Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-13
Rodney Drew 11/28/2005

Filed 02/16/2006

Page 1 of 2

Camile Melonakis-Kurz, et al v. Heartland Home Finance, Inc.

1 IN THE UNITED STATES DISTRICT COURT

Page i

2 FOR THE DISTRICT OF COLORADO
3

4 CAMILLE MELONAKIS-KURZ,
INDIVIDUALLY AND ON BEHALF OF

5 OTHER SIMILARLY SITUATED
EMPLOYEES,
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Plaintiff,
-vsHEARTLAND HOME FINANCE, INC.,

CIVIL ACTION NO.

03-MK-2485

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Defendant.
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VIDEOTAPED DEPOSITION OF RODNEY DREW

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The videotaped deposi tion upon oral examination of RODNEY DREW, a witness produced and sworn be fore me, Jenny L. Reeve, RPR, CSR No. 00-R-3006, a Notary Public in and for the County of Hamilton, State of Indiana, taken on behalf of the Plaintiffs, at the offices of Ice Miller, 3400 One American Square, Indianapolis, Marion County,

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In d i a n a ,on the 2 8 t h day 0 f No ve mb e r , 2 0 0 5 , at 1: 3 0
p.m., pursuant to the Federal Rules of Civil Procedure, all applicable rules, and all stipulations, if any, stated on the record, with wri tten notice as to time and place thereof.

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

Document 345-13
Rodney Drew 11/28/2005

Filed 02/16/2006

Page 2 of 2

Camille Melonakis-Kurz, et al v. Heartland Home Finance, Inc.

Page 48

1

Q

Okay.
MS. FISHER:
MR. CARR:

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4

I have no further questions.
I might just have a couple.

Let's

take a short break.

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6

MS. FI SHER: Okay.
MR. CARR: We'll try and get you out promptly

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on your plane.
THE VI DEOGRAPHER:

We are off the record.

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The time is 2:25.

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(A recess is taken, after which, the

proceedings resume as follows:)
THE VI DEOGRAPHER: We are back on the record.
The time is 2:38.

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15 CROSS-EXAMINATION,

16 QUESTIONS BY MR. DAVID J. CARR:
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18
Q

Mr. Drew, on direct examination you testified
about loan officers working over 40 hours.

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What if any understanding do you have today
about whether Heartland Home Finance loan officers
are supposed to work over 40 hours in a week?
A
Q

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They're not supposed to work over 40 hours. Okay. And how long have you had that understanding?
Since the inception of the time sheets.

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A