Free Objection - District Court of Arizona - Arizona

EXHIBIT 5
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Case 2:03-cv-02262-ROS Document 298-15 Filed O9/O1/2006 Page1 0f4

1
» Q, l UNITED STATES DESTRICT COURT
2 ARIZONA DISTRECT
3 __,_ w”____ _ _______ Mmmm W__________
)
4 KAYE SUTTON, es en individual )
end representative of a class )
5 consisting of others similarly )
situated, )
6 )
Plaintiff, )
7 >
vs. ) N0. CV2003—2262—FRX—ROS
8 }
BANK OF AMERICA, N.A., )
9 )
Defendant. )
10 _______ MmWm”___ ___________mm__ M)
11
i 12
14
15
16 DEPOSITION OF GRACE DUVAL
17
Tucson, Arizona
18 January 23, 2006
10:00 a.m.
19
20
21
22 MELANIE J. EUELDER
Certified Reporter #50343
23 EATON, GREEN & WILLIAMS, INC.
549 N. Sixth Avenue
__ g 24 Tucson, Arizona 85705
` 1 (520)623—0593 800—759—9022
25
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ll?
1 Q Making any comments or changes to any of the
2 brochures?
3 A No.
Q Q And the client manager position sells bank
5 product; is that correct?
6 A Yes.
7 Q What kind ot bank product does the client
8 manager sell?
9 A The client manager would determine, based on
l0 the individual client need, what was the best product or
11 service suited to the client, and sell that product or
12 service appropriately.
l3 Q Let's talk about the line of products that a
lé client manager has the ability to sell to a client.
15 Okay. Mortgages?
l6 A Yes.
ll Q Lines of credit?
38 A Yes.
29 Q Checking accounts?
20 A Yes.
21 Q Loans. What else?
22 A Certificate of deposits, car loans, boat
23 loans. Any deposit product offered by Bank of America
2Q investments within their scope.
25 Q And the investment would be a Bank of America
case 2:03-cv-02262-ROS I`E>7?>j5B°§w©ntGiQ9°§§ils & ii1aieIaLd9F7B°1?7200I6NC Page 3 of 4

l7B
1 do more complicated business loans, although we do
2 business loans in premier for people that have the
3 background. But what we like to do is get them engaged
4 with our client as the experts.
5 Q Bo you ever have joint meetings where you give
6 presentations to small business client managers?
7 A There's only two, but yes, I will meet with
B them.
9 Q Who are the two small business client managers
l0 in Tucson?
ll A That would be Kim Lane and Adriana Kong.
l2 Q Who is their supervisor?
13 A Lynn Searles.
ld Q And what was the meeting that you had with
15 them?
l6 A I met with both Kim and Adriana to talk about
l7 how we could do joint business in 2006.
18 Q Did you talk to them at all about overtime?
l9 A No.
2O Q In terms of incentive plans for client
21 managers, are they based in part on products sold?
22 A Yes.
23 Q What's your understanding of the relationship
24 between incentive bonus and product sold for a client
25 manager?
Case 2:03-cv—O2262-ROS ]l)p6%Bn§1éntG§§F8@i\5 & i€1ieLdLi>4§2OOIéQC Page 4 of 4

Case 2:03-cv-02262-ROS

Document 298-15

Filed 09/01/2006

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Case 2:03-cv-02262-ROS

Document 298-15

Filed 09/01/2006

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Case 2:03-cv-02262-ROS

Document 298-15

Filed 09/01/2006

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Case 2:03-cv-02262-ROS

Document 298-15

Filed 09/01/2006

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