Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-24

Filed 02/16/2006

Page 1 of 3

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IN THE UNITED STATES DISTRIC COURT FOR THE DISTRICT OF COLORADO

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

CAMILLE MELONAKIS-KURZ,

individually and on behalf

of other similarly situated

employees,

Plaintiffs,
vs.
HEARTLAND HOME ~INANCE, INC.,

CC~l1f

Defendant.

The Videotaped Deposition of CHARLES K. LUTTKE,
Taken at 1515 Michigan Avenue, N.E.,
Grand Rapids, Michigan,
Commencing at 2: 49 p.m.,

Wednesday, January 18, 2006, Before Patricia A. Way, CSR-1201.

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

Document 345-24

Filed 02/16/2006

Page 2 of 3

Charles K. Luttke 1/18/2006 Camile Melonakis-Kurz, et aL. v. Heartland Home Finance, Inc.
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A.
Q.

No.
Have you ever testified in court?

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4

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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6 7
8

A.
Q.

Yes.
You understand that that requires you to tell the

truth.
A.
Q.

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

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11

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A.
Q.

No.
Have you ever been convicted of a crime?

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. A.
Q.

Yes.
Where were you convicted?

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Montcalm County.
And were you incarcerated?

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Paradigm Reporting & Captioning Inc. 612-339-0545

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

Document 345-24

Filed 02/16/2006

Page 3 of 3

Charles K. Luttke 1/18/2006 Camile Melonakis-Kurz, et aL. v. Heartland Home Finance, Inc.
64
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this to the witness?

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MR. POCKRASS: If you would, please.

3 BY MR. POCKRASS:
4

Q.

I'd like you to take a look at what i s been marked as

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Exhibit 3 and ask whether that is your handwriting on
the first three -- well, all four pages of it, and
whether that's your signature on the fourth page?

MS. NOVAK: Steve, can I ask if you -- can
you identify what this exhibit is?

9

10 11
12

MR. POCKRASS: Sure. This is an application
for employment that he filled out with Heartland.

THE WITNESS: Yes. That's my signature.

13 BY MR. POCKRASS:
14
Q.

Do you remember completing this employment application

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wi th Heartland?
A.
Q.

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Vaguely, yes.
And if you'll look on the first page of Exhibit 3,

your employment application, there is a question that says have you ever pled guilty or no contest or been
convicted of a crime, and you circled the answer "no"?
A.
Q.

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Correct.
Why did you do that?

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A.
Q.

Because I didn't feel like putting on there yes.

If you look at the fourth page where it says applicant
statement, you see there that there's language that

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Paradigm Reporting & Captioning Inc. 612-339-0545