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

EXHIBIT J
Case 2:O3—cv—O2127-I\/IHI\/I Document 88-5 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, )
` >
Plaintiffs, )
)
vs. ) Case No.:
) CV'O3—2127PHX—MHM
Eagle Produce Limited Partnership, )
Phoenix Agro—Invest, Inc. )
)
Defendants. )
____________________________________ >
DEPOSITION OF BEATRIZ LIZARRAGA
y
Phoenix, Arizona
February 16, 2005
2:11 o'clock p.m. ps
Prepared by:
Deborah L. Tucker, RPR
Certified Court Reporter
p § (Copy) No. 50464

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64
1 write—up, so we know exactly, you know, what the problem
2 is.
3 Q. Okay. Do you know if the manual has any
4 section that talks about the process an employee goes
5 through if they disagree with a warning that is given to
6 them?
7 A. Yeah. It's in here somewhere. It's like you
8 have to go to your immediate supervisor. And then,
9 like, if your immediate supervisor —- like, you know,
10 you don't degree, then you can go to, like, the ranch
11 manager, which is, like, Jimmy Byrd. If Jimmy Byrd
12 wasn't in agreement, then you go to Steve Martori, which
13 is the owner.
14 Q. Okay. That's good. You don't have to look
15 for it.
16 Do you know if a worker has ever gone through
17 that process?
18 A. Oh, yeah, we've had several workers go through
19 that process.
20 Q. Who?
21 MR. NEWTON: Form.
22 THE WITNESS: Cynthia Valdez.
23 Q. BY MS. CAMPBELL: Who is she?
24 A. She was one of my dispatchers.
25 Q. What happened to her?
COASH & COASH, INC. (602) 258-1440
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