Case 1:03-cv-02485-MSK-PAC
Document 367-3
Filed 03/07/2006
Page 1 of 3
Jennifer Legree 1/20/2006
Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
Page 1
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 03-MK-2485
Camille Melonakis-Kurz, individually and on behalf of similarly situated employees,
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other)
) ) ) ) ) )
)
Plaintiff,
vs.
Heartland Horne Finance, Inc.,
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)
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Defendant.
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) ) )
VIDEOTAPED DEPOSITION OF JENNIFER LEGREE
FOR TRIAL
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January 20, 2006 3:01 p.m. Phoenix, Arizona
Prepared by:
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Cecelia Brookman, RPR Arizona Certified Reporter No. 50154
Prepared for:
Paradigm Reporting & Captioning Inc.
612-339-0545
Case 1:03-cv-02485-MSK-PAC
Document 367-3
Filed 03/07/2006
Page 2 of 3
Jennifer Legree 1/20/2006
Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
Page 31
1 I will represent to you that 1S, I believe, your
2 employment application. Was that filled out by you and
3 is that your signature at the end of it? Go ahead and
4 take a moment to look at it.
5 (Brief pause.)
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THE WITNESS:
Q.
Yes.
BY MR. CARR:
Is it accurate, to the best of
8 your knowledge?
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A.
Q.
To the best of my knowledge, yes.
How did you corne to work at Heartland?
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A.
I was actually referred there, through, Kevin
12 Karpovich recruited me.
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Q.
How did you know Kevin?
Just, he was a friend of the family.
A.
Q.
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He was a friend of the family?
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A.
Correct.
MR . CARR:
Let's go ahead and mark this as
18 defense Exhibit 2.
19 (Defendant's Exhibit No.2 was marked for
20 identification.)
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Q.
BY MR. CARR:
The court reporter has marked and
22 handed to you for purposes of identification -- it's
23 marked for purposes of identification defendant's
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Exhibi t 2, and it's handed to you.
Take a look at this
25 and tell me if this is a document you recognize.
Paradigm Reporting & Captioning Inc. 612 -339-0545
Case 1:03-cv-02485-MSK-PAC
Document 367-3
Filed 03/07/2006
Page 3 of 3
Jennifer Legree 1/20/2006
Camile Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.
Page 32
1
(Brief pause.)
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THE WITNESS:
Q.
I recall this document, yes.
BY MR. CARR:
Is that your signature on
4 Page 13?
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A.
Q.
Yes.
And are these your ini tials on the pages?
A.
Q.
Yep.
When you went to work for Heartland you had
9 worked as a wai tress, and so you had an understanding of
10 what overtime was as we speak of it in the United States;
11 correct?
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A.
Q.
Sure, yeah.
And what was your understanding of what was
14 overtime?
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A.
Q.
More than 40 hours a week.
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Take a look, if you will, on Page 4 of
And right there in the last line
defendant' s Exhibit 2.
18 it says, comply with all policies and procedures of the 19 employer which relate to the verification of hours worked
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approved overtime hours. Did you ever seek 21 preapproval for any of the overtime hours that you say
and pre
22 you have worked?
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A.
Well, this document carne out in June 11th, and
we were recording our hours prior to that point.
So as
25 you can see when I signed this, based on June 11th, there
Paradigm Reporting & Captioning Inc.
612-339-0545