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1 Q. So you were telling the counsel the truth when you

2 said she was fantastic?
3 A. At that moment, it was -- she was.
4 Q. What was your factual basis for telling the counsel
5 she was a fantastic student?
6 A. When you can get a 106 percent performance in your
7 class, I think it's because she's fantastic.
8 Q. Have you read the Rhodes College Fraternization
9 Policy?
10 A. No, I have not.
11 Q. Sorry?
12 A. No, I have not.
13 Q. Before you got here today, did you know there was a
14 fraternization policy?
15 A. No, I did not.
16 Q. Had you ever been advised that dating students was
17 against the Rhodes College policies?
18 A. Yes, I was.
19 Q. All right. So you knew that?
20 A. Well, at least that part, yes, I knew.
21 Q. And so you also knew that if a student claimed that
22 you asked them out on a date, that could invoke a
23 possible violation of the fraternization policy?
24 A. Yes, that's why I didn't ask any of my students to
25 do that. I never invited any of my students, never asked
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CROSS - DR. ROBERTO DELA SALUD BEA 94

1 any of my students to have any of those relations. I

2 knew that.
3 MR. COHEN: This would be Exhibit 21, Your
4 Honor, once it's admitted.
5 THE COURT: If you could, please, pass it to
6 the witness, let the witness identify it, then we will
7 get it marked as an exhibit and put it on the screen.
8 BY MR. COHEN:
9 Q. Dr. Bea, I will tell you that I got this exhibit
10 from the Rhodes College website which is the college's
11 campus map. Do you recognize what's in it?
12 A. Well, yes, that's a map of Rhodes College.
13 Q. And do you see that it identifies the building that
14 the students refer to as The Rat?
15 A. It's kind of dark. Yeah, I can see it here, yes.
16 Exactly, that's where it is.
17 Q. What is the name of the building that houses the
18 chemistry department?
19 A. It's Kennedy Hall.
20 Q. And is Kennedy Hall just a short walk and really
21 the next building from The Rat actually known as the
22 Burrow Refectory?
23 A. Uh-huh.
24 Q. And so does The Rat serve food?
25 A. Well, yes, that's the purpose for that building.
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1 Q. Is that where you had lunch November 19th, 2015?

2 A. Yes, that's the place.
3 Q. And is that where you encountered Ms. Bose and her
4 friend?
5 A. That's correct.
6 Q. And was her friend Chelsea Dezfuli who testified
7 here earlier?
8 A. Well, she was the one chosen as the witness, so I
9 guess she was the one. As I said, I was just quick, just
10 walking fast, just like inside, and I look over there at
11 the phone, said, is this your boyfriend, and I just walk
12 away. I didn't have enough time to recognize anybody
13 else.
14 Q. And in response to Ms. Krupicka's questions, you
15 did recall that after this brief encounter in The Rat,
16 Ms. Bose came up to you as you were leaving that Burrow
17 Refectory heading to your chemistry building?
18 A. That's correct, yeah, but --
19 Q. And would you tell the court why she approached
20 you, why she stopped you?
21 A. No, what I said was I just kept walking, and I just
22 went directly to the building. If Ms. Bose was walking
23 after me, I don't recall that. I was just walking
24 straight to the building and she was walking after me. I
25 don't know, maybe she was talking, and that's where she
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CROSS - DR. ROBERTO DELA SALUD BEA 96

1 was.
2 Q. She was talking to you, right?
3 A. Well, there were other people around. Maybe she
4 was talking to me, be I just went straight to Kennedy
5 Hall.
6 Q. Are you denying that she spoke to you?
7 A. I denying that I hear, yes, or I thought that she
8 was talking to me.
9 Q. And was she talking to you about the fact that you
10 had just recently put your head next to hers, looked at
11 her cell phone and inquired about her boyfriend?
12 A. I don't recall she telling me all that things --
13 all those things.
14 Q. Are you denying that she talked to you about those
15 issues?
16 A. I'm denying that, yeah, she talked about those
17 issues. I know that -- I know -- maybe she was walking
18 after me. Maybe she was talking to me, but that's the
19 only thing I remember.
20 Q. Would you repeat that last statement?
21 A. Maybe she was walking after me. Maybe she was
22 talking to me, but that's the only thing I remember,
23 maybe.
24 Q. And maybe she was talking to you --
25 A. Maybe she was talking to me.
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1 Q. -- about -- excuse me. Let me finish my question.

2 Maybe she was talking to you about how she felt
3 uncomfortable that you were inquiring about her personal
4 life?
5 A. Well, maybe she was saying that.
6 Q. Okay. And if she was correct in saying that, that
7 could be a violation of a policy that might affect your
8 tenure, right?
9 A. Well, but she didn't report anything as far as I
10 know. Could be, yes, but she didn't report it. It could
11 be a threat to my tenure if she reported it, but she
12 didn't report it. So probably it wasn't very important
13 after all.
14 If it was that important, she had the tools, she
15 has the offices, she has the possibility of reporting
16 this kind of very serious case. But if she didn't report
17 it, it probably wasn't as serious as she thinks or as she
18 mentioned. We can't wonder why she didn't do that.
19 MR. COHEN: I offer Exhibit 21.
20 THE COURT: I'm assuming that's the map of the
21 campus?
22 MR. COHEN: That's the map.
23 THE COURT: Any objection?
24 MS. KRUPICKA: No objection, Your Honor.
25 THE COURT: We will receive that as Number 21.
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CROSS - DR. ROBERTO DELA SALUD BEA 98

1 (Said item was marked as Exhibit 21).

2 BY MR. COHEN:
3 Q. Do you agree that it's a violation of a professor's
4 grant of tenure if they are found in violation of the
5 fraternization policy?
6 A. So, yeah, if I am found that I'm doing something
7 incorrect, yeah, it could be a threat for the tenure,
8 yes.
9 Q. And you also agree that you could be subject to
10 employee discipline and termination if you were found
11 guilty of unwanted harassment or romantic approaches to a
12 student?
13 A. Well, yes, yes, I know that I have that problem,
14 yes.
15 Q. You prepared and filed with the Honor Council an
16 accusation document; is that correct?
17 A. Well, what I did, I was giving some evidence that
18 Ms. Bose was actually cheating in my class.
19 MS. KRUPICKA: I'm sorry. What document are
20 you talking about?
21 MR. COHEN: I'll have that in just a moment
22 before I ask another question.
23 Your Honor, may I respond to Ms. Krupicka's
24 question?
25 THE COURT: Please do.
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