Free Reply to Response to Motion - District Court of Arizona - Arizona

EXHIBIT L
Case 2:O3—cv—O2127-I\/IHI\/I Document 88-7 Filed O9/19/2005 Page1 0f3

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
Abel Ruiz Diaz, )
Ubaldo Moreno, )
Piedad H. Renteria, )
Alejandro D. Mancilla, )
V
Plaintiffs, )
)
vs. ) Case No.:
) CV'03—2127PHX—MHM
Eagle Produce Limited Partnership, ) —
Phoenix Agro—Invest, Inc. )
)
Defendants. )
______________________________________ )
CIDEPOSITION OF JOHN REDMOND A
Phoenix, Arizona
February 15, 2005
1:30 o'clock p.m.
Prepared by:
Deborah L. Tucker, RPR
_ Certified Court Reporter
y g (Copy) No. 50464
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22
1 Q. BY MS. BRIDGE: Where did the workers get
2 their paychecks?
3 A. They got them at the farm office.
4 Q. Was there someone in the office in charge of
5 payroll also?
6 A. The ladies in the office would distribute the
7 paychecks at a pay window, and the paychecks came from
8 Scottsdale.
9 Q. Who employed the ladies in the office in 2002?
10 A. Eagle Produce.
11 Q. Who owns the tractors that Crew 94 uses?
12 MR. NEWTON: Foundation.
13 If you know, answer.
14 THE WITNESS: A lot of them belong to Eagle
15 Produce. And I think, but I don't know for sure, that
16 some of them belong to John Deere.
17 Q. BY MS. BRIDGE: Does Phoenix Agro also own the
18 tractors?
19 A. No. A
20 Q. Who owned the land that the workers worked on?
21 A. Part of it is leased land and part of it is
22 owned by Phoenix Agro.
23 Q. How much of the land is owned by ——
24 A. I don't know.
25 Q. —— Phoenix Agro?
COASH & COASH, INC. (602) 258-1440
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