Free Memorandum - District Court of Arizona - Arizona

EXHIBIT A
-1,
Case 2:03-cv-02262-ROS Document 194-2 Filed 11/28/2005 Page 1 of 2

sou as sees was FR taser. near. assi? atssaarsas ro stseaasvseos e_a1/at
STATE OF CALIFORNIA
i ss. AFFIDAVIT OF JAY PRICE
County of Sari Francisco
Before me this date appeared Jay Price, lrnown to me to be a credible .
person over the age of eighteen, and upon his oath deposes and says:
"I am iay J. Price and have personal knowiedge of the facts stated
herein. l am competent to testify regarding these facts.
In zwproximately Mag 2000 I asked Lloyd Aubry to travel to the
state of ashinggn, con not tnteryiews, and provide me with his
impressions regar " g the job of a Client Manager (then named "Prenner
Banl Aubry and 1 spoke by tel¢%pho11e_regar ' g his impressions. Linda Edwards,
Es?. and Barbara Davis, sq. joined in our conversation because they were
de ending the Bank a%_ai.nst California state law overtime claims filed
against the Bank in the .alifcrnia Superior Court. Both were attorneys with
Paul Hastings, Janowski and Walker.
I understand Ms. Dave took notes dnrinitlie conversation; however,
I do not have a recollection of reading them, t en or later. Ms. Dayts and
Ms, Edwards were in Los Angeles while Mr. Aubry and I were in different
ottices in San Francisco.
At the time E was employed bythe Bank as an attorney in its Legal
Department and was responsible for the cases Ms. Edwards and Ms. Davis
were defending.
Today I ani still employed by the lnk as an attorney in its Legal
Department and tn that capacity I am responsible for the defense of the
Bank in the naatter Hutton v, `Bank of Amer1ca." •
4 at ‘
Jay J, ""°”"
Subscribed and sworn to before me this 23rd day of November, 2005.
-_s.@i,,,.c.....e~
N Public
My commission expires: Febmary 8, 2008
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Case 2:03-cv-02262-ROS

Document 194-2

Filed 11/28/2005

Page 1 of 2

Case 2:03-cv-02262-ROS

Document 194-2

Filed 11/28/2005

Page 2 of 2