax: +1 202379 25431Mobile: +1 410 9265720
acarben7@deloitte.com Iwv/w.deloitte.com

Sent: Friday, June 19, 2015 9:22 AM
To: Samuel, Rajiv (US - Hyderabad)
Cc: Carberry, Alicia (US - Arlington); Lipskar, Leah Bensen (US - New York)
Subject: 396081 - Ranjith Keerikkattil
Please deactivate the account for 396081 - Ranjith Keerikkattil. He is being separated today. His hard drive and PDA
should be preserved.
Thank you,
« OLE Object: Picture (Device Independent Bitmap) »

Specialist Federal Practice. Talent Relations
Tel/Direct: +1 615 882 7129 | Fax: +1 615 750 7129 | Mobile: +1 615 785 0173
lesIiegarcia@deloitte.com | www.deloitte.com
Pfestcr iifr before pnrîno.
Exhibit L
From: Carberry, Alicia (US - Arlington)

To: Lipskar, Leah Bensen (US - New York)
CC: Garcia, Leslie Moore (US - Hernnitage)
Sent: 6/12/2015 5:11:23 PM
Subject: Stacy's Clearance Update
In Dorothy's absence I reached out to Buddy White and he provided me the following update on Stacy's clearance.
"Stacy was processed through OPM and was not successful. She does not have any clearance noted at this time. We believe
that Stacy is currently pending a suitability of access with Treasury."
Thanks!
Alicia
Alicia Carberry
Tel/Direct: +1 571 882 8942 | Fax: +1 202 379 2543 | Mobile: +1 410 926 5720
acarberry@deloitte.com | www.deloitte.com

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Case 1:16-cv-00827-CMH-MSN Document 95 Filed 05/09/17 Page 1 of 18 PageID# 1544

IN THE UNITED STATES DISTRICT COURT

V. Case No: l:16-cv-827-CMH-MSN

STACY SAWIN, etal.

PLAINTIFF'S OPPOSITION TO DEFENDANTS^

and Deloitte Services LP (collectively referred as "Defendants").

Defendants attempt to label Plaintiff as a vexatious litigant bystating:

accountable under the law.

' Am. Compl., Ex. R.

the next day via e-mail. (Keerikkattil Decl. f 2. and Ex. 1)

" Am. Compl., %68.

Monique Mignon, a Deloitte Talent/HR employee. Id.

mail containing the following hyperlink: https://casetxt.com/case/keerikkattil-v-hrabowski. This

Stacy Sawin. See Ex. G at DELOITTE005563.

states that installing, using or downloading any unauthorized software, applications or

for representing Stacy Sawin. See ECF No. 67-1.

Giovannelli. See ECF No. 67-2.

PLAINTIFF'S STATEMENT OF MATERIAL FACTS IN DISPUTE

Carberry Decl. (Dispute D's SOF ^ 16.)

Keerikkattil to keep his communications with her strictly professional?". Plaintiffs

at DELOITTE008670. (Dispute D's SOF ^ 5,6,10,11.)

to Monique Mignon, a Deloitte Talent/HR employee. See Ex. C at DELOITTE006680.

Plaintiff had stalked her. (Dispute D's SOF ^ 11,12,13,14,15.)

7. Alicia Carberry's investigation of Plaintiffs complaint against Ms. Sawin is laughable at

case of any litigation. In support of this:

evidence while denying Plaintiff the ability to present inculpatory evidence.

b) Deloitte's eDiscovery Litigation Analyst Aleta Jacobson found Snapchat, a wildly

unauthorized software, applications or technology services." See Ex. F at

DELOITTE008850. Despite conclusive evidence, Ms. Carberry and her subordinate

d) Defendants withheld sexually explicit MMSs identified by Ms. Jacobson from

realized that I had nothing on below the waist ... http://m.imgur.com/gallery/JZ85Pgu"

that they uncovered no explicit messages or e-mails.

(Dispute D's SOF ^ 22,25,26.)

mobile phone (Keerikkattil Decl. 111 •) (Dispute D's SOF f 23,24,25,26.)

entry of summary judgment." Id.

IL Title VII Discrimination

retaliation. 42 U.S.C. §§ 2000e-2(a)(l), 2000e-3(a). In order to survive summary judgment,

conclude that he was discriminated

Under McDonnell Douglas, a plaintiff demonstrates a prima facie case of sex

McDonnell Douglas, 411 U.S. at 802.

facie case of sex discrimination \xndQT McDonnell Douglas.

' Am. Compl., Ex. B.

discriminated against Plaintiff, a male compared to Stacy Sawin, afemale.

according to them Plaintiff "was a Senior Consultant in Deioitte's Information Management

from that of Ms. Sawin's.

Deloitte Consulting LLP has three tiers of employees:

(iii) Non-managerial employees - These employees have no supervisory responsibilities

no supervisory responsibilities as Deloitte Consulting Director Ritesh Verma clearly stated,

"Ranjith not responsible for anyone else". See Ex. H at DELOITTE008777

deny Defendant's Motion for Summary Judgment.

CERTIFICATION PURSUANT TO LOCAL CIVIL RULE 83.1M(2)

I declare under penalty of perjury that:

No other attorney has prepared, or assisted in the preparation of this document.

Executed on: May 9,2017

Dated: May 9,2017 Respectfully submitted,

IN THE UNITED STATES DISTRICT COURT

V. Case No: l:16-cv-827-CMH-MSN

DECLARATION OF RANJITH KEERIKKATTIL

RANJITH KEERIKKATTIL, under penalty of perjury, affirms as follows:

1. I started my employment with Deloitte Consulting LLP ("Deloitte Consulting") on

6. On May 10, Ms. Sawin sent me an invite on Linkedln. See Ex 4.

any questions regarding my e-mail.

14.1 also informed Deloitte Defendants that 1 would like to correct/supplement my

Dated: April 21,2017