STATE OF ARIZONA
_ ss. AFFIDAVIT OF SANDRA GUTI-HIE
County of Maricopa
Before me this date eippeared Sandra Guthrie, known to me to be a credible person
over the age of eighteen, an upon her oath deposes and says:
‘“I am Sandra Guthrie and make this affidavit upon my personal
knowledge.
I am the Administrative Assistant to the Market Manager for the
Scottsdale Market of the Premier Banking group of the Bank. of
America. Among other duties, I was responsible for receiving and
processing time sheets submitted by Client Managers during the time
p they were overtime eligible.
To ir; knowledge, all Client Managers in the Scottsdale Market
recor ed all the hours they worked. Our Market Manager, in my
presence, and I periodically reminded Client Managers to record all
the hours they worked. On occasion, questions arose about what
activities constituted work and those questions were answered.
I did encourage Client Managers to take lunch breaks to recharge
themselves, but they were not required to do so.
All Client Managers were paid for all time recorded.
I understand the concept of docking. Although the Client Managers
were overtime eligible, there was no policy or practice to dock t eir
pay while I was responsible for receiving and processing time sheets.
lf a Client Manager had docked time while he or she was overtime
eligible, it would be a mistake insofar as I know?
Sandra Guthrie
~//»
Subscribed and sworn to before me mis-{1 day of (ELO/9€’l· , 2005.
Notary Fublic n
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Case 2:03-cv—02262—FlOS Document 283-27 Filed 06/26/2006 Page 1 of1
Case 2:03-cv-02262-ROS
Document 283-27
Filed 06/26/2006
Page 1 of 1