Free Other Notice - District Court of Arizona - Arizona

EXHIBIT "A"
Case 2:04-cv-00384-ROS Document 567-2 Filed 06/16/2008 Page 1 of 10

Meritage v Hancock CV 04-0384 Defendants= Supplemental Deposition Designations Barbara Stanton (Sorget) Page 136 140 171 185 217 227 266 273 Line 25 23 6-22 3-24 24 12-24 18 1-24 267 14 218 21 Page 138 141 Line 22 11 Objection

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John Landon (11-15-04) 76 87 150 163 181 194 204 208 240 152 14-25 18 19 5 20-25 14 25 6 6-10 10 154 17 198 205 210 3 13 4 88 152 167 16 5 18

Steven Hilton (11-18-04) 22 25 27 30 67 69 97 106 146 155 22 2 24 13-19 18 24 10 15 6 20 69 72 98 110 147 157 4 23 17 3 10 18 23 26 29 6 8 25

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2 4 Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. In addition, as was properly objected to during the deposition and not cured, the questions asked were misleading because of the form of the questions and the fact that the questions were focusing a single clause of an agreement taken out of context of the entirety of the agreement and therefore the questions and answers given are not admissible under Fed. R. Evid. 104, 401 and 402. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage further objects that the line of questioning asking whether Meritage in agreeing to Hancock's employment agreement as written breaches Meritage's fiduciary duty is irrelevant because it does not tend to prove or disprove any issue of consequence in the instant case. Fed. R. Evid. 401 and 402. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite

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the fact that the deposition took place in November 2007. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage also objects for the lack of completeness causing the question and answer to be misleading. It should continue to the next question and answer, 39:6 to 39:10. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. In questions from 42:19 to 43:7 were properly objected to as lacking foundation since Mr. Hilton testified that he did not recall and remain so. Fed. R. Evid. 602. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage also objects for the lack of completeness causing the question and answer to be misleading. It should continue to the next question and answer, 69:14 to 70:1. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage objects on grounds that Hancock failed to disclose in

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compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007.

Roger Zetah 55 22 56 7

David Cornwall 164 173 201 205 213 215 220 229 246 3 9 16 23 7 4 2 24 5 165 181 205 212 214 219 228 230 248 22 24 16 25 21 5 15 18 13

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Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage also objects that Mr. Pidgeon's out-of-court declarations are hearsay because each were made after the existence of the particular relationship for which the question was about had terminated. Fed. R. Evid. 801. Meritage further objects to the elongated, repeated and compound question from 30:17 to 31:6. It was properly objected to and effectively withdrawn with no answer. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage also objects that Mr. Pidgeon's out-of-court declarations are hearsay because each were made after the existence of the particular relationship for which the question was about had terminated. Fed. R. Evid. 801. The withdrawn question at 43:22-25 is objectionable and should be removed. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in

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November 2007. Meritage also objects that Mr. Pidgeon's out-of-court declarations are hearsay because each were made after the existence of the particular relationship for which the question was about had terminated. Fed. R. Evid. 801. Lastly, for completeness and to avoid misleading the jury, the follow-up questions and answers at 55:24 to 56:24 should be included. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage also objects that Mr. Pidgeon's out-of-court declarations are hearsay because each were made after the existence of the particular relationship for which the question was about had terminated. Fed. R. Evid. 801. Lastly, the question and answer was properly objected to because it assumed facts not in evidence and presumed duties limited to the assumed facts and contract. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage also objects that Mr. Pidgeon's out-of-court declarations are hearsay because each were made after the existence of the particular relationship for which the question was about had terminated. Fed. R. Evid. 801. Lastly, for completeness and to avoid misleading the jury, the follow-up question and answer at 85:22 to 86:5 should be

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included. Meritage objects on grounds that Hancock failed to disclose in compliance with this Court's orders these deposition designations despite the fact that the deposition took place in November 2007. Meritage also objects that Mr. Pidgeon's out-of-court declarations are hearsay because each were made after the existence of the particular relationship for which the question was about had terminated. Fed. R. Evid. 801. Meritage also objects that the designation starts midanswer. Indeed, the colloquy that the answer belongs to begins at 121:17.

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