Free Motion for Summary Judgment - District Court of Arizona - Arizona

Exhibit 2

Case 2:02-cv-02157-SRB

Document 50-3

Filed 05/01/2006

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Case 2:02-cv-02157-SRB

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Case 2:02-cv-02157-SRB

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Case 2:02-cv-02157-SRB

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DEPOSITION

OF CHASE BRIGHT- November

21, 2005

4

1 2 3 4 5 6 7 8 BY MR. BRINTON: a witness Certified truth, herein, Reporter

CHASE having been

BRIGHT, first duly sworn by the and nothing but the

to speak the truth and testified

was examined

as follows:

EXAMINATION

Q. A. Q. A. Q. A.

Please give me your complete name.
Chase Arnold Bright. currently is with whom?

9 10 11 12 13 14 15 16
17

And your employment

J.P. Morgan Chase. In what capacity? I'm currently the human resource business partner

in Chase Bankcard Services. Q.
refer

Just for the ease of any conversation, may we
to that bank as the bank?

A. Q.
resource A.

Yes.
Why do you call yourself business That's partner? that I currently generalist. I was the employee with J.P. Morgan have. It is the HR -- the human

18 19
20 21 22 23 24 25

the title

equivalent

to a human

resources

Just for clarification, relations in 2001. Q. Were your duties manager for the western

region

in 2001 any different

than they

GRIFFIN AND ASSOCIATES Case 2:02-cv-02157-SRB Document 50-3

(602)

264-2230

Filed 05/01/2006

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DEPOSITION

OF CHASE BRIGHT-

November

21, 2005

5

1 2

are today?

A. Q.
A.

Yes. What were they in 2001?
2001 the -- my duties of discrimination including consisted of conducting region any by

3 4
5 6 7 8 9 10

investigation any Chase

in the western

employee,

any line of business. reviewing reduction in

It also included force plans, including responding

to any administrative of Labor.

complaints,

the EEOC,

the Department

Q. A. Q. A. Q.

When did you start employment with the bank?
September In what of 1994.

11
12 13

capacity?

I was hired as an employee relations officer.
When did you first start to gain any information on how to conduct harassment? an investigation into a

14
15 16 17

or expertise complaint

of sexual

A.

That probably would have started in the late I worked for Sentry Insurance as an HR

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21 22 23 24 25

'80s, early '90s. representative. Q.
1994, Well,

if you started

with the bank

in September in --

how is it you worked Excuse me, the me. '70s.

with Sentry have been

Insurance

A.
excuse would

It would My dates

-- '94, '84 -It probably

are wrong.

have been the early

'80s. Insurance?

Q.

How long were you with Sentry

GRIFFIN AND ASSOCIATES Case 2:02-cv-02157-SRB Document 50-3

(602)

264-2230

Filed 05/01/2006

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Case 2:02-cv-02157-SRB

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Case 2:02-cv-02157-SRB

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Case 2:02-cv-02157-SRB

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Case 2:02-cv-02157-SRB

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