Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00986-JCH Document 96-11 Filed 06/24/2005 Page 1 013
Exh1b1t 10

Case 3:03-cv-00986-JCH Document 96-11 Filed 06/24/2005 Page2of3 _
macsvvzn
A 1 p I MAY 7- 2004
’ 2 *** CONFIDENTIAL ***
3 UNITED STATES DISTRICT COUR'IT-_ " ` "
DISTRICT OF CoNNECT@
4 ©/®y
5 -------—-——-——-——-——-------—--—- X
6 SUSAN E. WOOD : l
7 Plaintiff : 4
8 VS. z N0. 3;03CV098(JCH>
9 SEMPRA ENERGY TRADING CORP. ;
1· 10 Defendant r , :
ll —----——-——-—---————--————--——-—— X
l2 DEPOSITION 7
14 THE DEPoSITIoN OF JACQUELINE K. MITCHELL, I
15 taken on behalf of the Plaintiff, pursuant to
` 16 the Federal Rules of Civil Procedure, before A
17 Melodie Ajello, Registered Professional
18 Reporter, Notary Public within the State of A
19 Connecticut, on the 13th day of April, 2004, at A
20 2 p.m, at the offices of Brendan O'Rourke &
21 Associates, 27 Pine Street, New Canaan,
22 Connecticut .
24
25 GoI.DEARB AND AJEI.I.o REPORTING SERVICES
I ·" 24 East Avenue #1372
Goldfarb &Ajc1lo _ Y
203-972-8320 ENCLOSED.) U

Case 3:03-cv-00986-JCH Document 96-1 1 Filed 06/24/2005 Page 3 of 3 Q
` Pagc27 E
1 them, and they're tied out each —— at the end of each g
2 month with a marketer, and really this is the way it goes: E
3 The trader puts it together and ties it out with the §
4 marketer at the end of each week, or if he doesn't get to g
5 it by the end of the month. And usually by the end of g
6 each quarter, I review it. i
7 Q. Do those reports enable you to determine the i
8 profitability of each individual marketer? ` i
m
9 A. Yes. In my business, because I get —— I get %
10 cost allocated to my business unit, so I throw in —— add E
f ll all the cost associated with each book of business, and so E
12 I can determine whether or not one of my units is é
13 profitable. 'K ‘ i A
14 Q. Well, when you say units? Q
15 A. I run a couple of different —- a few g
16 different businesses. i
U 17 Q. I'm just going to take a brief moment for» %
18 you to go back and give me your educational background g —
19 from starting with college and a summary of your career ;
- 20 ppath ¤hx¤ugh Sempra. If you would do that now, I would E
21 appreciate it. g
22 A. Okay. I graduated from University of E
23 Houston with a degree in business. I started -- I was E
24 with an energy company. I'm from Texas. I was with an J
25 energy company in Texas. I started in '88, moved to Q
203-972-8320