Free Reply to Response to Motion - District Court of Colorado - Colorado

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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7

THE WITNESS:
Q.

Yes.

BY MR. CARR:

Is it accurate, to the best of

8 your knowledge?
9

A.
Q.

To the best of my knowledge, yes.
How did you corne to work at Heartland?

10 11

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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17

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.)
21
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.)

2 3

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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24
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