UNITED STATES DISTRICT COURT WESTERN ISTRICT OF LOUISIANA LAFAYETTE DIVISION MARISELA VALDEZ HUERTA, CINDY ALEJANDRA CABRERA HUICHO, ISY ELIZABETH GONZALEZ VALENZUELA, PERLA YASMIN LAGARDA HUERTA, MARTA ICELA FLORES GAXIOLA, MIRIAM JOHANA MENDIVIL TALAMANTE AURORA MENDIVIL ARMENTA VERSUS L.T. WEST, INC., JAMES CRAIG WEST, LUCAS TROY WEST, CATHERINE WEST, ROBERT LUCAS LAVERGNE, TOWN OF MAMOU CIVIL ACTION I 'k DEPOSITION OF NOE DARVELIO CASTRO PAVA THROUGH AN INTERPRETER, ELISA P. BRODBECK TAKEN FOR AND ON BEHALF OF THE PLAINTIFFS AT THE HOMEWOOD SUITES LAFAYETTE, LOUISIANA ON TUESDAY, MAY 8, 2012 BEGINNING AT 3:30 P.M. REPORTED BY: GINGER S. GRIFFIN, CERTIFIED COURT REPORTER. ALL-STATE Associated Reporters Inc. (225) 216-2036 NUMBER APPEARANCES: ATTORNEYS FOR PLAINTIFFS MS. JULIET V. BERGER-WHITE MS. CARYN C. LEDERER HUGHES, SOCOL, PIERS, RESNICK, DYM, LTD. 70 WEST MADISON STREET SUITE 4000 CHICAGO, ILLINOIS 60502 Representing Marisela Valdez Huerta, Cindy Alejandra Cabrera Huicho, Isy Elizabeth Gonzalez Valenzuela, Perla Yasmin Lagarda Huerta, and Marta Icela Flores Gaxiola MS. SPRING MILLER MS. STACIE JONAS SOUTHERN MIGRANT LEGAL SERVICES, A PROJECT OF TEXAS RIOGRANDE LEGAL AID, INC. 311 PLUS PARK BOULEVARD - SUITE 135 NASHVILLE, TENNESSEE 37217 via telephone Representing Miriam Johana Mendivil Talamante and Aurora Mendivil Armenta ATTORNEYS FOR DEFENDANTS MS. MARIA F. MANUEL ONEBANE LAW FIRM 1200 CAMELLIA BOULEVARD SUITE 300 LAFAYETTE, LOUISIANA 70508 Representing L.T. West, Inc., James Craig West, Lucas Troy West, and Catherine West Associated Reporters Inc. (225) 216-2036 MS. JOY C. RABALAIS BORNE WILKES 200 WEST CONGRESS - SUITE 1000 LAFAYETTE, LOUISIANA 70502 Representing Town of Mamou, Robert McGee, and Lucas Lavergne INTERPRETER: Ms. Elisa P. Brodbeck International Translations Bureau ALSO PRESENT: Ms. Monica G. Chavez, paralegal for Ms. Berger-White Mr. J. Craig West, defendant. Associated Reporters Inc. (225) 216-2036 NOE DARVELIO CASTRO PAVA - May 08, 2012 K) C) K) C) C) Did you ever hear that they had any restrictions on with whom they could leave the property? No, of course not. Did you ever hear from anyone that Craig West would get angry if any of these women left the property without his permission? No, I didn't hear that. Did you ever hear from anyone that Craig West would get angry if any of these women left the property with certain people? No, not that either. Do you know of any time that Marisela, Isy, Perla, Alejandra, or Johana left the L.T. West property? Normally they would go out frequently. About how many times a week would they go out? Normally on weekends. Where did they go? I don't know. Did they leave during the day or during the night? After the work day. In the evenings? In the evenings. Did they go out during the week also? Associated Reporters Inc. 64 (225) 216-2036 NOE DARVELIO CASTRO PAVA - May 08, 2012 Sometimes. How do you know that they left? Because I lived across from them. And you saw them leave the property when you were watching? Exactly. Did you see them get into a car? Yes. Do you know who was driving the car? No, I do not know. Do you know if it was the same person every time they left? I didn't pay attention normally. What I would see is that people would arrive, they would come, get in the car, and leave. Did all of these women leave at the same time together? No. Isy and Marisela would leave. the ones that went out more frequently. They were They went out more frequently than Perla and Alejandra? Yes . About how often did Marisela and Isy leave? I couldn't tell you how many times a week. I know there were more than the others. And I do Associated Reporters Inc. (225) 216-2036 65 NOE DARVELIO CASTRO PAVA - May 08, 2012 know that they went out during the weekend. Did you ever see the car that they got into? Yes. What color car was it? It was a burgundy colored Silverado and a Camaro. And also -- I don't remember the name of the other THE INTERPRETER: The interpreter needs to clarify. THE WITNESS: (Through the interpreter) A Suburban. I don't remember the color. BY MS. LEDERER: Do you know if either Craig or Cathy West ever drove any of those cars? No. No, you don't know? Or no, they did not drive the cars? No, they did not drive those cars. Do you know how many times Marisela and Isy left in the Silverado? No, I don't remember. But generally they didn't leave in the Silverado. They left in the Mustang. About how many times did they leave in the Associated Reporters Inc. 6 6 (225) 216-2036 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION MARISELA VALDEZ HUERTA, CINDY ALEJANDRA CABRERA HUICHO, ISY ELIZABETH GONZALEZ VALENZUELA, PERLA YASMIN LAGARDA HUERTA, MARTA ICELA FLORES GAXIOLA, MIRIAM JOHANA MENDIVIL TALAMANTE, AURORA MENDIVIL ARMENTA PLAINTIFFS CIVIL ACTION NO: VERSUS DIVISION L.T. WEST, INC., JAMES CRAIG WEST, LUCAS TROY WEST, CATHERINE WEST, ROBERT MCGEE, LUCAS LAVERGNE, TOWN OF MAMOU DEFENDANTS 'The deposition of ALFREDO ROSALES, taken in connection with the captioned Cause, pursuant to the following stipulations before Susan Erkel, Certified Court Reporter, at Homewood Suites, Presidential Suite, Room 11%, 201 Kaliste Saloom Road, Lafayette, Louisiana 70508, on the 9th day of May 2012, beginning at 9:00 a.m. ASSOCIATED REPORTERS, INCORPORATED (225) 216-2036 FOR THE PLAINTIFFS, MIRIAM JOHANA MENDIVIL TALAMANTE AND AURORA MENDIVIL ARMENTA: (VIA TELEPHONE) SPRING MILLER, ESQ. STACIE JONAS, ESQ. SOUTHERN MIGRANT LEGAL SERVICES, A PROJECT OF TEXAS RIOGRANDE LEGAL AID, INC. 31l PLUS PARK BOULEVARD, SUITE 135 NASHVILLE, TENNESSEE 37217 (615) FOR THE PLAINTIFFS, MARISELA VALDEZ HUERTA, CINDY ALEJANDRA CABRERA HUICHO, ISY ELIZABETH GONZALES VALENZUELA, PERLA YASMIN LAGARDA HUERTA, AND MARTA ICELA FLORES GAXIOLA: JULIET ESQ. CARYN C. LEDERER, ESQ. MONICA GARRETON CHAVEZ, ESQ. HUGHES, SOCOL, PIERS, RESNICK, DYM, LTD. 70 WEST MADISON AVENUE, SUITE 4000 CHICAGO, ILLINOIS 60602 (312) 604*2622 ASSOCIATED REPORTERS, INCORPORATED (225) 216-2036 FOR THE DEFENDANTS, L.T. WEST, JAMES CRAIG WEST, LUCAS TROY WEST AND CATHERINE WEST: MARIA F. MANUEL, ESQ. ONEBANE LAW FIRM 1200 CAMELLIA BOULEVARD, SUITE 300 LAFAYETTE, LOUISIANA 70508 (337) 237*2660 FOR THE DEFENDANTS, ROBERT MCGEE, LUCAS LAVERGNE, AND TOWN OF MAMOU: JOY C. RABALAIS, ESQ. BORNE AND WILKES, L.L.P. 200 WEST CONGRESS STREET, SUITE 1000 LAFAYETTE, LOUISIANA 70502 (337) 232ml604 THE INTERPRETER: GALLARDO ALSO PRESENT: J. CRAIG WEST ASSOCIATED REPORTERS, INCORPORATED (225) 216'2036 Town of Mamou, the Mamou Police Department and some of its police officers. I just have very few questions for you, okay? A Okay. The party that you talked about to celebrate Mother?s Day in May of 2011 A thhuh (affirmative). was this party before or after the time that the girls were detained by the police? A I don't remember. Did Marisela or lay look upset at the party? A No. They were very happy all the time. When you were called asking you to translate that the police were there, do you remember what time that was? A No but approximately five or eix in the evening. NQW, Were you called to translate for the incident that the girls got brought to the police department? A Not that time. So the time that you were called to translate, can you tell me the color of the police unit? A I don't remember. Do you remember seeing a police officer? ASSOCIATED REPORTERS, INCORPORATED (225) 216-2036 174 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION MARISELA VALDEZ HUERTA, CIVIL ACTION CINDY ALEJANDRA CABRERA HUICHO, ISY ELIZABETH GONZALEZ VALENZUELA, PERLA YASMIN LAGARDA HUERTA, MARTA ICELA FLORES GAXIOLA, MIRIAM JOHANA MENDIVIL TALAMANTE, AURORA MENDIVIL ARMENTA VERSUS NUMBER L.T. WEST, INC., JAMES CRAIG WEST, LUCAS TROY WEST, CATHERINE WEST, ROBERT MCGEE, LUCAS LAVERGNE, TOWN OF MAMOU DEPOSITION OF PAOLA HARO OSUNA THROUGH AN INTERPRETER, ELISA P. BRODBECK TAKEN FOR AND ON BEHALF OF THE PLAINTIFFS AT THE HOMEWOOD SUITES LAFAYETTE, LOUISIANA ON TUESDAY, MAY 8, 2012 BEGINNING AT 9:15 A.M. REPORTED BY: GINGER S. GRIFFIN, CERTIFIED COURT REPORTER. Associated Reporters Inc. (225) 216-2036 APPEARANCES: ATTORNEYS FOR PLAINTIFFS MS. JULIET V. BERGER-WHITE MS. CARYN C. LEDERER HUGHES, SOCOL, PIERS, RESNICK, DYM, LTD. 70 WEST MADISON STREET - SUITE 4000 CHICAGO, ILLINOIS 60602 Representing Marisela Valdez Huerta, Cindy Alejandra Cabrera Huicho, Isy Elizabeth Gonzalez Valenzuela, Perla Yasmin Lagarda Huerta, and Marta Icela Flores Gaxiola MS. SPRING MILLER MS. STACIE JONAS SOUTHERN MIGRANT LEGAL SERVICES, A PROJECT OF TEXAS RIOGRANDE LEGAL AID, INC. 311 PLUS PARK BOULEVARD SUITE 135 NASHVILLE, TENNESSEE 37217 via telephone Representing Miriam Johana Mendivil Talamante and Aurora Mendivil Armenta ATTORNEYS FOR DEFENDANTS MS. MARIA F. MANUEL ONEBANE LAW FIRM 1200 CAMELLIA BOULEVARD - SUITE 300 LAFAYETTE, LOUISIANA 70508 Representing L.T. West, Inc., James Craig West, Lucas Troy West, and Catherine West Associated Reporters Inc. (225) 216-2036 MS. JOY C. RABALAIS BORNE WILKES 200 WEST CONGRESS - SUITE 1000 LAFAYETTE, LOUISIANA 70502 Representing Town of Mamou, Robert McGee, and Lucas Lavergne INTERPRETER: Ms. Elisa P. Brodbeck International Translations Bureau ALSO PRESENT: Ms. Monica G. Chavez, paralegal for Ms. Berger-White Mr. J. Craig West, defendant. Associated Reporters Inc. (225) 216-2036 PAOLA HARO OSUNA - May 8, 2012 That's all the questions I have. Thank you. CONTINUED EXAMINATION BY MS. MANUEL: Who paid for the documents required for you to come to the U.S. to work? What do you mean that I needed? The visa. L.T. West, from the paperwork for the visa, transportation ticket, meals, hotel, and then when we came to work also, transportation. MS. MANUEL: Thank you. CONTINUED EXAMINATION BY MS. I just have a couple of other questions. You testified that the five women from the trailer went out to bars? Is that right? NO. What I said is that they would go out. The ladies that would come back to the house, they'd come back with having been drinking. Who from the house would go out with any of the five women from the trailer? THE WITNESS: Marta, Ramona, Alma, Esther, Bertha, Beatriz. Anyone else from the house that you can remember Associated Reporters Inc. 142 (225) 216-2036 PAOLA HARO OSUNA - May 8, 2012 went out with our clients, who went out with the five women from the trailer? No. They were older people. They were ladies. Other than believing that the women who had gone out had been drinking, do you have any personal knowledge as to where the women went when they left the L.T. West premises? Well, because the ones that went with them also made comments of where they went. Edith also went. Where did -- Shopping. Not necessarily to party or to bars. Also going shopping. On how many occasions did you know of Marisela, Isy, Perla, Alejandra, or Miriam Johana going out and leaving the L.T. West property? On weekends for sure. During the week, sometimes also. During your employment with L.T. West is it fair to say that the five women in the trailer left the L.T. West premises on more than five occasions? Oh, yes, more. Only counting weekends it's much more than five. You said that Johana had invited you to stay in Associated Reporters Inc. 143 (225) 216-2036