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

EXHIBIT I
Case 2:O3—cv—O2127-I\/IHI\/I Document 88-4 Filed O9/19/2005 Page1 0f3

_A` 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'03—2I27PHX—MHM
Eagle Produce Limited Partnership, )
Phoenix Agro-Invest, Inc. )
>
Defendants. )
____________________________________ >
DEPOSITION OF GILBERTO VIGUERIA
Phoenix, Arizona
February I6, 2005
9:10 o'clock a.m.
Prepared by:
Deborah L. Tucker, RPR I
I Certified Court Reporter
i (Copy) No. 50464
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31
1 THE WITNESS: During the day.
2 Q. BY MS. RODIS: Okay. When you were a tractor
3 driver, how many workers were on the day shift on
4 average?
5 MR. NEWTON: Form, foundation.
6 THE WITNESS: Well, the average on the day
7 shift would have been, well, from 16 to 32.
8 Q. BY MS. RODIS: Sixteen to 32 workers?
9 MR. NEWTON: Form, foundation.
10 THE WITNESS: Right.
11 Q. BY MS. RODIS: And on average how many workers
12 were on the night shift?
13 MR. NEWTON: Form, foundation.
14 THE WITNESS: Sometimes five, seven.
15 Q. BY MS. RODIS: Did you prefer to work days or
16 nights?
17 A. Days.
18 Q. Why?
19 A. Because at night you can't see anything. It's
20 really dark.
21 Q. Is it harder to drive at night?
22 A. Yes.
23 Q. When you were working under the supervision of
24 Chester who did he have driving nights?
25 MR. NEWTON: Form.
COASH & COASH, INC. (602) 258-1440
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