Free Other Notice - District Court of Arizona - Arizona

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1 Lydia A. Jones — 017178
' ROGERS & TI-IEOBAILD LLP
2 7 The Camelback Esplanade, Suite 850
_ 2425 East Camelback Road
3 7 Phoenix, Arizona 35016
I Telephone: (602) 352-5582
4 7 [email protected]
5 7 Attorneys for Plaiiitiffs
6 UNITED STATES DISTRICT COURT
7 7 ARIZONA DISTRICT
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7 KAYE HUTTON, as an indixjidual and No. CV2003-2262~Pl1X-ROS
·· 9 · rriprcsenmtive of a class consisting of _
7 o ers similarly situated, DECLARATION CIF OPT—IN
10. _ _ _ mths COOPER
. 7 Plaintiftj it ·
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12 7 VS" 7
13 7 BANK OF AMERICA, N.A.,
7 Qefendant. ___
14 r“ "— 1
15 7 1. I, Julia Cooper, am over th.e age of 18 and I make this declaration based
16 7 upon my personal knowledge, unless otherwise stated.
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‘ J 7 2. I am an opt-in plaintiff in this action and am seeking retroactive
_ ' 18 overtime compensation tbr the hours in excess of 40 that I worked on
19 7 behalf of the Bank of America trom October 31, 2001 through March
_ 2002.
so 7
21 7 3. From October 31. 2001 through March 2002 I worked on average 9-12
7 hours per day for the Bank.
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23 4. The client manager position is a sales position. As such, there was
24 7 pressure on my supervisors, the market managers, to ensure that sales
goals and targets were met. This was especially tme during 2001 and
25 7 2002 when the Bank increased the sales goals for the client manager
, position.
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Case 2:03—cv—02262—ROS Document 162-2 Filed 10/13/2005 Page 1 012

1 5 . Dining 2001 and through March 2002, I was told that the client
A manager position was not a 40 hour a week job, and that as client
3 manager, I had to "do what 1 have to do," to meet the Ban1c’s sales
goals and targets. 1
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4 i 6. I have read plaintiff Kaye Huttorfs, on behalf of herself and the opt-in
5 plaintiffs, Objections and Responses to Defendanfs First Set of
- Interrogatories and First Request for Production of Documents, and
6 based my conversations with other client managers, I believe they
reflect the experience ofthe collective and I hereby adopt and
7 incorporate herein by reference Ms. I—Iutton’s Objections and
8 Responses.
9
I 0 I cleelare upon the penal of perjury that the above statements are true.
I1
,2 Jun cesper
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14 DATED this 26*1* day of August 2005. 1 1 ‘
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Case 2:03—cv—02262—ROS Document 162-2 Filed 10/13/2005 Page 2 of 2

Case 2:03-cv-02262-ROS

Document 162-2

Filed 10/13/2005

Page 1 of 2

Case 2:03-cv-02262-ROS

Document 162-2

Filed 10/13/2005

Page 2 of 2