Free Statement - District Court of Arizona - Arizona

1
*I? 1 UNITED STATES DISTRICT COURT
2 ARIZONA DISTRICT
3 _________W F____ _m_________w ____ M ____M wm
)
4 KAYE HSTTON, as an individual )
and representative of a class )
5 consisting of others similariy )
situated, }
6 )
Plaintiff, )
7 }
vs. ) No. CV2003—2262—?HX~ROS
8 )
BANK OF AMERICA, N.A., }
9 )
Defendant. )
10 mww____mw____Mw ____ _m ____ Mm____)
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. 12
13
14
15
16 DEPOSITION OF GRACE DUVAL
17
Tucson, Arizona
18 January 23, 2006
20:00 a.m.
19
20
21
22 MELANIE J. BUILDER
Certified Reporter #50143
23 EATON, GREEN & WILLIAMS, INC.
$@9 N. Sixth Avenue
J. 24 Tucson, Arizona 85705
T {520)623—0593 B00—759—9022
25
(38892. ·5 · '$ Brut- *$° · -•630§0••• QQQ O
EATON, GREEN & WILLIAMS, IEC.

IQ2
l Q So in other words, if I started as a growth
2 client manager here in 2006, would you provide me with a
3 list of Bank of America clients in which to try to
4 develop a client manager relationship with?
5 A Yes.
6 Q And I would take that list of bank clients and
7 contact them and see what product I could sell them?
B A I would contact them to start a relationship
9 process.
l0 Q Okay. You personally would contact them and
ll say, I’m going to have —— I'm so—and~so, and I'm going
12 to have my new client manager, insert name, and I'd like
I3 to introduce you to him, or something like that?
ld A No, I wouldn't. I mean, the client manager,
15 when they're assigned the list of clients —-
I6 Q Um~hum.
l7 A —— the very first thing they need to do is, of
t 18 course, mate contact.
29 Q Okay.
20 A Let‘s say, make contact, their job is to be in
2l touch with the client, to build trust, then talk about
22 what financial goals these clients need to achieve.
23 Q Okay. And then to sell product, once you get
24 that trust?
25 A If it's a product they need, yes.
Case 2’O3‘°"‘O2262‘ROS %%°A%?,“* 駧i·é€¤ r FVUQQQQ/i?;@@90@NcP&ge 2 of 4

2l6
l Q And you said that you determined it was
2 basically a time management issue?
3 A It was a variation. Time management,
4 organization. Mostly organization, and not using the
5 support partners that she had available.
6 Q Okay. So on the times where Stephanie would
? tell you she could not adequately get her job done
8 within 40 hours a week, you indicated that essentially
9 you would try to work with her in time management,
I0 believing that she could do her job within 40 hours a
ll week, or encourage her to use a support person?
l2 A That would be the people that supported her,
23 assistants. She tended to do it herself, instead of let
14 the support team ....
l5 Q And who was the support team?
I6 A That would be the premier relationships
17 center.
IB Q Which is where?
19 A In Tempe.
20 Q When was that introduced, do you remember?
2l A Before I came to premier.
22 Q Do you ever remember Stephanie Ciark
23 indicating to you that the §ob actually required 50 or
24 60 hours a week, as opposed to 40?
25 A Not 50 or 60.
Case : —cv- . ·• ocumen : - · ne 06262006 age30 4
EATON, GREEN & WILLIAMS, INC.

219
l A No.
2 Q Do you remember hearing from any source that
3 Stephanie Ciark was working 55 to 60 hours a week?
4 A No,
5 Q I take it that surprises you?
6 A What surprises me?
7 Q That she was working 55 to 60 hours a week.
8 A It would surprise mer
9 Q Never heard that?
10 A That she was working 55 to 60 hours a week and
li not recording it; is that the question?
E2 Q Yes.
$3 A That surprises me.
14 MR. CEESTER: Can we go off the record?
15 (A discussion was held off the record,
16 after which the foliowing further
17 proceedings were had herein:)
18 BY MR. O'CONNOR:
19 Q Do you ever recall having any conversations
20 with Stephanie Clark about other client managers’
21 overtime work?
22 A No.
23 Q Do you remember having conversations with
2% Stephanie Clark about any other client manager‘s either
25 job performance or hours worked?
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Case 2:03-cv-02262-ROS

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