Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-52

Filed 02/16/2006

Page 1 of 3

EXHIBIT 0

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

Document 345-52

Filed 02/16/2006

Page 2 of 3

j

IN THE UNTED STATES DISTRICT COURT FOR THE DISTRICT OF COLORAO
Civil Action No. 03-MK-2485 (pac)

Camile Melonas-Kur,
individually and on behalf of other similarly situation employees,

Plaitiff,
v.
Hearland Home Finance, Inc.,

Defendant.

AFFIDAVIT OF RACHELLE SCHUSTER
I. Raehelle Schuster. having fit been duly sworn upon my oath, state hat the following
are tre:

1. I am an adult, over the age of 21, and of sound mind. I am Cc mpetent to testify.

and I have personal knowledge of

the facts set fort herein.

2. 1 am a resident of Ohio. 1 am employed by Hearland H )ine Finance, Inc.
("Hearland") at its corporate offce in Middleburg Heights, Ohio, and E.Ol responsible for

.

maintanig personnel records for current and former Heartland employees.
3. According to my review of Hearland's records, Jason Nah ik ("Nahikll) was

employed by Heartland from August 23, 2000 until July 16. 2002. Nahik' if¡lS rured as a loan

offcer. He became an Assistant Branch Manager in St. Louis, Missour. on :i.ptember 8, 2000.
He then became a Brach Manager on Februar 13,2001. He remained in th II position until his
employment terminated.

FURTHER AFFIANT SA YETH NAUGHT.

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

Document 345-52

Filed 02/16/2006

Page 3 of 3

I hereby af, under the penalties for perjur. that the foregoing repre~ ~iitations are tre

and correct.

Dated: 5 dO. lJf

Ll Rachelle Schuster

acl

STAlE OF

DfllD

)

COUNY OF (~i-A-)i lJ¿.!l )

) 58:

State of 0 If¡ b . tlis ~ day ,~f ~. 2004.

Subscribed and sworn to before me, a Notary Public in and for ll1.1li.¡Ó. t~ounty,

cze¿t7~ N~PUbliC. ()
Printed
County of

_

Residence:

d.1I'f :.bIJI-A-

My Commission Expires:

CAAOI- A TONE Nowy Public Siae OfOblo

My commsson 'Epii i.27.(S

..

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