FILED DATE: 4/2/2019 3:27 PM 2017L000060 FILED 4/2/2019 3:27 PM DOROTHY BROWN CIRCUIT CLERK COOK COUNTY, IL 2017L000060 FILED DATE: 4/2/2019 3:27 PM 2017L000060 THE CIRCUIT COURT OF COOK COUNTY COUNTY DEPARTMENT - LAW DIVISION JESSE ESCAMILLA, as Special Administrator of the Estate of TELESFORA ESCAMILLA, Deceased Plaintiff, vs. CASE NO.: 17 000060 AMAZON.COM LLC, et a1., Defendant. DEPOSITION OF LEONARD WRIGHT (Inpax Shipping) January 25, 2019 11:00 a.m. 100 Hartsfield Centre Pkwy Atlanta, Georgia Shari L. Snow, CCR Job No. 29626 FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25. 2019 Pages 2.5 Page2 Pagea 1 APPEARANCES OF COUNSEL 1 INDEX OF EXAMINATION 2 On behalf of the Plaintiff: 2 Pa 3 MICHAEL D. FISHER Attorney at Law 3 Examination by Mr. Fisher 4 4 GWC, LTD 4 Examination by Mr. McAvoy 150 One E. Wacker Drive - Suite 3000 5 5 Chicago, Illinois 60601 312-464-1200 6 INDEX OF EXHIBITS 6 MFisher?GWCLaw.com Exhibit 1 Courier Application 55 7 8 Exhibit 2 Inpax Website page 62 On behalf Of Amazon: 9 Exhibit 3 Inpax Welcome letter 66 9 REBECCA DIRCKS Attorney at Law 10 Exhibit 4 Video {thumb drive) 65 10 Benesch Friedlander Coplan 11 Exhibit 5 Work Order 100 333 West Wacker Drive - Suite 1900 12 Exhibit 6 Terms of Service 114 11 Chicago, Illinois 60606 312_212_4940 13 Exhibit 7 13th Amendment to Terms of 115 12 RDircks?BeneschLaw.oom Service 13 14 '14 On behalf of Inpax: . . 15 TERRENCE P. MCAVOY 15 (Original exhibits retained by Mr. Fisher.) Attorney at Law 15 16 Hinshaw Culbertson 17 151 NOrth Franklin Street - Suite 2500 13 17 Chicago, Illinois 60606 312-704-3281 19 10 TMcAvoy?HinshawLaw.com Page 4 Page 5 1 DEPOSITION OF LEONARD WRIGHT 1 companies? 2 January 25, 2019 2 A Yes. 3 LEONARD WRIGHT. 3 Did it have to do with someone being injured 4 being first duly sworn, was examined and 4 and naming an Inpax company as a defendant? 5 testified as follows: 5 A No. 6 EXAMINATION 6 In that deposition my guess is they probably 7 BY MR. FISHER: 7 gave you some ground rules. I'm going to give you 8 State your name and spell your last name for 8 ground rules for this deposition, and they're pretty 9 the record, please. 9 easy. Most importantly, if for any reason you do not 10 A Leonard Wright. 10 understand a question that ask of you today, will 11 MR. FISHER: Let the record reflect 11 you please let me know? 12 this is the discovery deposition of Leonard 12 A Sure. 13 Wright taken pursuant to notice. Let the record 13 0 Okay. If you answer my questions, I'm going 14 further reflect this deposition will be taken in 14 to assume you understood the question; is that fair? 15 accordance with all applicable Circuit Court of 15 A Yep. 16 Cook County rules and codes. 16 0 All right. I'm going to be asking you 17 BY MR. FISHER: 17 questions about Inpax. I'm going to be asking you 18 0 Mr. Wright, you've indicated to me before we 18 questions about an occurrence that involved someone 19 started today that you've given some prior 19 who perished as a result of the accident and that 20 depositions. Approximately how many times have you 20 family and the circumstances regarding Mr. Gray's hire 21 given depositions, would you say? 21 and working for one of your companies. 22 A Once. 22 If you don't remember something or you don't 23 When was that, approximately? 23 know something in response to a question i ask, you 24 A Seven years ago. 24 have to tell me that, okay? 25 Did it have to do with one of your Inpax 25 A Okay. EcoScribe Solutions 888.651.0505 immu- - FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25, 2019 Pages 6.9 - Page 6 Page 7 I understand because some time has passed 1 What's your marital status? you may not know or remember all the things, and 2 A Single. that's perfectly ?ne. 3 Have you ever been married? A Yes. 4 A Yes. All right. Last thing. Our court reporter 5 For how long have you had a single status? is Shari and she's taking down everything that we?re 6 A Nine years. saying. And she has a very difficult time taking down 7 Okay. If somehow we lose track of you a gesture like a nod of the head or words like mhm-hm (af?rmative) and uh-uh (negative). 8 before this case goes to trial in Cook County, is 9 there someone here in the Atlanta area or- the Chicago A Yeah. 10 area that typically would know where you are, a So if you mean yes, say yes; if you mean no, 11 brother, a parent, something like that, who I promise say no. Good? 12 not to reach out to unless we just can?t ?nd you? A Got it. 13 A Sure. All right. So let's get started. Where do 14 Who would that be? you live? 15 A My daughter. A Atlanta, Georgia. 16 What's her name? What's the street address? 17 A Morgan Wright. A 2634 Anastasia Cove, Decatur, Georgia 30033. 18 And is she here in Atlanta? How long have you lived at that address for, 19 A Yes. 20 approximately? 20 Do you happen to have an address for her, a 21 A Two years. 21 street address and a telephone number? 22 Any plans on moving from that address? 22 A I got the phone number. 23 A No. 23 I'll take it. And again, I promise I 24 Who do you live there with? 24 wouldn't use it for any other purpose but just to ?nd 25 A By myself. 25 you. . Page 8 Page 9 1 A (229)886-8261. 1 A Yes. 2 MR. FISHER: And, Terry, whether 2 No problem. We're used to doing that so 3 Mr. Wright is employed by an lnpax entity or not 3 I'll correct you if I have to, if I remember. 4 at the time of trial, are you going to make 4 A Fine. 5 him -- at least will you be my contact to reach 5 Ever serve in the military? 6 out to him? 6 A No. 7 MR. Yes. 7 0 Ever been a member of a union? 8 MR. FISHER: Okay. 8 A No. 9 BY MR. FISHER: 9 Teamster or othemise? 10 What's your date of birthOkay. I apologize for the nature of the 12 Could you describe your highest level of 12 next couple of questions the law permits me to ask. I 13 education? 13 mean no disrespect. Have you ever been convicted of a 14 A College degree. 14 felony? 15 What was your degree in and what school did 15 A Yes. 16 you graduate from? 16 One time or multiple felonies? 17 A Albany State College. 17 A One. 18 What was the degree? 18 And do you know what the nature of the 19 A Physical education. 19 felony was, what was the charge? 20 Did you attend high school in the Atlanta, 20 A Drugs. 21 Georgia area? 21 Okay. Did you serve time? 22 A Lee County High School. 22 A Yes. 23 Is that in Georgia? 23 How much time did you serve? 24 A Mhm-hm (affirmative). 24 A Three years. 25 Okay. That's a yes? 25 Where was the -- did you have atrial or did EcoScrr'be Solutions 888.651.0505 II .l FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25, 2019 Pages 10..13 Page 10 Page 11 1 you plead guilty? 1 easiest one ?rst, which is, do you know of a 2 A Guilty. 2 gentleman by the name of Valdimar Gray? 3 Okay. And where was that at. what county 3 A No. 4 and state? 4 0 Well, do you understand that he was involved 5 A It's Chattanooga, Tennessee. 5 in a traffic accident in Chicago in December of 201 6 6 And when was that, when is it that you pled 6 where he killed a woman? 7 guilty, what year? 7 A Yes. 8 A 1997. 8 0 Okay. At that time, was he working for one 9 And that's the only felony? 9 of your companies, as you understood it? 10 A Right. 10 A Yes. 11 Okay. And have you ever been charged with 11 What company was it that Valdimar Gray was 12 any crimes where you were alleged to have committed a 12 working for? 13 crime of fraud or dishonesty? 13 A lnpax. 14 A No. 14 Which one? 15 0 Okay. Can you tell me a little bit about 15 A Shipping Solutions. 16 your work history. Are you currently employed? 16 And I think it has an "Inc." at the end, 17 A Yes. 17 incorporated, correct? 18 Who are you employed with? 18 A Yes. 19 A lnpax. 19 Okay. So we know that's one of them. Can 20 I've looked up on the corporate indexes, 20 you tell me the names of the other Inpax companies 21 et cetera, there's a number of lnpax entities out 21 that exist with different names but the word "Inpax" 22 there. Are you employed by all of them or do you have 22 or doing the same thing that lnpax does that you're 23 some role in all of those companies? 23 part of? 24 A Yes. 24 A Yes. We have Ship lnpax Logistics. 25 .0 Okay. So let's start off with i think the 25 Okay. Page 12 Page 13 1 A And Inpax Final Mile Delivery. 1 what the corporate status of DCH Inpax, LLC is. Is it 2 Any others? 2 a separate corporate entity? 3 A That's it. 3 A Yes. 4 0 At the time that I filed this lawsuit, there 4 Did you have to have it incorporated? 5 was a company that had the name DCH lnpax, LLC. Are 5 A Yes. 6 you familiar with that company? 6 Are you an owner of that company? 7 A Yes. So basically when you do delivery 7 A Yes. 8 service, you have to get a DOT number in that state in 8 Does that company still exist today? 9 order to do business in that state. So you have to 9 A Yes. 10 create a entityjust for a DOT number. 10 Is that the company in Illinois that has 11 Okay. When you create an entitythe Federal DOT number? 12 create a corporate entity or do you create an entity 12 A It's a state DOT number. 13 that's doing business that's a wholly owned subsidiary 13 0 Okay. Did that company in that name enter 14 of one of the other companiesinto any shipping agreements with any Amazon company? 15 A So basically you just have to get a state 15 A No. 16 business license -- 16 0 Okay. Are all of the agreements with 17 0 Okay. 17 companies like Amazon, are they all -- do they all -- 18 A -- and that particular site in Chicago was 18 do they all enter into agreements with lnpax Shipping 19 just DCH, whatever you got that number is right there. 19 Solutions, Inc.? 20 0 Okay. So DCH Inpax, 20 A Yes. 21 A Does no business. It's just a -- you have 21 Do you happen to know the State Department 22 to get -- in order to get a license to deliver in that 22 of Transportation number for DCH lnpax, 23 state, you have to ?le a -- you can't be the same 23 A No. 24 name in every state. 24 Is it your understanding in order to be 25 I think I understand. I'm just wondering 25 involved in the courier and shipping business in the EcoScri'be Solutions 888. 651.0505 'f'll I'"m iIl': . Hi? FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25. 2019 Pages 14.17 Page 14 Page 15 1 state of Illinois in 2016 a company had to have a 1 as what we've been talking about, DCH lnpax, LLC, in 2 Department of Transportation number? 2 what states does the company do business? 3 A Yes. 3 A Georgia, North Carolina, Florida, Ohio, 4 0 Okay. So let's go back. lnpax Shipping 4 Illinois, Texas. 5 Solutions, Inc., when did you -- as I understand it, 5 0 That's it? 6 you're the owner of that company? 6 A Yep, that's it. 7 A Yes. 7 0 Okay. And do you know in the last year, 8 read your website. 8 in - let's take 2017 what the revenue of that 9 A Yes. 9 companyioompanies were? 10 When did that company start to do business 10 A '17? In '17? 11 under that name, approximately? 11 0 Let's say '17 because maybe you don't have 12 A 2011. 12 '18 done yet. 13 Okay. And it continues to do business 13 A Yeah. 43 million. 14 today? 14 And what's your title with lnpax Shipping 15 A Yes. 15 Solutions Inc. 16 I saw on the website you started that 16 A The CEO and president. 17 business with a single vehicle and yourself? 17 And it's a closely held corporation; in 18 A That's correct. 18 other words, it's not publicly traded? 19 And you've grown that business to what now? 19 A That's correct. 20 How many employees do you have? 20 So you own shares of stocks in the company? 21 A Over a thousand. 21 A Yes. 22 Congratulations. 22 What's your percentage of ownership? 23 A Thankswhat states does lnpax Shipping 24 What was your percentage of ownership in 25 Solutions, Inc. or one of its local subsidiaries such 25 December of 201 6? Page 18 Page 17 1 A 100, 1 So who are the other officers of the company 2 And are there multiple other shareholders 2 now? You're the CEO-President. he's the CFO- Any 3 now or just a single other shareholder? 3 other officers of the company currently? 4 A Single. 4 A My daughter is secretary. 5 Your daughter Morgan? 5 Morgan? 6 A No. 6 A Morgan, yes. 7 0 Who's the other shareholder now? 7 0 HOW Oid'S Merge". by the Way? 8 A David WilliamsDavid Williams to you? 9 And does that name all the of?cers? 10 A CFO. 10 A Yes-- 11 Was Mr. Williams working for the company 11 Does she have any other title With the 12 back in 2016? 12 company besides secretary. which is a corporate title? 13 A Yes! but just as a -- 13 A She's just payroll administrator. 14 Employee? 14 0 Was she the secretary of Inpax Shipping 15 A He was a contractor. 15 Solutions, Inc. back in December of 2016 also? 16 Oh, okay. Did David Williams, as a 16 A 17 contractor, do business under a particular name? 17 HOW did YOU decide to get into the 13 A Yes. 18 shippinglcourier business? 19 What name did he do business under? 19 A Out of college I used to work for a software 20 A Williams Financial, 20 company that we manufactured and produced diskettes. 21 But now he's a full-blown employee and part 21 So, you know, now everything is downloaded, right? 22 owner? 22 Yep- 23 A Yes. 23 A Back then you had to have 10 diskettes. So 24 And also an officer? 24 we would get the master file from, say, Peachtree 25 A Yes. 25 SoftWare and make 20 million copies of that and EcoScrr'be Solutions 888.651.0505 "nit-F - I a: '11" FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 18..21 Page 16 distribute it. And we used, you know, trucking companies, courier companies. and I was over the production and the fulfillment and shipping. So I just decided one day I'm going to get into the courier business. We do a lot of courier work. That's how I started. It's not something that runs in your family per se; you're the ?rst one? A Right. 0 Okay. Impressive story. So before i get back into Inpax and what I want to know in this case, ljust want to get through Page 19 What was your title there? A Production shipping manager. And from when to when were you with The Software Company, approximately? A Right out of college. '86 through '93. What did you do between '93 and 2011 when you incorporated Inpax Shipping Solutions? A From '90 0 Part of that time was what we talked about earlier? A Yes. So in 2000 Is when I originally started the business, which was it was RoadOne Express 13 your work history. Before you started Inpax Shipping 13 at the time. 14 Solutions. were you employedYes. 15 A And then in 2009, obviously, the economy 16 Who were you employed with immediately 16 crashed and I had to regroup and start over. 17 before you started the company? 17 Okay. And then under the lnpax name? 18 A The Software Factory. 18 A Well, the name started out as Ship Inpax. 19 What was the name of the company? 19 And then I changed the name for marketing purposes in 20 A The Software Factory. 20 2011 to lnpax Shipping Solutions. 21 Georgia company? 21 So does "Inpax" stand for something? 22 A Yes. 22 A Yeah. 23 0 Were you an owner of that company, a 23 What?s it stand for? 24 shareholder? 24 A It was just me Googling. playing around on 25 A No. 25 the computer, and In some type of Latin code "in" Page 20 Page 21 1 means on and ?pax? means packages. So Ijust said 1 an Amazon company? 2 "packages on a truckwhen Valdimar Gray started with lnpax, 4 A That's how I came up with it. 4 which I think was sometime in 2016, as I understand 5 No, it's interesting. I was wondering. 5 it is that your understanding? 6 So basically that's your, at least from the 6 A I'm not sure. 7 time of college on, that we've now discussed, your job 7 Okay. Do you know anything about how it was 8 history? 8 that he was hired? 9 A Right. 9 A I know our process for hiring, but how he 10 0 Okay. Have you yourself ever hauled 10 was hired, no. 11 sundries with semi tractor-trailers; in other words, 1 1 So let's just talk about it just for two 12 have you ever been a commercial truck driver? 12 seconds. Let's talk about the company's process 13 A No. 13 ?rst. Would lnpax Shipping Solutions, nc.'s process 14 So the kind of work that Valdimar Gray was 14 be the same as DCH Inpax, LLC's process: it's all the 15 doing on the day of the occurrence, he's using a cargo 15 same? 16 van, I think they refer to it as, and he's delivering, 16 A DCH doesn't have a process. 17 I guess, smaller packages, not big packages. What's 17 Okay. So Valdimar Gray is hired by Inpax 18 that ?eld of delivery service called? Does it have a 18 Shipping Solutions, Inc? 19 name? 19 A Right. 20 A Usually, courier work. 20 0 Okay. And that's who his employer is at the 21 0 Okay. And did you yourself at any point in 21 time of the occurrence? 22 time actually do courier work before starting your 22 A That's correct. 23 companies? 23 And he's employed as a direct employee? 24 A No. 24 A Yes. 25 Have you ever worked directly for Amazon or 25 Is he a salaried employee, an hourly EcoScribe Solutions 888. 651. 0505 ?Ii FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 22.25 Page 22 Page 23 1 employee; how does it work? 1 those cities. 2 A Hourly employee. 2 I saw on the website of your company 3 Okay. Was he a full-time employee. someone 3 Amazon's not the only company that lnpax Shipping 4 that would have been entitled to bene?ts if they were 4 Solutions provides services for; there's some other 5 offered? 5 large companies too. 6 A Yes. 6 A Yes. 7 32-plus hours a week? 7 KPMG. DHL and Fed Ex also use your company 8 A Yes. 8 to courier packages? 9 And do you know who at Inpax Shipping 9 A Yes. 10 Solutions, Inc. hired Mr. Gray? 10 Okay. And they did so in 2012? 11 A No. 11 A Yes. 12 Do you know -- so Inpax Shipping Solutions, 12 Was Amazon your biggest customer back at 13 Inc.. do they have. back in -- let's use 2016 as your 13 that time. 2016? 14 point of reference. Did they have different offices 14 A Yes. 15 or locations in the Chicagoland area at that time? 15 In terms of volume? 16 A Yes. 16 A Yes. 17 0 Tell me the locations of the different lnpax 17 I mean. what percentage of your company's 18 Shipping Solutions offices. 18 business came from Amazon. would you say. back in 19 MR. In Chicago area? 19 2016? 20 BY MR. FISHER: 20 A 70 percent. 21 In the Chicagoland area in 2016. 21 Okay. I don't mean to repeat it, just want 22 A 30 we work inside the building with Amazon. 22 to make sure I understand and just tell me if I got 23 Okay. 23 this right. Basically what happened as it pertains to 24 A So we don't have an office. Basically we 24 business in the Chicagoland area in 2016. Inpax 25 have sites that we work for Amazon. I can 'give you 25 Shipping Solutions. Inc. didn't have its own Page 24 Page 25 1 standalone or its own actual of?ce space; it named 1 A Yes. yes. 2 its locations wherever it was doing work for Amazon. 2 . I mean. were there employees at that 3 at like the Amazon warehouses? Is that kind of how it 3 location? 4 workedValdimar Gray gets hired. let?s say, in 6 Okay. 6 2016. Does he go somewhere to have an interview? 7 A So that's the reason why you have to have 7 A Yes. 8 that DCH -- 8 Where would he have gone to get an 9 0 Okay. 9 interview. what were the possibilities? 10 A -- DOT number. 10 A The location at the Amazon location at. I 11 Got it. 11 think it's 2800 Southwest Ave. 12 A 80 we just reported to work at the Amazon 12 0 Let's see if We got this. I've got 2801 13 warehouses. 13 South Western? 14 So where was the -- the entity known as DCH 14 A Yeah. that's it. 15 lnpax. LLC with the Department of Transportation 15 Okay. 16 number. did it have an address in the Chicagoland 16 MR. When you say that you mean 17 area? 17 2801 South Western? 18 A No. 18 MR. FISHER: South Westem Avenue. 19 Did it have an address anywhere? In other 19 Chicago. Illinois. Does that sound right? 20 words, if the DOT has to send correspondences out. 20 MR. Right. And that's South 21 where did they send them to? 21 Western. 22 A Yeah. So I wouldn't know that address. but 22 MR. FISHER: Correct. it's "South" and 23 we chose an address to be able to get that. I don't 23 then "Western". 24 know it. likefor you. 24 BY MR. FISHER: 25 But it's in Chicagoland? 25 And that was an Amazon facility? Solutions 888.651.0505 II I'll "fl-F: l' --. ll] FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25. 2019 Pages 2629 Page 26 Page 27 1 A Yes.- 1 Have you ever spoken to him? 2 Was that a warehouse? Was it an office 2 A No, 3 warehouse? What was it? 3 So we've got one Amazon location back in 4 A Office warehouse- 4 2016 at 2801 South Western Avenue In Chicago? 5 Had you ever been out there? 5 A Right. 5 A Have i ever been there? 6 And was the second location that I know of 7 0 Yes 7 8290 Austin Avenue in Morton Grove? 8 A Yes. 8 A Yes. 9 0 Had you been out there any time in 2015? 9 That was also a Amazon warehouse location? 10 A I'm not sure, but I'm quite sure I did visit 10 A Yes. 11 there in '16. 11 Besides those two locations in 2016, did 12 Oksv- i mean. is it Your custom and 12 Inpax have other places where it was working in the 13 practice since you've been in business doing business 13 Chicagoland area? 14 in Chicagoland that you get out thereYes, 15 Chicago at least once or twice a year? 15 What other places? 16 A Probably more like four. 16 A It's in Lisle. 17 0 Okay. When you go out to the Chicagoland 17 0 Okay. Was that also an Amazon facility? 18 area with regards to your company, what do you go 18 A Yes. 19 therefor, what?s the purpose of those trips? 19 Any others? 20 A Meet the manager. May have a meeting. Meet 20 A Mundelein. 21 my manager. meeting with him May have a meeting with 21 Mundelein is very close to where I live. 22 the Amazon manager. 22 A Oh, okay. 23 0 Okay. Had YOU ever met Vaidimer Grey before 23 And that was also an Amazon facility? 24 the day of this occurrence, personally? 24 A Yes. 25 A I've never met him. 25 Is that -- are those the locations that Page 28 Page 29 1 lnpax Shipping Solutions was doing business out of in 1 the Lisle location and the Mundelein location at the 2 the Chicagoland area in 2016? 2 time? 3 A Yes. 3 A I think just -- I'm not sure, but I think 4 Is lnpax Shipping Solutions still doing 4 just the South Western and Lisle. 5 business out of those locations? 5 Would he have had an of?ce at those 6 A Only two. 6 locations, at the Amazon Lisle of?ce and the Amazon 7 Which two remain? 7 Western Avenue location? 8 A Lisle and Mundelein. 8 A No. 9 Okay. Would each of those locations in 2016 9 So he would show up at that location and he 10 have had a lnpax manager for the Inpax operations 10 would stand in the middle of the warehouse? Where 11 going on at those facilities? 11 would he place his belongings, et cetera? 12 A Yes. 12 A We have a station, like a table pretty much 13 So do you know which location Mr. Gray was 13 in the warehouse -- 14 hired out of? Do you know if it was 2801, 8290 or any 14 0 All right. 15 of the others? 15 A -- with our computers, and that's kind of 16 A No. 16 his of?ce in the warehouse, yeah. 1? Okay. So let's talk about -- let's use 17 And that is in the actual warehouse area? 18 December of 2016 as your point of reference. Can you 18 A Yes. 19 tell me who the name of lnpax's highest ranking 19 All right. And then at the 2801 South 20 manager was at the 2801 South Western Avenue facility? 20 Western Avenue location, did he have any assistant 21 A Byron West. 21 managers or people that assisted him in doing what his 22 What was his title? 22 job was? 23 A Inpax regional Chicago manager. 23 A Yes. 24 Was he the highest ranking manager, 24 And who was that at the 2801 location? 25 including over the managers at the Austin location. 25 A I don't know. EcoScribe Solutions 888. 651. 0505 . i'l FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 30..33 Page 30 Page 31 1 0 Okay. You don't recall? 1 say he's working at 2801 South Western, that's his 2 A I mean, I don't know their names, but I know 2 point of -- that's where he gets the packages. 3 what they do. He had dispatchers up under him. 3 If he has a dispatcher, would that be his dispatcher 4 The title of those people would have been 4 for the whole day? That's the person that would 5 dispatcher; they were the next in rank? 5 dispatch him throughout the day? 6 A Yes. 6 A Maybe mornings, and then another one comes 7 Do you know how many different dispatchers 7 in midday. 8 in December of 2016 were working out of the 2801 8 Okay. And then if we talk about the Lisle 9 location? Would it have been one, two, three? 9 facility where Byron West was also the Chicago 10 A Ifl had to guess, I would say three. 10 regional manager at that facility, again, his under 11 Best estimate? 11 his immediate underlings in the hierarchy of the 12 A Estimate. 12 company's authority would have been dispatchers? 13 And is there a way I understand you might 13 A Yes. - 14 not have that information off the top of your head, 14 Do you happen to know the names of any of 15 but is there a way, are there records that would be 15 those dispatchers at Lisle? 16 available if you asked someone to look for those 16 A No. 17 - names, we could identify those people? 17 Do you know how many there would have been; 18 A Sure. 18 again, best estimate, three? 19 Do you happen to know who was dispatching 19 A Three. 20 Valdimar Gray on December 22nd, 2016? 20 Below the rank of dispatcher, are there 21 A No. 21 other supervisors that were working for lnpax at these 22 But there should be some record of who that 22 facilities? 23 would have been? 23 A No. 24 A Yes. 24 Did we just get to courier drivers at that 25 - On a particular day, Valdimar Gray, let's 25 point and drivers? . Page 32 Page 33 1 A Yes. 1 MR. Right. 2 And thenjust to get an idea, but at the 2 MR. FISHER: I agree though. 3 8290 Austin location, who was the manager at that 3 BY MR. FISHER: 4 location in December of 2016? 4 And how about the manager at the Mundelein 5 A I wouldn't know. 5 facility December of 2016, who was that? 6 Don't remember? 6 A I don't know. 7 A Uh-uh (negative). 7 Is that person, to the best of your 8 And you just no, that's no? 8 knowledge, still working with the company or notcould probably say not to that one. 10 Thank you. 10 Okay. Again, if I asked you to go back to 11 Is that person still with the company, 11 the office and have somebody pull certain records, 12 whoever it was; do you have any idea? 12 that we could identify these namesthem. 14 MR. 1 think he does not 14 Okay. As I understand it, Mr. West is no 15 know. 15 longer employed by the company: is that true? 16 A Right. That's correct. 16 A That's correct. 17 BY MR. FISHER: 17 When did he leave the employ of lnpax 18 Okay. Did I do a double negative? 18 Shipping Solutions, Inc.? 19 MR. Kind of. Although I guess 19 A '17 sometime. 20 I'll stipulate we've already disclosed Byron 20 Did he leave under good circumstances or was 21 West. I think a lot of these questions that 21 he let go? 22 you're asking Mr. Wright can be answered by Byron 22 A Let go. 23 West. 23 Was there a reason for that? 24 MR. FISHER: I'm hoping so. lwon't 24 A I guess just lack of leadership, lwould 25 know that until I ask 'em. 25 say. EcoScribe Solutions 888.651.0505 II .- 1? FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 34.37 Page 34 Page 35 1 Ultimately was that your decision? 1 the dispatchers were at the Mundelein facility, I'm 2 A No. 2 assuming you wouldn't be able to tell me that off the 3 Who makes that decision to let the regional 3 top of your head; is that true? 4 manager go? 4 A Correct. 5 A At that time I don't know who our -- I don't 5 And the same would be true of the 8290 6 remember who was our, like, national manager. But 6 Austin: you wouldn't be able to tell me who the 7 whoever was over him at the time. It could have been 7 dispatchers were; is that correct? 8 David at that time. 8 A Correct. 9 0 David who? 9 So in the Chicagoland area would it have 10 A Williams. He may have been in that role. 10 been Byron West back in 2016 who would have done the 11 Did Byron West's dismissal in 2017 have 11 hiring and ?ring of drivers or is it someone else? 12 anything to do with the Valdimar Gray incident 12 A Him and other people would, but Byron, he 13 involving Miss Escamilla? 13 had the authority to hire and fire. 14 A No. 14 Did you play any role in hiring Byron West 15 Was there any discipline or reprimands 15 when he was originally hired? 16 L. levied in your company to anybody as a result of the 16 A No. 17 'Valdimar Gray-Escamilla occurrence? 17 How long had he been with the company for 18 A I'm not sure but I don't think so. 18 would you say before he was let go in '17? 19 Is this the only time an employee of yours 19 A I think we started there in '15. 20 has been in a traf?c collision where someone 20 So he had been with the company between from 21 has perished as the result, that you know of? 21 around 2015 until he was let go in 2017? 22 A That's correct. 22 A Yes. 23 Okay. So let's talk now about the so I 23 What was his background in the type of 24 think we've covered what I can get at this point. 24 business your company did; do you know? 25 In terms of dispatchers, if I asked you who 25 A Well, he started with us as a driver. I do Page 36 Page 37 1 know that from speaking with him. I think he worked 1 December of 2016. Was there someone at the company 2 at some management at I think I can recall he was 2 with the title "National," you know, ?National 3 with, is it the Tribune? 3 Manager"? 4 Okay. Did he have anything to do with the 4 A If Charles was there at that time, he would 5 delivery, the physical delivery of papers? 5 be that guymanager. 6 What's his last name? 7 Okay. Just trying to get a sense of it. I 7 A Hollowell. 8 mean, did he have any background that you are aware of 8 Just like it sounds? 9 when your company hired him in 2015 in the courier 9 A Yeah. 10 service business? 10 He might have been gone from the company by 11 A I'm not sure. 11 December of 2016? 12 Do you know if he had ever been a courier 12 A May have. 13 himself other than with your company before he was 13 If he was gone, would it have been David 14 named the regional manager? 14 Williams who was acting as the national manager? 15 A Not sure. 15 A Yes. 16 And, you know, just to get it straight, as 16 Do you have written job descriptions for the 17 of December of 2016 his immediate boss or supervisor, 17 various titles that we've discussed here: Regional 18 "he" being Byron West. would have been whom? 18 manager, national manager, dispatcher, drivers? 19 A Either David Williams -- he reported either 19 A Yes. 20 to David Williams or myself. 20 Where would I ?nd these titles? What 21 Was there a national manager that oversaw 21 document contains those titles or is it something, 22 the regional managers? 22 just individual documents? 23 A Yes, at one time Charles Hollowell. but I 23 A Individual documents. 24 don't know if he was there at this time. 24 Okay. Did these written job descriptions 25 So I'm referring to just point of reference 25 exist back in December of 2016? EcoScribe Solutions 888. 651. 0505 i'l I'll. ill FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 38..41 Page 38 - Page 39 A Yes. 1 A Yes. 1 2 Have they changed since then? 2 0 Okay. Can you describe for me what managing 3 A (There was no response.) 3 lnpax's daily activities day to day would entail? 4 Are the descriptions of these various titles 4 understand he physically goes out to those locations. 5 the same? 5 What did you understand he would be doing? 6 A About the same. 6 A He would make sure the dispatchers would get 7 Okay. Do you have so I just want to 7 all the vans loaded and packages in the vans to go out 8 make sure I get the titles right when ask for it. 8 for route delivery that day. And of course hiring and 9 So we've got national manager? 9 recruiting. 10 A Mhm-hm (affirmative). 10 0 Okay. 11 have regional manager? 11 A Hiring and recruiting drivers. 12 A Yes. 12 0 Anything else that you can think of? 13 Dispatcher? 13 A No. 14 A Yes. 14 Who handled things like payroll? 15 And then would the couriers be referred to 15 A We do that here in Atlanta. 16 as drivers or couriers? 16 Back-end work? 17 A Drivers. 17 A Yeah, here in Atlanta. . 18 Okay. A regional manager like Byron West, 18 0 Okay. So how would a driver like Valdimar 19 what did you understand in December of 2016 his 19 Gray, how would his hourly information get back to 20 day-to?day job duties and responsibilities to be? 20 Atlanta at that time, and is that electronic? 21 A Hiring, firing -- hiring and firing drivers 21 A Yes. Clocks in on electronic time clock. 22 and managing the day-to-day operations for lnpax. 22 And that's all transferred electronically 23 And because he had two different warehouses, 23 here to Atlanta? 24 he was responsible he'd be going back and forth 24 A Yes. 25 between Lisle and Western Avenue? 25 And for Valdimar Gray, as of December of Page 40 Page 41 1 2016. the company was taking out tax and social 1 job descriptions would have been as dispatchers? 2 security withholding? 2 A You know, helping, like I said, get the vans 3 A Yes. 3 lined up and loaded out. And they monitor the 4 If Valdimar Gray needed to take a personal 4 drivers' performance throughout the day to make sure 5 day, a vacation day, a sick day, he would have to 5 we're delivering properly and on schedule. 6 clear that with his immediate manager, Mr. West? 6 0 Okay. So getting the vans lined up. Would 7 A Yes. 7 the vans be returned each evening to a particular 8 If Mr. Gray was violating some lnpax company 8 location, one of those four locations? 9 rules, whatever they may have been, it would have been 9 A Yes. 10 Inpax through Mr. West that would have been 10 0 Okay. The vans that drivers like Mr. Gray 11 responsible for discipline or citation? 11 would use in 2016, were those either owned or leased 12 A Yes. Well, the dispatcher could and 12 by Inpax? 13 escalate it up to - 13 A Yes. 14 0 Got it. 14 Did Inpax own certain vehicles like some of 15 A -- Byron. 15 those cargo vans or did they lease them all? 16 So any other job duties and responsibilities 16 A Lease them all. 17 you can think of that Mr. West was fulfilling in his 17 And was there a particular lessor that the 1B role as regional manager in December of '16 that you 18 company used at that time? 19 haven't told me about? 19 A Enterprise. 20 A No. 20 0 Okay. And who was the person at lnpax that 21 Okay. Let's talk about the dispatchers. 21 arranged, that entered into the arrangement with 22 We've already talked about it, and I understand you 22 Enterprise for the leasing of all of these various 23 don't recall individual names of dispatchers at those 23 cargo vans; was that you or? 24 various facilities. 24 A Yes, me. 25 Can you tell me what you understand their 25 0 Okay. If the vans needed maintenance or Solutions 888. 651.0505 rll'r"mm . llf" FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 42.45 Page 42 Page 43 1 repair during the course of a leaseresponsible to do that? 2 Did you investigate into that? I mean, did 3 A We had warranty on it, so I think we used 3 it ever come up at all that there was some mechanical 4 Firestone back then. 4 problem that resulted in this occurrence? 5 What I'm asking, was that something 5 A No. 6 according to the leases that your company was entering 6 All right. So the task for a dispatcher of 7 into with Enterprise as of 2016, if there was a 7 getting the vans lined up, would the dispatcher assign 8 problem with a van, it needed maintenance, it needed 8 a driver in 2016 in the Chicagoland area to a 9 repair, would it be returned to Enterprise to do that 9 particular unit or particular van or would the drivers 10 maintenance repair? 10 day after day use the same vans over and over? In 11 A No. 11 other words, if Valdimar Gray is using Van 49, does he 12 So that fell on Inpax? 12 use it every day? 13 A That's correct. 13 A I'm not sure. 14 Okay. And then you had a -- some service 14 Okay. And when you say "get the vans lined 15 contract with another entity? 15 up," in the order in which they're going to be loaded; 16 A That's correct. 16 is that what it was? 17 Did you ever hear or learn of any 17 A Yes. 18 allegations with regards to the occurrence with 18 And how would the dispatcher know what order 19 Mr. Gray and my client, Mrs. Escamilla, that there was 19 and which vans would be loaded with what? Was that 20 some defect in the cargo van he was using at the time 20 done in coordination with Amazon? 21 which he claims resulted in this occurrence in one way 21 A Yeah. Amazon supplies us a route, the 22 or another? 22 routes for the clay, and we put them in the order that 23 A No. 23 we run them in. 24 You never heard about any mechanical 24 And who would actually do the loading of the 25 problems or anything like that? 25 packages into the cargo vans? Page 44 Page 45 1 A The driver. 1 (Discussions were held off the 2 The driver would actually do that? Yes? 2 record.) . 3 A Yes. - 3 MR. FISHER: Back on the record. 4 Was there a policy or procedure back in 4 BY MR. FISHER: 5 December of 2016 as to how to load a cargo van. how to 5 Would the dispatcher. before a particular 6 secure that load? 6 van went out of a facility in the Chicagoland area in 7 A How to load was by the route sheet, so 7 December of 2016, would he do the ?nal check of a 8 however they were listed on the route sheet. 8 cargo van's load to make sure everything was on there, 9 Whatever was getting delivered ?rst would 9 everything was in properly before the doors are 10 be to the tail end of the van; whatever was being 10 closed? Would that be part of the dispatcher's job? 11 delivered last would be towards the front of the van? 11 A Well, he probably couldn't make sure 12 A That's correct. 12 everything that was, probably, but, you know, as long 13 Okay. How about in terms of a proper 13 as this guy loaded everything that was staged right 14 procedure for stacking and securing that load in a 14 there by the van, yes. 15 van, was there any company rule or policy or manual 15 0 Okay. And it would be Amazon who would 16 regarding that? 16 stage the cargo for a particular load? 17 A No, just load it to make it fit the van 1? A Not necessarily. 18 to - in order. 18 Who would do that? 19 And were the packages that would ?t into a 19 A So basically the way it works is, is Amazon 20 cargo van, were they secured in any way or were they 20 will have sorters come in at night, and they sort out 21 pretty much 21 the routes and they -- we drive through the building 22 A Floor loaded, all loose. 22 and they're just sitting right there and their routes 23 Okay. 23 are just numbered in some numerical order. 24 MR. FISHER: Teny, I know you're 24 Okay. 25 rolling your eyes. Off the record. 25 A 80 I guess, in a sense, yeah, the sorters. EcoScrr'be Solutions 888.651.0505 'rll'r'm M: :l 1-. 'll FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25. 2019 Pages 46..49 I Page 46 Page 47 1 And then would the dispatcher and the 1 detour? 2 drivers then move those loads into position? 2 A That's correct. 3 A Yes. 3 And that there's not any problems? 4 In particular bays? 4 A That's correct. 5 A Yes. Just go down the line and you pick 5 0 Okay. And so when the driver like Mr. Gray 6 'em. yeah. 6 would get a load before he leaves whatever facility it 7 And then how would the dispatchers for Inan 7 was, would there be some paperwork generated for that 8 in December of 2016 monitor the driver's performance. 8 load that he would be provided with? Now. I know in 9 how would they go about doing that? 9 some industries it's a bill of lading or something or 10 A Because on our software that we use. it's on 10 a delivery ticket. With Inpax in 2016, was there some 11 the screen the monitor on our 11 paper that accompanied the load? 12 computer. So you can see his movements and how fast 12 A No. 13 he's going. 13 0 it was all electronic? 14 So back in December of 2016. once a driver 14 A That's correct. 15 like Mr. Gray has his load and he leaves the facility 15 So if I wanted to know at the time of this 16 that he?s gotten his load at, somebody at Inan is 16 occurrence what load had been loaded onto Mr. Gray's 17 able to monitor his every movement? 17 cargo van that day before the occurrence. what do 18 A Yes. 18 ask for? What's that calledwas all scanned Into the device. 20 A Yes. 20 I know. but if I - I'm assuming that the 21 And it would be the dispatcher that. whoever 21 company has some way. if they ever needed it. they 22 his dispatcher was for that load. would be responsible 22 could print out that load for that day. What do ask 23 for doing that? 23 for? 24 A Yes. 24 A Probably his manifest. 25 Making sure he's not going on a frolic and a 25 So. and would a driver back in December of Page 48 Page 49 1 2016 have more than one manifest for the day or would 1 of 2016, you're unaware of anybody at the company 2 typically he get a load and it would take him all day 2 saying. at the end of every year we're going to delete 3 to deliver? 3 that data, correct? 4 A All day to deliver. 4 A Yeah, correct. 5 0 Okay. So I would ask for Gray's manifest 5 And if someone created that policy at your 6 for that day? 6 company. you would know about it, being the president 7 A Yes. 7 and 8 MR. Would Inpax still have 8 A Yes. 9 that? 9 Would that manifest list the order in which 10 THE WITNESS: Probably not. 10 packages were delivered that day? 11 BY MR. FISHER: 11 A Yes. 12 0 Okay. What's the company policy with 12 And the location? 13 regards to keeping that electronic data? I mean. 13 A Yes. 14 because it's -- 14 Was there some time constraints or -- placed 15 A I'm quite sure you can go back and pull it 15 on the drivers back in December of 2016: in other 16 out of the device. 16 words. you have to be in at a particular time and you 17 Okay. 17 have to have completed your route at a particular 18 A But not a hard copy paperwork. 18 time? 19 If it's on the device, I'm sure it can be 19 A Yes. So you have to start at a certain time 20 printed somewhere? 20 and end at a certain time. You cannot drive over 10 21 A Yes. 21 hours in a day. 22 0 Just has to be transferred to a printer? 22 And I'm assuming with regards to Mr. Gray's 23 A That's correct. 23 route the day of this occurrence. you wouldn't know 24 What I'm asking about is the data that, the 24 when he started and when he ?nished? 25 manifest data that would have been created in December 25 A No. EcoScribe Solutions 888. 651. 0505 l" l' 5 ll'l'l ll] FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 50.53 Page 50 Page 51 1 And I also assume that you -- would it be 1 A So the sorters atnight put the routes 2 true that you don't know where in his delivery 2 together. 3 manifest he was at the time of this occurrence, 3 But what I'm assuming is, I'm assuming 4 whether he was closer to the beginning of it, middle 4 somebody because it just makes sense to me, that that true? 5 somebody, before you send drivers out with a loaded 6 A lwouldn't know. 6 cargo van, when the loads are being calculated, 7 0 Okay. Has it occurred where a driver goes 7 there's an effort to put packages that are going in 8 over his or her 10 hours? 8 the same geographical area in the same van? 9 A I wouldn't know, but I imagine it's 9 A Yes. 10 possible. 10 Who does that? Who did that back in 11 What are they told? If you get to 10 hours 11 December of 2016? 12 are they told to bring it back? 12 A Amazon sorted that. 13 A You're supposed to come back, yes. 13 Okay. So we've talked about the dispatchers 14 And then we'll redeliver with another 14 now. If a dispatcher was monitoring a particular 15 person? 15 driver on a particular day in 2016 and that driver was 16 A The next day. 16 starting to run behind in that dispatcher?s opinion, 17 Okay. What's the reasoning behind that 17 was the dispatcher charged with the responsibility of 18 rule; do you know? 18 making contact with that driver for the purposes of, 19 A No, we just -- our routes were you either 19 you know, trying to get things sped up or something 20 got eight-hour routes, nine-hour routes, 10-hour 20 like that? 21 routes. 21 A So what we do in a situation where we deem a 22 And who put the routes together? Would it 22 guy's falling behind on his route. we send another 23 have been the dispatchers? 23 driver to help. 24 A Yes. Well, we get the manifest from Amazon. 24 And they would meet up somewhere and 25 0 Right. 25 transfer some of the packages? Page 52 Page 53 1 A Yes. . 1 MR. FISHER: Other than him. 2 Do you know if that happened Mr. Valdimar?s Gray, involving Mr. Gray? 3 How about -- same question. How about, do 4 A I'm not sure. 4 you recall the name of the Amazon rep at the 5 0 Okay. I would have to talk to either the 5 Austin-Morton Grove location in December of 2016? 6 dispatcher or Mr. West? 6 A No, I don't remember him either. 7 A Gray, yes. 7 Do you know out of what location Mr. Gray 8 MR. Gray. 8 was dispatched out of on the day of this occurrence, 9 MR. FISHER: Or Mr. Gray. 9 before it happened? 10 BY MR. FISHER: 10 A (There was no response.) 11 0 Okay. So let?s talk about the Amazon 11 Do you know if it was out of the South 12 facilities managers or the facility contacts back in 12 Western, the Austin, the Lisle, the Mundelein? 13 December of 2016. Let's start with the Amazon 13 A I would be guessing, but I think it's the 14 location that was located at 2801 South Western. Do 14 South Western. 15 you know the name of the Amazon representative that 15 0 Okay. 16 your company dealt with there? 16 A I think. 17 A I can see his face, but I can't remember his 17 And if I asked you the same questions about 18 name. He's not there anymore. 18 Lisle and Mundelein, the Amazon representative who had 19 Okay. Can you recall the names of 19 the most contact with the Inpax people at those two 20 any Amazon employees who worked with your company at 20 locations on that day, at that time? 21 2801 South Western Avenue in Chicago as of December of 21 A Now, I do know the Lisle guy; he's still 22 2016? 22 there. 23 A No. 23 0 Who's the Lisle guy? 24 MR. Other than Jeff Base-less 24 A Steve Fearaday. 25 (levity)? 25 How do I do you know how to spell his EcoScribe Solutions 888.651.0505 FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 54.57 Page 54 Page 55 1 last name? 1 that agreement, the one that would have been in effect 2 A Fear, F-E-A-R. 2 in December of '16 3 3 A Yes. 4 A Fearaday, A-D-A-Y. 4 -- on behalf of Inpax? 5 0 Thank you. Do you know what his title was? 5 A Yes. 6 A He was the station manager. 6 Okay. Before I get to that, let me -- I 7 Would that have been the person, the title 7 don't want to -- I'm jumping around too much. Let me 8 of the person at Amazon at these four locations that 8 come back to that in just a second. 9 would have had the most contact with lnpax at these 9 Let's talk about the company's policy when 10 locations regarding deliveries? 10 it hires drivers like Valdimar Gray back when he was 11 A The station manager. 11 hired. And I think I have a document that talks about 12 Station managers? 12 when Mr. Gray was hired. 13 Okay. So was Inpax Shipping 13 (Document marked for identi?cation 14 Solutions, Inc., did it enter into some contract 14 as Plaintiff's Exhibit 1.) 15 arrangement with an Amazon entity for providing 15 BY MR. FISHER: 16 courier services to Amazon at that time? Again, let's 16 For the record, what I'm handing you right 17 use 2016 as your point of reference. Was there a 17 now is what I've marked as Plaintiff's Exhibit 18 written agreement? 18 Number 1. And this purports to be the courier 19 A For those stations or just in general? 19 application for Mr. Gray. It's a package of -- and 20 Well, I don't know. Let's start with in 20 it?s seven pages and they're numbered at the bottom by 21 general. Was there some general agreement that -- 21 me. Have you ever seen this before? .22 between Inpax and an Amazon entity for the entire 22 A No. 23 country? 23 0 Okay. And I'll represent to you that the 24 A Yes. 24 attorneys for lnpax provided these documents to me 25 0 Okay. Were you the person who negotiated 25 pursuant to written discovery in our case. Page 56 Page 5? 1 It appears, though, that Mr. Gray applied 1 0 Okay. And then the applicant. like we see 2 for his position on or around September 27th of 2016 2 here, would have ?lled out a bunch of different boxes 3 based on the top of the ?rst page. Do you have any 3 concerning his quali?cations for a position? 4 reason to disagree that that was the approximate time 4 A Yes. 5 that Mr. Gray would have applied for a position with 5 And it appears Mr. Gray did that on or 6 Inpax? 6 around September 27th of 2016 based on these 7 A I wouldn't know. 7 documents? 8 Okay. So Kimberly Clark, do you know who 8 A Yes. 9 she is? 9 0 Okay. And he was required to identify 10 A Mhm-hm (affirmative), yes. 10 driving years of experience, where here he puts 11 Who is Kimberly Clark? 11 "three" on page one at the bottom? 12 A She works in our accounting department. 12 A Yes. 13 Back in 2016 was she part of did she have 13 Driving History, Vehicle Type; he says 14 recruiting responsibilities? 14 "car," correct? 15 A No. 15 A Yes. 16 Okay. How is it that drivers were recruited 16 He's asked to ?ll in the box that refers to 17 in the Chicagoland area; I mean, would they hold job 17 violations in the last three years, correct? 16 fairs. would they put ads in the paperguess. I don't know. 19 know, Monster? 19 MR. Well, itjust says 20 A Indeed. 20 "Violations." 21 Indeed? 21 BY MR. FISHER: 22 A Yes. 22 Says "Violations. Check if not applicable." 23 Okay. So most of that recruiting was 23 And what's bullet-pointed is: have no violations in 24 electronic? 24 the last three years. 25 A Yes. 25 You'd agree that's what it says? EcoScn'be Solutions 888. 651.0505 .l 7 ill FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 58.61 Page 58 Page 59 1 A Yes. 1 Would you agree with me that at least when 2 Okay. And you have no reason to disagree 2 Mr. Gray did his application he didn't list any 3 that this isn't an accurate document from the 3 employers in the courier business? 4 recruiting of Mr. Gray, do you? 4 A (There was no response.) 5 MR. Well, let me just object 5 He lists bouncer. Rack in 6 to "the recruiting." I mean, he applied. 6 loss prevention, and Monterrey Security as a security 7 MR. FISHER: Okay. of?cer? 8 MR. We have the application 8 A Yes, correct. 9 here. But go ahead. 9 Okay. And then questions are asked of him 10 MR. FISHER: We can stip, can we not, 10 if he had ever served in the armed forces, if he had 11 Terry, that this is Mr. Gray's application? 11 been convicted of a felony, if he's a US. citizen, 12 MR. Sure. Imean. this was 12 what's his highest level of education. I'm looking at 13 produced in his - part of his personnel file, 13 the bottom of page three. 14 believe. 14 A Yes. 15 MR. FISHER: Absolutely. 15 And then apparently on September 27, 2016 he 16 BY MR. FISHER: 16 signs and dates the application, agreed? 1? So any of the questions that were asked, 17 A Yes. 18 there's starting on page two there's questions that 18 All right. And just by seeing this -- and 19 are asked -- that Mr. Gray is asked to ?ll out 19 then he's asked some additional questions beyond that; 20 regarding his job history, correct? 20 starting on pages four and five he's asked about his 21 A Yes. 21 driver's certi?cation, he's asked about his driver's 22 Okay. And if you just start with employer, 22 license requirements, drug and alcohol testing, 23 you know. on page two Employer One and Employer Two 23 accident reporting guidelines, things of that nature, 24 are identified. On page three there's Employers 24 correct? 25 Three, there's an Employer Three identified. 25 A Correct. Page 60 Page 61 1 To which he responds in an appropriate 1 application was ?lled out in September of 2016? 2 fashion, correct? 2 A No. 3 A Yes. 3 Okay. And the occurrence took place on 4 All right. He's asked a question on 4 December 22nd. Maybe it had something to do with 5 page six, something about speeding, driver 5 that? 6 certi?cation, and he indicates that: I have read and 6 A Something to do with that, yes. 7 understand the speeding requirements. 7 All right. Fair enough. 8 Do you know what the speeding requirements 8 MR. Mike, we've been going a 9 he's referring to are? 9 little over an hour. Do you mind if we take a 10 A Probably the handbook. reading the driver 10 two-minute break? 11 manual, handbook. 11 MR. FISHER: Yes, please. 12 So I want to talk to you about that in a 12 (Deposition in recess, 12:03 pm. 13 second. Okay. And then if you look at the page 13 to 12:12 pm.) 14 seven. there's a web address under Recruiting Inpax. 14 MR. FISHER: We're back on. 15 and it appears it's sent to Kimberly Clark. 15 BY MR. FISHER: 16 Was that policy and procedure at the time, 16 Last issues on this application. When 17 that once a potential driver in the Chicagoland area 17 someone like Valdimar Gray gets hired by Inpax. is 18 ?lls out his application, recruiting sends the 18 this application the is this the document by which 19 application over to Kimberly Clark here in Atlanta? 19 he gets hired or is it followed up with a personal 20 A Once he's been hired, yes. 20 interview or a secondary questionnaire or pretty much 21 Okay. So, but the fact that this was sent 21 is the information contained on Plaintiff's Exhibit 22 to Kimberly Clark on December 23rd, 2016 means that at 22 Number 1 the basis under which he gets hired? 23 least before that -- strike it. 23 A So he fills this out and then he goes to an 24 Do you know why this would have been sent to 24 interview. 25 Kimberly Clark on December 23rd, 2016, when the 25 Okay. Do you know who interviewed Mr. Gray? EcoScribe Solutions 888.651.0505 mm: ., FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 62.65 Page 62 Page 63 1 A No. 1 website? 2 Is there a standard set of questions for 2 A Yes. 3 that interview that existed in September of 2016, or 3 Okay. Was the website similar back in 2016? 4 is it just whatever the interviewer asks? 4 A I would think so. 5 A I imagine it is. I don't know what that 5 0 Okay. On page three. your website indicates 6 would be. 6 the company's core capabilities. Do you see that? 7 Whose job responsibility was it to interview 7 A Yes. 8 drivers in 2016? 8 On-Demand Service, Same-Day Freight, 9 A Either Byron or the lead dispatcher. 9 Scheduled Delivery, Expedited Shipping. One-Hour 10 Do you know who the lead dISpatcher was at 10 Delivery, Dedicated Fleet. 11 the Chicago, the 2801 address? 11 How does your company go about guaranteeing, 12 A No. 12 like. one-hour delivery? 13 0 Next thing I want to have you take a look at 13 A Call us up and you law ?rm, say you 14 real quick is what I'm marking as Plaintiff's Exhibit 14 need something delivered from South Wacker over to 15 Number 2. 15 North Wacker: we'll say, We'll get it there in an hour 16 - (Document marked for identification 16 for you. 17 as Plaintiff?s Exhibit 2.) 17 0 Okay. And you're charged accordingly? 18 BY MR. FISHER: 18 A Yes. 19 I'm going to hand you now what I've marked 19 And if you turn to page four. the website 20 asPIaintiff?s Exhibit 2 for identification. For the 20 identi?es all of the different vehicles your company 21 record, this purports to be the pages that make up 21 had the ability to utilize? 22 your company's website currently. Can you just verify 22 A Yes. 23 that. 23 How many vehicles does your company 24 If you just leaf through this, does this 24 currently lease or rent? 25 look like to be the various pages of your current 25 MR. Now? Page 64 Page 65 1 MR. FISHER: Now. 1 Okay. Of the vehicles that are identi?ed, 2 A Lease or rent? 2 car, cargo van, sprinter, straight truck, 3 BY MR. FISHER: 3 tractor-trailer, what is the most-used vehicle in the 4 Approximately. 4 fleet? 5 A 500. 5 MR. Now? 6 How many tractor-trailers does the company 6 BY MR. FISHER: 7 lease or rent? 7 0 Now. 8 A Zero. 8 A Cargo van. 9 Okay. So if your company is retained to do 9 How about 2016? 10 a larger load that requires a tractor-trailer, what 10 A Cargo van. 11 does it do? 11 If you take 'a look on pages 10 and 11, 12 A We send it, but they're not leased or 12 that's the portion of the website that pertains to 13 rented. 13 drivers. Do you see that? 14 0 They're owned? 14 A Uh-huh (affirmative). 15 A Yes. 15 0 That's a yes? 16 How many vehicles does your company own? 16 A Yes. 17 A 60. 17 0 Okay. On page 11 it lists the basic 18 Would the numbers have been similar in 18 requirements that a driver needs to have to hire on 19 December of 2016, leased and owned vehicles? 19 with your company, I'm assuming in a non-commercial 20 A No. 20 sense, driving cargo vans or vans? 21 0 Less or more back then? 21 A That's correct. 22 A Less. 22 So 21 years or older with a valid driver's 23 And -- 20 percent less, 10 percent less; 23 license. three-year motor vehicle report, knowledge of 24 what would you say? 24 the city and passing a drug screen. Those would be 25 A 30. 25 the basic requirements. correct? EcoScribe Solutions 888.651.0505 "I'il'I??mnl? . "l FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Pages 66..69 assesses:30m~mmnw~A Page 66 A Yes. Your company would hire people with no experience as a courier delivery? A Yes. 0 Okay. Those are all the questions I have on that. We can put it aside. I was provided -- l'm going to show you the next document was provided. We'll mark it as Plaintiff's Exhibit Number 3. (Document marked for identi?cation Page 6? A On page two it says "Handbook." Okay. And was this handbook being used for new hires back in 2016? A Yes. This is a true and accurate copy, to the best of your knowledge? A Yes. What's the purpose of this document? A Basically tell employees a little bit about the company and what our rules and regulations are. as Plaintiff's Exhibit 3.) 11 Besides this document. did the company have BY MR. FISHER: 12 any others that it used for drivers in terms of rules I'm going to hand you what I've marked as 13 and regulations for drivers? Plaintiff's Exhibit Number 3. and I'm going to ask you 14 A I think we do. In the safety department we to tell me what this document is. 15 would have, probably have some for drivers, but I A Looks like the first page is my welcome 16 don?t know about Amazonl the guys that drove letter. And this looks like the handbook. 17 for Amazon. So I mean. speci?cally what is this called? 18 0 Let's start off with you mentioned safety In the ?rst page it says "Your Employee Manual.?l Is 19 department. Does your company have a safety 20 this document, Plaintiff's Exhibit Number 3, pages 1 20 department? 21 through 87, is this the employee manual that your 21 A Yes. 22 company uses? 22 Did it have a safety department in December 23 A No. I mean, I'd call it -- I can refer to 23 of'16? 24 it as Manual or Handbook. 24 A Yes. 25 Okay. 25 Where was the safety department located? ls Page 66 Page 69 1 it in Atlanta? 1 A Fleet and safety. . 2 A Yes. 2 And what did you understand his duties and 3 What's the purpose of the safety department? 3 responsibilities to be? 4 A From a -- it's two different perspectives of 4 A Manage the ?eet of vehicles in the safety 5 the safety department. So you got the employee-based, 5 department, keep us in compliance with the rules and 6 employees that drive these vans that are employees; 6 regulations. 7 they're not in the same category as the big trucks. 7 Department of Transportation rules? 8 So the safety and compliance for these guys aren't 8 A Yes. 9 tracked like tractor-trailers or box trucks. 9 Federal Motor Carrier Safety rules? 10 Their hours don't have to be tracked and 10 A Yes. 11 things of that -- 11 Were couriers like Mr. Gray responsible to 12 A Yeah. 12 comply with the Federal Motor Carrier Safety 13 They don?t have to turn in a driver's log? 13 Regulations? 14 A That's correct. 14 A No. 15 0 They don't have to do those things? 15 Did the company have a set of safety rules 16 A That's correct. 16 for drivers like Mr. Gray, courier drivers who drove 17 But what I'm asking. you had a safety 17 vans? 18 department in December of '16? 18 A Yes. 19 A Yes. 19 Those safety rules. are they encompassed in 20 Let's start with this. Who was the head of 20 this Plaintiff?s Exhibit Number 3 or was there a 21 the safety department back then? 21 separate document? 22 A In '16? It was probably Rusty Cook. 22 A It was probably a separate document. 23 Is Mr. Cook still with the company? 23 Do you know what that was called? 24 A Yes. 24 A No. I don't know what it was called but it 25 What was his title? 25 was probably a driver's manual. EcoScribe Solutions 888.651.0505 II. I: ?Il FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25, 2019 Pages 70.73 Page 70 Page 71 1 Okay. 1 That's all I'm interested right now. 2 MR. FISHER: Terry, I've never seen it. 2 A So either this or another manual somewhere 3 I don't think that's been produced but -- okay. 3 else that would be used for employee drivers. 4 BY MR. FISHER: 4 So, and I'm not critical either way. I'm 5 So if I asked Terry to produce for me the 5 just asking you as the owner-president of the company, 6 courier?s driver manual, is that what you're referring 6 as of 2016, do you believe there to have been 7 to? 7 something tantamount to a courier's driver manual that 8 A Sure. 8 existed? 9 MR. go ahead and ask 9 A (There was no response.) 10 him. I don't even know if is there one? 10 0 That laid out for a courier his rules and 11 THE WITNESS: I'm quite sure we have 11 regulations per his job? 12 one. 12 A On the employee side it's probably this. 13 MR. Or are you guessing? 13 "This" being Plaintiff?s Exhibit Number 3? 14 MR. FISHER: Hejust said there was 14 A Yes. 15 one. 15 0 Okay. You're familiar with this document, 16 MR. He said he thought there 16 right? 17 was. 17 A Yeah. 18 THE WITNESS: We should have one, butl 18 Can you show me anywhere in this document 19 don't know if this particular one here for these, 19 where it talks about any types of rules. regulations 20 if this is the one that we would use for the 20 or policies pertaining to those courier drivers, if 21 employee drivers, because the rest of our drivers 21 you know? 22 are independent contractors on 22 MR. Let me just object to the 23 BY MR. FISHER: 23 extent that that Exhibit 3 is 87 pages long. 24 0 Mr. Gray was an employee driver? 24 But go ahead. 25 A That's correct. 25 MR. FISHER: I think I laid a Page 72 Page 73 1 foundation. If he doesn't know, who's going to 1 MR. FISHER: Yeah, I know. I'm ?ne 2 know? 2 with that. - 3 THE WITNESS: Well, I don't write, do 3 THE WITNESS: (Witness examining 4 all of this. I got thousands of employees, they 4 document.) This is more just a handbook. This 5 do this. 5 wouldn't have a drivers manual. 6 BY MR. FISHER: 6 BY MR. FISHER: 7 And it's ?ne. If you don't know -- 7 I'm going to ask you a question in a couple 8 A No, I don't. 8 minutes. I want you to ?nish reading this. 9 If you can't point me to pages, that's ?ne. 9 A All right. (Witness examining document.) 10 read it, read every page of it yesterday and 10 Okay. You have now had the opportunity to 11 didn't find a single reference to courier driver's 11 read over, actually turn every page of what we've 12 rules and regulations while driving vans or similar 12 marked as Plaintiff's Exhibit 3, which you have called 13 vehicles. Is that possible? 13 the "Employee Manual/Handbook." Is that true? 14 MR. Did you see any reference 14 A Yes. 15 to obeying all rules and regulations? 15 0 Okay. My question MR. FISHER: Terry, when we're done we 16 any rules or regulations pertaining to the speci?c 17 can -- 17 task of a courier or a driver driving a cargo van or a 18 MR. Well, go ahead. 18 similar vehicle? 19 MR. FISHER: This is the president of 19 A No. 20 the company. If I don't ask this gentleman, who 20 0 All right. Do you have an understanding or 21 would you suggest I ask? 21 some knowledge of the fact that there is some other 22 MR. Well, then. okay. 22 document than Plaintiff's Exhibit Number 3 that 23 MR. FISHERactually lays out the company's policies. procedures, 24 through the manual, he has to go through it. 24 and rules and regulations for drivers pertaining to 25 MR. Let him go through it. 25 driving vans? EcoScribe Solutions 888. 651.0505 mm: - Ill: Ill'l II Ili FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25. 2019 Pages 74.77 Page 74 Page 75 1 A I think I have some documentation for that 1 Lewis as a HR director at that time. 2 that I can provide for you. 2 Had you seen the driver's manual in the 3 What do you call that document so I know 3 past? 4 what to formally ask for? 4 A I'm quite sure we got one. It's not this, 5 A Driver's manual. 5 though. 6 Okay. And did that driver's manual exist in 6 Did it address the rules of the road, so to 7 December of 2016? 7 speak. for the drivers? 8 A I'm quite sure it did. 8 A It probably talked about, you know, the 9 Do you know who prepared that driver's 9 being safe and just basic rules and regulations of 10 manual? Was it prepared out of the safety department? 10 driving. 11 A Probably the human resources department. 11 Okay. I mean, that's important to you as 12 Who in human resources would have the 12 the owner of this company with these number of 13 experience and the knowledge to put together a 13 employees and these number of vehicles. it's important 14 driver's safety manual? 14 to you that they operate their vehicles, the drivers, 15 A Well, I think because these were employee 15 safely. correct? 16 drivers, these are the only employee drivers. the 16 A Yes. 17 director at that time. Lewis Richardson. 17 It's important to you that they don't 18 He was the human resources director? 18 endanger other drivers on the roadway. correct? 19 A Yes. 19 A Yes. 20 He's no longer with the company? 20 It's important to you that they don't 21 A No. 21 endanger pedestrians in the street crossing the 22 And he had some experience as a courier 22 street, true? 23 driver? 23 A Sure. 24 A No. In this case. you know, like I said, 24 And that would be one of the reasons why 25 it's different sets of rules for what Rusty did and 25 there was a driver's manual? Page 76 Page 77 1 A Should be. And I think back then we had -- 1 referred to on page 56? 2 they watched film also. 2 A That's correct. They should. yes. 3 I think they did too. and we're going to get 3 Okay. On page six of Exhibit 3. this 4 to that. I have one of those that have been produced 4 employee manual. or employee manuallhandbook. that's 5 for me. 5 the page that refers to your company's mission 6 A Yeah. 6 statement? 7 Okay. On page 56 of Plaintiff's Exhibit 7 A Mhm-hm (af?rmative). 8 Number 3. under Health and Safety, there is reference 8 Did you have some role in developing this 9 to a safety manual. 9 mission statement? 10 A Uh-huh (affirmative). 10 A Some of it. I put most of it together. 11 And it refers to: A safety manual has been 11 The third paragraph reads: We will develop 12 designed to educate you on safety in the workplace. 12 and maintain the high standards of professional 13 If you do not have a copy of this manual. please see 13 competence. integrity and service. 14 your HR department. . 14 Do you see that? 15 A I think that's what I'm talking about. 15 A Yes. 16 That's different than what Exhibit 3 is? 16 That's something that's important to you as 17 A What you're looking at now. 17 the owner of the company? 18 It's different than Exhibit 3? 18 A Yes. 19 A That's correct. 19 And I mean no disrespect to you. Can you 20 Okay. Would each new hire dating back to 20 tell me what your company did in 2016 with regards to 21 2016 get a copy of Plaintiffs Exhibit Number 3. the 21 developing the highest standards for its drivers? 22 employee manual/handbook? 22 A You know, we train them with our basic 23 A Yes. 23 training that we do every other driver. So out of 24 And would each new employee. especially 24 thousands of drivers, they get the same amount of 25 company drivers. receive a copy of the safety manual 25 training. 50 we feel that we trained him at the best EcoScrr'be Solutions 888. 651. 0505 I . FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 78.61 cn-P-wN?Lo Page 1'8 of our ability to go out and do the job, and an accident happened. Was there someone in the Chicagoland area from the time that Mr. Gray gets hired in -- looks like July. August, September of 2016 -- is there someone in the Chicagoland area working for Inpax that had the responsibility of training Mr. Gray to be a driver making sure that he knew the company rules, regulations, policies, procedures? A Yes. So each station has driver trainers. Do you know who Mr. Gray's driver trainer was? A No. Again, would that be something if you ask one of your assistants to help you find, that that data would be available to you; you could identify who the driver trainer was out of the 2801 location in 2016, the second half? A It's possible, but who knows. I mean. what was the company's policy? You've told me, and I believe you, that safety was very important? A Sure. We've talked about it now. if some new driver was assigned a driver trainer, would there be a?a?jgmm?mmwaPage 79 some documentation either in the new driver's ?le or with the company so that the company could prove, hey, we trained this person and here's the guy who trained him and his qualifications? Is there something that we can go back to and ?nd? A Probably the -- his paycheck, because what we do is when he comes in he does what we call a ride-along. Right. A For like three days. And then that driver trainer rides with him until he deems he's ready to go. So how do we determine who Mr. Gray's driver trainer was? A We could probably ask Byron. So short of Byron, because he doesn't work for the company anymore, right? A Right. If he doesn't remember, how do we ?nd out? A I wouldn't know. Okay. A There would have to be someone that worked for the company who would know. Okay. So with regards to Mr. Gray's driver trainer, it would be fair to say you don't know who AQmooumm-h-coM?x Page 80 that was, correct? A Correct. You don't know what that person's quali?cations are; would that also be true? A Well, if he was a driver trainer he was obviously quali?ed to train him. Okay. What training was provided to the drivers' trainers to make sure that they were competent to train new drivers? A So he probably there was some rules and guidelines that we looked at internally, he was probably deemed to be a good driver based on his delivery performance and he could get the job done, so he was probably promoted. So you're using the word "probably." I understand -- A Yes. -- but hard for me to work in "probablies." As you sit here today, can you describe for me the training that was provided to your employees who are going to act as driver trainers in the Chicagoland area in 2016? A No. Can you describe for me what rules and guidelines they were given that they were supposed to 338mm-qoacns-mMPage B1 impart to new drivers? A No. Would someone in the safety department know that because it was their responsibility to know that? A Not sure. So you said Rusty Cook would have been the safety -- what was his title back in 2016? A Compliance. But not for the employee side. Who was the head of the safety department in 2016? A For my company? 0 Yes. A Rusty. Okay. And who's the head of the safety department now? A Keisha Arnold. But Mr. Cook is still working for the company? A Yes. What's his role now? A Fleet manager. Okay. Do you know what Rusty Cook's background and training was with regards to industrial and delivery service training? A Other than being with me at the company and EcoScribe Solutions 888.651.0505 i: ?ll FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 82.85 Page 82 Page 83 1 we -- since day one, no. 1 Any other written documents that your 2 And that's on-the-job training -- 2 company prepared or PowerPoint presentations or video 3 A Sure. 3 that your company prepared to use as training 4 - which I don't minimize, but I'm saying, 4 materials for new drivers back in 2016? 5 was there any formal training that Mr. Cook had to 5 A All I know would be the one that's mentioned 6 enable him to have the quali?cations to be the top 6 in here. Anything else -- 7 man in the safety department of your company? 7 And the one mentioned in here, you're 8 A l'm not sure, no. 8 pointing to Plaintiff's Exhibit Number 3 on page 56, 9 How many people work in the safety 9 the safety manual? 10 department currently? 10 A Correct. 11 A Three. 11 0 Okay. As long as we're on the topic, it's 12 How many worked in the safety department 12 my understanding that employees of your company in 13 back in 2016? 13 2016 that were employed and paid by Inpax but that 14 A Two. 14 were being used to deliver Amazon packages also 15 So Rusty Cook, and who else back then? 15 received some training from Amazon, is that true, for 16 A I don't recall who was the other person at 16 in the Chicagoland area? 17 the time. 17 A Like what do you mean "training 18 And I'm sorry if I've beaten this horse 18 from Amazon"? 19 pretty good. So ljust want to make sure that I've 19 Were they provided video training materials? 20 identified. back in 2016, all of the different 20 Did they have to attend training courses? That's what 21 training material that your company would have 21 I'm asking. 22 prepared for new drivers in the" Chicagoland area. 22 A There's a video that we have to watch to 23 .I know we have the Employee ManuaIIHandbook 23 deliver the Amazon packages. Now, whether it was 24 we've marked as Exhibit 3. You've identified a 24 around at that time, I don't recall. 25 driver's manual that existed that we don't have here. 25 What I'll tell you is that I was provided I Page 84 .. I Page 85 1 with some video by counsel, and I have, I think the 1 now. It's a couple of minutes long. And ljust 2 one that's pertinent I brOUth with me on my iPad, and 2 3 I'm going to play it. It's three minutes long. 3 (Document marked for identi?cation 4 And I apologize we gotta play it for three 4 as Plaintiff's Exhibit 4.) 5 minutes but I don't know how else to do it. And we'll 5 (Video recording was played.) 6 mark it formally. I'll have it put on a disc after 6 BY MR. FISHER: 7 the deposition. We'll mark it as Plaintiff's Exhibit 7 I've just shown you what we?ve marked as 8 Number 4. And I want to see if you can tell me if 8 Plaintiff's Exhibit Number 4 for identification, a 9 this is what you're referring to. 9 video that I've identi?ed. Have you ever seen that 10 MR. While we're waiting for 10 before? 11 you, Mike, I think this was the video clip or 11 A Yes. 12 video produced by -- 12 What is that video? What do you understand 13 MS. DIRCKS: Yeah, we produced it. 13 that to be? 14 MR. Either Reb -- the Benesch 14 A A safety video from Amazon that they -- we 15 ?rm, right? 15 provide for all of our drivers before they go on the 16 MS. DIRCKS: Yep, that's correct. 16 road. 17 MR. FISHER: And I assume her people 17 And would Mr. Gray have been provided that 18 are going to say "Yeah, it was mandatory that 18 video? Would he have been required to see that video? 19 these guys watch this," but I have to ask him 19 A If that -- if in 2016 it was around, yes. 20 about itfirst. 20 He would have had -- you can't -- you can not without 21 MR. Right. 21 it. 22 MR. FISHER: Okay. The video appears 22 lwill tell you that it's been provided 23 to have been produced by Amazon in this case 23 by Amazon and they've told us that that was around in 24 through discovery and it's identi?ed as Amazon 24 2016. Do you have any reason to disagree with that? 25 000115MP4. And I'm going to play this for you 25 A No. EcoScribe Solutions 888.651.0505 'll FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 86.Page 86 Okay. As part your company's agreement with Amazon as of 2016, was it mandatory that every one of your company's drivers, before they hit the road with any Amazon product, they would watch that video? A They would have to watch that video. And were they expected to follow the policies and procedures set forth in that video? A To the best of their ability, yeah. Everyone does everything to the best of their ability. MR. Not necessarily. BY MR. FISHER: You just watched -- Yeah. - MR. FISHER: Well, hopefully when it comes to safety, they do. MR. Well, that's not the point. My objection is noted. MR. FISHER: I never even heard you object. MR. Go ahead. BY MR. FISHER: MR. My objection is - to your question is not true. Page 87 MR. FISHER: I didn't -- you didn't object. You just said -- made a comment -- MR. Well, that's my objection. MR. FISHER: If you're making an objection, make an objection. Am I supposed to guess at what you're doing? MR. No, just made an objection. MR. FISHER: Fair enough. You didn't say the word "objection," so I had no idea what the objection was. MR. Objection. MR. FISHER: There you go. BY MR. FISHER: 0 That video, it's a good thing? A I think so, yeah. It lays forth some valid points regarding the safe operation of vehicles for your drivers? A Yes. Do you believe that all of those points made in that video regarding safe driving are valid points? A Yes. Would you like to know that all of your drivers, as of 2016 to today, are following the edicts laid out in that video? Page 88 A I would think we would do the best of our ability to do that, yes. Okay. With an towards safety? A True. Safety for your drivers, correct? A Mhm-hm (af?rmative), yes. Safety for other motorists on the roadway, correct? A Yes. 0 Safety for pedestrians? A Yes. Okay. Do you have any reason to believe that Mr. Gray did not see that video? MR. Objection to the extent it calls for Mr. Wright to speculate. But go ahead. A I mean, it's part of the process that we hire them, so. BY MR. FISHER: Okay. Now, tell me about that. Is it your understanding that in order to have a contract with Amazon as of 2016, where you provided drivers and the courier service for Amazon in the Chicagoland area your drivers had to see that video? A It's part of the hiring process. YesPage 89 But it was mandatory? A Yes, part of the process. If your drivers refused to watch that video, would you be allowed to send them on Amazon courier jobs? - A It won't let you go through the process without him watching it. So in addition to the Amazon video we just looked at and marked as Plaintiff's Exhibit Number 4, what other requirements did Amazon have for your company to provide drivers to deliver Amazon packages, 2016? MR. Could you repeat that question or read it back. MR. FISHER: You can read it back. (Whereupon the court reporter read back the referred-to portion as follows:) THE REPORTER: So in addition to the Amazon video we just looked at and marked as Plaintiff's Exhibit Number 4, what other requirements did Amazon have for. your company to provide drivers to deliver Amazon packages. 2016?" (Whereupon the reading back was Solutions 888.651.0505 '1 ?ll? "l i" ll 'rrF - ilf' FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 90..93 page 9.0 Page 91 1 concluded.) 1 me what process you're referring to? 2 MS. DIRCKS: I'm going to object. 2 A So once we Interview and he passed the -- 3 That's vague. I mean, can we lay a foundation 3 our drug screening, background check, the last thing 4 for that? 4 he does before we put him on board in our system is 5 BY MR. FISHER: 5 watch that video. 6 You can go ahead. 6 That's the process you're referring to? 7 MR. FISHER: ldon't have to lay a 7 A Yes. 8 foundation. It's a discovery deposition. I'll 8 And when you refer to you're talking 9 lay a foundation at trial after I learn what 9 about drivers? 10 other requirements there are. 10 A Any drivers. 11 MS. DIRCKS: I made my objection for 11 Drivers generally and Mr. Gray? 12 the record, sir. 12 A Yes. 13 MR. FISHER: Okay. 13 Okay. Before a driver You know, the basic things that I have on 14 road working for Inpax in 2016 in the Chicagoland 15 the application, which is, you know, clean MVR, pass a 15 area, other than the driver trainer who rides along 16 background check, watch the video, watch that video. 16 with him, does that driver get tested in any way? 17 and that's about it. 17 A Sure. So he rides along ?rst for about 18 BY MR. FISHER: 18 three days. He rides with a experienced driver. 19 Did Amazon, besides the video, provide any 19 Okay. 20 other written rules, regulations, policies or 20 A Then the driver trainer puts him in the seat 21 procedures that had to be followed by Inpax drivers in 21 and he's tested. Once the driver trainer deems that 22 the Chicagoland area in 2016? 22 he's qualified to drive at this pointjob. And the job consists of more than just driving. 24 Okay. You had mentioned that watching the 24 So let's talk about that for a second. So 25 video was part of the process. Could you describe for 25 you got the ride-along guy. Does the ride-along Page 92 I I Page 93 1 trainer prepare any paperwork with regards to his 1 Well, to follow the same principles laid out 2 training and riding along of a new driver in 2016? 2 in the video; not just to be safe, but to do those 3 A I'm not sure. 3 defensive driving things that are identi?ed in the 4 Once the driver trainer determines in his 4 video? 5 mind that the new driver is trained and able to do the 5 MR. Object to the form of the 6 job, does he prepare any type of paperwork that goes 6 question. 7 in the new driver's personnel ?le to establish the 7 But go ahead. 8 fact that he's gone through the process: He's seen 8 A Yes, to the best of my knowledge. 9 the'video, he's had driver training, the driver 9 BY MR. FISHER: 10 trainer thinks he's good? Does someone sign off on 10 Okay. I want to talk about when your 11 that indicating that all of this has occurred? 11 company first started providing courier services 12 A I'm not sure. 12 for Amazon in the Chicagoland area. Okay? 13 Okay. Was Mr. Gray expected, as of December 13 A Mhm-hm (af?rmativeexpected to practice the safety 14 Can you tell me approximately when that was, 15 principles that are discussed in that video, 15 by memory? 16 Plaintiff's Exhibit Number 4, to the best of his 16 A I think summer, maybe, 2015. 17 ability? 1? How did it come about that your company was 18 MS. DIRCKS: Objection. Vague. 18 going to do this? Did you reach out to Amazon? 19 Expected by who? 19 Did Amazon reach out to you? 20 BY MR. FISHER: 20 A I reached out to Amazon. 21 You can answer. 21 Okay. And who was the person that you 22 A To the best of my knowledge, yes. 22 reached out to in Amazon to see if your company could 23 I mean, you expected that out of drivers 23 gain their business? 24 working for your company, correct? 24 A His name, well, Ijust met him at a show, an 25 A To be safe, yes. 25 exhibit show, and through the ECA. EcoScribe Solutions 888.651.0505 Willi? .1, :r FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 94.97 Page 94 Page 95 What's the A Yeah. Express Carrier Association. Because I don't want you to answer Is your company a member of that? something -- Yes. Does the Express Carrier Association promulgate standard practice guides or best practices 7 in the industry? 8 A Sure. I think they do. They have different 9 classes and we can go to a retreat or something. 10 Does your company subscribe to their best 11 practices? 12 A I don't, I don't know. I mean, I don't know 13 what that is. DIFOIDD MR. Object to the form of the 15 question. 16 THE WITNESS: I don't even know if -- 17 MR. What do you mean by "best 18 practices"? It sounds as 19 BY MR. FISHERmanual? A prescription? 22 BY MR. FISHER: 23 0 Remember when we talked at the beginning and 24 i said if you don?t understand a question it's 25 you tell me so. A I don't know what that is, so. 0 I'm not really worried about your counsel. whether he understands or not. He'll understand soon enough. A get it. But I care if you understand because you're the guy under oath. A I don't know if they would even have something like that. Okay. Because I thought you said yes and if that's not correct, that's ?ne. MR. That's my objection. A I don't know. I've never attended anything like that. BY MR. FISHER. 0 Okay. Do you subscribe does your company subscribe to the Express Carriers Association, do they have a magazine, pamphlets. safety guides, anything that your company subscribes to? 23 A No. 24 Is there some quali?cations you need to 25 establish to be a member of the Express Carriers NMM MAO Page 96 1 Association? 2 A No. 3 Is your company a member of that 4 organization? 5 A Yes. 6 Q. So you were at some event around 2015 and 7 you reached out to someone at Amazon at one of these 8 events. Do you remember the name of the person you 9 reached out to? 10 A Just, you just leave your card and talk with 11 people, so I don't know who it was. 12 Ultimately you got in touch with someone and 13 you started -- you entered into a negotiation to act 14 as a courier for Amazon in the Chicagoland area, true? 15 A Yes. 16 And besides Chicagoland, your company acts 1? as a courier for Amazon in all of the states you do 18 business in? 19 A $0 in the beginning we were not in Chicago 20 when we ?rst started. We were in Atlanta. 21 Right. We know you ultimately went to 22 Chicago because we know Valdimar Gray was 23 delivering Amazon 24 A Right, right. Yeah. 25 -- right? So at some point before December Page 97 1 of 2016. your company added Chicagoland to its Amazon 2 routes? 3 A That's correct. 4 0 Okay. So what I'm trying to ?gure out is 5 who did you negotiate your Amazon deal with generally, 6 and then who in Chicago was your contact person? 7 A The guy that signed me up was Joe AI-zee-tah 8 or something like that. .9 Can you spell it as best you can? 10 A 0? Something like that. 11 And do you know what Amazon entity he worked 12 for? 13 A Prime Now. 14 0 That's what it's called? 15 A Mhm-hm (af?rmative). 16 Okay. And that's a yes? 17 A Yes. 18 And did you ultimately gain a contact in the 19 Chicagoland area once your company was going to do 20 deliveries in Chicagoland? 21 A So Prime Now we started here in Atlanta. 22 Okay. 23 A $0 Prime Now went away. So the Prime Now 24 went away, so they introduced me - Joe introduced me 25 to someone, I don't remember, that was in the Amazon EcoScn'be Solutions 888. 651. 0505 I ll mill: FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Job 29626 Leonard Wright January 25, 2019 Pages 98.101 Page 98 Page 99 1 networkI and then we -- our ?rst location was 1 So the DSP person in Chicago now is Bill 2 Chicago. 2 Seleger? 3 So who's your contact in Chicago regarding 3 A Yes. 4 the services your company provides in Chicago? 4 5 A Now? 5 A Yes. lthink it's I-E-R. 6 Well, at the beginning. 6 And before it was Bill Selegier. the guy in 7 A What was his name? I don't know at the 7 Chicago. the DSP guy was Steve Wilson? 8 beginning, but I know the guy 8 A Yes. 9 Is your contact now? 9 How about in December of 2016 who was it: do 10 A Yeah. 10 you remember? 11 0 Who's that? 11 A I think it was Steve Wilson. 12 A David Oheya 12 0 Okay. And do you happen to know the actual 13 Is he located out of Chicago? 13 name of the company Steve Wilson worked for at that 14 A No. 14 time? 15 Where is he located? 15 A Amazon. 16 A Texas. 16 So there?s a lot of different Amazon 17 Do you know what his title is? 17 entities by design. They go by a lot of different 18 A He's moved on to higher' but he's over like 18 names. Do you know if it was Amazon.com, 19 the DSP managers. 80 now there's a Chicago area guy 19 Amazon.com.dedc. SMX Amazon. Amazon Logistics? Do you 20 that I deal with. 20 know if it's any of those companies? 21 0 Who's that? 21 MR. Don't guess. 22 A Bill Seleger. It used to be 22 A I don't know which one he worked for. 23 Wilson. 23 BY MR. FISHER: 24 0 Okay. What does stand for? 24 Okay. So I want to start off with what 25 A Delivery service provider. 25 we'll mark as Plaintiff's Exhibit Number 5. For the Page 100 Page 101 1 record, this purports to be the Delivery Provider 1 BY MR. FISHER: 2 Terms of Service Work Order between, at least on its 2 Every question i ask you is if you know, 3 face, Amazon Logistics. Inc. and Inpax Shipping 3 because if you didn't know. I expect you to tell me. 4 Solutions dated March 23rd, 2015. 4 A (Witness examining document.) I don't know 5 (Document marked for identi?cation 5 if this is the first one. 6 as Plaintiff's Exhibit 5.) 6 There might have been one before this. March 7 BY MR. FISHER: 7 of 2015? If you would just take a look at this 8 A I don't think so. But this might be the 9 document and tell me if you recognize what it is? 9 first one. I'm not sure. 10 A Yes. 10 Regardless when this was entered into. this 11 And what is this document? 11 wouid have been applicable to the work after 12 A The Delivery Provider Terms of Service 12 March 23rd of 2015? 13 Agreement Work Order. 13 A Yes. 14 And would this work order have been in 14 Agreed? 15 effect in December of 2016? 15 A Yes. 16 A Yes. 16 0 Okay. Generally speaking, this agreement 17 And this lays out the basic terms -- would 17 just indicates that your company's going to provide 18 this have been the ?rst delivery terms of service 18 delivery services to various Amazon locations 19 work order between your company and Amazon? 19 for Amazon? 20 A This particular one here? 20 MR. Let mejust object to the 21 Yes. Would this be the ?rst one that you 21 form. The agreement says what it says. 22 entered into? 22 MR. FISHER: Every contract says what 23 MR. If you know. If you don't 23 it says. It doesn't stop me from being allowed 24 know, just tell him you don't know. 24 to ask about it. 25 - 25 MR. That's just my objection. EcoScrr'be Solutions 888.651.0505 171'" 'll FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 102.105 Page 102 MR. FISHER: That's a bad objection, Terry. That's all I'm saying. MR. You're saying generally here's what the contract says. and I'm saying the contract speaks for itself. MR. FISHER: Everybody does. but it doesn't -- MR. If you want to argue, waste your time. but go ahead. MR. FISHER: Do you know of a case that says I'm not allowed to ask about the contract from the guy who signed it? MR. Generally. that's all. No. I didn't say you couldn't ask it. I just object to the form. MR. FISHER: It's a bad objection. MR. Well. I disagree. That's Page 103 1 forth the terms. obligations and rights of the parties 2 to the contract regarding services your company's 3 going to provide for Amazon in delivering Amazon 4 packages, true? 5 MR. Same objection. 6 But if you understand his question. go 7 ahead. '8 A Ask the question again. 9 BY MR. FISHER: 10 Sure. 11 MR. FISHER: If you want to read it 12 back for him. I'm sorry. 13 (Whereupon the court reporter read 14 back the referred-to portion as 15 follows:) 16 THE REPORTER: Okay. So if 17 you turn to and generally speaking. the 13 my objection. 18 purpose of this agreement is it lays forth the 19 A This is actually Prime Now. 19 terms. obligations and rights of the parties to 20 BY MR. FISHER: 20 the contract regarding services your company's 21 So would this have been the ?rst contract 21 going to provide for Amazon in delivering Amazon 22 that your company entered into with Amazon? 22 packages, true?" 23 A Yes. 23 (Whereupon the reading back was 24 Okay. So if you turn to -- and generally 24 concluded.) 25 speaking. the purpose of this agreement is it lays 25 MR. Same objection. Page 104 Page 105 1 A I mean. if it's -- it's .a work order. We do 1 MR. Objection. 2 the work for Prime Now in this work order. so I guess 2 MR. FISHER: Why don't you provide me 3 that?s what I mean, it's a work order that we were 3 the signature pages, Terry? 4 given to do. 4 MR. Because I don't know if 5 BY MR. FISHER: 5 there are signature pages. Counsel. 6 When you entered into the agreement pursuant 6 MR. FISHER: That's why I asked him the 7 to Plaintiff's Exhibit Number 5. did you understand 7 question. 8 you were binding your company to the terms of the 8 MR. Well. that's why I 9 agreement? 9 objected. because you said they're signed. and 10 A Yes. 10 don't see a signature. 11 If you didn't like the terms of the 11 FISHER: You don't have to raise 12 agreement. you wouldn't have signed it? 12 your voice. 13 A That's correct. 13 MR. I'm not raising my voice. 14 And this is the agreement that you 14 MR. FISHER: You absolutely are raising 15 originally signed? 15 your voice. 16 A Yes. Originally. yes. 16 MR. I'm not. 17 0 Okay. 17 MS. DIRCKS: I can -- 13 MR. Well. let me just object. 18 MR. Do you see any signatures 19 There is no signature pages on Exhibit 5. 19 on this agreement. Counselor? 20 BY MR. FISHER: 20 MR. FISHER: Terry. you want to swear 21 Did you originally sign this agreement and 21 me in and put me under oath. I'm happy to answer 22 your counsel just hasn't provided me the signature 22 your questions. 23 pages? 23 MR. Good. Could you swear him 24 MR. Well. 24 in? 25 MS. DIRCKS: Just. 25 MR. FISHER: It's my deposition. Solutions 888.651.0505 rr' i .- FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 106.109 Page 106 I Page107 Okay. And is it your best understanding and 1 MR. Well, you just told me to 1 2 swear you in. .2 recollection that your relationship with Amazon 3 MR. FISHER: Let?s take a break. 3 providing them delivery services started around March 4 (Deposition in recess, 1:1:13 pm.) 5 A Yes. 6 BY MR. FISHER: 6 And you were the person at Inpax that 7 We're again referring to Plaintiff's Exhibit 7 negotiated the contract with Amazon? 8 Number 5, which you've already started to talk about. 8 A The rates. 9 If you take a look at Number 1, Services, just take a 9 Well, this document? 10 look at that paragraph. 10 A No. Just this, is all I negotiated 11 A Mhm-hm (affirmative). 11 (Indicating). 12 It indicates that your company is going 12 Was everything else Amazon handed you a 13 that Amazon is going to tender to you 13 piece of paper and said: If you want to work for us, 14 deliverables from delivery stations, sort centers, 14 this is what you do? 15 fulfillment centers and other distribution points and 15 A Yep. 16 be accepted by you Monday through Sunday, 365 days a 16 Okay. Is there anything in Plaintiffs 17 year at times and days designated by Amazon. 17 Exhibit Number 5 that you could, if you look at it, 18 As of March 23rd, 2015, was that the case. 18 that is inconsistent with the document you entered 19 was Amazon tendering packages? 19 into with Amazon around that time, March of 2015? 20 A Shipments? 20 A If this is the same document, no. 21 Packages, yes. 21 Well, I'm asking you to look at it and tall 22 A Shipments to me, yes, yeah. 22 me, is there something there that stands out to you 23 And consistent with what I've just read to 23 that you go, there's no way I agreed to do this? 24 you? 24 A No. 25 A Sure. 25 Okay. So if you turn to page two of Page 108 Page 109 1 Plaintiff's Exhibit Number 5, there's a section that 1 signed by Amazon Logistics, Inc. and Inpax Shipping 2 deals with insurance requirements. Do you see that? 2 Solutions, correct? 3 A Yes. 3 A Yes. 4 And it indicates how much insurance you are 4 But the copy we have doesn't have signed 5 going to provide for your people doing Amazon delivery 5 signatures on it, does it? 6 work, correct? 6 A No. 7 A Yes. 7 Do you recall signing this document and just 8 And did you comply with that provision? 8 the one we have that had the signatures isn't in front 9 A Yes. 9 of you? 10 And if you turn to page three, Paragraph 7, 10 A That's correct. 11 there's a reference to personnel performing services. 11 0 Okay. Now, having looked at the name Amazon 12 Do you see that? 12 Logistics, Inc., is it your understanding that?s the 13 A Yes. 13 company you've been dealing with, with regards to 14 You agreed back in approximately March of 14 providing delivery services? 15 2015 that your employees Working for lnpax performing 15 A Yes. As far as this document goes. 16 services under this agreement would satisfy the 16 Okay. We have others. The part of this 17 criteria set forth in the policies and the Schedule 1? document that you negotiated would be on 18 to this work order, correct? 18 pages seven and eight, Schedule and Schedule D, or 19 A Schedule (Witness examining document.) 19 is itjust Schedule on page eight? 20 It's page 11. 20 A Just eight, D. 21 A (Witness examining document.) Yes. 21 Can you explain this Fees for Services to 22 Okay. And if you turn to page four, there's 22 me. just what it means? 23 a signature page. 23 A Yeah. 80 we would show up at -- this 24 A Mhm-hm (af?rmative). 24 particular warehouse is open from eight to midnight. 25 There's a place for this document to be 25 So I would schedule some drivers for four hours, some EcoScn'be Solutions 888. 651.0505 mill :7 .1: Ii FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 110..113 Page 110 Page 111 1 drivers had six hours, some had eight, and some had 1 that Amazon had that your drivers had to wear 2 10. 2 particular clothing; is that correct? 3 And this shows how much your company was 3 A Amazon shirts, yes. 4 being paid for those four-, six-, eight? and 10?hour 4 Okay. So even though they were your 5 routes? 5 employees, directly employed by you, paid by you, 6 Yes. 6 overseen by you, your drivers running these Amazon 7 That's not how much the drivers were paid 7 routes had to wear Amazon shirts? 8 per se: that's how much your company was being paid. 8 A Yes. 9 and then you paid your drivers what you paid your 9 0 Okay. Did that remain true in Chicago? 10 drivers? 10 A Yes. 11 A That's correct. 11 At the time of Mr. Valdimar's occurrence 12 Okay. And this particular -- Plaintiff's 12 involving Miss Escamilla was he required to wear an 13 Exhibit Number 5 pertains to a location in the Atlanta 13 Amazon shirt driving Amazon routes? 14 area? 14 A Yes. 15 A Yes. 15 If you take a look at Schedule of 16 0 Okay. Was there an agreement ultimately 16 Exhibit 10, "Vehicle Branding Specifications." ltake 17 prior to December of 2016 signed with regards to the 17 that to mean that the vehicles --the vehicles your 18 locations in the Chicagoland area: just like this, but 18 company owned or leased, driven by your drivers. lnpax 19 just referring to the Chicago locations? 19 drivers, had to have a placard or placards on them 20 A Yes, but. 20 indicating they were Amazon, correct? 21 Okay. I think have it. 21 A In the beginning they thought we would do 22 A Okay. 22 this. But not -- they didn't hold us to this part of 23 Okay. Let?s just do one other thing. 23 it. 24 According to this agreement, if you turn to page nine, 24 So are you aware of the fact that the cargo 25 Schedule E, there was a uniform specification 25 van being driven by Mr. Gray actually had an Amazon Page 112 Page 113 1 placard on it? 1 did they? 2 A No." I didn't know. Sometimes what they 2 A No. 3 would do, because they have - if you deliver downtown 3 If you take a look at Schedule on "page 11, 4 or something, you put it in your dash, they'll know 4 these were all of the requirements Amazon had of your 5 you're inside delivering. 5 company for the drivers your company provided them 6 This was actually on the back 6 to deliver Amazon packages? 7 A He could -- 7 MR. Object to the form. 8 -- an Amazon sign? 8 MR. FISHER: You don't really want to. 9 A He could have had it on there, yeah. 9 MR. What? 10 0 Okay. 10 BY MR. FISHER: . 11 A But this, they pretty much -- at one point 11 0 Go ahead, you can answer. 12 they were going they thought we were going to do 12 Can you repeat the 13 that, make that, enforce that policy, but they didn't 13 question. 14 enforce that as much. 14 (Whereupon the court reporter read 15 What did you understand the purpose 15 back the referred-t0 portion as 16 behind -- in this agreement, behind Amazon requiring 16 follows:) 17 your drivers to wear an Amazon shirt and, in the cases 17 THE REPORTER: If you take 18 they did it, have an Amazon placard on the vehicle? 18 a look at Schedule on page 11. these were all 19 A I don't know why they would do that, but 19 of the requirements Amazon had of your company 20 other than theyjust wanted the customer. I guess, to 20 for the drivers your company provided them to 21 know that this was an Amazon package driver. 21 deliver Amazon packages?" 22 0 Okay. I mean. your drivers weren't working 22 (Whereupon the reading back was 23 wearing lnpax clothing, right? 23 concluded.) 24 A No. 24 MR. FISHER: What's the objection? 25 And the vehicles didn't say "lnpax" on them, 25 don't understand it. Solutions 888.651.0505 -l - FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 114..117 Page 114 Page 115 1 MR. You're talking too fast. 1 Bates stamped Amazon 118 through 129. 2 ldidn't quite get it. 2 BY MR. FISHER: 3 MR. FISHER: That I understand. 3 Take a look at this. Tell me if you 4 MR. Okay. 4 recognize what it is. 5 MR. FISHER: I happen to be a fast 5 A (Witness examining document.) Only thing, 6 talker. 6 you know, usually when I get a work order,.l have -- 7 A Yeah, similar. Yeah, we do the same thing 7 go back to Exhibit 5. Usually the standard work order 8 now. 8 would have me of what I'm doing here, so. 9 BY MR. FISHER: 9 I?m just asking if you recognize it. I 10 If your company back in 2015, back at the 10 can?t tell you that I know what it is. It was 11 time of the occurrence. even today, if your company is 11 provided to me by the attorneys for Amazon as being 12 going to provide delivery services with your drivers 12 somehow pertinent or relevant to this case. I don't 13 to Amazon, these requirements must be followed? 13 know, if you can't identify it, maybe someone 14 A Yes. 14 at Amazon will. I'm just asking, do you know what it 15 0 These are Amazon requirements? 15 is? 16 A For us, yes. 16 A Yeah, I may have seen this before, but 17 Okay. We can put that aside. 17 usually, what I usually read is like It has a delivery 18 (Document marked for identification 18 work, you know, similar to this thing right here 19 as Plaintiff?s Exhibit 6.) 19 (indicating) the delivery provided terms of service 20 BY MR. FISHER: 20 work order. And it would have attached what I'm doing 21 I?m going to show you now what I have marked 21 with the rates and where. So this, I can't really 22 as Plaintiff's Exhibit 6 with today's date on it. 22 speak to that, if I've seen this particular document. 23 MR. FISHER: For the record, this 23 0 Okay. 24 purports to be a delivery provider terms of 24 (Document marked for identification 25 service, last updated June 21st. 2016. And it is 25 as Plaintiffs Exhibit 7.) Page116 Page117 1 BY MR. FISHER: 1 It would be? 2 0 Let me show what I've marked Plaintiff's 2 A This one, yeah, the 13th amendment. 3 Exhibit 7 for identi?cation with today's date. 3 Okay. And it appears that this 13th 4 MR. FISHER: For the record, I'm 4 amendment is between lnpax Shipping Solutions and 5 handing you Plaintiff's Exhibit Number 7, which 5 Amazon Logistics, Inc.? 6 is identi?ed as the 13th Amendment to Work Order 6 A Yes. 7 under the Delivery Provider Terms of Service. 7 0 That helps refresh your recollection that A So, yeah. 8 that's the Amazon entity that you had contracted with? 9 BY MR. FISHER: 9 A Well, I guess, in the beginning it 10 Appears to be dated September 25th. 2016. 10 was Amazon, whatever that one was. 11 It's effective as of that date according to the ?rst 11 From -- in the beginning on Exhibit 5 it 12 page. 12 was Amazon Logistics, Inc. 13 On the second page or two of sevenYeah. So this is what I was talking about. 14 I'm looking under Work Order on Number 5, 15 I do recognize this. 15 page one, between Amazon Logistics, Inc. -- 16 0 Okay. So let's take a look at this. This 16 A Okay. 17 Plaintiff's Exhibit Number 7, what do you recognize 17 -- and you. 18 this to be? 18 A Right. 19 A A updated work order. 19 And the company's name, lnpax Shipping 20 Would this updated work order effective 20 Solutions. 21 September 25th, 2016, which it says "amends the work 21 A Right. 22 order dated March 23rd, 2015," would this have been 22 So it looks like that's the same entity 23 applicable to the work that Valdimar Gray was doing on 23 that's listed in Plaintiff's Exhibit Number 7, the 24 the day of the occurrence in December of 2016? 24 13th amendment; would you agree? 25 A This one, yes. 25 A Yes. EcoScrr'be Solutions 888.651.0505 li"l' IT .I FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 118..121 Page 118 Page 119 1 Okay. So it looks like from 2015 at least 1 work your company does for Amazon? 2 through this amendment, the 13th, dated 2 A No. He was just one of the Amazon people in 3 September 25th, 2016, your company is entering into 3 Seattle. Not my contact. 4 agreements with Amazon Logistics, Inc.; would you 4 All right. And if you turn to page three of 5 agree? 5 seven, Schedule B, Distribution Points. 6 A Yes. 6 A Mhm-hm (affirmative). 7 Are you aware of your company entering into 7 This particular 13th amendment applies to 8 agreements with any other Amazon entity? 8 the 12 distribution points listed on page three of 9 A No. 9 seven, Schedule 10 Okay. So if we turn to the second page of 10 A Mhm-hm (affirmative). 11 Exhibit 7, two of seven, there's a signature page on 11 0 Yes? 12 this, which Terry is very thankful for. And is 12 A Yes. 13 that -- under lnpax Shipping Solutions, is that your 13 And on those distribution points there's 14 signature? 14 three of them in the Chicagoland area; would you 15 A Yes. 15 agree? 16 And it looks like you signed this document 16 A Yes. 17 September 19th, 2016, correct? 17 DCH1 Alsip, Illinois; DCH2 Chicago. 18 A Yes. 18 Illinois; DCH3 Lisle, Illinois; and Chicago, 19 And then for Amazon Logistics, inc. it looks 19 Illinois, correct? 20 like a gentleman by the name of Hany, H-A-N-Y, last 20 A Yeah, but I don't think DCH1 was in Alsip. 21 name signed for Amazon, correct? 21 Where do you think it was? 22 A Hany. 22 A That South West 2801. 23 And you recognize that gentleman? 23 South Western Avenue? 24 A Yeah. 24 A Whatever, yeah. 25 That's your point of contact regarding the 25 Okay. That's fair enough. So you Page 120 Page 121 1 understand that this would have been the agreement 1 different locations there's a different fee schedule? 2 that actually applied to the time period and location 2 A Yes.- 3 where Mr. Gray struck Miss Escamilla? 3 And those are pretty self-explanatory? 4 MS. DIRCKS: Objection. Calls for a 4 A Yes. 5 legal conclusion. 5 All right. And then if you turn to page 6 A What was the question again? 6 five of seven of Plaintiff?s Exhibit 7, Paragraph 7 BY MR. FISHER: 7 Number 4 is entitled "Uniform and Vehicle Brand 8 Yeah. This is the contract document that 8 Promotion Fee." 9 applies to the time and place where Mr. Gray struck 9 Do you see that? 10 Miss Escamilla? 10 A Yes. 11 MS. DIRCKS: Same objection. 11 It says: In consideration of accepting the 12 BY MR. FISHER: 12 uniform and vehicle promotion fee, you agree that all 13 Is that true, in your opinion? Not true? 13 of your personnel who are visiting customer premises 14 A Well, we had this contract at the time where 14 or otherwise interacting with customers will wear a 15 he -- when he had the accident, yes. 15 uniform that complies with the speci?cations set 16 Okay. And the terms and conditions that are 16 forth on Schedule to this work order. 17 contained within Plaintiff's Exhibit Number 7 were the 17 Did I read that correctly? '18 terms and conditions that applied between Amazon and 18 A Mhm-hm (affirmative), yes. 19 Inpax Shipping Solutions? 19 Let's take a look at Schedule E. Do you 20 A Yes. 20 know what the uniform requirements were for this 21 All right. And then if you turn to page 21 particular contractual documents? Was it the same as 22 four of seven there's a fee schedule, Schedule D, Fees 22 what you had mentioned before, that your drivers are 23 Payable by Amazon. 23 wearing an Amazon shirt? 24 A Yes. 24 A I'd rather not guess. I'd like to see what 25 And can you just explain to me, for 25 Schedule is. EcoScn'be Solutions 888. 651. 0505 IT I FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 122..125 Page 122 Page 123 1 I would too. It hasn't been provided to me. 1 A That's fair to say. 2 unfortunately. 2 So what this agreement says at the bottom, 3 A Because these things change so much, you 3 tell me if you agree, is: Amendment Schedule has 4 know. 4 changed in this Plaintiff's Exhibit 7, and -- 5 Do you have any idea if Mr. Gray was wearing 5 A 6 an Amazon shirt on the day of the occurrence? 6 -- has changed, but all other amendments 7 A No idea. 7 remain the same. 8 Do you know what the uniform -- 8 A That's correct. 9 MS. DIRCKS: If you want me to clear 9 All right. Having seen that, would you 10 this up a little bit. The reason it's not 10 agree pursuant to Plaintiff's Exhibit Number 5, your 11 attached, I believe, is becauSe it wasn't 11 drivers were still wearing, as of September 25th. 12 changed. 12 2016, and during the pendency of this amendment, 13 MR. FISHER: Tell me why you think 13 Amazon shirts? 14 that. 14 A Yes. 15 MS. DIRCKS: Because these are the only 15 And there's also a reference on page ?ve of 16 things that were amended, Schedule and Schedule 16 seven, there's a reference in Subparagraph 4-B: All 17 D, if you look on the very ?rst page. 17 of your vehicles will, while being used'to provide 18 MR. FISHER: Oh. 18 services under the agreement, meet the vehicle 19 BY MR. FISHER: 19 branding-specific portions set forth on Schedule 20 So if you take a look at the ?rst page, 20 of -- to this work order. 21 Item Number 3 says: No other amendments con?ict. 21 Did I read that correctly? 22 So this refers to an amendment to the 22 A Yes. 23 original work order that was dated March 23rd, 2015. 23 And once again, there is no Schedule 24 which we've marked as Plaintiff?s Exhibit 5; remember 24 attached, so we have to go back -- 25 that? 25 A To the original. Page 124 Page 125 1 Right. Which talked about the vehicle 1 did you ?rst learn of this incident? 2 placards. 2 A Byron called me. 3 A Yeah. 3 Byron West? 4 So again. even in the 13th amendment to the 4 A Yes. 5 original work order of March of 2015 there is a 5 And did he call you on the date of the crash 6 reference to vehicles that your company is using with 6 or did he call you the day after? 7 your drivers to deliver Amazon packages will meet the 7 A The day of. 8 vehicle branding specification that we referred to 8 And do you recall approximately what time he 9 earlier saying there has to be an Amazon placard? 9 called? 10 A Yes. 10 A It was in the afternoon. 11 Okay. We can put that aside. 11 Byron West at that time was living in the 12 Let's talk about the day of the occurrence 12 Chicagoland area? 13 and the occurrence to the extent that you know about 13 A Yes. 14 it. According to the police report, this occurrence 14 Had he originally at some point lived in the 15 took place involving Mr. Gray and Miss Escamilla on 15 Atlanta area? 16 December 22nd, 2016. Do you have any reason to 16 A No. 17 disagree that that was the date of the occurrence? 17 Were you social friends with himNot really. 19 Have you seen any accident or incident, 19 0 Just professional associates? 20 investigations or reports concerning the event? 20 A Yes. 21 A Only what counsel have shown me. 21 Okay. So he called you in the afternoon, 22 And that would have been today? 22 and to the best of your recollection, can you tell us 23 A No. I've seen it before then, but basically 23 what he told you? 24 what 24 A There had been a fatality in Chicago. Well, 25 Why don't we start off and talk about: How 25 originally he he said, We had a driver hit EcoScrr'be Solutions 888. 651. 0505 "ll ll ml" - l: .. FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25, 2019 Pages 126.129 Page 126 Page 127 1 someone. 1 call, did you do something or tell somebody to do 2 and I asked: When you say hit 2 something? 3 someone, he was talking about live, hit someone that 3 A I told Byron to just keep me posted with 4 was walking. So at the time he didn't know if she was 4 what's going on. Then he called me, you know, later 5 passed away or not. 5 on, a few hours later and told me that the lady that 6 Okay. 6 was struck passed away at the hospital. 7 A Then he called me later to tell me she did. 7 Did he tell you anything else at that time? 8 So he originally called you in the afternoon 8 A That was it. 9 and he tells you that there 9 Did you have any questions for him? 10 A A driver that hit -- 10 A (There was no response.) 11 Someone? 11 Because so far he told you there was an 12 A -- someone. So I assumed that hitting 12 accident, it involved a pedestrian, the pedestrian has 13 someone was hitting a person in a car. 13 passed away. 14 Another car, right? 14 A Yeah. So ljust asked him how did it 15 A Then he explained happen. He didn't know a whole lot at that time, so 16 person. 16 he said let him investigate everything and he'll get 17 Okay. Did he give you -- did he explain to .- 17 back with me. 18 you anything else about how or why the occurrence took 18 Okay. 19 place other than it was a vehicle striking a personthink the driver was pretty 20 A He didn't. That's all he said at that time. 20 shook up. So that conversation didn't happen until 21 Okay. After that phone call took place -- 21 the next day. 22 did you take any notes. by the way, create any 22 Okay. So let's continue to just talk about 23 documents? 23 December 22nd, 2016. Besides these two telephone 24 A No, I remember it because I was in the gym. 24 conversations with Mr. West, did you have any 25 Okay. And then in response to that phone 25 conversations with anybody else that day about the Page 128 Page 129 1 occurrence? 1 of the occurrence. which is the 22nd of December 2016. 2 A Yeah. David, our CFO. 2 other than these three conversations you've just 3 And he wasn't in the Chicagoland area? 3 describeddon't remember. If it was, it wasn't 5 And you spoke to David approximately what 5 relevant to that. 6 time? 6 Did you prepare any documents, either 7 A Right after I talked to Byron. 7 e?documents, e-mails, written documents? 8 The ?rst time or the second timeSecond time. 9 Did you require or request anybody who 10 And tell me what you and David discussed. 10 worked for you in your company to prepare any 11 A That we had had a pedestrian that our driver 11 documents in response to this event? 12 hit and she had passed away. 12 A There's -- there should be some documents 13 Did he make -- did he have any suggestions 13 that they prepared for this, like, for example, the 14 on what you andior the company should do at that 14 protocol of what happens when an accident happened. 15 point? 15 So yes, there's going to be some documents. 16 A No. I mean, we know pretty much Byron 16 Okay. So I'm asking you, did you 17 followed the procedures of what to do, you know, drug 17 A Not me, no. 18 test the driver and Breathalyze him. 18 I'm asking you. 19 How did the drug test come out? 19 A I'm not in the I'm not involved in that. 20 A Negative. 20 You're not part of the process? 21 Okay. Did David have any, you know, you 21 A No. 22 talked to David, you told him what you had learned. 22 Other than being noti?ed? 23 Did he say anything else. any response? 23 A That's correct. 24 A I don't remember. 24 What I'm asking you is, did you, on the day 25 Okay. Did you speak to anyone else the day 25 you learned of this occurrence, did you give EcoScribe Solutions 888.651.0505 mill: I: fl" l' .. FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 130..133 Page 130 directions to any of your employees to do something? A Yeah, I just told Byron: Make sure you follow the proper procedures, the drug screen, the Breathalyzer test for the driver. Do you know what documents, if any, e-documents, handwritten documents, were prepared by members of your organization? A No. Have you ever seen any documents that were prepared by members of your organization following this occUrrence? And it doesn't have the day of, the week of, the month of. A I can't recollect. I'm quite sure I've read the case ?le and seen everything. I understand that you met with Mr. McAvoy _L?l 01-5- Page 131 MR. FISHER: Terry, can I see the pictUres you showed him? MR. I believe I showed him two pictures. All these photos have been produced, Mike. MR. FISHER: Terry, I'm not claiming othenivise. BY MR. FISHER: Terry's just indicated to me. that he showed you two photographs; is that your recollection? A Yes. Are those the only two photographs you've ever seen of the scene of this occurrence? A Like I said, I seen -- I think I've seen all the photographs, but today just, he showed me these before we started here today. 16 two. A Uh-huh (affirmative). 17 On days prior to today, have the attorneys Which, of course. is your right to do. 18 sent you other photographs to look at? A Right. 19 A I've had that same report, yes. I've seen 20 I'm not allowed to ask you what you and he 20 that before. 21 spoke about because he's your attorney. but I am 21 What same report are you referring to? 22 allowed to ask you what he showed you and what you 22 A All that same pictures. 23 looked at. 80 that's what I'm asking you right now. 23 The two pictures that Terryjust referred 24 What did he show you. what have you looked at? 24 to? 25 A We just looked at the pictures of the scene. 25 A Yes. Page 132 Page 133 1 Were you also shown, besides the pictures, 1 the day following this accident. Who did you talk to 2 any other documents? 2 about this occurrence? 3 MR. Today? 3 A Byron. 4 MR. FISHER: Today or any day. 4 What time did you speak to Byron on the 23rd 5 A Not today. 5 of December? 6 BY MR. FISHER: 6 A That morning. 7 How about other days? 7 What did he say to you and what did you say 8 A Yeah. 8 to him that day? 9 Police reports, incident reports? 9 A Asked him about the police report. He said 10 A Police reports and, you know, your ?lings. 10 he would look into it and research it and go down 11 Okay. You've seen my Answers to 11 there. 12 Interrogatories? 12 So you asked him to get you the police 13 A Some of 'em. 13 report, you wanted to see it? 14 Have you seen my Complaint at Law? 14 A Yes". 15 A I think so. 15 What else did you talk about? 16 You read the police report. Did you read 16 A I don't remember. 17 the statement of the eyewitness? 17 Had he spoken to Mr. Gray by that time? 18 A I don't recall. 1B A I think Mr. Gray -- I don't know if it was 19 Have you ever read the statement of the 19 that day or the next, it may have been a couple days 20 eyewitness? 20 later. I don't think he talked to him the next day. 21 A I probably have but I don't remember what it 21 Did you have an understanding Mr. Gray was 22 said. 22 arrested at the scene? I 23 You don't? 23 A Yes, I think so. 24 A No. 24 Taken in? 25 Okay. I want to go back to the next day, 25 A Yeah. EcoScrr'be Solutions 888. 651. 0505 'rll'l" mm- - FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 134..137 Page 134 Page 135 1 Who else did you talk to on 12/23/16, the 1 what do you recall about it? 2 day after this occurrence, besides that morning 2 A It was pretty vague other than the fact 3 conversation with Mr. West who you referenced the 3 that, you know. there was an accident. But I don't 4 police report? And by the way, did he say anything 4 remember. I can't -- it's been so long. man, I don't 5 else, give you any other information? 5 remember. 6 MR. Objection. You got to 8 Okay. So you said at some point in time 7 slow down. 7 that Mr. West had spoken to Mr. Gray; that was your 8 A- ljust don't remember. ldon't really 8 understanding? 9 remember other than the key fact I asked about the 9 A Yeah. 10 police report. Anything else that day, I probably 10 Did Mr. West tell you what Mr. Gray had told 11 wouldn't remember. 11 him about the occurrence? 12 BY MR. FISHER: 12 A The only thing I can recollect was that he 13 0 Okay. I just want to make sure, all right? 13 told me how distraught the guy was. He didn't really 14 Did you speak to anyone else on the 23rd besides 14 go Into detail other than the fact that he indicated 15 Mr. Byron West in the morning? 15 that the lady walked out in front of him. 16 A I don't remember. 16 Do you know whether or not the lady who was 17 Okay. Let's talk about the next five days, 17 killed in this accident, Miss Escamilla, do you know 18 so that whole ?rst week. Did you speak to anyone 18 if she was in a crosswalk or not when she got hit? 19 else about this occurrence? 19 A I don't know. 20 A Not to my knowledge. 20 Do you know when Miss Escamilla got hit, it 21 Did you receive any reports, incident 21 she was in the ?rst third of the street, the middle 22 reports. accident reports, police reports? 22 of the street or had already crossed over two-thirds 23 A Took a while to get the police report for 23 of the street when she got hit? 24 some reason. 24 A I don't know. 25 Ultimately when you got the police report, 25 Do you know what speed Mr. Gray was going at Page 136 Page 137 1 the time he hither? 1 know that? 2 A Don't know. 2 A Not to my knowledge. 3 Do you know whether or not Mr. Gray has been 3 0 Okay. Did you know that there was an 4 alleged to have ran two stop signs preceding his 4 eyewitness who was behind Mr. Gray for the two stop 5 striking Miss Escamilla? 5 signs preceding where he hit Miss Escamilla and she 6 A No. 6 has given a statement that he did not stop at either 7 You haven't heard that? 7 of those stop signsjust object to the 9 You understand Mr. Gray has been charged 9 form of the question insofar as it's my 10 with vehicular homicide, correct? 10 understanding that this alleged eyewitness may 11 MR. Objection to the form of 11 have changed her story about the stop signs. 12 the question. 12 MR. FISHER: I haven't seen anything to 13 Not to my knowledge. 13 the contrary of the statements she's given. but. 14 BY MR. FISHER: 14 A No. 15 You didn't? 15 BY MR. FISHERwhere you were -- it was in one 16 Okay. So because you don't know -- you 17 of the documents that I read that. 17 didn't know that Mr. Gray was charged with reckless 18 Do you know there's charges pending against 18 homicide, you don't know why he was charged with that. 19 him right now for vehicular homicide? 19 do youMR. Objection to the form. I 21 Do you know what speed Mr. Gray was going at 22 think it?s reckless homicide. the charges. 22 the time he struck Miss Escamilla? 23 MR. FISHER: Yeah. it could be. 23 MR. Objection. Asked and 24 BY MR. FISHER: 24 answered. 25 And he has an upcoming trial. You didn't 25 A No. EcoScribe Solutions 888.651.0505 .. FILED DATE: 4/2/2019 3:27 PM 2017L000060 - JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 138..141 Page 138 Page 139 1 BY MR. FISHER: 1 lived before expiring following this occurrence? 2 Do you know how old Miss Escamilla was? 2 A Not exactly. 3 A I think they said 83 or 84. 3 Do you know who she's survived by, who her 4 0 Okay. And when you heard that Mr. Gray -- 4 immediate family is, how many children she has, things 5 when Byron West said Mr. Gray said that she walked out 5 of that nature? 6 in front of Mr. Gray's vehicle, did you picture in 6 A No. 7 your mind that she had ran out into the street when he 7 Do you know what street Mr. Gray was 8 said that, as opposed to an 84-year-old woman crossing 8 traveling on in the minute before this occurrence? 9 the street? 9 A No. 10 MS. DIRCKS: Objection. Foundation. 10 Do you know what direction he was traveling? 11 MR. Objectiondidn't think about it. No. 12 Do you know how fast he was going? 13 BY MR. FISHER: 13 A No. 14 0 Didn't think about it one way or another? 14 Do you know the Speed limit of that street? 15 A Well, I mean, I'm quite sure I had thoughts 15 MR. Objection. 16 but it wasn't what you're saying. 16 A No. 17 Have you spoken to a single person who's 17 BY MR. FISHER: 18 witnessed the occurrence? 18 Do you know -- we're at about 20 Ever speak to Mr. Gray? 20 the three-hour, Mike, three-hour. Are you almost 21 A Nope. 21 done? 22 Ever speak to any of the police officers who 22 MR. FISHER: Getting there. 23 investigated this occurrence? 23 MR. What does that mean? '24 A No. 24 MR. FISHER: I'm getting there. 25 Do you know for how long Miss Escamilla 25 MR. Close? Page 140 Page 141 1 MR. FISHER: We've taken a number of 1 client somehow walked out in front of this 2 breaks, so we're at the three-hour -- 2 vehicle. 3 MR. Two short breaks, but. I 3 MR. Counsel, I'mjust asking 4 mean, you're obviously just drilling him with 4 you, are you almost done. because we're almost -- 5 questions -- with questions that he obviously 5 MR. FISHER: And I'm telling you, I'm 6 cannot know. 6 getting there. 7 MR. FISHER: Terry, how do I know what 7 THE WITNESS: What's getting there? 8 he's 8 MR. You can't give me 9 MR. But go ahead. 9 anything? Because we're -- you got about another 10 MR. FISHER: -- gonna say at trial? 10 10 minutes, if that. 11 MR. Oh, sure. He knew, 11 MR. FISHER: Terry, if you choose to 12 sitting in Atlanta, in his office in Atlanta or 12 terminate this deposition, then we'll see what 13 somewhere in Atlanta. he knows the position of 13 Judge Flanagan has to say about it. That's all I 14 Miss Escamilla walking across this intersection? 14 can tell you. It's up to you. 15 MR. FISHER: Well, now I know he 15 MR. Well, three?hour rule, so 16 doesn't know -- 16 I'll give you another 10 minutes. 17 MR. How he knows -- 17 MR. FISHER: You do what you think you 18 MR. FISHER: so I know he won't 18 gotta do. I would hate to see them drag him into 19 testify to that at trial. 19 Chicago. 20 MR. How he knows, he could 20 MR. We'll hate to drag you 21 possibly know what speed limit the vehicle was 21 back down here to Atlanta again, Mike. 22 going? He couldn't possibly know some of these 22 MR. FISHER: I'll bet you, Terry. 23 answers to any of these questions. 23 Let's put money on it. 24 MR. FISHER: Terry, he thought, based 24 BY MR. FISHER: 25 on Mr. West's conversation with him, that my 25 Did you know if Mr. Gray was issued EcoScn'be Solutions 888.651.0505 Tl.? I i! mum: - a: FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Pages 142..145 Page 142 Page 143 1 citations at the time of his arrestOkay. What devices did your company. issue 3 Did you know that he was issued a citation 3 to Mr. Gray that he would utilize in his delivery 4 for failure to yield a right-of-way to a pedestrian in 4 route? Is it called a Rabbit, a handheld device of 5 a crosswalk? 5 some sort? 6 A No. 6 A Yeah. 7 Have you ever seen his arrest report, by the 7 Is it called a Rabbit? 8 way? 8 A Yes. 9 A No. 9 Okay. Is he supposed to use that in the 10 Did you know that he didn't have proof of 10 vehicle or should that only be used when the vehicle 11 insurance with him at the time of the occurrence? 11 is stopped and parkeduses it -- well, it gives you the GPS. 13 Did you know that he didn't have a drivergives you the direction. 14 license with him at the time of the occurrence? 14 Has anybody ever run the diagnostics on that 15 A I think I heard that, yeah. 15 Rabbit to determine if at the point of impact if 16 Should he have, according to your company's 16 Mr. Gray had that Rabbit in his hand or not? 17 rules. had proof of insurance and a driver'slicense 17 A No. 18 with him if he was doing a delivery for your company? 18 Is there a way to do that, that you know of? 19 A Driver's license. 19 A I don't know. 20 Proof of insurance, you got it, you can just 20 The Rabbit that he would have had the day of 21 pull it up. 21 the occurrence. Mr. Gray, was that turned in to your 22 Did you know he was issued two citations for 22 of?ce? 23 failing to stop at a stop signWho owns that Rabbit? 25 You've never seen the arrest report? 25 A Amazon. Page 144 Page 145 1 I'm sorry, Amazon? 1 fail to yield to a pedestrian in a crosswalk? 2 A Yes. 2 A Yes. 3 That's an Amazon? 3 Should a driver of one of your delivery 4 A Well, it's my Rabbit but Amazon puts the app 4 vehicles fail to stop at a stop sign? 5 on it. 5 A Should they? No. 6 Do you know where the particular Rabbit that 6 They should stop at every stop sign, right? 7 Mr. Gray was using on the day of the occurrence is at 7 A Yes. 8 this point? 8 Complete and full stop, true? 9 A No. 9 A That is correct. 10 As I understand it, your company provided an 10 If a driver of one of your delivery vehicles 11 underlying policy of insurance of $1 million with a 11 failed to come to a stop at a stop sign. would that be 12 umbrella policy of an additional $4 million? 12 a violation of your company rules? 13 A Yes. 13 A Yes. 14 That would have covered this occurrence? 14 Would that be an unreasonably dangerous act? 15 A Yes. 15 A Yes. 16 Any additional insurance? 16 Should a driver of one of your vehicles in 17 A No. 1? doing deliveries not exceed the speed limit, should 18 Should a driver working for your company 18 they stay within the speed limit? 19 yield to pedestrian traf?c in a crosswalk? 19 A Yes. 20 A Yes. 20 The video that you saw, doesn't it tell the 21 If a driver working for your company falls 21 drivers that they should stay within the speed limit? 22 to yield to a pedestrian in a crosswalk, would it be a 22 A Yes. 23 violation of your company rules? 23 If a driver fails to stay within the speed 24 A Sure. 24 limit and he's working for your company, would that be 25 Would that be unreasonably dangerous to do, 25 a violation of your company's rules, trainings and ECOScn'be Solutions 888.651.0505 In?. I: 2' FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Pages 146..149 Page 146 Page 147 1 policy? 1 "Especiallyshould be cautious when we're 3 Would that be unreasonably dangerous 3 crossing. 4 conduct? 4 BY MR. FISHER: 5 A Yes. 5 only used the word "especially" because 6 Should a driver of one of your delivery 6 it's in the video you saw. 7 vehicles be aware of the things in front of him during 7 A Okay, well, yeah, if it's in there, yes. 8 a left-hand turn? 8 Would you agree? 9 A Say that again. 9 A Yes. 10 Should a driver of one of your delivery 10 And if a driver of an Inpax vehicle was not 11 vehicles be aware of what's in front of him during a 11 especially cautious traveling through an intersection, 12 left-hand turn? 12 would that be a violation of company rules? 13 A Yes. 13 A Yes. 14 Would a driver who is unaware of what's in 14 Would that be dangerous? 15 front of him during a left-hand turn be in violation 15 A Yes. 16 of your company's policies and procedures? 16 Should a driver of one of your delivery 17 A Yes. 17 vehicles be especially cautious when making a 18 Would it be unreasonably dangerous for a 18 left-hand turn? 19 driver making a left-hand turn, an Inpax vehicle, to 19 MR. Especially? 20 not know what's in front of him? 20 MR. FISHER: Especially cautious. 21 A He should know what's in front of him. 21 MR. Objection to the form. 22 Should a driver of an lnpax vehicle making 22 MR. FISHER: I'm only 23 deliveries of Amazon packages be especially cautious 23 MR. But you can answer. 24 traveling through an intersection? 24 MR. FISHER: It's in the video. 25 MR. Objection to the form: 25 A . They should be cautious. At all times they Page 143 I Page 149 1 should be cautious of everything. 1 in there, that's what he should do. 2 BY MR. FISHER: 2 MR. Okay. Now we're after 3 Should a driver of an Inpax vehicle doing 3 it's after 2:00 o'clock, Mike. Are you done? 4 deliveries of Amazon packages. when approaching 4 MR. FISHER: Nope. 5 pedestrians, make himself known to that pedestrian by 5 MR. Then we're done. It's 6 either contact, ?ashing lights or honking his 6 after 2:00 o'clock. We've been going at it for 7 horn? 7 more than three hours. 8 MR. Objection. Calls for 8 THE WITNESS: Yeah, yeah. I got to get 9 speculation. 9 to a meeting. 10 A [don't know. 10 MR. FISHER: One more question. 11 BY MR. FISHER: 11 BY MR. FISHER: 12 Do you remember seeing that in the video? 12 Do you have any criticisms of 13 That's what the video says. 13 Miss Escamilla, the person who's dead? 14 A Well, he should follow the video. 14 A Huh? 15 If the video says that a driver of an lnpax 15 Do you have any criticisms of the conduct of 16 vehicle approaching a pedestrian. that he should make 16 Miss Escamilla with regards to this occurrence? 17 himself visible by either contact, honking his 17 MR. Objection. Calls for 18 horn. ?ashing his lights, would you disagree with 18 speculation. He wasn't there, he doesn't know 19 that? 19 what happened. 20 MR. Objection. 20 A I don't. Like I said, no. I don't. 21 A I don't remember what it says. 21 MR. FISHER: Okay. Those are all the 22 BY MR. FISHER: 22 questions I have. Thank you. 23 Should your driver 23 MR. Thank you. 24 MR. Objection. 24 Oh, one question. Mr. Wright. 25 A Follow what was on the video? If that was 25 EcoScribe Solutions 888.651.0505 .: a. ?Ii FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Pages 150..153 Page 150 Page 151 1 EXAMINATION 1 DISCLOSURE 2 BY MR. 2 3 He asked you earlier. Mr. Wright, about 3 Pursuant to Article of the Rules and 4 Exhibit Number 3, which was the handbook for Inpax 4 magmatic? ?f the Board ?f ?awning ?f the 5 Shipping 5 Judicial Council of Georgia. I make the following 6 A Yes. 6 disclosure: 7 And rules of the roads and handbooks, 7 I a? a Georgia C?I?ti?e?i calm: Repc?rtfr' et cetera. On page 55 it says -- one Of the I am-here as airepresentative of Premier Reporting. 9 provisions is: Uphold the law - and I'm reading from 9 Frame? was ?magma lineronde aim? . . 10 reporting serVices for the deposition. Premier 10 Page 55 - Inpax Shippmg SglunopS' to 11 Reporting will not be taking this deposition under any 11 Integnty begins WIth WIth Iaws' and 12 contract that is prohibited by 0.C.G.A. S-ll-28tcl . 12 reQUIatlonS Where we do 13 Premier Reporting has no contract/agreement 13 And the paragraph continueS: That inCIUdeS 14 to provide reporting services with any party to the 14 complying with the rules of the road. correct? 15 case. any counsel in the case! or any reporter or 15 A That's correCt' 16 reporting agency from whom a referral might have been 16 Okay Thank YOU. made to cover this deposition. 17 MR MCAVOY: we'll reserve Signature- 13 Premier Reporting will charge its usual and 18 YOU don't have any queStionS or do 19 customary rates to all parties in the case, and a 19 MS. DIRCKS. NO. I don't. 20 financial discount will not be given to any party to 20 MR. Okay, thank you. We'll 21 this litigation. 5 . Lg) 21 reserve. 22 Z. 22 (Whereupon the above-entitled 23 Shari L. Snow 23 matter was concluded at 2:05 pm.) 13-2253 24 24 25 25 Page 152 Page 153 1 CERTIFICATE 1 DEPOSITION ERRATA SHEET 2 STATE OF GEORGIA: 2 Deponent: LEONARD WRIGHT 3 COUNTY OF FULTON: 3 Deposition Date: January 25, 2019 4 4 To Reporter: 5 I hereby certify that the forgoing transcript 5 I have read the entire transcript of my deposition 6 was reported, as stated in the caption, and the 6 taken in the captioned matter or the same has been 7 questions and answers thereto were reduced to 7 read to me. I request that the following changes be 8 typewriting under my direction; that the foregoing entered upon the record for the reasons indicated. I 9 pages represent a true, complete and correct 9 have signed my name to the Errata Sheet and 10 transcript of the evidence given upon said hearing, 10 appropriate certificate and authorize you to attach 11 and I further certify that I am not of kin or counsel 11 both to the original transcript. 12 to' the parties in the case; am not in the employ of 12 Page No._ Line No._ Change to: 13 counsel for any of said partiesReason for Change: 14 way interested in the result of said case. 14 Page No._ Line No. Change to: 15 - (f 15 Reason for Change: 16 Aafo/ Z: ??aw 16 Page No._ Line No._ Change to: 17 Shari L. Snow. 13-2253 Reason for Change: 13 13 Page No._ Line No._ Change to: 19 19 Reason for Change: .20 20 Page No._ Line No._ Change to: 21 21 Reason for Change: 22 22 Page No._ Line No-_ Change to: 23 23 Reason for Change: 24 24 Page No._ Line No._ Change to: 25 25 Reason for Change: EcoScrr'be Solutions 888. 651. 0505 I: if?. i FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Page 154 Page No. Line No. Reason for Change: Change to: Page 154 Page no. Line No. Reason for Change: Change to: Page No. Line No. Reason for Change: Change to: Page No. Line No. Reason for Change: Change to: Page No; Line No. Change to: Reason for Change: Page No. Line No. Reason for Change: Change to: Page No. Line No. Reason for Change: 'Change to: Page No. Line No. Reason for Change: Change to: Page No. Line No. Reason for Change: Change to: Page No. Line No: Reason for Change: Change to: Page No. Line No. Reason for Change: Change to: SIGNATURE: LEONARD WRIGHT DATE: EcoScribe Solutions 888.651.0505 Ir II. II FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Exhibits Exhibit 1 3:7 55:14.17.18 61:21.22 Exhibit 2 3:8 6214.15.17.20 Exhibit 3 3:9 66:9.11.14.20 69:20 71:13.23 73:12.22 76:7.8.16.18.21 77:3 82:24 83:8 150:4 Exhibit 4 3:10 84:78 85:4.8 89:9.21 92:16 Exhibit 5 3:11 99:25 100:6104:7.19 106:7.8107:17108:1 110:13115:7 117:11 122:24123:10 Exhibit 6 3:12 114:19.22 Exhibit 7 3:13115:25116:3.5.17 117:23118:11 120:17121:6123:4 $1 144:11 $4 144:12 0 000115MP4 84:25 1 55:14.18 61:22 66:20 106:9 10 17:23 49:20 50:8.11 64:23 65:11 110:2111:16141:10.16 10-hour 50:20 110:4 100 16:1 11 65:11.17108:20113:3.18 118 115:1 12 119:8 12I23I16 134:1 129 115:1 12:03 61:12 12:12 61:13 13th 116:6 117:2.3.24 118:2 119:7 124:4 15 35:19 16 26:11 40:18 55:2 67:23 68:18.22 17 15:10.11 33:19 35:18 18 15:12 1997 10:8 19th 118:17 1:08 106:4 1:13 106:5 2 62:15.17.20 20 17:25 64:23 2000 19:11 2009 19:15 2011 14:1219:6.20 2012 23:10 2015 35:21 36:9 93:16 96:6 100:4 101:7.12106:18107:4.19108:15 114:10116:22118:1122:23124:5 2016 11:514:115:2515:1217:15 21:4 22:13.21 25:5 25:9 27:4.11 23:29.13 30:3.20 32:4 33:5 35:10 36:17 37:1.11.25 38:19 40:1 41:11 42:7 43:3 44:5 45:7 46:8.14 47:10 45:149:1.15 51:11.15 52:13.22 53:5 54:17 55:2.13 57:5 59:15 60:22. 25 51 :1 52:35 53:3 54:19 55:9 57:3 71 :5 74:7 75:21 77:20 75:5.13 50:22 51 :7.10 52:13.20 53:4.13 55:19.24 55:2 57:24 55:22 59:12.24 90:22 91:14 92:2.14 97:1 99:9100:15 123:12124:16127:23129:1 2017 15:8 34:11 35:21 2019 4:2 21 65:22 21st 114:25 229 886-8261 8:1 22nd 30:20 61:4 124:16 127:23 129:1 23rd 60:22.25 100:4 101:12 106:18 116:22 122:23133:4 134:14 25 4:2? 25th 115:1o.21 115:3123:11 Job 29626 Index:$1n60 2634 6:18 27 17:8 59:15 27th 56:2 57:6 2300 25:11 2801 25:12.17 27:4 28:14.20 29:19.24 30:8 31:152:14.2162:1178:17 119:22 2:00 149:3.6 2:05 150:23 3 3 66:9.11.14.20 69:20 71:13.23 73:12. 22 76:8.16.18.21 77:3 82:24 83:8 122:21 150:4 30 64:25 30033 6:18 32-plus 22:7 365 106:16 4 4 84:8 85:4.8 89:9.21 92:16121:7 4-B 123:16 43 15:13 49 43:11 5 5 99:25100:6104:7.19 106:8 107:17 123:10 500 64:5 55 150:8.10 56 76:7 77:1 83:8 6 114:19.22 60 64:17 EcoScn'be Solutions 888.651.0505 - - ?li JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: 7..amendments FILED DATE: 4/2/2019 3:27 PM 2017L000060 7 7 108:10115:25116:3.5.17117:23 118:11 120:17121:6123:4 70 23:20 8I11I63 8:11 8290 27:7 28:14 32:3 35:5 83 138:3 84 138:3 84-year-old 138:8 86 19:5 87 66:21 71:23 9 90 15:2319:8 93 19:5.6 A A-D-A-Y 54:4 A-L-Z-E-T 97:10 ability 63:21 78:1 86:8.10 88:2 92:17 able 24:23 35:2.6 46:17 92:5 about 5:17.1810:1515:1 19:9 21:7. 11.12 28:17 31:8 33:4 34:23 38:6 40:19.21.22 42:24 44:13 46:9 48:24 49:6 51:13 52:11 53:3,17 55:9.11 59:20.21 60:5.12 63:11 65:9 67:9.16 71 :19 75:8 76:15 78:24 84:20 88:20 90:17 93:10.17 95:5 99:9 13.25 126:3.18 12722.25 130:21 11 137:11 138:12.14139:19141:9.13 150:3 above-entitled 150222 absolutely 58:15105:14 accepted 106:16 accepting 121:11 accident 513115 59:23 73:2 120:15 124:19127:-2129:14133:1 134:22 135:3.17 accompanied 47:11 accordance 4:15 according 42:6 110:24 116:11 124:14142:16 accordingly 63:17 accounting 56:12 accurate 58:3 67:5 across 140:14 act 80:21 96:13145:14 acting 37:14 activities 39:3 acts 96:16 actual 24:1 29:17 99:12 actually 20:22 43:24 44:2 73:11.23 102:19111:25112:6120:2 added 97:13 addition 89:8.20 additional 59:19144:12.16 address 6:17.19.22 7:20.21 24:16.19. 22.23 60:14 62:11 75:6 administrator 17:13 ads 56:18 af?rmative 6:9 8:24 38:10 56:10 65:14 76:10 77:7 88:6 93:13 97:15 106:11108:24119:6.10121:18 130:17 after 43:10 84:6 90:9101:11 125:6 126:21 128:7 134:2 149:2.3.6 afternoon 125210.21 126:8 again 7:23 31:10.18 33:10 54:16 78:14 103:8 106:7 120:6123:23 124:4 141:21 146:9 against 136:18 ago ?4:24 agree 33:2 57:25 59:1 117:24 118:5 119:15121:12123:3.10147:8 agreed 59:16 101:14 107:23 108:14 agreement 54:18.21 55:1 86:1 100:13101:16.21 102:25103:18 104:6.9.12.14.21 105:19 108:16 110:16.24112:16120:1 123:2.18 agreements 118:4.8 ahead 58:9 70:9 71:24 72:18 86:21 88:16 90:6 93:7 102:9103:7 113:11 140:9 AI-zee-tah 97:7 Albany 8:17 alcohol 59:22 allegations 42:18 alleged 10:12136z4137z10 allowed 89:4 101:23 102:11 130:20. 22 almost 139:20141:4 along 91:15.17 92:2 already 32:20 135:22 Alsip 119:17.20 also 16:24 17:15 23:7 27:9.17.23 31 :9 50:1 76:2 80:4 83:14 123:15 132:1 Although 32:19 Amazon 13:14.17 20:25 21:1 22:22. 24:2.3.12 25:10.25 26:22 27:3.9.17.23 29:6 43:20.21 45:15.19 50:24 51:12 52:11.13.15.20 53:4.18 54:8.15.16.22 67:16.17 83:14.15.18. 23 84:23.24 85:14.23 86:2.4 88:22.23 89:4.8.10.11.20.22.23 90:19 93:12.18. 19.20.22 96:7.14.17.23 97:1.5.111.25 99:15.16.19100:3.19101:18.19 102:22 103:3.21 106:13.17.19 107:2. 7.12.19108:5109:1.11 111:1.3.6.7. 13.20.25112:8.16.17.18.21 113:4.6. 19.21 114:13.15115:1.11.14117:5.8. 10.12.15118:4.8.19.21 119:1.2 120:18.23 121:23 122:6 123213 124:7. 9 143:25 144:1.3.4146123 148:4 Amazon's 23:3 Amazon.com 99:18 Amazon.com.dedc 99:19 amended 122:16 amendment 116:6117:2.4.24118:2 119:7 122:22 123:3.12 124:4 amendments 122:21 123:5 Solutions 888. 651.0505 - ?-11 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25. 2019 Job 29626 Index: amends..Base-Iess FILED DATE: 4/2/2019 3:27 PM 2017L000060 amends 116:21 amount 77:24 Anastasia 6:18 andlor 128:14 another 31:6 42:15.22 50:14 51:22 71:2126:14138:14141:9.16 answer 5:13 92:21 95:2 105:21 113:11 147:23 answered 32:22137:24 answers 132:11 140:23 any 5:9 6:22 7:2410:1212:213:14 17:2.11 20:21 26:9 27:19 28:14 29:20 31:14 32:12 34:15 35:14 36:8 40:16 42:17.24 44:15.20 47:3 52:20 56:3 58:17 59:2 67:12 71:19 72:14 73:16 82:5 83:1 85:24 86:4 88:12 90:19 91:10.16 92:1.6 99:20105:18118:8 122:5 124:16.19 126:22 127:9.24 128:13.21.23 129:6.10130:1.5.9 132:2.4 134:5.21 138:22 140:23 144:16149:12.15150:18 anybody 34:16 49:1 127:25129:9 143:14 anymore 52:18 79:17 anyone 128:25134:14.18 anything 21:7 34:12 36:4 39:12 42:25 83:6 95:16.21 107:16126:18127:7 128:23134:4.10137:12141:9 anywhere 24:19 71:18 apologize 9:11 84:4 app 144:4 apparently 59:15 appears 55:1 57:5 60:15 34:22 115:10 117:3 applicable 4:15 57:22 101:11 116:23 applicant 57:1 application 55:19 58:8.11 59:2.16 60:18.19 61:1.16.18 90:15 applied 56:1.5 58:6 120:2.18 applies 119:7120:9 approaching 148:4.16 appropriate 60:1 approximate 56:4 approximately 4:20.23 6:20 14:11 19:4 64:4 93:14108:14125:8128:5 are 7:10 8:410:16.18.2212:513:6.16. 17 16:2 17:1 27:25 30:15 31:20 36:8 38:4 45:9.23 50:11.12 51:6.7 58:19.24 59:9 60:9 65:1 66:5 67:10 68:6 69:19 70:13.22 74:16 80:4.20 84:18 87:21. 24 90:10 92:15 93:3 105:5.14 108:4 22122:15131:12.21 139:20141:4 149:3.21 area 7:9.10 8:21 22:15.19.21 23:24 24:17 26:18 27:13 28:2 29:17 35:9 43:8 45:6 51:8 56:17 60:17 78:3.6 80:22 82:22 83:16 88:23 90:22 91:15 93:12 96:14 97:19 98:19110:14.18 119:14125:12.15128:3 aren't 68:8 argue 102:6 armed 59:10 Arnold 81:16 around 19:24 35:21 55:7 56:2 57:6 83:24 85:19.23 96:6 107:3.19 arranged 41:21 arrangement 41:21 54:15 arrest 142:1.7.25 arrested 133:22 aside 66:6114:17124:11 ask 5:10.23 9:12 32:25 38:8 47:18.22 48:5 66:14 70:9 72:20.21 73:7 74:4 78:14 79:15 84:19101:2.24102:11.14 103:8 130:20.22 asked 30:16 33:10 34:25 53:17 57:16 58:17.19 59:9.19.20.21 60:4 70:5 105:6 126:2 127:14 13329.12 134:9 137:23 150:3 asking 5:16.17 32:22 42:5 48:24 68:17 71:5 83:21 107:21 115:9.14 129:16.18.24130:23141:3 asks 62:4 assign 43:7 assigned 78:25 assistant 29:20 assistants 78:15 assisted 29:21 associates 125:19 Association 94:2.5 95:20 96:1 assume 5:14 50:1 84:17 assumed 126:12 assuming 35:2 47:20 49:22 51:3 65:19 Atlanta 6:16 7:9.18 8:20 39:15.17.20. 23 60:19 68:1 96:20 97:21 110:13 125:15140:12.13141:21 attached 115:20 122:11 123:24 attend 8:20 83:20 attended 95:16 attorney 130:21 attorneys 55:24115:11 131:17 August 78:5 Austin 27:7 28:25 32:3 35:6 53:12 Austin-morton 53:5 authority 31:12 35:13 available 30:16 78:16 Ave 25:11 Avenue 25:18 27:4.7 28:20 29:7.20 38:25 52:21 119:23 aware 36:8 111:24 118:7 146:7.11 away 128:12 back 14:416:1217:15.2318:1122:13 23:12.16 27:3 33:10 35:10 37:25 38:24 39: 19 42:4 44:4 45:3 46:14 47:25 48:15 49:15 50:12.13 51:10 52:12 55:8.10 56:13 61 :14 63:3 64:21 67:3 68:21 76:1.20 79:5 81:7 82:13. 15.20 83:4 89:14.15.17.25103:12.14. 23108:14112:6113:15.22114:10 115:7123:24127:17132:25141:21 Back-end 39:16 background 35:23 36:8 81:23 90:16 91:3 bad 102:1.16 Base-less 52:24 Solutions 888.651.0505 "71" 111']! Ir FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Index: based..certain based 56:3 57:6 80:12 140:24 basic 65:17.25 75:9 77:22 90:14 100:17 basically 12:7.15 20:6 22:24 23:23 45:19 67:9 124:23 basis 61:22 Bates 115:1 bays 46:4 beaten 82:18 because 6:1 15:11 38:23 46:10 48:14 51:4 70:21 74:15 79:6.16 81:4 95:2.9. 13 96:22 101:3 105:4,9 112:3 122:3. 11,15126:24127:11 130:21 137:16 141:4,9 147:5 been 7:3 9:7.1310:11 15:1 20:12 22:4 26:5.6.9.13 30:4,9,23 31:12.17 34:7, 10.20 36:12.18 37:10.13 40:9,10 41:1 47:16 48:25 50:23 54:7 55:1 59:11 60:20.24 61:8 64:18 70:3 71:6 76:4,11 81:6 84:23 100:14.18101:6.11 102:21 109:13 116222 120:1 122:1 124:22 125:24 131:4133:19135:4136:3,9149:6 before 4:18 7:818:11.13.17 20:22 26:23 35:18 36:13 45:5,9 47:6.17 51 :5 53:9 55:6.21 60:23 85:10.15 86:3 91:4.13 96:25 99:6101:6115:16 beginning 50:4 94:23 96:19 98:6.8 111:21117:9.11 begins 150:11 behalf 55:4 behind 50:17 51:16,22112:16137:4 being 4:4 5:3 36:18 44:10 49:6 51:6 67:2 71:13 75:9 81:25 83:14 101:23 believe 58:14 71:6 78:21 87:20 88:12 122:11 131:3 belongings 29:11 Below 31:20 benefits 22:4 Benesch 64:14 besides 17:12 27:11 67:11 90:19 96:16127:23132:1 134:2.14 best 30:11 31:18 33:7 67:6 77:25 86:8.9 88:1 92:16.22 93:8 94:6.10.17 97:9 107:1 125:22 bet 141 :22 between 19:6 35:20 38:25 54:22 100:2.19117:4.15120:18 beyond 59:19 big 20:17 68:7 biggest 23:12 bill 47:9 98:22 99:1.6 binding 104:8 birth 8:10 bit 10:1567:9122:10 board 91:4 boss 36:17 bottom 55:20 57:11 59:13 123:2 bouncer 59:5 box 57:16 68:9 boxes 57:2 Brand 121:7 branding 111:16124:8 branding-speci?c 123:19 break 61:10106:3 breaks 140:2,3 Breathalyze 128:18 Breathalyzer 130:4 bring 50:12 brother 7:11 brought 84:2 building 22:22 45:21 bullet-pointed 57:23 bunch 57:2 business 12:9.13.16.21 13:2514:10 13.17.1915:216:17.1917:1818:5 19:12 23:18.24 26:13 28:1.5 35:24 36:10 59:3 93:23 96:18 150:12 Byron 28:21 31 :9 32:20.22 34:11 35:10.12.14 36:18 38:18 40:15 62:9 79:15.16125:2.3.11 127:3 128:7.16 130:2 133:3.4 134:15 138:5 calculated 51 :6 call 63:13 66:23 74:3 79:7 125:5.6 126:21 127:1 called 20:18 47:18 66:18 69:23.24 73:12 97:14 125:2.9.21 126:7.8 127:4 143:4.7 calls 88:15 120:4148:8 149:17 came 20:4 23:18 can 10:1511:19 22:25 24:24 28:16 32:22 34:24 36:2 39:2.12 40:17.25 46:12 48:15.19 52:17.19 58:10 62:22 66:6.23 71:18 72:17 74:2 77:19 79:5 80:19.24 84:8 85:20 89:15 90:3.6 91:22 92:21 93:14 94:9 97:9 105:17 109:21 113:11.12114:17120:25 124:11 125:22130:12131:1 135:12 141:14142:20147:23 can't 7:12 12:23 52:17 72:9 85:20 115:10.13.21 130:13135:4141:8 cannot 49:20 140:6 capabilities 63:6 car 57:14 65:2 126:13.14 card 96:10 care 95:9 cargo 20: 15 41:15.23 42:20 43:25 44:5.20 45:8.16 47:17 51:6 65:2.8.10. 20 73:17111z24 Carolina 15:3 Carrier 69:9.12 94:2.5 Carriers 95:20.25 case 7:8 18:12 55:25 74:24 84:23 102:10106:18115:12130:14 cases 112:17 category 68:7 cautious 146:23 147:2.11.17.20.25 148:1 centers 106:14,15 CEO 15:16 49:7 CEO-PRESIDENT 17:2 certain 33:11 41:14 49:19.20 EcoScrr'be Solutions 888.651.0505 I: l-F' JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: certi?cation..contrary FILED DATE: 4/2/2019 3:27 PM 2017L000060 certification 59:21 60:6 cetera 10:21 29:11 150:8 CFO 16:1017:2128:2 change 122:3 changed 19:19 38:2 122:12 123:4.6 137:11 charge 9: 19 charged 10:11 51:17 63:17136:9 137:17.18 charges 136:18.22 Charles 36:23 37:4 Chattanooga 10:5 check 45:7.57:22 90:16 91:3 Chicago 7:911:512:18 22:19 25:19 26:15 27:4 28:23 31:9 52:21 62:11 96:19.22 97:6 98:2.3.4.13.19 99:1.7 110:19111:9119:17.18125:24 141:19 Chicagoland 22:15.21 23:24 24:16, 25 26:14.17 27:13 28:2 35:9 43:8 45:6 56:17 60:17 78:3.6 80:21 82:22 83:16 88:23 90:22 91 :14 93:12 96:14.16 97:1.19.20110:18119:14125:12 128:3 children 139:4 choose 141:11 chose 24:23 Circuit 4:15 circumstances 5:20 33:20 citation 40:11 142:3 citations 142:1.22 cities 23:1 citizen 59:11 city 65:24 claiming 131:6 claims 42:21 Clark 56:8,11 60:15.19.22.25 classes 94:9 clean 90:15 clear 40:6 122:9 client 42:19141:1 clip 84:11 clock 39:21 Clocks 39:21 close 27:21 139225 closed 45:10 closely 15:17 closer 50:4 clothing 111:2112:23 code 19:25 codes 4:16 college 8:14.17 17:19 19:5 20:7 collision 34:20 come 43:3 45:20 50:13 55:8 93:17 128:19145111 comes 31:6 79:7 86:16 comment 87:2 commercial 20:12 commitment 150:10 committed 10:12 companies 5:1.21 10:23 11:9.20 12:1413:1718:2 20:23 23:5 99:20 company 5:4 11:11 12:5.6 1326.8,10, 13.1414:1.6.1015:2.2016:11 17:1.3. 12.2018:17.19.21.2319:4 21:123:2, 3.7 26:18 32:11 33:8.15 34:16 35:17. 20.24 3629.13 37:1.10 40:1.8 41:18 42:6 44:15 47:21 48:12 49:1,6 52:16. 20 64:6.9.16 65:19 66:2. 22 68:23 69:15 71:5 72:20 74:20 75:12 76:25 77:17.20 78:8 79:2,17,23 81:11.18.25 82:7,21 83:2.3.12 89:11.23 92:24 93:11.17.22 94:3.10 95:19.22 96:3,16 97:1.19 98:4 99:13100:19102:22104:8106:12 114:10,11 118:3.7119:1124:6128:14 145:12.24147:12 company's 21 :12 23:17 31:12 55:9 62:22 63:6 73:23 77:5 78:20 86:1.3 101:17103:2,20117:19142:16 145:25146:16 company/companies 15:9 competence 77:13 competent 80:9 Complaint 132:14 Complete 145:8 completed 49:17 compliance 68:8 69:5 81:8 complies 121:15 comply 69:12108:8 complying 150:11.14 computer 19:25 46:12 computers 29:15 concerning 57:3124:20 concluded 90:1 103:24113:23 150:23 conclusion 120:5 conditions 120:16.18 conduct 146:4149:15 conflict 122:21 Congratulations 14:22 consideration 121:11 consistent 106:23 consists 91:23 constraints 49:14 contact 8:5 51:18 53:19 54:9 97:6.18 98:3.9 118:25119:3 148:6.17 contacts 52:12 contained 61:21 120:17 contains 37:21 continue 127:22 continues 14:13150:13 contract 42:15 54:14 88:21 101:22 102:4.5.11.21 103:2.20 107:7 120:8. 14 contracted 117:8 contractor 16:15.17 contractors 70:22 contractual 121:21 contrary 137:13 EcoScrl'be Solutions 888.651.0505 min ll- :r . FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Index: conversation..deliver conversation 127:20 134:3 140:25 conversations 127:24.25129:2 convicted 9:13 59:11 Cook 4:16 7:8 68:22.23 81:6.17 82:5. 15 Cook's 81:22 coordination 43:20 capies 17:25 copy 48:18 67:5 76:13.21.25 109:4 core 63:6 corporate 10:2012:1213:1.217:12 corporation 15:17 correct 9:311:1714:1815:19 21:22 25:22 32:16 33:16 34:22 35:4.7.8 42:13.16 44:12 47:2.4.14 48:23 49:3.4 57:14.17 58:20 59:8.24.25 60:2 65:21. 25 68:14.16 70:25 75:15.18 76:19 77:2 80:12 83:10 84:16 88:5.8 92:24 95:14 97:3104:13108:6.18109:2.10 110:11111:2.20118:17.21119:19 correctly 121 :17 123:21 correspondences 24:20 could 8:12 30:17 33:9.12 34:7 40:12 47:22 78:16 79:2.15 80:13 89:13 90:25 93:22 105:23 107:17 112:7.9 136:23 140:20 couldn't 45:11 102:14140:22 counsel 84:1 95:5 104:22 105:5 124121 141:3 Counselor 105:19 country 54:23 county 4:16 7:8 8:22 10:3 couple 9:12 73:7 85:1 133:19 courier 13:25 18:2.4.5 20:20.22 23:8 31 :24 36:9.12 54:16 55:18 59:3 66:3 69:16 71:10.20 72:11 73:17 74:22 88:23 89:4 93:11 96:14.17 courier's 70:6 71:7 couriers 38:15.16 69:11 course 39:8 42:1 130:18 courses 83:20 court 4:15 6:5 89:16103:13113:14 Cove 6:18 covered 34:24144:14 crash 125:5 crashed 19:16 create 12:10.11.12 126:22 created 48:25 49:5 crime 10:13 crimes 10:12 criteria 108:17 critical 71:4 criticisms 149:12.15 crossed 135:22 crossing 75:21 138:8147:3 crosswalk 135:18 142:5 144:19.22 145:1 current 62:25 currently 10:16 17:3 62:22 63:24 82:10 custom 26:12 customer 23:12112z20121z13 customers 121:14 D-A-Y 54:3 daily 39:3 dangerous 144:25145:14 146:3.18 147:14 dash 112:4 data 48:13.24.25 49:3 78:16 date 8:10114:22116:3.11 124:17 125:5 dated 100:4 116:10.22 118:2 122:23 dates 59:16 dating 76:20 daughter 7:1516:5 17:4 David 16:8.9.16 34:8.9 36:19.20 37:13 98:12 128:2.5.10.21.22 day 18:4 20:15 26:24 30:25 31:4.5 39:3.8 40:5 41:4 43:10.12.22 47:17.22 48:1.2.4.6 49:10.21.23 50:16 51:15 52:2 53:8.20 82:1 116:24 122:6 124:12 125:6.7 127:21.25128:25 129:24 130:11.12132:4.25133:1.8. 19.20 134:2.10 143:20 144:7 day-to-day 38:20.22 days 79:10 91:18106:16.17131:17 132:7133:19134:17 DCH 12:5.19.2013:1.2215:121:14.16 24:8.14 DCH1 119:17.20 DCHZ 119:17 DCH3 119:18 dead 149:13 deal 97:5 98:20 dealing 109:13 deals 108:2 dealt 52:16 Decatur 6:18 December 11:515:2517:15 28:18 30:8.20 32:4 33:5 36:17 37:1.11.25 38:19 39:25 40:18 44:5 45:7 46:8.14 47:25 48:25 49:15 51:11 52:13.21 53:5 55:2 60:22.25 61 :4 64:19 67:22 68:18 74:7 92:13 96:25 99:9 100:15 110:17116:24124:16127:23129:1 133:5 decide 17:17 decided 18:4 decision 34:1.3 Dedicated 63:10 deem 51:21 deemed 80:12 deems 79:11 91:21 defect 42:20 defendant 5:4 defensive 93:3 degree 8:14.15.18 delete 49:2 deliver 12:22 48:3.4 83:14.23 89:11. EcoScrr'be Solutions 888.651.0505 ru- 1i: 1111 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25. 2019 Job 29626 Index: deliverables..drivers FILED DATE: 4/2/2019 3:27 PM 2017L000060 23112:3113:8.21 124:7 deliverables 106:14 delivered 44:9.11 49:10 63:14 deliveries 54:10 97:20 145:17 148:23 148:4 delivering 20:16 41:5 98:23 103:3.21 112:5 delivery 12:1.7 20:18 36:5 39:8 47:10 50:2 6623 80:13 81:24 98:25100:1.12.18101:18106:14 19116:7142:18143:3145:3.10 148:8.10147:16 department 13:21 14:2 24:15 56:12 67214.19.20.22.25 68:3.5.18.21 6925.7 74210.1176214 8123.9.15 8227.10.12 deposition -4:1.12.14 5:6.8 61:12 84:7 90:8 105:25 106:4141z12 depositions 4:20.21 describe 8:12 39:2 80:19.24 90:25 described 129:3 descriptions 37:16.24 38:4 41:1 design 99:17 designated 106:17 designed 76:12 detail 135:14 determine 79:13143:15 determines 92:4 detour 47:1 develop 77:11 developing 77:8.21 device 47:19 48:16.19 143:4 devices 143:2 DHL 23:7 diagnostics 143:14 did 4:25 5:3 8:15.20 9:21 .23.25 13:4. 1314:5.1016:16.1917:1719:6 20:21 22:14 23:10 27:11 29:20 31 :24 32:18 33:17.20 34:11 35:14.24 3624.8 37:24 38:19 39:5 41:14.15 42:17 43:2 51:10 54:14 56:13 57:5 59:2 87:11.22 69:2.15 72:14 73:15 74:6,8,25 75:6 76:3 77:8. 20 83:20 88:13 89:10.22 90:19 93:17. 18.19 97:5.18104:7.21 108:8111:9 127:1.7.9.14.24 128:13.19.21.23.25 129:8.9.18.24.25 130:24 132:16133:1.4.7.15.21 134:1. 4,14,18,21 135:10137:3.6138:8 141:25 1423.10.13.22 143:2 didn't 23:25 59:2 72:11 87:1.9101z3 102:14104:11 114:2 126:4.20127:15.20135:13 13 different 11:21 22:14.17 30:7 38:23 57:2 63:20 68:4 74:25 76:16.18 82:20 94:8 99:16.17121:1 dif?cult 6:7 DIRCKS 84:13.16 90:2,11 92:18 104:25105:17120:4.11 122:9.15 138:10150:19 direct 21:23 direction 139:10143:13 directions 130:1 directly 20:25111:5 director 74:17.18 75:1 disagree 58:4 58:2 85:24 102:17 124:17148218 disc 84:6 discipline 34:15 40:11 disclosed 32:20 discovery 4:12 55:25 84:24 90:8 discussed 20:7 37:17 92:15 128:10 discussions 45:1 dishonesty 10:13 diskettes 17:20.23 dismissal 34:11 dispatch 31:5 dispatched 53:8 dispatcher 30:5 31:3.20 37:18 38:13 40:12 43:8.7.18 45:5 48:1.21.22 51:14.17 52:6 82:9.10 dispatcher's 45:10 51:16 dispatchers 30:3.7 31:12.15 34:25 35:1,? 39:6 40:21.23 41:1 46:7 50:23 51 :13 dispatching 30:19 disrespect 9:13 77:19 distraught 135:13 distribute 18:1 distribution 106:15119:5.8.13 document 37:21 55:11.13 58:3 61:18 62:16 6718.11 69:21.22 71:15.18 73:4.9.22 74:3 85:3 100:5.9. 11 1097.15.17114218115:5.22.24 118:18 120:8 documentation 74:1 79:1 documents 37:22.23 55:24 57:7 83:1 121:21 126:23129:6.7.11.12.15 130:5.6.9 132:2 136:17 doors 45:9 DOT 12:8.10 13:11.12 24:10.20 double 32:18 down 6:6,7 46:5 133:10 134:7 141:21 downloaded 17:21 downtovirn 112:3 drag 141218.20 drilling 140:4 drive 45:21 49:20 68:6 91:22 driven 111:18,25 driver 20:12 35:25 39:18 43:8 44:1.2 46:14 47:5.25 50:7 60:5. 10.17 65:18 70:8.24 71:7 73:17 74:23 77:23 79210.13.24 8025.12.21 91:13.15.18.18.20.21 92:2. 4.5.9112:21 125:25126z10127z19 145:3,10. 148:3.15.23 driver's 46:8 59:21 85:22 68:13 89:25 72:11 73:5 74:5.6.9.14 75:2.25 79:1 82:25 92:7142:13.17.19 drivers 31:24.25 35:11 37:18 38:16. 17.21 39:11 41 :10 43:9 46:2 49:15 51:5 55:10 56:16 62:8 65:13 67:12.13. 15 69:16 70:21 71:3.20 73:24 74:16 76:25 77:21.24 80:9 81 :1 82:22 83:4 85:15 86:3 87:18.24 88:5. - EcoScribe Solutions 888.651.0505 i .: 'r '1ill FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: drivers'..explain 22.24 89:3.11.23 90:21 91:9.10.11 123:11 124:7 145:21 drivers' 41 :4 80:8 driving 57:10.13 65:20 72:12 73:17. 25 75:10 87:2191:23 93:3111:13 drove 67:16 69:16 drug 59:22 65:24 91:3 128217.19 130:3 Drugs 9:20 DSP 98:19.24 99:1.7 duly 4:4 during 42:1 123:12146:7.11.15 duties 36:20 40:16 69:2 e-documents 129:7130:6 E-L-K-O-R-D-Y 118:21 e-mails 129:7 earlier 19:10 124:9 150:3 easiest 11:1 easy 5:9 ECA 93:25 94:1 economy 19:15 edicts 87:24 educate 76:12 education 8:13.19 59:12 effect 55:1 100:15 effective 116:11.20 effort 51:7 eight 109:18.19.20.24110:1 eight- 110:4 eight-hour 50:20 either 36:19 41:11 50:19 52:5 53:6 62:9 71:2.4 79:1 84:14 129:6 137:6 148:6.17 electronic 39:20.21 47:13 48:13 56:24 electronically 39:22 else 35:11 39:12 71:3 82:15 83:6 84:5 107:12 126:18 127:7.25 12823.25 133:15134:1.5.10.14.19 em 32:25 46:6 132:13 employ 33:17 employed 8:310:16.18.2218:14.16 21:23 33:15 83:13111z5 employee 16:14.21 21:23.25 22:1.2.3 34:19 66:19.21 70:21.24 71 :3.12 73:13 74:15.16 76:22.24 77:4 61 :8 62:23 employee-based 68:5 employees 14:20 25:2 52:20 67:9 68:6 72:4 75:13 80:20 83:12 108:15 111:5 130:1 employer 21 :20 employers 58:24 59:3 enable 82:6 encompassed 69:19 end 11:16 44:10 49:2.20 50:5 endanger 75:18.21 enforce 112:13.14 enough 61:7 87:9 95:7119:25 entail 39:3 enter 13:13.18 54:14 entered 41:21 96:13100:22101:10 102:22 104:6 107:18 entering 42:6118:3.7 Enterprise 41:19.22 42:7.9 entire 54:22 entities 10:2199z17 entitled 22:4121:7 entity 8:312:10.11.1213:2 24:14 42:15 54:15.22 97:11 117:8.22118:8 escalate 40:13 Escamilla 34:13 42:19111:12120:3. 10 124:15 135:17.20 136:5 137:5.22 138:2.25140:14149:13.16 especially 76:24 146:23 147:1.5.11. 17.19.20 establish 92:7 95:25 estimate 30:11.12 31:18 even 70:10 86:19 94:16 95:11 111:4 114:11 124:4 evening 41 :7 event 96:6 124:20 129:11 events 96:8 ever 7:3 9:5.7.1310111 20:10.12.25 26:5.6.23 27:1 36:12 42:17 43:3 47:21 55:21 59:10 85:9130:9131:13132:19 13820.22 142:7 143:14 every 12:24 43:12 46:17 49:2 72:10 73:11 77:23 86:2101:2.22 145:6 Everybody 102:6 Everyone 86:9 everything 6:6 17:21 45:8.9.12.13 86:9107:12127:16130:14146:1 exactly 139:2 EXAMINATION 4:6150:1 examined 4:4 examining 73:3.9101:4 108:19.21 115:5 example 129:13 exceed 145:17 exhibit 55:14.17 61:21 62:14.17.20 66:9.11.14.20 69:20 71:13.23 73:12. 22 76:7.16.18.21 77:3 82:24 83:8 84:7 85:4.8 89:9.21 92:16 93:25 99:25 100:6104:7.19106:7107:17108:1 110:13111:16114:19.22115:7.25 116:3.5.17117:11.23118:11 120:17 121:6122:24123:4.10150:4 exist 11:21 13:6 37:25 74:6 existed 62:3 71:8 82:25 expect 101:3 expected 86:6 9213.14.19.23 Expedited 63:9 experience 57:10 66:3 74:13.22 experienced 91:18 expiring 139:1 explain 109:21 120:25126:17 EcoScribe Solutions 888. 651. 0505 r. ir In: I: ?rl'r' FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: explained..gave explained 126:15 Express 19:12 94:25 95:20.25 extent 71:23 88:14124:13 88:3 148:6.17 eyes 44:25 eyewitness 132:17.20137:4.10 F-E-A-R 54:2 face 52:17100:3 facilities 28:11 31:22 40:24 52:12 facility 25:25 27:17.23 28:20 31 :9.10 33:5 35:1 45:6 46:15 47:6 52:12 fact 60:21 73:21 92:3 111:24134:9 135:2.14 Factory 18:18.20 fail 145:1.4 failed 145:11 failing 142223 fails 144:21 145:23 failure 142:4 fair 5:14 61:7 79:25 87:9 119:25 123:1 fairs 56:18 falling 51:22 familiar 12:6 71:15 family 5:20 18:7 139:4 fashion 60:2 fast 46:12114:1.5139:12 fatality 125:24 Fear 54:2 Fearaday 53:24 54:4 Fed 23:7 Federal 13:1169:9.12 fee 120:22121:1.8.12 feel 77:25 Fees 109:21 120:22 fell 42:12 felonies 9:16 felony 9:14.19 10:9 59:11 ?eld 20:18 figure 97:4 file 12:23 17:24 58:13 79:1 92:7 130:14 filed 12:4 filings 132:10 fill 57:16 58:19 ?lled 57:2 61:1 fills 60:18 61:23 film 76:2 final 12:145:7 Financial 16:20 find 7:12.24 37:20 72:11 78:15 79:5. 19 fine 6:3 9:4 72:7.9 73:1 95:14 finish 73:8 ?nished 49:24 fire 35:13 Firestone 42:4 firing 35:1133:21 firm 63:13 84:15 ?rst 4:411:1 18:8 21:13 44:9 56:3 66:16.19 84:20 91 :17 93:11 96:20 98:1 100:18.21 101:5.9102:21 116:11 122:17.20125:1 128:8134:18135:21 FISHER 4:7.11.17 8:2.8.9 22:20 25:18.22.24 32:17.24 33:2.3 44:24 45:3.4 48:11 52:9.10 53:1 55:15 57:21 58:7.10.15.16 61:11.14.15 62:18 64:1. 3 65:6 66:12 70:2.4.14.23 71 :25 72:6. 16.19.23 73:1.6 84:17.22 85:6 86:12. 15.19.22 87:1 .4.9.13.14 88:19 89:15 90:5.7.13.18 92:20 93:9 94:19.22 95:18 10.16.20 103:9.11 104:5.20 105:2.6. 11.14.20.25 106:3.6113:8.10.24 114:3.5.9.20.23 115:2 116:1 .4.9 120:7.12122:13.18.1913111.6.8 132:4.6134:12136:14.23.24 137:12. 15.18.24 141:5.11.17.22.24 147:4.20. 22.24148:2.11.22 149:4.10.11.21 fit 44:17.19 five 59:20121:6123:15134:17 Flanagan 141:13 ?ashing 148:6.18 fleet 63:10 65:4 69:1.4 81:21 Floor 44:22 Florida 15:3 follow 86:6 93:1 130:3 148:14.25 followed 61:19 90:21 114:13128117 following 87:24 130:10 133:1 139:1 follows 4:5 89:18103:15113:16 forces 59:10 form 93:5 94:14101:21 102:15113:7 136:11.21 137:9 146:25 147121 formal 82:5 formally 74:4 84:6 forth 38:24 86:7 87:17103:1.18 108:17121:16123:19 foundation 72:1 90:3.8.9 138:10 four 26:16 41 :8 54:8 59:20 63:19 108:22 109:25 120:22 four- 110:4 fraud 10:13 Freight 63:8 friends 125:17 frolic 46:25 front 44:11 109:8135:15138:6141:1 146:7.11.15.20.21 fulfilling 40:17 fulfillment 1823106215 full 145:8 full-blown 16:21 full-time 22:3 further 4:14 gain 93:23 97:18 gave 5:7 Solutions 888.651.0505 '1 'rll'r" mm .: 1 . 1' FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: general..himself general 54:19.21 generally 91:11 9725101216 10223. 13.24 103217 generated 47:7 gentleman 11:2 72:20 118:20.23 geographical 51:8 Georgia 6:16.18 8:21.23 15:3 18:21 gesture 6:8 give 5:7 22:25 126217 12922513425 141:8.16 given 4:19.21 80:2510424 13726.13 gives 143:12.13 good 6:12 33:20 80:12 82:19 87:15 92:10 105223 Googling 19:24 gotta 84:4141z18 GPS 46:11.19143:12.13 graduate 8:16 Gray 11:2.1120:14 21:3.17 22:10 25:5 26:23 28:13 30:20.25 34:12 39:19.25 40:4.8 41:10 42:19 43:11 46:15 47:5 52:3.7.8.9 53:7 55:10.12. 19 56:1.5 5725 5824.19 59:2 61:17.25 69:11.16 70:24 78:4.7 85:17 88:13 91:1192:13 96:22111:25116:23 120:3.9122:5124:15133:17.18.21 135:7.10.25 136:3.9 137:4.17.21 138:4.5.20 139:7141:25143:3.16.21 144:7 Gray's 5:20 47:16 48:5 49:22 58:11 78:11 7921324 138:6 Gray-escamilla 34:17 ground 5:7.8 Grove 2727 53:5 grown 14:19 guaranteeing 83:11 guess 5:6 20:17 30:10 32:19 33:24 45:25 57:18 87:6 99:21 104:2 112:20 117:9 121:24 guessing 53:13 70:13 guidelines 59:23 80:11.25 guides 94:6 95:21 guilty 10:1.2.7 guy 37:5 45:13 53:21.23 79:3 91:25 95:10 97:7 95:5.19 99:5.7 102:12 135:13 guy's 51:22 guys 57:15 55:5 54:19 125:24 H-A-N-Y 118220 half 78:18 hand 62:1966:13143216 handbook 60:10.11 66:17.24 67:1.2 73:4 150:4 handbooks 150:7 handed 107:12 handheld 143:4 handing 55:16116:5 handled 39:14 handwritten 130:6 Hany 11820.22 happen 7:20 13:21 30:19 31:14 99:12 114:5 127:15.20 happened 23:23 52:2 53:9 78:2 129:14149219 happens 129:14 happy 105:21 hard 48:18 80:18 hate 141:18.20 hauled 20:10 he 1124.6.8 16:15.19 2128.9.25 22:3 2526.8 28:24 2925.9.11.20 30:3 3122.3 32:14 33:17.20.21 34:10 35:12.15.17. 18.20.21.25 36:1.2.4.6.8.12.13.18.19. 24 3724.10.13 38:23.24 39:4.5.6 40:5 42:20.21 43:11 4527.11 46215 4726.8 4822 49:24 5023.4 5426 55:10 57:9.10. 13 58:6 5922.5.10.15 6021.6 61:19.22. 23 70:14.16 72:1 .2324 74:18.22 7828 7927.11.16.19 8025.10.11.13.14 84:20 85:18.20 91:2.4.8.17.18.22 9226.14 95:6 97:1198:13.15 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148:5.17 EcoScn'be Solutions 888.651.0505 1 .1. '11 FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Job 29626 Leonard Wright January 25, 2019 Index: hire..Jeff hire 5:20 35:13 65:18 66:2 76:20 88:18 hired 21 :8.10.17 22:10 25:5 28:14 35:15 36:9 55:11.12 60:20 61:17.19, 22 78:4 hires 55:10 67:3 hiring 21 :9 35:11.14 38:21 39:8.11 88:25 his 21:20 28:22 31:12.3. 10.11 35:23 36:17 37:6 38:19 39:19 40:61? 46:12.15.16.17.22 47:24 50:2. 8 51:22 52:17 53:25 54:5 56:2 57:3 58:13.20 592.12.20.21 60:18 68:25 69:2 71:10.11 79:4.6 80:12 8127.20 92:1.4.16 93:24 98:7.17 103:6 136:4 history 10:16 18:13 20:8 57:13 58:20 hit 86:3 125:25126:2.3.10.15128:12 135:18.20.23 136:1 137:5 hitting 126:12.13 hold 56:17111z22 Hollowell 36:23 37:7 homicide honking 148:6.17 hopefully 86:15 hoping 32:24 horn 146:7.18 horse 82:18 hospital 127:6 hour 61:9 63:15 hourly 21:25 22:2 39:19 hours 22:7 49:21 50:8.11 68:10 109:25110:1 127:5 149:7 HR 75:1 76:14 human 74:11,12,18 99:5 idea 32:2.12 87:10 122:5.7 identification 55:13 62:16.20 66:10 85:3,8100:5114:18115:24116:3 identified 58:24.25 65:1 82:20.24 17.18.20.21 213.13.14.17 22:9.12.17 84:24 85:9 93:3 116:6 23:3.24 24:15 27:12 28:1 .4.10.23 . . 31 :21 33:17 38:22 40:8.10 41:12.14. 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II rr: FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25. 2019 Job 29626 Index: job..location job 20:7 29:22.37:16.24 38:20 40:16 41 :1 45:10 56:17 58:20 62:7 71:11 78:1 80:13 91:23 92:6 jobs 89:5 Joe 97:7.24 Judge 141:13 July 78:5 jumping 55:7 June 114:25 keep 69:5127:3 keeping 48:13 Keisha 81:16 key 134:9 killed 11:6135:17 Kimberly 56:8.11 60:15.19.22.25 kind 20:14 24:3 29:15 32:19 knew 78:8140:11 know 5:11.23 6:2 7:10 9:1811:1.19 13:21 15:717:21 18:1.12 21:7.9 22:9. 12 24:22.24 27:6 28:13.14 29:25 30:2. 7,19 31:14.17 32:5.15.25 33:6 34:5.21 35:24 36:1 .12,16.24 37:2 41:2 43:18 44:24 45:12 47:8.15.20 49:6.23 50:2. 6.9.18 51 :19 52:2.15 53:7.11.21.25 54:5.20 57:18 58:23 60:8.24 61:25 62:5.10 67:16 69:23.24 70:10. 19 71:21 72:1 .2.7 73:1 75:8 77:22 78:11 7920.23.25 80:3 81 22 82:23 83:5 84:5 87:23 90:14.15 94:12.16 95:4.11.16 96:11.21.22 97:11 98:7.8.17 100:23.24 101:2.3.4 102:10 105:4 112:2.4.19.21 128:16.17.21 130:5132:10133:18 136:2.3.18 137:1.3.16.17.18.21 138:2.25 139:3.7. 141:25142:3.10.13.22143:18.19 144:6146:20.21 148:10 149:18 knowledge 33:8 65:23 67:6 73:21 74:13 92:22 93:8 134:20 136:13 137:2 known 24:14148:5 knows 78:19140:13.17.20 KPMG 23:7 lack 33:24 lading 47:9 lady 127:5135:15.16 laid 71:10.25 87:25 93:1 large 23:5 larger I 64:10 last 4:8 6:5 15:7 37:6 44:11 54:1 57:17.24 61:16 91:3114:25118:20 later 126:7 127:4,5 133:20 Latin 19:25 law 9:12 63:13132:14150:9 laws 150:11 lawsuit 12:4 lay 90:37.9 lays 73:23 87:17 100:17 102:25 103:18 lead 62:9.10 leadership 33:24 leaf 62:24 learn 42:17 90:9 125:1 learned 128:22129z25 lease 41:15.16 42:1 63:24 64:2,? 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l' FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA VS AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Index: ocations..minutes 52:14 53:5.7 78:17 98:1 110:13120:2 locations 22:15.17 24:2 27:11.25 28:5.9 29:6 39:4 41:8 53:20 54:8.10 101:18110:18.19121:1 log 68:13 Logistics 11:24 99:19100:3109:1.12 117:5.12.15118:4.19 long 6:19 7:5 35:17 45:12 71:23 83:11 84:3 85:1 135:4 138:25 longer 33:15 74:20 look 30:16 60:13 62:13.25 65:11 100:8106:9.10107:17.21 111:15 20131:18133:10 looked 10:20 80:11 89:9.20 109:11 130:23.24.25 looking 59:12 76:17 117:14 looks 66:16.17 78:4117:22118:1.16. 19 loose 44:22 lose 7:7 loss 59:6 lot 18:5 32:2199:16.17127:15 made 87:27.20 90:11 magazine 95:21 maintain 77:12 maintenance 41:25 42:8.10 make 8:4 17:25 23:22 38:8 39:6 41:4 44:17 45:8.11 62:21 80:8 82:19 87:5 makes 34:3 51 :4 making 46:25 51:18 78:8 87:4 146:19,22 147:17 man 82:7135z4 Manage 69:4 management 36:2 manager 19:2 2620.21.22 28:10.20. 23.24 31 :10 32:3 33:4 34:4.6 36:6.14. 2137:3.14.18 38:9.11.18 40:6.18 54:6.11 81:21 managers 28:25 29:21 36:22 52:12 54:12 98:19 managing 38:22 39:2 mandatory 84:18 86:2 89:1 manifest 47:24 48:1 .525 49:9 50:3. 24 manual 44:15 60:11 66:19.21.24 69:25 70:6 71 :2.7 72:24 73:5 74:5.6. 10.14 75:2.25 76:9.11.13.25 77:4 82:25 83:9 94:21 manuallhandbook 73:13 76:22 77:4 82:23 manufactured 17:20 many 4:20 14:20 30:7 31 :17 63:23 64:6.16 82:9.12139:4 March 100:4 101:6.12106:18107:3. 19108:14 116:22122:23124:5 marital 7:1 mark 66:8 84:6,? 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FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Index: Miss..one Miss 34:13111:12120:3.10124:15 135:17.20 136:5137:5.22 138:2.25 140:14149:13.16 mission 77:59 Monday 106:16 money 141:23 monitor 41:3 46:8.11.17 monitoring 51:14 Monster 56:19 Monterrey 59:6 month 130:12 more 26:16 48:1 64:21 73:4 91 :23 149:7.10 Morgan 7:17 16:5 17:56.7 morning 133:6134:2,15 mornings 31:6 Morton 27:7 most 5:9 53:19 54:9 56:23 77:10 most-used 65:3 motor 65:23 69:9.12 motorists 88:7 move 46:2 moved 98:18 movement 46:17 movements 46:12 moving 6:22 multiple 9:1616:2 Mundelein 27:20.21 28:8 29:1 33:4 35:1 53:12.18 MVR 90:15 name 4:8 7:1611:212:5.2413:13 19 20:19 28:19 37:6 52:15.18 53:4 54:1 93:24 96:8 98:7 99:13 109:11 117:19118:20.21 named 24:1 36:14 names 11:20.21 30:2.17 31:14 33:12 40:23 52:19 99:18 naming 5:4 national 34:6 36:21 38:9 nature 9:11.18 59:23139:5 necessarily 45:17 86:11 need 63:14 95:24 needed 40:4 41:25 42:8 47:21 needs 65:18 negative 6:9 32:7.18 128:20 negotiate 97:5 negotiated 54:25 107:7.10 109:17 negotiation 96:13 network 98:1 never 26:25 42:24 70:2 86:19 95:16 142:25 new 67:3 76:20.24 78:24 79:1 80:9 81:1 82:22 83:4 92:2.5.7 next 9:12 30:5 50:16 62:13 66:8 127:21 132:25133:19.20134:17 night 45:20 51:1 nine 7:6110:24 nine-hour 50:20 nod 6:8 non-commercial 65:19 Nope 138:21 149:4 59:5 North 15:3 63:15 noted 86:18 notes 126:22 notice 4:13 notified 129:22 number 7:21.2210:21 12:8.10.19 13:11.12.2214:2 24:10.16 55:18 61:22 62:15 6629.14.20 69:20 71 :13 73:22 75:12.13 76:8.21 83:8 84:8 85:8 89:9.21 92:16 99:25 104:7 106:8.9 23120:17121:7122:21 123:10140:1 150:4 numbered 45:23 55:20 numbers 64:18 numerical 45:23 o'clock 149:3.6 oath 95:10105z21 obeying 72:15 object 58:5 71 :22 86:20 87:2 90:2 93:5 94:14101:20102:15104:18 113:7 137:6 objected 105:9 objection 86:18.24 87:3.5.8.10.11.12 88:14 90:1192118 95:15101:25 102:1.16.18103:5.25105:1 113:24 120:4.11 134:6136:11.21 137223 138:10.11 139:15146:25147:21 148:8.20.24 149:17 obligations 103:1.19 obviously 19:15 80:6 140:4.5 occurred 50:7 92:11 occurrence 5:18 20:15 21:21 26:24 34:17 42:18.21 43:4 47:16.17 49:23 50:3 53:8 61:3111:11114:11 116:24 129:1.25130:11 131:13133:2134:2, 14143:21 144:7.14149z16 offered 22:5 Office 22:24 24:1 26:2.4 29:5.6.16 33:11 140:12143:22 officer 16:24 59:7 of?cers 17:1.3.9138:22 of?ces 22:14.18 Oheya 98:12 Ohio 15:3 old's 17:7 older 65:22 On-demand 63:8 on-the-job 82:2 once 4:22 26:15 46:14 60:17.20 91 21 92:4 97:19 123:23 one 4:25 5:219:16.1711:1.8.14.19 12:1414:2518:4.8 27:3 30:9 31:6 33:9 36:23 41:8 42:21 48:1 55:1 57:11 EcoScribe Solutions 888.651.0505 .11.. Elli? .- - FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: one-hour..pertaining 58:23 70210.12.15.18.19.20 7524.24 7624 78:15 8221 8325.7 8422 86:2 96:7 99:22 100220.21 10125.6.9 109:8 110223112211116225117:2.10.15 119:2136:16138:14145:3.10.16 14626.101472161492102415028 one-hour 6329.12 only 1029 23:3 28:6 34:19 74216 115:5 122215124221 131212135212143210 147:5.22 open 109:24 operate 75:14 operation 87:18 operations 28:10 38:22 opinion 51:16120:13 opportunity 73:10 opposed 138:8 order 1229.22 13:24 43:15.18.22 44:18 45:23 49:9 88:21 1002.13.14. 19.20.22117214121216122223 123220 12425 organization 96:4130:7.10 original 122:23 123:25 124:5 originally 19:11 35:15104:15.16.21 125:14.25 126:8 other 7:2411:2012:1415:1816:2.3.7 17:1.3.1120:1123:4 24:19 27:12.15 31:2135:12 36:13 40:16 43:1149:15 52:24 53:1 73:21 75:18 77:23 81:25 82:16 83:1 88:7 89:10.22 90:10.20 91:15106:15110:23112:20118z8 122:21 123:6126:19129:2.22131:18 132:2.7134:5.9135:2.14 others 12:2 27:19 28:15 67:12109216 othemise 9:9121:14 131:7 our 6:5 21 :9 29:15 34:56 46:10.11 50:19 55:25 56:12 67:10 70:21 77:22 78:1 85:15 88:1 9123.4 98:1 128:2.11 out 7:12 82610221 172191925.18 24:20 26:5.9.14.17 2821.5.14 3028 3924.7 4021 41 :3 4526.20 47222 48216 51 :5 5327.8.11 57:2 58:19 60:18 6121. 23 71 :10 73:23 74:10 77223 7821,17 79:19 87225 91 :13 92:23 9321.18.19. 20.22 9627.9 97:4 98:13 100217 107222128219135:15138:5.7141:1 over 14:21 18:2 19:16 28:25 34:7 43:10 49:20 50:8 60:19 61 :9 63:14 73:11 98:18 135222 oversaw 36:21 overseen 111:6 own 15:20 23:25 2421 41214 64:16 owned 12:13 4121164214.19111218 owner 13:6 14:6 16:22 18:23 75:12 77:17 owner-president 71:5 ownership 15:22.24 owns 143:24 p.m. 61:12.13106:4.5150:23 package 55:19112:21 packages 20:1 .21? 23:8 31 :2 39:7 43:25 44:19 49:10 51 :7.25 83:14.23 89:11.24 103:4.22 106:19.21 113:6.21 124:7 146:23 148:4 page 5623 57:11 58218.23.24 59:13 6025.13 6325.19 65217 66216.19 67:1 72:10 73:11 76:7 7721.3.5 8328107225 108210.20.22.23 109219 110224 11323. 8120221 121:5122:17.20123215 15028.10 pages 55:20 59:20 62:21.25 65:11 66:20 71:23 72:9 104:1923 105:3,5 109218 paid 83:13 110:4.7.8.9 111:5 pamphlets 95:21 paper 47:11 56:18107:13 papers 36:5 paperwork 47:7 48:18 92:16 paragraph 77:11 106110 108:10 121:6 150:13 parent 7:11 parked 143:1 1 part 11223 16:21 19:9 45:10 56213 58:13 8621 88217.25 89:2 90:25 109216111222129220 particular 12:18 16:17 30225 4127.17 4329 4525.16 4624 49216.17 51214.15 70219100220109224110212111:2 11522211927 121221 144:6 parties 103:1.19 pass 90:15 passed 6:1 91:2 126:5 12726.13 128:12 passing 65:24 past 75:3 pax 20:1 Payable 120:23 paycheck 79:6 payroll 17:13 39:14 Peachtree 17:24 pedestrian 127:12128:11 142:4 144:19.22145:1 148:5.16 pedestrians 75:21 88:10 148:5 pendency 123:12 pending 136:18 people 29221 3024.17 35:12 53:19 66:2 8229 84217 96211 10825 11922 percent 23:20 64:23 percentage 15:22.24 23:17 perfectly 6:3 performance 41 :4 46:8 80:13 performing 108:11.15 period 120:2 perished 5:19 34:21 permits 9:12 person 31 :4 32:11 33:7 41:20 50215 5427.8.25 7923 82216 93:21 9628 97:6 99:110726126213.16.19138:17 149213 person's 80:3 personal 40:4 61:19 personally 26:24 personnel 58:1392:7106:11 121:13 perspectives 68:4 pertaining 71 :20 73:16.24 EcoScn'be Solutions 888.651.0505 "frr . 1? Ill FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Index: pertains..put pertains 23:23 65:12 110:13 pertinent 84:2115:12 ph 97:8 98:12 phone 7:22126:21.25 photographs 131:10.12.15.18 photos 131:4 physical 8:19 36:5 physically 39:4 pick 46:5 picture 138:6 pictures 130:25 131:2.4.22.23 132:1 piece 107:13 placard 111:19112:1.18124:9 placards 111:19124:2 place 29:11 61:3 108:25 120:9124:15 126:19.21 placed 49:14 places 27:12.15 Plaintiff's 55:14.17 61:21 62:14.17. 20 6629.11.14.20 69:20 71 :13 73:12. 22 76:7,21 83:8 84:7 85:4,8 89:9.21 92:16 99:25 100:6 104:7 106:7 107:16 108:1 110:12114:19.22115:25116:2. 5.1711723120:17121z6122124 123:4.10 plans 6:22 play 35:14 84:34.25 played 85:5 playing 19:24 plead 10:1 please 4:9 5:1161:1176:13 pled 10:6 point 20:21 22:14 28:18 31:2.25 34:24 36:25 54:17 72:9 86:18 91:22 96:25112211 118:25125:14128:15 135:6 143:15 144:8 pointing 83:8 points 87:17.20.21 police 138:22 policies 71:20 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92:8 129:20 produce 70:5 produced 17:20 58:13 70:3 76:4 84:12.13.23131:4 product 86:4 production 18:319z2 professional 77:12125:19 promise 7:11.23 promoted 80:14 promotion 121:8.12 promulgate 94:6 proof 142:10.17.20 proper 44:13130:3 properly 41:5 45:9 protocol 129:14 prove 79:2 provide 74:2 85:15 89:11.23 90:19 101:17103:3.21 105:2108:5114:12 123:17 provided 47:8 55:24 66:78 80:7.20 83:19.25 85:17.22 88:22 104:22 113:5.20115:11.19122:1 144:10 provider 98:25 100:1 .12 114:24 116:7 provides 23:4 98:4 providing 54:15 93:11 107:3 109:14 provision 108:8 provisions 150:9 publicly 15:18 pull 33:11 48:15 142221 purports 55:18 62:21 100:1 114:24 purpose 7:24 26:19 67:8 68:3 102:25 103:18112:15 purposes 19:19 51:18 pursuant 4:13 55:25104:6 123:10 put 43:22 50:22 51 :1 .7 56:18 66:6 EcoScribe Solutions 888.651.0505 m1 1 FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: puts..requiring 74:13 77:10 84:6 91:4.13105:21 112:4114:17124:11141:23 puts 57:10 91 :20 144:4 qualifications 57:3 79:4 80:4 82:6 95:24 qualified 80:6 91:22 question 5:10.14.23 53:3 60:4 73:7. 15 86:25 89:14.19 93:6 94:15.24 101:2103:6.8.16105:7113:13.17 120:6 136:12 137:9149:10.24 questionnaire 61:20 questions 9:12 32:21 53:17 58:17.18 59:9.19 62:2 66:5 105:22 127:9 140:5.23 149:22 150:18 quick 62:14 quite 26:10 48:15 70:11 74:8 75:4 114:2130:13138:15 Rabbit Rack 59:5 raise 105:11 raising 105:13.14 ran 136:4138:7 rank 30:5 31:20 ranking 28:19.24 rates 107:8115:21 reach 7:12 8:5 93:18.19 reached 93:20.22 96:79 read 14:8 60:6 72:10 73:11 89:14.15. 16103:11.13106:23113:14115:17 121:17123:21130:13132:16.19 136:17 reading 60:10 73:8 89:25 103:23 113:22 150:9 reads 77:11 ready 79:11 real 62:14 really 95:5113:8115:21 125:18134:8 135:13 reason 5:9 24:7 33:23 56:4 58:2 85:24 88:12 122:10124:16 134:24 reasoning 50:17 reasons 75:24 Reb 84:14 recall 30:1 36:2 40:23 52:19 53:4 82:16 83:24109:7125:8132:18135:1 receive 76:25134:21 received 83:15 recess 61:12106z4 reckless 136:22137:17 recognize 100:9 115:4.9 116:15.17 118:23 recollect 130:13 135212 recollection 107:2 117:7 125:22 131:10 record 4:9.11.13 30:22 44:25 45:2.3 55:16 62:21 90:12100:1 114:23116:4 recording 85:5 records 30:15 33:11 recruited 56:16 recruiting 39:9.11 56:14.23 58:4.6 60:14.18 redeliver 50:14 refer 20:16 66:23 91:8 reference 22:14 28:18 36:25 54:17 72:11.14 76:8108:11 123:15.16124:6 referenced 134:3 referred 38:15 77:1 124:8 131:23 referred-to 89:17 103:14 113:15 referring 36:25 60:9 70:6 84:9 91:1.6 106:7110:19131:21 refers 57:16 76:11 77:5122:22 reflect 4:11.14 refresh 117:7 refused 89:3 regarding 5:20 44:16 54:10 58:20 87:17.21 98:3 103:2.20 118:25 Regardless 101:10 regards 26:18 42:18 48:13 49:22 77:20 79:24 81:23 92:1 109:13 110:17 149:16 regional 28:23 31:10 34:3 36:14.22 37:17 38:11.18 40:18 regroup 19:16 regulations 67:10.13 69:5.13 71:11. 19 72:12.15 73:16.24 75:9 78:9 90:20 150:12 relationship 107:2 relevant 115:12129:5 remain 28:7111:9123:7 remember 5:22 6:2 9:3 32:6 34:6 52:17 53:6 79:19 94:23 96:8 97:25 99:10 122:24 126:24 128:24 129:4 132:21 148:12.21 rent 63:24 64:2.7 rented 64:13 rep 53:4 repair repeat 23:21 89:13 11 3:12 report 65:23124:14131:19.21 132:16 133:9.13 134:4.10.23.25 142:7.25 reported 24:12 36: 19 reporter 6:5 89:16.19103:13.16 113:14.17 reporting 59:23 reports 124:20 132:9.10 134121.22 represent 55:23 representative 52:15 53:18 reprimands 34:15 request 129:9 require 129:9 required 57:9 85:18111z12 requirements 59:22 60:7.8 65:18.25 89:10.22 90:10 108:2 113:4.19 114:13.15121z20 requires 64:10 requiring 112:16 EcoScrr'be Solutions 888.651.0505 FILED DATE: 4/2/2019 3:27 PM 2017L000060 I - JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: research..sends research 133:10 reserve 150:17.21 resources responds 60:1 response 5:23 38:3 53:10 59:4 71:9 126:25127:10128:23129:11 responsibilities 38:20 40:16 58:14 69:3 responsibility 51 :17 62:7 78:7 81 :4 responsible 38:24 40:11 42:2 46:22 69:1 1 rest 70:21 result 5:19 34:16.21 resulted 42:2.1 43:4 retained 64:9 retreat 94:9 returned 41:7 42:9 revenue 15:8 Richardson 74:17 ride-along 79:8 91:25 rides 79:1191:15.17.18 riding 92:2 right 5:16 6:5.1410:1012:1917:21 18:919:5 20:9 21:19 23:23 25:19.20 27:5 29:14.19 32:16 33:1 38:8 43:6 45:13.22 50:25 55:16 59:18 60:4 61:7 71:1.16 73:9.20 79:9.17.18 84:15.21 96:21 .2425 112:23 115:18 117:18.21 119:4120:21 121:5123:9124:1 126:14 128:7 130:18.19.23 134:13 136:19 145:6 right-of?way 142:4 rights 103:1.19 road 75:6 85:16 86:3 91 :14 150:14 Roadone 19:12 roads 150:7 roadway 75:18 88:7 role 10:23 34:10 35:14 40:18 77:8 81 :20 rolling 44:25 route 39:8 43:21 44:7,8 49:17.23 51:22 143:4 routes 43:22 45:21.22 5019.20.21.22 51:197:2110:5111:7.13 rule 44:15 50:18 141215 rules 4:16 5:7.8 40:9 67:10.12 69:5.7. 9.15.19 71:10.19 72:12.15 73:16.24 74:25 75:6.9 78:8 80:10.24 90:20 142:17144:23 145:12,25 147:12 150:7.11.14 run 43:23 51:16143:14 running 111:6 runs 18:7 Rusty 68:22 74:25 82:15 S-E-L-E-G-E-R 99:4 safe 75:9 87:18.21 92:25 93:2 safely 75:15 safety 67:14.18.19.22.25 68:3.5.8.17. 21 69:1.4.9.12.15.19 74:10.14 76:8.9. 11.12.25 78:21 81:3.7.9.14 82:7.9.12 83:9 85:14 86:16 88:3.5.7.10 92:14 95:21 said 20:1 41 :2 70:14.16 74:24 81:6 87:2 94:24 95:13 105:9 107:13 125:25 126:20127:16131:14132:22 133:9 135:6 138:3.5.8 149:20 salaried 21 :25 same 11:2212223 21:14.15 35:5 38:5. 6 43:10 51 :8 53:3,17 68:7 77:24 93:1 103:5.25 107:20 114:7117:22 120:11 121:21 123:7131:19.21.22 Same-day 63:8 satisfy 108:16 saw 14:16 23:2136:16145:20147:6 say 4:216:11.1215:1117:24 23:18 25:5.16 30:10 31:1 33:9.25 35:18 43:14 63:13.15 64:24 79:25 84:18 87:10102:14112:25123:1 126:2 128:23133:7134:4140:10141113 146:9 saying 6:7 49:2 82:4 102:2,3,4 124:9 138:16 says 57:13.19.22.25 68:19 67:1 101:21.22.23102:4.11116:21 121:11 122:21 123:2 148:13.15.21 150:8 scanned 47:19 scene 130:25131z13 133:22 schedule 41:5108:17.19109:17.18. 19.23 Scheduled 63:9 school 8:15.20.22 screen 46:11 65:24130:3 screening 91:3 se 18:8110:8 seat 91:20 Seattle 119:3 second 27:6 55:8 60:13 78:18 91:24 116:13118:10128:8.9 secondary 61:20 seconds 21:12 secretary 17:4.12.14 section 108:1 secure 44:6 secured 44:20 securing 44:14 security 40:2 59:6 see 25:12 46:12 52:17 57:1 63:6 65:13 72:14 73:15 76:13 77:14 84:8.20 85:18 88:13.24 93:22105:10.18 108:2.12121:9.24131:1 133:13 141:12,18 seeing 59:18 148:12 seen 55:21 70:2 75:2 85:9 92:8 25 Seleger 98:22 99:2 Selegier 99:6 self-explanatory 121:3 semi 20:11 send 24:20.21 51:5.22 64:12 89:4 sends 60:18 EcoScrr?be Solutions 888. 651.0505 I mull. ll I: I-F- .- IIT FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: sense..speci?cation sense 36:7 45:25 51 :4 65:20 sent 60:15.21.24131:18' separate 13:2 69:21.22 September 5622 57:6 59:15 61:1 62:3 782511621021 118:3.17123211 serve 9:5.21.23 served 59:10 service 12:8 20:18 36:10 42:14 63:8 77:13 81:24 88:23 114:25115:19116:7 services 23:4 54:16 93:11 98:4 101:18103:2.20106:9107:3 108:11. 16109:14.21 114:12123z18 set 62:2 69:15 8627108217121z15 123119 sets 74:25 seven 4:24 55:20 60:14 109:18 116:13118:11 119:5,9120:22121:6 123:16 shareholder 16:3,718:24 shareholders 16:2 shares 15:20 - Shari 6:6 she 6:7 7:18 17:11.14 56:9.12.13 137:5 13825.7 139:4 she's 6:617:13137:1313923 sheet 44:7,8 Ship 11:2419:18 Shipments 10620.22 shipping 11:15 13:14.13.25 14:4.24 21:13. 13 22:9.12.13 23:3.25 23:1.4 33:18 54:13 53:9100:3109:1 117:4.19 113:13120:19150:5.10 shipping/courier 17:18 shirt 111:13112:17121:23122:6 shirts 111:3.7123:13 shook 127:20 short 79:16 140:3 should 30:22 70:18 76:1 77:2 128:14 6,16,17,21 14722.16. show 29:9 66:7 71 :18 93:24.25 109:23 114:21 116:2 130224 showed shown 85:7124:21 132:1 shows 110:3 sick 40:5 side 71:12 81:8 sign 92210104221 11228142223 signature 108:23118:11.14150:17 signatures 105:18109:5.8 signed 97:7102:12104212,15105:9 signing 109:7 signs 59:16 136:413725.7.11 similar 63:3 64:18 72:12 73:18114:7 115:18 since 26:13 38:2 82:1 single 722.514217 16:3.4 72:11 138:17 sir 90:12 sit 80:19 site 12:18 sites 22:25 sitting 45:22140:12 situation 51:21 six 60:5 77:3 110:1 six? 110:4 slow 134:7 smaller 20:17 SMX 99:19 social 40:1 125:17 software 17:19.25 18:18.201924 46:10 Solutions 11:1513:1914:5,2515:15 17:1518:1419:7,20 21:13.18 22:10. 12.18 23:4.25 2821.4 33:18 54:14 1002410922117:4.20118213120219 Solutions' 150:10 some 4:19 5:7 6:1 10:23 19:25 23:4 30:22 36:2 40:8 41 :14 42:14.20 43:3 45:23 47:7,9,10,21 49:14 51:25 54:14, 21 59:19 67:15 73:21 7421.22 77:8.10 78:24 79:1 80:10 83:15 84:1 87:17 95:24 96:6.25 109125 110:1 125:14 129:12,15132213134:24135:6 140:22 143:5 somebody 33:11 46:16 51:4,5 127:1 somehow 7:7115:12141:1 someone 5:3,18 7:9 22:3 30:16 34:20 35:11 37:1 49:5 61:17 78:3,6 79:22 81:3 92:10 96:7.12 97:25115:13 something 5:22.23 7:11 18:7 19:21 37:21 42:5 47:9 51:19 60:5 61:4,6 63:14 71:7 77:16 78:14 79:4 94:9 9523.12 9728.10 107:22 112:4 127:1,2 130:1 sometime 21:4 33:19 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Ii FILED DATE: 4/2/2019 3:27 PM 2017L000060 I - JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: speci?cations..Terry specifications 111:16121:15 speculate 88:15 speculation 148:9149z18 sped 51:19 speed 135:25 137:21 139:14 140:21 145:17.18.21.23 speeding 60:57.8 spell 4:8 53:25 97:9 spoke 128:5130:21 spoken 27:1 133:17135:7138:17 sprinter 65:2 stacking 44:14 stage 45:16 staged 45:13 stamped 115:1 stand 19:21.23 29:10 98:24 standalone 24:1 standard 62:2 94:6 115:7 standards 77:12.21 stands 107:22 start 10:2514:1019:16 49:19 52:13 54:20 58:22 67:18 68:20 99:24 124:25 started 4:19 6:1414:1618:6.13.17 19:12.18 21 :3 35:19.25 49:24 93:11 96:13.20 97:21 106:8 107:3 130:16 starting 20:22 51:16 58:18 59:20 state 4:8 8:17 10:4 12:8.9.15.23.24 13:12.21 14:1 statement 77:6,9 132117.19 137:6 statements 137:13 states 14:24 15:2 96:17 station 29:12 54:6.11.12 78:10 stations 54:19106:14 status 7:1,5 13:1 stay Steve 53:24 98:22 9927.11.13 still 13:8 28:4 32:11 33:8 48:8 53:21 68:23 81:17123:11 stip 58:10 stipulate 32:20 stocks 15:20 stop 101:23 136:4 137:4.6.7.11 142:23145:4.6.8.11 stopped 143211 story 18:10137z11 straight 36:16 65:2 street 6:17 7:21 75:21.22 13521.22. 23 138:7.9 139:7.14 strike 60:23 striking 126:19136:5 struck 120:3.9 127:6 137:22 Subparagraph 123:16 subscribe 94:10 95:19.20 subscribes 95:22 subsidiaries 14:25 subsidiary 12:13 such 14:25 suggest 72:21 suggestions 128213 summer 93:16 Sunday 106:16 sundries 20:11 supervisor 36:17 supervisors 31:21 supplies 43:21 supposed 50:13 80:25 87:5 143:9 sure 5:12 7:13 21:6 23:22 26:10 29:3 30:18 34:18 36:11.15 38:8 39:6 41:4 43:13 45:8.11 46:25 48:15.19 52:4 58:12 70:8.11 74:8 75:4.23 78:8.23 80:8 81 :5 82:3.8.19 91:17 92:3.12 94:8 101:9103:10 106:25130:2.13 134:13138:15140:11144:24 survived 139:3 swear 105:20.23106:2 sworn 4:4 system 91 :4 table 29:12 tail 44:10 take 7:23 15:8 40:4 48:2 61:9 62:13 65:11 100:8106:3.9111:15.16113:3. 17115:3116:16121:19122:20 126:22 taken 4:13.14133:24 140:1 taking 626.7 40:1 talk 21:11.12 28:17 31:8 34:23 40:21 52:5.11 55:9 60:12 91 :24 93:10 96:10 106:8124:12.25127:22133:1.15 134:1.17 talked 19:9 40:22 51 :13 75:8 78:24 94:23 124:1 128:7.22 133:20 talker 114:6 talking 15:176:15 91:8114:1 116:14 126:3 talks 55:1171z19 tantamount 71:7 task 43:6 73:17 tax 40:1 Teamster 9:9 telephone 7:21 127223 tell 5:24 10:15 11:20 22:17 23:22 28:19 35:2.6 40:25 66:15 67:9 77:20 83:25 84:8 85:22 88:20 93:14 94:25 100:9.24 101:3 107:21 11523.10 122:13123:3 125:22126:7 127:1.7 128:10135:10141:14145:20 telling 141:5 tells 126:9 tender 106:13 tendering 106219 Tennessee 10:5 terminate 141:12 terms 23:15 34:25 44:13 67:12 100:2. 12.17.18103:1.19104:8.11 114:24 115:19116:7120:16.18 Terry 8:2 44:24 58:11 70:2.5 72:16 102:2 105:3.20 118112 13121.6.23 14027.24 141:11.22 EcoScribe Solutions 888.651.0505 mm"- '1 ""111 FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25, 2019 Job 29626 Index: Terry's..underlings Terry's 131:9 test 128:18.19 130:4 tested 91:16.21 testi?ed 4:5 testify 140:19 testing 59:22 Texas 15:4 98:16 thankful 118:12 thing 6:511:22 62:13 87:15 91:3 110:23114:7115:5.18135:12 things 6:2 39:14 51:19 59:23 68:11. 15 90:14 93:3122:3.16139:4146:7 think 10:2511:1612:25 20:16 21:4 25:11 29:3 32:14.21 34:18.24 35:19 36:1.2 39:12 40:17 42:3 53:13.16 55:11 63:4 67:14 70:3 71:25 74:1.15 76:1.3.15 84:1.1187:16 88:193216 94:8 99:5.11 101:8110z21 119:20.21 20.23136:22138:3.12.14141:17 142:15 thinks 92:10 third 77:11 135:21 thought 70:16 95:13111:21112:12 140:24 thoughts 138:15 thousand 14:21 thousands 72:4 77:24 three 9:24 30:9.10 31:18.19 57:11.17. 24 58:24.25 59:13 63:5 79:10 82:11 84:3.4 91:18108:10119:4.8.14129:2 149:7 three-hour 139:20140:2141:15 three-year 65:23 through 18:12 19:5 40:10 45:21 62:24 66:21 72:24.25 84:24 89:6 92:8 93:25106:16115:1 118:2146:24 147:11 throughout 31:5 41:4 ticket 47:10 time 6:1.7 8:4 11:8 12:4 19:9.13 20:7.22 21 :21 22:15 23:13 26:9 29:2 36:23.24 37:4 39:20.21 41 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FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZON.COM LLC Leonard Wright January 25, 2019 Job 29626 Index: underlying..woman underlying 144:11 understand 5:10 6:1 11:4 12:251425 21:4 23:22 30:13 33:14 38:19 3924.5 40222.25 60:7 69:2 80:16 85:12 94:24 95:6.9 103:6 104:7 112215 113225 1142312021 13021513629144210 understanding 13:24 21:5 73:20 83:12 88:21 107:1 109:12133:21 135:8 137:10 understands 95:6 understood 5:1411:9 unfortunately 122:2 uniform 110:25121:7.12.15.20122:8 union 9:7 unit 43:9 unless 7:12 unreasonably 144:25 145:14 146:3. 18 until 32:25 35:21 79:11 127:20 up 10:20 20:4 29:9 30:3 40:13 4123.6 43:3.7.15 51:19.24 61:19 62:21 63:13 9727109223122210127220141214 142221 upcoming 136:25 updated 114:25116:19.20 Uphold 150:9 use 7:24 22:13 23:7 28:17 41:11 43:10.12 46:10 54:17 70:20 83:3 143:9 used 9:217:19182141z18 42:3 67:2. 12 71:3 83:14 98222123217143210 147:5 uses 66:22 143212 using 20:15 42:20 43:11 80:15 124:6 144:7 usually 20:20 115:6.7.17 utilize 63:21 143:3 vacation 40:5 vague 90:3 92:18 135:2 Valdimar 11:2.11 20:14 21:3.17 25:5 26:23 30220.25 34212.17 39218.25 40:4 43:11 55:10 61 :17 96222116223 Valdimar's 52:3111:11 valid 65:22 87:17.21 van 20:16 4228.20 4329.11 4425.10.11. 15.17.20 45:6.14 47:17 5126.8 6522.8. 10 73217111225 van's 45:6 vans 39:7 41:2.6.7.10.15.23.25 43:7. 10.14.19.25 65:20 68:6 69:17 72:12 73:25 various 37:17 38:4 40:24 41 :22 62:25 101218 vehicle 14:17 57:13 65:3,23 73:18 8126:19138:6140:21 141:2143:10 146:19,22 147:10146:3.16 vehicles 41 :14 63:20.23 64:16.19 65:169:4 72:13 75:13.14 87:18 16146:7.11147:17 vehicular 136:10.19 verify 62:22 Video 8322.19.22 8421.11.12.22 85:5. 9.12.14.18 86:4.5.7 87:15.21.25 88:13.24 89:3.8.20 90:16.19.25 91 :5 9229.15 93:2.4 145:20 147:6.24 148:12.13.14.15.25 violating 40:8 violation 144:23 145212.25 146215 147212 violations visible 148:17 visit 26:10 visiting 121:13 voice 105:12.13.15 volume 23:15 Wacker 63:14.15 waiting 84:10 walked 135:15138:5141:1 walking 126:4 140:14 wanted 47:15 112:20133z13 warehouse 26:23.4 27:9 29:10.13, 16.17 109:24 warehouses 24:3,13 38:23 warranty 42:3 waste 102:9 watch 83:22 64:19 66:4.5 89:3 90:16 91:5 watched 76:2 86:13 watching 69:7 90:24 wear 111:1.7.12112217121214 wearing 112:23121223 122:5123:11 web 60:14 website 1428.16 23:2 62:22 63:1.3.5. 19 65:12 week 2227130212 134218 welcome 66:16 well 112419218 35:25 40:12 45:11 50:24 54:20 57:19 58:5 70:9 72:3.18. 22 74:15 80:5 86:15.17 87:3 9321.24 9826 102:17 104:18.24 105:8 106:1 107:9.21 11729120214125224138215 140215141:15143:12144:4147:7 148214 went 45:6 96:21 97:23.24 West 28:21 31:9 32:21.23 33:14 35:10.14 36:18 38:18 4026.10.17 5226 119222 12523.11 127:24 13423.15 135:7.10 138:5 West's 34:11 140:25 Western 25:13.17.18.21.23 27:4 28:20 2924.7.20 31 :1 38:25 52:14.21 53:12.14119223 whole 31:4127:15134:18 wholly 12:13 Williams 16:8.9.11.16.20 34:10 36:19.20 37:14 Wilson 96:23 9927.11.13 withholding 40:2 witnessed 138:18 woman 11:6 138:8 EcoScribe Solutions 888.651.0505 Ii Iii" .- FILED DATE: 4/2/2019 3:27 PM 2017L000060 JESSE ESCAMILLA vs AMAZONCOM LLC Leonard Wright January 25. 2019 Job 29626 Index: wondering..yield wondering 12:25 20:5 word 11:21 80:15 87:10147:5 words 6:8 15:18 20:11 24:20 43:11 49:16 work 10:1617:1918:5.13 22:1.22.25 24:2.12 39:16 79:16 80:18 104:1.2.3 121:16 122:23 123:20 124:5 worked 20:25 24:4 36:1 52:20 79:22 82:12 97:1199:13.22129:10 working 5:21 11:8,1216z11 27:12 30:8 31 :1 .21 33:8 78:6 81 :17 91:14 92:24108:15112:22144:18.21 145:24 workplace 76:12 works 45:19 56:12 worried 95:5 Wright 4:1 .3.10,1 3.18 7:17 8:3 32:22 88:15149z24 150:3 write 72:3 written 37:16.24 54:18 55:25 83:1 90:20 129:7 year 10:715:7 26:15 49:2106:17 years 4:24 6:21 7:6 9:24 57:10.17.24 65:22 yesterday 72:10 yield 142:4 144:19.22 145:1 Solutions 888.651.0505 I 11