Free Motion to Compel - District Court of Colorado - Colorado

Case 1:03-cv-02485-MSK-PAC

Document 355-9

Filed 02/23/2006

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EXHIBIT H

Case 1:03-cv-02485-MSK-PAC

Document 355-9

Filed 02/23/2006

Page 2 of 3

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IN THE UNITED STATES DISTRIC COURT
FOR THE DISTRICT OF COLORADO

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Civil Action No. 03-CV-2485 (MSK/PAC)

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CAMILLE MELONAKIS-KURZ,

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individually and on behalf

of other similarly situated

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employees,

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Plaintiffs,
vs.
HEARTLAND HOME FINANCE, INC.,

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Defendant.

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The Videotaped Deposition of CHARLES K. LUTTKE,
Taken at 1515 Michigan Avenue, N.E.,

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Grand Rapids, Michigan,
Commencing at 2: 49 p.m.,

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Wednesday, January 18, 2006,

Before Patricia A. Way, CSR-1201.

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Case 1:03-cv-02485-MSK-PAC

Document 355-9

Filed 02/23/2006

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A.
Q.

No.
Have you ever testified in court?

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A.
Q.

No.
You understand that the oath that you were given today
is the same oath that you would give in a court.

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A.
Q.

Yes.
You understand that that requires you to tell the

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truth.
A.
Q.

Yes.
Anything that would prevent you from telling the truth
to the questions I ask you today?

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A.
Q.

No.
Have you ever been convicted of a crime?

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A.
Q.

Yes.
How many times have you been convicted?

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A.
Q.

Once.
When was that?

A.
Q.

1995.
What was the crime?

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A.
Q.

Embezzlement.
Is that a felony?

A.
Q.

Yes.
Where were you convicted?

A.
Q.

Montcalm County.

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And were you incarcerated?