Free Response to Motion - District Court of Colorado - Colorado

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

Document 345-12

Filed 02/16/2006

Page 1 of 2

i

IN THE UNITED STATES DISTRICT 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 FINANCE, INC.,

t~l1f

Defendant.

The Videotaped Deposition of PAUL G. DINKEL,
Taken at 1515 Michigan Avenue, N.E.,
Grand Rapids, Michigan,
Commencing

at 8:23 a.m.,

Wednesday, January 18, 2006,

Before Patricia A. Way, CSR-1201.

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

Document 345-12

Filed 02/16/2006

Page 2 of 2

PaulG. Dinkel 1/18/2006

Camile Melonakis-Kurz, et aL. v. Heartland Home Finance, Inc.
55
1

A.
Q.

Tom Gable.
How did you find out about the job at Heartland?
Through Jim Moore.

2 3
4

A.
Q.

Did you fill out an application?
I don't recall exactly.

5 6
7 8 9

A.

I'm assuming so. Usually

that's part of the process.
Q.

Was your electronic mail fraud conviction a felony?
Yes, it was.

A.
Q.

You said that you served five months' time. Where did
you serve the time?

10

11
12

A.
Q. A.
Q.

Terre Haute, Indiana.
And where were you tried, what court?

13
14

Florida.
What city?
Fort Lauderdale.

15

A.
Q.

16
17 18

Did you list that conviction on your application with

Heartland?
A.
Q.

I don't recall.

19

Possible that you didn't list it?
It's possible.

20

A.
Q.

21
22 23
24 25

So you wouldn't be surprised if your application

didn't have check-marked yes, you've been convicted of
a felony?
A.

I'm a pretty honest guy and I usually answer honestly.
I -- that's a possibility.

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