Free Brief - District Court of Colorado - Colorado

Case 10:24 3224757 12/28/2005 1:03-cv-02073-WDM-KLM

DocumentBEARTOOH 221-6

FORD Filed

12/28/2005

PagePAGE 201 1 of

AFFIDAVIT

OF TONY A HOUSE )

Si ArE OF
COUNTY

MONTANA

)
OF STILLWATER)

I am over the age of 18 and competent perjury to the followlng facts: 1

to make this affidavit.

I hereby

swear under the penalty of

My name is Tonya House and I reside at 15 Sandstone Columbus, Montana.

Court Road, PQB 327, in

2

I worked at Larry Miller Toyota in Denver, as the Finance Director, from January 1999 to June 2001. During that time. there were on average of ninety employees

at any

given time at both Larry Miller Toyota and Larry Miller Used Car Supermarket. There were never Below is a list of fewer than 15 employees at either location during my employment. employees, and the general managers they reported to. In addition to this list, there were approximately fifteen service technioians at Larry Miller Toyota and four at the used car location. There was also a staff of lot technicians. have also included a list of Corporate employees whom department managers reported directly. At that time there were also other Corporate employees working for LandCar.

I

1999 Mark Dundun
Mark Kalon TonyaHouse
Roberta Pulse Robert Silcox Dana Lily Sandi Shaner

GM

2000..June 2001 Bob Cockerham Richard Newendyke John Petro Director TonyaHouse Roberta Pulse Dennis Sohoenfeld Connie Coyne Sandi Shaner Audra Holzer Christi Bollig Mindy Allhands Sharon Bartesona Joscelyn Gilleroy Rhonda Wright

GM

OM used car store

GSM
Finance Comptroller Service Director Parts Manager

GSM
Finance Director Comptroller Service Director Parts Manager ASst Office Manager Office Office Office

Audra Hol~er
Christi Bollig Margaret Amy Belyea Crystal Velasquez Bridgett Becky Allen Bethany Melissa Ayers Thomas Greiner Matt Coyne David Saed

Office Office
Office Office Office Office Office Receptionist Receptionist F&i Secretary F&I . F&/ F&I

Office
Office Office

Amy Belyea Ma.rilyn Sanchez
Dion Duvall Thomas Greiner Matt Coyne Lynn Zeigler James Vanya Melissa Ayers Don Reader Arlene Reader AI Gallegos Brian Bayda Phil Schwed Karl Evans West Ballard

Office
Parts Parts F&I

F&I F&I
Special Finance F&I Secretary Fleet Fleet

Damian Morine
Lynn Zeigler Charles Leatherbarrel Tim Murphy Sherry Keopke Dion Duvall Melody Bellow West Ballard Al Gallegos

F&I Flit
Fleet F=leet Special Fin Parts Service Sales

Sales Sales
Sales

Sales
Servioe Writer

Sales

12/28/2005

10:24 3224757 Case 1:03-cv-02073-WDM-KLM

BEARTOOH Filed 12/28/2005 FORD Document 221-6

Page 2 of 2 PAGE

02

Phil Schwed Monte Robbins Matt Urland Bob Ward

Sales Sales Sales Sales Sales Manager Manager Manager Manager Relations Mgr

Jason Mckeele Robert Gibson Marty Cain

Sales Manager

Sales Ma."'lager
Sales Manager Sales Manager Sales Manager

Da···. Barron e
Nicole

lee Ledger
Tom Batey Becky Allen Ginnie Schoenfeld

St John

Customer

Recon Manager
Receptionist

Corporate Office
Riohard Nelson Tony Schnurr Bryant Henry Pat Kronenberger Jim Schoenfeld

Jack Mutterspa Dan Ware
Carolyn Ashburn Clark Whitworth Richard Dickert Brent Baren

3

Further affiant sayeth naught.

-~Jl~
Before me, (\ t-.ylcffice, duly authorize to l'.Idmlnister oaths, in and for said tate, personally appeared Tonya House, whose name is subsoribed to the foregoing Affidavit. and who affirms, that said statements are true and that she acknowledges the execution of said instrument to be of her own free act and

ole nt-

J).erJv

,·

voluntary deed.
Subscribed

and affirmed

to before me this 27th day of December

2005.

~.

~ ~2.(Commission Expires)

3- 2lX.x..o