Free Notice of Deposition - District Court of Arizona - Arizona

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Mishka L. Marshall (#016641) MARSHALL LAW GROUP, P.C. 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Telephone: 602/274-7873 Facsimile: 602/274-8207 Attorney for Plaintiffs

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

ERNEST E. PETERSON, JR. and CELESETE M. PETERSON, husband and wife, Plaintiffs, V. AMERICA WEST AIRLINES, INC., a Delaware corporation doing business in Arizona; JOHN and JANE DOES I-X;
BLACK CORPORATION I-X, WHITE LIMITED LIABILITY COMPANIES I-X,

Case No. CV-04-0141 PHX ROS NOTICE OF DEPOSITION

Defendants.

YOU ARE HEREBY NOTIFIED that, pursuant to Rules 26 and 30 of the Federal Rules of Civil Procedure, deposition will be taken upon oral examination of the person whose name is stated below at the time and place stated below before an officer authorized by law to administer oaths. If the names are not known, a general description sufficient to identify those persons is given below. ENTITY TO BE EXAMINED: America West Airlines, Inc. MATTERS ON WHICH EXAMINATION IS REQUESTED: Plaintiff seeks to

Case 2:04-cv-00141-ROS

Document 76

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depose representative(s) of Defendant who may testify regarding Plaintiff's complaints of harassment and discrimination, Defendants' investigation of Plaintiff's complaints and what, if any action was taken. The corporate designee(s) should also be able to testify in detail about all steps taken during the processing of Plaintiff's application for employment; the fuel leak that led Plaintiff to deplane the aircraft and Brent Hernisen's subsequent aggressive behavior toward Plaintiff, including Defendant's investigation and response to Mr. Hernisen's conduct. The corporate designee(s) should further be able to testify about Defendant's refusal to allow Plaintiff Celeste Peterson to use travel vouchers on June 12, 2003 as well as Defendant's refusal to sell Mrs. Peterson tickets for travel on the same day. The corporate designee(s) should be able to testify about Defendants' policies, procedures and practices regarding employment discrimination complaints, training and remediation; Defendant's policies and procedures regarding maintenance problems that involve fuel spillage and steps a line maintenance supervisor is to take in the event of fuel spillage. The designee(s) should also be able to testify about Plaintiff's application for other positions with Defendant, Defendant's decision to select other candidates and the reasons that Plaintiff was not selected for any of the positions for which he applied. The designee(s) should also be able to testify about Defendant's policy regarding internet access for nonwork related matters, including any monitoring conducted of employees' email and internet usage and disciplinary measures taken for violation of Defendant's internet/email policies. The designee(s) should be able to testify about all

information contained in Defendant's answer, all disclosure statements; and responses to Plaintiff's First Set of Interrogatories and First Request for Production of Documents to Defendants. The designee(s) should be able to testify about the

matters outlined herein for the time period from January 2001 to the present.

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DATE AND TIME OF DEPOSITION: Friday, December 16, 2005 at 9:30 a.m. PLACE OF DEPOSITION: Marshall Law Group, P.C. 777 E. Thomas Rd., Suite 210 Phoenix, Arizona 85014 602/274-7873

Please notify this office immediately if a translator, language interpreter or reasonable accommodations are required. Submitted this 28th day of November, 2005. MARSHALL LAW GROUP, P.C. s/Mishka L. Marshall Mishka L. Marshall 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Attorney for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that on November 28, 2005 I transmitted by electronic filing the

15 16 17 18 19 20 21 22 23 24 25 26 s/Mishka L. Marshall Mishka L. Marshall foregoing Notice of Deposition to the United States District Court for the District of Arizona and mailed the same to: Troy P. Foster Justin S. Pierce Lewis & Roca, LLP 40 N. Central Ave. Phoenix, Arizona 85004-4429 Attorneys for Defendant

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