Free Reply - District Court of Arizona - Arizona

Merclzzznt Transaction Systems, Inc.
vs.
Nelcela, Inc., et al.
And related Cross and T lzird-Party Claims
N0. CI V-02-1 954-PHX-MHM
l Nelcela, Inc., Len Campagna and Alec Dollarhide’s Reply
Statement of Fact in Support of Their Motions for
Partial Summary Judgment .
EXHIBIT D
(Relevant Deposition Testimony l
of Rose Ana Iniguez)
Case 2:O2—cv—O1954-I\/IHI\/I Document 362-5 Filed O4/24/2006 Page 1 of 4

$l¥Q § IN THE SUPERIOR COURT OF THE STATE OF ARIZONA Q
I IN AND FOR THE COUNTY OF MARICOPA Q H
EBOCOM, INC., et al., * i
Plaintiffs, * Q
~k ,
VS. * Case #CV200l—009026 0
* Case #CV200l—0l9l26 $
; NELCELA, INC., et al., * (Consolidated) , I
' Defendants. * i f
V ~k~k*9<~k—k~}<~k—k·k:k-~k~k~)<*>\·~k*~k—k~k~)<-k:* MERCHANT TRANSACTION SYSTEMS, INC.,* I
Plaintiff, *
* y
VS. * y
* C
y NELCELA, INC., et al., *
i Defendants. * § T
9<—k—9c~k*—k-kick9<*~J<~k9<*~k~k~k—)<¤• NELCELA, INC., * g
Third Party Plaintiff, * ;
* .
VS_ * 1
uk
POST INTEGRATIONS, INC., an *
’ Illinois Corporation; EBOCOM, INC.,*
a Delaware Corporation; MARY GERTDS*
and DOUGLAS McKINNEY, husband and *
wife; JOHN and JANE DOES I—X; ABC *
Corporations I—X; ABC Limited *
Liability Companies I—X; and ABC *
Partnerships I—X, * ;
Third Party Defendants.* {
l DEPOSITION OF ROSE ANA INIGUEZ i
Wednesday, September I5, 2004 f
Phoenix, Arizona 2
10:00 am. - -
dI‘IVBI‘a¤¤ I1IX
I PREPARED FOR: . cuunr nspunrzns
Attorney Manolio ,
i I
365E.CORONADOROAD,SUWE150 ·
BY: PHOENIX, ARIZONABSOO4
p F Rochelle L. Dobbins, RPR pg%£S;E£z
“ “; AZ Certified Court Reporter #5072l '£$j§;f££§“ y
I Case 2:O2—cv—O1954-I\/IHI\/I Document 362-5 Filed O4/24/2006 Page2of4

101
1 A I can just remember being on the’Ne1cela
2 system roughly a year, possibly more. I don't remember
3 exactly when we converted off of that system.
4 Q Do you remember when you did convert off the
5 Nelcela system, what happened? Did someone come in and I
6 physically remove the Nelcela system and give you a new i
7 system? What happened? ,
8 A I don't recall anybody coming in and
9 removing the Nelcela system. I don‘t remember exactly e
10 how that happened. I t
11 Q Do you remember how thenew system was put I
12 in place? t
13 V MR. QUIGLEY: Object to form, foundation.
14 _ A I just know that the system was available. E
15 X Q The new system? i
16 A The new system. · 1
17 Q How did the new system, the Ebocom system,
18 differ from the Nelcela system?
19 A Functionality. It still had the same `
2O functionality.
21 Q Same functionality as the Nelcela system?
V 22 A All systems, basically, have the same
23 functionality. .
24 Q Anything notably different? Anything that X
25 you can remember different between the Nelcela system
_ Dnivsn AND mx y j I
Case 2:O2—cv—O1954-I\/IHI\/I Document 362-5 Filed O4/24/2006 Page3of4

102 i
1 and the Ebocom system that you are now using? g
2 A. The only thing I can remember is the Ebocom . g
3 system had a different type of format when we converted g
4 to it. _ ~ E
5 MR. QUIGLEY: Is it okay to take a break? p
6 (A BRIEF RECESS WAS TAKEN)
7 Q Right before we took a break, we were
8 talking about switching from the Nelcela system to the y 3
9 Ebocom system, correct? 4
10 A Yes. i {
11 Q And you mentioned very specifically earlier, Q
12 when you switched from using CIA as your main system to i
13 MSA, there were specific functions that you knew were E
14 enhanced from the CIA system, correct? i
15 X A Yes. 4
16 Q And when you switched from MSA to Nelcela, · E
17 are there any specific functions that you can recall 1
18 being different between the two systems? i
19 A I think we went over those. I couldn't i
20 print, I couldn't see detail.
21 Q Those were what you considered to be
» 22 problems, correct?
23 A Yes. , E
24 Q I don't want to know what the problems were. L
25 A There were also system differences.
Daivsa AND Nix i
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