Free Statement - District Court of Arizona - Arizona

1 EXHIBIT A
Case 2:04—cv—00424-ROS Document 344-2 Filed 12/10/2007 Page 1 0f 4

» In The Matter ok D
DIPPOLD VS. HONEYI/I/ELL
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF ARIZONA `

MEL VIN THOMAS JONES
NOVEMBER I1, 2005 _

_ JD REPORTING, INC. `
CERTIFIED COURT REPORTERS
389 East Palm Lane
Phoenix, Arizona 85004
Phone: (602) 254-1345
Fax: (602) 254-2548
E—MaiI address: [email protected] _
Word index included with this condensed transcript
""”*‘“““i""“"T"T" F E i`T ?7`T F"G IIIIIIII I · • · - I - - ‘ · · · · - · · I ~

MELVIN JONES November 11, 2005
V Page 9 Page 11
1 0 Then you became an employee of the Signal 1 what was the incentive?
2 Companies? 2 A It was my full salary.
3 A AlliedSignal. yes. 3 O Your full salary for that period of time you
4 O was it first Signal Companies, and then it 4 didn't have to work?
5 became AlliedSignal? Does that sound correct to you? 5 A Right. Right. It was a salary continuation
6 A That's correct. 6 until —— through September, I think it was. Yeah.
7 O Then it became Honeywell? 7 0 Sometimes in voluntary incentive programs there
8 A Right. 8 are pension enhancements or other incentives that affect
9 O And at the time that you departed the company, 9 your pension. was there any aspect of that to the
10 that was October of 1993. Correct? 10 incentive program?
11 A That was my retirement date, yes. That was my 11 A No.
12 retirement date. 12 O So just salary continuation?
13 0 Did you actually discontinue active employment 13 A Salary continuation until my retirement started.
14 before your retirement date? 14 0 Did you have any understanding at the time as to
15 A Yes. 15 whether you were going to be laid off?
16 Q How long prior to your retirement date, 16 A Well, this was a voluntary. I took a
17 approximately, had you discontinued employment? 17 voluntarily layoff, and I requested it. Okay?
18 A May of that same year, '93. 18 0 Right. And my question, just to clarify it:
19 Q All right. And in May of 1993, the company you 19 Did you have any belief at that time that you were going
20 worked for was Honeywell? 20 to be involuntarily laid off if you didn't volunteer?
21 A N0. 21 A No. No.
22 O All right. One thing I'm not up on here —— 22 0 Okay. At the time that you stopped working in
23 A It was AlliedSignal. 23 May of 1993, what was your job?
24 0 Okay. It was AlliedSignal. 24 A I was a senior programmer analyst in the
25 Okay. And what was the reason for the fact that 25 information systems department.
Page 10 Page 12
1 you ceased working in May of 1993 but did not retire until 1 0 And was that here in Phoenix?
2 October of 19937 2 A Yes.
3 A They were doing a lot of downsizing, and I 3 O All right. Where physically did you work?
4 requested a -- I requested voluntary —- what do you call 4 A Well, you mean toward the end or -—
5 it? 5 O Yeah. Let's start with toward the end.
6 0 A voluntary incentive program? 6 A Toward the end was basically on 36th Street and
7 A Yeah. Yeah. 7 Washington where the plant is there. That's where I
B O Okay. All right. 8 finished the last few years.
9 A And they gave me one. 9 Before that, I had transferred to a different
1O 0 Okay. And if I'm understanding you correctly 10 division. I had worked at this division for a number of
11 then, part of that package that you received was that you 11 years, and then I transferred to another division, which
12 were paid from May through October of 1999? 12 was Garrett General Aviation Services Division, because
13 A That's correct. 13 they wanted me to come down there and install some
14 Q Excuse me. May through October of 1993? 14 equipment and do some things. So I worked for them for
15 A Yeah. It was actually May 10th was the day that 15 about six or seven years. And then they merged all this
16 I left. 16 back in. And so I was there, left there for about six or
17 O Okay. Then you were paid through October of 17 seven years, and then I was back again, same place.
18 19937 18 O Okay. when you say you were back again, when
19 A Right. 19 was that? A couple years before --
20 Let's see. No. October through September, 20 A Probably the last three years. Probably '90.
21 yeah. 21 1990.
22 0 All right. And on October 1 of 1993, you began 22 Q All right. Why don't we do it this way. Just
23 participating and receiving your pension? 23 in very broad terms, you began employment in July of 1955.
24 A That's correct. 24 Correct?
25 O The incentive for you to voluntarily retire, 25 A Right.
3 (Pages 9 to 12)
602.254.1345 JD Reporting [email protected]
Case 2:O4—cv—OO424—ROS Document 344-2 Filed 12/10/2007 Page 3 of 4

MELVIN JONES November 11, 2005
Page 97 Page 99
1 A Right. I did. 1 Thanks, Mr. Jones.
2 Q Let me just clean it up. 2 THE WITNESS: Thank you.
3 Did you receive it in this form,in a form like 3 (whereupon the deposition was concluded at
4 this? 4 4:39 p.m.)
5 A I don't think so. I think it was different. I 5
6 think when I received it, it was on like a hard copy like 6 MELVIN THOMAS JONES
7 that you could put in a notebook. But, you know —- but I 7
8 don't think it was exactly like this. But it was ` B
9 information about your secured benefit account. 9
10 Q Okay. And looking at the next page, you see the 10
11 retirement income section "Normal Retirement Income"? 11
12 A Right. 12
13 Q And then there are some columns there. One is 13
14 "Value if you choose to transfer SBA to the retirement 14
15 plan." And then the next column is "Withdraw SBA and 15
16 purchase an annuity." It's giving two separate scenarios 16
17 there. 17
18 A Uh-huh. 18
19 0 And at the bottom is the total. Do you see 19
20 that? 20
21 A Uh-huh. 21
22 Q Do you recall ever having seen calculations for 22
23 you where there was a column that you chose to transfer 23
24 your SBA balance into the retirement plan and one if you 24
25 chose to retain the SBA balance and not transfer it into 25
Page 98 Page 100
1 the retirement plan? 1 C E R T I F I C A T E
2 A I don't —— I don't remember specifically, but I 2
3 may have. I don't remember seeing a projected balance. I 3 I. Christina L. Larsen, Certified Reporter for
4 just always remember getting a statement that showed what 4 the State OT AVlZ¤¤¤· dv CBVYTIYZ
5 I had. CurrBnt1y had_ 1n thErS_ 5 That the foregoing deposition was taken by me;
6 MR_ DELANY: L6t·S take E brEak_ 6 that I am authorized to administer an oath; that the
7 (The deposition was at recess from 4:25 p_m_ to 7 witness before testifying was duly sworn by me to testify
B 4:37 peme) 8 to the whole truth; that the questions propounded by
9 Q BY MR. DELANY: whije you were en eetive 9 counsel and the answers of the witness were taken down by
10 eme1eyee' were you ewere ef enyene eeme1e1niee ebeut the 10 me in shorthand and thereafter transcribed under my
11 SBA Offset te the eeeeiee benefit? 11 direction; that, upon request, the transcript was made
12 A I eee_t eeee]1 eeybeeye The eely ee the first 12 available to the witness to read and sign; and that the
13 time it really kind of hit me between the eyes was my exit 13 foregoing pages are a fu11' true` and accuraté trénscript
14 interview and when I realized what was there. I guess I 14 Of al] proceedings and testimony had upon the tak1ng of
15 said deposition, all to the best of my skill and ability.
15 didn't really realize what -- I don't remember anybody 16 I FURTHER CERTIFY that I em in ne wey re1eeee te
16 C0mp1Bining about it` 17 any of the parties hereto nor am I in any way interested
17 MR. DELANY: All right. That's all I have, 18 in the outcome hereefe
1B Mr. Jones, for today. We're leaving the depositions open 19 DATED at Phoenix. Ar1ZOna' this 20th day of
19 as we have with the others -- 20 November, 2005_
20 THE WITNESS: Okay. 21
21 MR. DELANY: -- to address document issues and 22 Chr1St1na Le Larsen
22 privilege issues, but we'll conclude for today. 0€rt1f1€d Reporter #50011
23 MS. KROLL: we will read and sign. 23 For the gtatg Of Arizona
24 MR. DELANY: But we have concluded. Most people 24
25 are usually going for the door much quicker than you are. 25
25 (Pages 97 to 100)
602.254.1345 JD Reporting [email protected]
Case 2:04—cv—00424-ROS Document 344-2 Filed 12/10/2007 Page 4 of 4

Case 2:04-cv-00424-ROS

Document 344-2

Filed 12/10/2007

Page 1 of 4

Case 2:04-cv-00424-ROS

Document 344-2

Filed 12/10/2007

Page 2 of 4

Case 2:04-cv-00424-ROS

Document 344-2

Filed 12/10/2007

Page 3 of 4

Case 2:04-cv-00424-ROS

Document 344-2

Filed 12/10/2007

Page 4 of 4