Free Response in Support of Motion - District Court of Arizona - Arizona


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Date: December 31, 1969
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State: Arizona
Category: District Court of Arizona
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164
KATINKA BRYSON, formerly KATINKA DUFEK
l0/26/O4
1 A- I don*t think so, huh·uh, noi
2 Q- If I wanted to know for sure, where would E look?
3 Do you know?
4 A- I don't know where you would look, but you could
5 ask Eddie Toro. Honestly, in fact »~
6 Q. Okay.
7 A- —— l'm quite certain they wouldn't be includedl
8 QJ Okay-
9 Ai I don't ~— this is a senior management, and a
10 department head of a zone is not considered part of senior
11 management-
12 Q, Something you just alluded to that I have been
13 trying to figure out for some time in this case, and maybe
le you can actually explain it, you talked about people in
l5 corporate who are going to assume a VPA might qualify for
16 SMIPs even though they are not yet at that level or
17 something like that?
18 A- Yes.
19 (whereupon Deposition Exhibit Number 8 was masked
20 for identification")
21 Q- Let me show you what's been marked as Exhibit B
22 and give you an opportunity to look at it- Show a copy to
23 counseli
24 Have you had a chance to look at Exhibit ~— what
25 is that -- B?
RAYNBO COURT REPORTING, LTD-
Case 2203-Cv-01950-NVW [)OCUm9 OFA{9¤/@L@?15®r5" Pag91Of4

165
KATINKA BRYSON, formerly KATINKA DUFEK
10/26/04
l A. Yes.
2 Q. Could you tell us what this is, please?
3 A. This is a memo dated April iith, 2001, from Jack
4 Weekes to me. Jack was my immediate supervisor in
5 corporate.
6 Q. What was Mr. Weekes’ position?
7 A. He was VP of marketing.
B Q. was he a direct report to Chuck Wright?
9 A. Yes.
10 Q. Okay. And this, the subject here is the 2001 APE
ll transition bonus program; correct?
12 A. Yes.
13 Q. And I'm hopeful that you can really maybe —— do
le you know what the APE transition bonus program is?
15 A. This is the bonus program for people such as
16 myself who were formerly AFEs in the field coming in to
17 corporate where our responsibilities would not allow us to
18 earn a bonus like we did in the field. We aren't production
19 units in corporate. We had job functions that didn*t have
20 the production units that we had in the field with agents.
21 So we had a bonus in the field that with our move to
22 corporate was taken away because it's not available there.
23 And so in order to offset the loss of that bonus
24 potential this bonus was offered to us to incent us for our
25 performance in this new role.
RAYNBO COURT REPORTING, LTD.
Case 2:O3—cv—O1950—NVW Document 271-4 Filed O9/O7/2005 Page 2 of 4

i
ti-/1l!{)1
To: Katinita Dufek I
From: lack Weekes C
Subject: 2001 APE Transition Bonus Program l
E arn pleased to inform you that you are eligible to receive the AFE"l'ransition Bonus, which
is uniqtse to sorne UE5 Leadership empioyees. The objective behind the AH Transition Bonus ,
Program is to provide additional incentive and reward for efiective perfortnance, p
The 2001 APE bonus can oe earned by Company perionnance and Marketing expense
management periorrnance based on the following criteria and award matrix:
Company Performance Marketing
Universal Dept ;
SMJQP Expense Total
Threshold (50%} $12,000 $3,000 $15,000 h
Target (100%) $24,000 $6,000 $30,000
Maximum (150%} $35,000 $9,000 $45,000 Z
Universal SMIP E
There is an established level of performance that acts as an "ort/oft" switch to activate the Senior
Management Incentive Plan and create the opportunity to earn an award The tlrst step involves
State Farrn°s ability to teach or surpass the State Farm Performance Standards in ALI,. of the '
following three categories:
Compliance, Policyholder Protection Fund! Written Premium (P&C), and Adjusted
Operating ProilU'Earned Premium (P&C)
Once the State Farm Performance Standards have been met or surpassed, the plan becomes
activated and you have the opportunity to earn an award based on the specific performance
measures in four performance categories:
Growth, Expense Control, Customer Satisfaction, and Agency Success/Employee `
Satisfaction ,
The State Fann Performance Standards and scorecard for the Senior Management Incentive Plan are
attached Note that each product line has specific objectives For the year which must be met to get a
SMI? payout. it will be possible to under- or oveoachieve any of the individua! bonus components
with corresponding payout ranging from 0% to achieved to 150% achieved.,
.
EXHIBET NO..<.;g i
lc · 2 tt cw ‘
S 1 itk} **' .
Case 2:03-cv-01950-NVW Document 271-4 Filed O9/O 7/2005 Paggt;3 grrgrrgnonnaots
Produced Pursuant to Protective Dfdéf

I
Marketing Department Exoense
lvierketing department expense management goals expressed as a percent change versus the
"2OOCl baseline" budget is as foliowsz
Threshold +4.0%
iarget +23%
Maximum 0%
Again, payout for expense management performance will range from 0% to E50% achieved l
depending on perforrnancer Detail on expense management targets is etaached.
I continue to be pleased that we can offer the APE Transition Bonds Program to appropriately
align rewards with performance. Itiianlc you for your continued commiunena to Marketing at
State Pam: and ell that you do to keep State Farm our customer? first and best afhoicei
Sincerely,
{?£·;£
.laclg_Weelces
FW/mb
Attachments
Cc: Robert Dunn

l
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