Claus Scherer was the manager at Rockwell when the company was sued for sexual harassment by a former employee Pendy. Pendy moved for summary judgment, offering deposition transcripts of various employees. Pendy's deposition detailed instances of harassment of her in the workplace, including comments about her body, instances of unwelcome touching, and crude sexual jokes made in her presence. Another deposition offered by another Rockwell employee includes complaints by other employees as to Scherer's harassment. In his own deposition, offered to oppose summary judgment for Pendy, Scherer testified that he could not recall the incidents alleged by Pendy and others. Another deposition of two other employees offered stated that they have never witnessed the incidents.

You are the trial judge ruling on Pendy's Motion for Summary Judgment.

1. How do you rule whether to grant it or not?

2. Discuss the standard that is applicable in whether a trial court determines a party is entitled to summary judgment.

3. Aside from testimonies, what is another form of pre-trial discovery that the court may consider in support of a motion for summary judgment? Fully explain your ruling as a judge.