Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-27

Filed 02/16/2006

Page 1 of 2

Adam Provost 12/14/2005 Camile Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

CAMILLE MELONAKIS-KURZ, individually and on behalf of other similarly situated employees,

Plaintiffs,
VS.
CIVIL ACTION FILE NO. 03-MK-2485

HEARTLAND HOME FINANCE, INC.,

Defendant.
VIDEOTAPED DEPOSITION OF
ADAM PROVOST
De c e mb e r 1 4, 2 0 0 5

10:46 a.m. Tiffany Alley & Associates 400 Perimeter Center Terrace Atlanta, Georgia

Karen F. Gifford, RPR, CCR-B-1887 Craig Fine, Videographer

Paradigm Reporting & Captioning Inc.

612-339-0545

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

Document 345-27

Filed 02/16/2006

Page 2 of 2

Adam Provost 12/14/2005
Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 77

1 BY MR. MATTHEWS:
2 3

Q.

I'm going to hand you what's been marked as
Can you identify what that

Defendant's Exhibi t 3.

4 document is?

5 A. Employment Agreement.
6 Q. Is that your Employment Agreement with 7 Heartland? A. Yes. 8
9

Q.

And there's an ini tial at the bottom of each

10 page of this agreement, pages 1 through 12, and then a

11 signature on page 13. Are those your initials and is
12 that your signature?
13
14
A.
Q.

Yes.
to

15

Would you look at page 4, paragraph 6, Employee's Duties. I want to direct your attention

16 paragraph 6E, and one of the duties identified in 6E
1 7 is, quote, "Comply wi th all policies and procedures of

18 the employer which relate to the verification of hours
19 worked and preapproved overtime hours," end quote.

20 Have you seen that provision in this
21 agreement before?
22
A.
Q.

Have I seen it?

23
24

A.
Q.

Yes. Yes.

I've signed it.

25

When did you first see provision 6E in your

Paradigm Reporting & Captioning Inc.

612-339-0545