Free Objection - District Court of Arizona - Arizona

EXHIBIT 1
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Case 2:03-cv-02262-ROS Document 299-3 Filed O9/O1/2006 Page 1 of 4


1
1 IN THE UNITED STATES DISTRICT COURT
A FOR THE DISTRICT OF ARIZONA
* 2
3 No. CV2003—2262~PHX—ROS
4 KAYE K. HUTTON, as an individual and as representative
of a class consisting of others similarly situated,
5
Plaintiff,
6
BANK OF AMERICA, N.A., A¢’%w*§
8
Defendant.
9
10 VIDEOTAPE DEPOSITION OF: KAYE K. HUTTON
August 17, 2005
ll
I2 PURSUANT TO NOTICE, the videotape deposition of
KAYE K. HUTTON was taken on behaif of the Defendant at
13 422 East Vermijo, Suite 309, Downtown Executive Center,
Colorado Springs, Colorado 80903, on August 17, 2005, at
' 14 9:35 a.m., before Yvonne Jorensen Wallace, Registered
Professional Reporter and Notary Public within Colorado.
15
A P P E A R A N C H S
‘ { l 6
For the Plaintiff:. LYDIA A. JONES, ESQ.
17 Rogers & Theobald, LLP
2425 East Cambelbaok Road
IB Phoenix, Arizona 850l6
19 For the Defendant: CHARLES L. CHESTER, ESQ
Ryley Carlock & Applewnite
20 One North Central Avenue
1 Suite 1200
2l Phoenix, Arizona 85004~44l7
Y 22 Also Present: Barbara Horn, Videographer
23
; 25 _
H U {NSF + Ge I Si, i UC . (303] 832-5966 me oar sea sure Bum
Denver Colorado EOEOB
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case 2:O3—cv—O2262-ROS Docu em zessrrrrgnrrsa 09/ 1/2Id®·s< '·“°P§@s‘*Q Or 4

KAYE K. HUTTON
il6
I A. Or a banking center, they're a little bit more
2 high touch. So it just led you to another product to
3 sell.
4 Q. And how about their banking preferences? You
ii 5 try to learn that so you could figure out what products
ay 6 might be a good match?
in 7 MS. JONES: Objection to form.
B Q. (BY MR. CHESTER) Kind of the same concept you
9 just talked about.
l0 A. You know, preference on how they do their
li banking would tell you what's going to be the best
l2 products to fit them. Most people say, "Okay. I have a
13 telephone. I just call up and I get my balance." Weii,
14 we ali know that that‘s not happening anymore. So you
I5 know that you need to get them an access ID, or you need
16 another product that gets them so that they can do
I? what's favorite to them more easily. So it’s just
18 picking the products that kind of fit into their
19 preference.
20 Q. How about —~ I'm on the second page of this
2l Exhibit 6. Does it heip you to perform your job if you
22 know what their savings and investment needs are, what
23 their goals are?
24 MS. JONES: Objection to form.
25 A. Yes. Because what, in the future, can I sell
Case 2:O3—cv—O2262-ROS Document 299-3 Filed O9/O1/2006 Page 3 of 4

KAYE K. BUTTON
117
1 yon? Okay? You have a kid that's turning six. Do you
2 have college planning for him? Can 1 set you up a
3 college planning mutual fund? It all helps in driving
4 the saies and what further —— what further needs does
5 this client have to sell them. in
6 Q. (BY MR. CHESTER) Okay. Same thing with F1
7 regard to retirement goals, retirement needs? sd
8 A. Yes. Because, one, do you have an IRA now?
9 If not, shouldn't we start ~~ shouldn't you start a ,
10 retirement plan? Or is it at another institution? Can
11 E sell you one here and get it moved? _
12 Q. Credit and borrowing, same ~~ same concept? _
13 If you know what their needs are, what their goals are, 1;
14 it's easier to match products?
15 MS. JONES: Objection to form.
16 A. It's easier to get the saie lined up, because EQ
17 if you know they're buying a home in six months, you
18 have it penned in your future sales bucket to go back
19 and get that loan.
20 Q. (BY MR. CHESTER) Okay. Let me show you
21 what's marked as Exhibit 7. Have you ever seen this J
22 document before? Q
23 A. Yes. nl
24 Q. What is this document?
25 A. The bank's vision of what our role is at a
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