Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-19

Filed 02/16/2006

Page 1 of 2

Eric Jerold 11/10/2005 Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
2

Page 1

3

4 CAMILLE MELONAKIS-KURZ,

etc., et al.,

5

Plaintiffs,
6 vs.
7 HEARTLAND HOME FINANCE, INC. ,
8

Case No. 03-CV-2485

Defendant.
9

10 11
12

THE VIDEOTAPED DEPOSITION OF ERIC JEROLD THURSDAY, NOVEMBER 10, 2005

13 The videotaped deposition of ERIC JEROLD,
14 called by the Plaintiffs for examination pursuant 15 to the Federal Rules of Civil Procedure, taken

16 before me, the undersigned, Barbara J. Sedlak,
19 offices of Cady Reporting Services, 55 Public

17 Registered Professional Reporter and Notary Public

18 within and for the State of Ohio, taken at the
21 the day and da te above set forth.
22 23 24

20 Square, Cleveland, Ohio, commencing at 3: 00 p. m. ,

25 CADY REPORTING SERVICES, INC.
Paradigm Reporting & Captioning Inc.

612-339-0545

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

Document 345-19

Filed 02/16/2006

Page 2 of 2

Eric Jerold 11/10/2005 Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 12

1

Q

Okay.

Did you -- what about Don Flynn, what

2 3
4

did he tell you about how many hours the loan
officers could record on their time sheets?
A

I vaguely remember having any conversations

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6 7
8
Q

wi th Don about that.

It was mostly Bob Janda

regarding time sheets.
Okay.
Did you have any conversations with Don
Flynn about hours or pay for loan officers?
A

9

Besides the standard 40 hours full-time, that's
abou tit.

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11 12
Q

Wha t do you mean by "the standard hour s, 40?"
Wha t do you mean?

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14

A
Q

Full-time, 40 hours a week.

I'm sorry. You cut out.
Full-time, 40 hours a week.

15

A
Q

16
17 18

Don Flynn would just say full-time, 40 hours
per week?

A
Q

Yes.
What did you understand that to mean? To mean that they were not to work over 40
hours in a week.

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22

A

Q

You understood it to mean they were not to work
over 40 hours a week?

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A

No.

That 40 hours was supposed to be what they

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worked during the week and that's what was to

Paradigm Reporting & Captioning Inc.

612-339-0545