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Susana Martin Cross-examination
Page 2119 B – 2120 C: Susana Martin admits that her leadership training after becoming team leader was cut short and that she at the time of my employment never had received training about bullying at work.

Page 2123 C – 2126 G: Susana Martin denies that she ever said that Jose Luis Aznar was gay. She lies here. Ms Martin agrees that there was a breaking point in her working relationship with Camp 2. Jose Luis Aznar never approached her to ask if she had said that he was gay or not. Ms Martin said that sometimes it was not easy to work with Jose Luis Aznar, he could be grumpy.

Page 2128 A – 2129 D: Susana Martin states that she did not notice that Jose Luis Aznar did not like her and she denied that Camp 2 were acting against her. In page 2130 B – F: Susana Martin states that she did not feel anger towards Jose Luis Aznar and never perceived anger from Jose Luis Aznar towards her.

Page 2136 A – 2138 E: During several walks outside the office, when we were talking about tensions and being bullied, Susana Martin stated that I was upset by the tensions. “Tensions” was constantly used as a euphemism for “bullying”. Ms Martin agrees that we had many such conversations. In page 2152 G – 2153 C: Susana Martin confirms that I used the word bullying regularly in meetings with her but she then plays it down to disagreements, as part of her script.

Page 2145 G – H: Susana Martin lies when she said that she had never said that Dennis Dorland was useless. In page 2151 C – 2152 B: Ms Martin is confronted with the evidence that she did say that Mr Dorland was useless. She got caught out with a lie under oath but the Chairman makes nothing of it.

Page 2148 A – 2151 B: Susana Martin states that a minimum score of 80 is required in the monthly evaluations. She agrees that the 10 cases to be evaluated are hand-picked by her. She agrees that, in theory, she could have picked 10 bad cases. Ms Martin also states that these quality reports were as well used to get rid of bad employees.

Page 2174 E – 2176 E: Susana Martin never saw me provoking any other team members in her presence, neither was this reported by the more mature colleagues. In page 2177 G – 2178 D: Ms Martin confirms that never any complaints were filed about me provoking colleagues and that only Camp 2 were called in for meetings, not I.

Page 2181 F – 2182 B: I point out Susana Martin's selective memory. Ms Martin accepts that her interventions to stop the bullying were unsuccessful.

Page 2194 F – 2195 G: Susana Martin denies that she spoke to Luis Pinto (VIP manager) to inform him that Yousri Amrani was a bad employee and could not even do simple tasks. Again she lies about this.

Page 2205 C – E: Susana Martin states that I had “a really big smile” during the chaos meeting of 30th January 2018. In page 2207 F – H: Ms Martin remembers that Jose Luis Aznar came up with the accusation that I made Camp 2 look ridiculous for going to shift-supervisors and team leaders with questions.

Page 2209 F – 2210 G: I make a statistical analysis of how low the chances were that I would have two zero scores on a monthly quality evaluation. Susana Martin denies that she did on purpose put two bad cases in my evaluation to score me down.

Page 2220 B – 2236 G: My May 2018 holiday request is discussed. Susana Martin had stated that this holiday was impossible. I expose several possibilities to have made that one day I needed possible and I show that Ms Martin had misled Danielle Wood from HR with Jalila Kessissa's holiday request that did not overlap with my own request. Ms Martin struggles heavily to give answers and is caught out with evasive answers. In short: the holiday was possible but the question why it was not allowed by Susana Martin was never answered. She stresses the need to have several people on the floor although chat and phone hours were from 12h00 till 20h00 and weekdays were less busy than weekend days when only one person was on shift. She is misleading here, giving false information. She cannot explain herself out of it. There were three changes of the shift roster after my holiday request, these could have been used to make my holiday possible. With hindsight, Ms Martin admits that my holiday could have been possible. This comes in the context that other team members had complained about being bullied with holiday requests.

Page 2246 G – 2248 G: A blank email was sent to a customer because of a bug in the updated software which had been changed recently. This was not my fault but Ms Martin refused to remove it from my quality evaluation to be able to score me down. This is identical to Stef van Veen when Ms Martin refused to accept that his English was correct and she was wrong.

Page 2253 G – 2258 G: The daily workload incident is discussed. Susana Martin admitted that at times she read her work email from home. In reality, she checked it all the time, we all did this. She denies the story, mostly that she couldn't recall the situation. This was revenge for me criticising her for the first time by making a problem out of nothing, that I hadn't done the useless daily workload email. The problem was that she did not see the statistics of the English chats, which we did the overflow for, another example of her not understanding her job. In page 2264 C – 2267 A: Susana Martin agrees that the daily workload was a minor issue, but she kept bringing it up in meetings with management and HR, it happened only once and two weeks later it was abolished. She made a problem out of nothing.

Page 2269 G – 2273 F: while I had the “trap meeting”, Jose Luis Aznar had an identical meeting but Mr Aznar's was short and no specific user cases were presented. The minutes of this meeting were taken by Samira Mouhayar but were never disclosed.

Page 2274 F – 2276 A: The “trap meeting” was to talk about “team atmosphere”, but unlike in Jose Luis Aznar's meeting, complicated user cases were presented to me without having been informed previously about them. It ends with referring to the one-off incident of the daily workload, a non-event, which has nothing to do with the user cases. Ms Martin states that I was begging during the meeting to stop her fighting with me. I point out that her instructions for those cases were wrong.

Page 2292 E – 2293 G: I point out that Susana Martin was misleading HR about me, to make me look bad. Ms Martin wrote in the email that the first bad evaluation was sent before I told her I wanted another job and, again she misrepresented my attitude about leaving the poker training, the unjustified criticism which was never corrected. In page 2298 A – H: Susana Martin brings up to HR that I left my own team alone, making me look bad, although she then admits that I sat with the English team with her and Samira Mouhayar's permission. In page 2299 G – 2300 C: Susana Martin had informed HR that I had lied to her about the 2017 Christmas holiday, then admits that lying was not the correct word. There actually never was a problem with this Christmas holiday request.

From the above, it is crystal clear that Susana Martin lied on several occasions and tried to talk herself out of situations where she bullied me and others. Her attempts to talk herself out of the incriminating events failed when Ms Martin was confronted with the contemporary evidence. Her credibility was obviously very low, still the Chairman preferred her evidence over mine. As other team members had complained to HR about being bullied by Ms Martin, it is more likely than not that Ms Martin did indeed bully some of her staff.

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