Free Other Notice - District Court of Arizona - Arizona

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Mishka L. Marshall (#016641) MARSHALL LAW GROUP, P.C. 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Telephone: 602/274-7873 Facsimile: 602/274-8207 Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

KESORN HENDERSON Case No. CV 04 0754 PHX JAT Plaintiff, V. GUARDSMARK, LLC, a Delaware corporation doing business in Arizona; GUARDSMARK, INC. a Delaware corporation doing business in Arizona;
JOHN and JANE DOES I-X; BLACK CORPORATION I-X, WHITE LIMITED LIABILITY COMPANIES I-X,

NOTICE OF RULE 30(B)(6) DEPOSITION

Defendants.

YOU ARE HEREBY NOTIFIED that pursuant to Rules 26 and 30(b)(6) of the Federal Rules of Civil Procedure, a deposition will be taken upon oral examination of the person(s) whose names are stated below, at the time and place stated below, before an officer authorized by law to administer oaths. If the names are not known, a general description sufficient to identify those persons is given below. ENTITY TO BE EXAMINED: Guardsmark, LLC

Case 2:04-cv-00754-JAT

Document 54

Filed 07/21/2006

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MATTERS ON WHICH EXAMINATION IS REQUESTED: Plaintiff seeks to depose representative(s) of Defendant who may testify regarding Plaintiff's complaints of age, race, national origin and gender based harassment and discrimination, Defendants' investigation of Plaintiff's complaints and what, if any action was taken. The corporate designee should be able to provide detailed

testimony regarding investigation into Plaintiff's complaints, including but not limited to any interviews conducted and statements obtained, and any corrective action taken by Defendant. The corporate designee(s) should further be able to testify about Defendants' policies, procedures and practices regarding employment discrimination complaints, Defendants' no slur policy, training and remediation; Defendant's selection of Lisa Benedict for the supervisor position; and Defendant's refusal to assign Plaintiff to Chase Manhattan Bank or any other post Plaintiff requested. The designee(s) should also be able to testify about all information contained in Defendant's answer, initial and supplemental disclosure statements; and responses to Plaintiff's interrogatories and request for production of documents. DATE AND TIME OF DEPOSITION: Friday, July 31, 2006 at 10:00 a.m. PLACE OF DEPOSITION: Marshall Law Group, P.C. 777 E. Thomas Rd., Suite 210 Phoenix, Arizona 85014 602/274-7873

Please notify this office immediately if a translator, language interpreter or reasonable accommodations are required. Submitted this 21st day of July, 2006. MARSHALL LAW GROUP, P.C.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 District of Arizona. s/Mishka L. Marshall Mishka L. Marshall s/Mishka L. Marshall_ Mishka L. Marshall 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Attorney for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that on July 31, 2006 I transmitted by electronic filing the foregoing Notice of Rule 30(b)(6) Deposition to the United States District Court for the

Case 2:04-cv-00754-JAT

Document 54 - 3 Filed 07/21/2006

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