Free Reply to Response to Motion - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 72-8

Filed 11/29/2006

Page 1 of 2

Case 1:05-cv-00231-EJD

Document 72-8

Filed 11/29/2006

Page 2 of 2

JETTE MICHALS
Page 103

Q. I s there some sort of a bank
2 guideline that sets out the authorities of an

3 AVP?
4

A.
Q.

I don't recall.

5

Is there any type of bank guideline

6 that sets out the authority of directors?
7 8

A.
Q.

I don't recall.

IS a bank director above an AVP?

9

A.
Q.

Yes.
In status, hierarchy?

10

11 A. Much higher.
12 Q. What comes directly below a

13 director? Are there assistant directors?
1 4 A. I don't know.
15

Q.

Did you -- as an AVP, were you an

16 assistant to a vice-president? No. It was just a title. 17 A.
Hl

Q.

When did you receive that title?

19

A.

I came in with that title. That's

20 what I had at Citibank.
?J

Q.

Are you still an assistant

22 vice-president?
23
24

A.

Yes.
(Deposi tion Exhibit l7 was marked.)

25

Q.

Take a look at what i s marked as

App 0025

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