On March 02, 2015 a
Motion-Secondary
was filed
involving a dispute between
Rigoli, Brianne,
and
C.R. England, Inc. A Utah Corporation,
England Global Logistics Usa, Inc. A Utah Corporation,
Torres, Lorena,
Rigoli, Brianne,
for Wrongful Termination
in the District Court of San Bernardino County.
Preview
1 SNYDER LAW LLP
F I L E D
Barry Clifford Snyder SB 62844 SUPERIOR COURT OF CALIFORNIA
2 COUNTY aF SAN BERNARDINO
Ashle y Ann Dorris SB 229361
SAN BERNARDINO DISTRICT
Jessica Farley SB 280123
S3 3 Hollister Avenue Suite 240 APR 16 2018
Santa Barbara California 93111
4
Telephone No 05 692 2800
gy G G1G
Facsimile No 805 692 2801
5 DANIEL IERLEIN DEPUTY
bsnyder@snyderlaw com
adorris@snyderlaw com
6
j farley@snyderlaw com
Attorneys for Defendants C R ENGLAND 1NC
ENGLAND GLOBAL LOGISTICS USA 1NC
g
and LORENA TORRES
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
FOR THE COUNTY OF SAN BERNARDINO
12
BRIANNE RIGOLI Case No C1VDS 1502545
I
13
Plaintiff Hon Janet M Frangie Department S29
14
v
DEFENDANT S OBJECTIONS TO
15
C R ENGLAND INC a Utah Corporation PLAINTIFF S AMENDED NOTICE OF
ENGLAND GLOBAL LOGISTICS USA INTENT TO READ THE SWORN
l6
INC a Utah Corporation LORENA TORRES TESTIMONY OF GLEN TAYLOR AT
an individual and DOES 1 through 10 THE TIME OF TRIAL
1
inc usive
Trial Readiness Conference April 9 2018
g
Defendants Trial April 10 2018
19
20
21
22
23 TO THE COURT PLAINTIFF AND HER COUNSEL OF RECORD
24
Defendant C R England Inc objects to the deposition testimony of G en Taylor that is
25
offered by plaintiff Brianne Rigoli at trial
26
27
28
i
1
DEFENDANT S OBJECTIONS TO PLAINTIFF S AMENDED NOTICE OF INTENT
SNYDERLAW I LP
I
3R3HollisierAve
Sui e 240
TO READ THE SWOIaN TESTIMONY OF GLEN TAYLOR AT THE TIME OF TRIAL
S nlaBarbara CA 931 I I
1
Deposition of Christian Thurgaad
Plaintiffs Defense Contested Excerpt Objection s Per
2 Testimony
Designation Objection Evidence Code
11 17 12 1 1 Q Okay And excuse me do you Vague and ambiguous
feel you re up to speed about what as to what
4
happened happened especially
5 MS DORRIS 1 ll object that that s vague in light of his
and ambiguous as to what happened testimony at 97 5 9
6
when you re referring to a lawsuit that has
7 numerous allegations in it
MR DIDAK Okay
g
THE WITNESS I do
44 18 20 2 Q Okay You don t believe that C R Argumentative
9
England tries to whitewash complaints do
10 you
11 A Absolutely not
51 12 52 9 3 Q And it doesn t matter whether the Cumulative
12 complaint is substantiated or not still you
can t retaliate against the employee
13
1V4S DORRIS Again it lacks foundation
14 It calls for speculation It s overbroad It s
vague Ambiguous And its an incomplete
15
hypothetical
6 THE WITNESS And again it really I
mean I guess I mean I ve whatever the
1
context would be I mean I can you ask
that question again please
g
Mr DIDAK Sure
19 Could you read it back please
THE WITNESS Thanks
20
21 MS DORRIS Same objections
THE WITNESS Again our procedure
22
it doesn t matter what the complaint is it s
23 going to HR That s our procedure Once
they have that what they do with it is what
24
they do with it It s not something that 1
would deal with at that point
25
52 14 4 Q But you understand that whatever HR Cumulative
26
does with it they shouldn t be retaliated
against because they made the complaint
27
MS DORRIS Again it lacks
Zg foundation It calls for speculation It s
vague Ambiguous lt s overbroad and it
SNYDERLAW LLP DEFENDANT S OBJECTIONS TO PLAINTIFF S AMENDED NOTICE OF INTENT
53A3HoIlis
Suile 240
erA e
TO READ THE SWORN TESTIMONY OF GLEN TAYLOR AT THE TIME OF TRIAL
Sanla Barbara CA 931 I I
Document Filed Date
April 16, 2018
Case Filing Date
March 02, 2015
Category
Wrongful Termination
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
1 SNYDER LAW LLP F I L E D Barry Clifford Snyder SB 62844 SUPERIOR COURT OF CALIFORNIA 2 COUNTY aF SAN BERNARDINO Ashle y Ann Dorris SB 229361 SAN BERNARDINO DISTRICT Jessica Farley SB 280123 S3 3 Hollister Avenue Suite 240 APR 16 2018 Santa Barbara California 93111 4 Telephone No 05 692 2800 gy G G1G Facsimile No 805 692 2801 5 DANIEL IERLEIN DEPUTY bsnyder@snyderlaw com adorris@snyderlaw com 6 j farley@snyderlaw com Attorneys for Defendants C R ENGLAND 1NC ENGLAND GLOBAL LOGISTICS USA 1NC g and LORENA TORRES 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF SAN BERNARDINO 12 BRIANNE RIGOLI Case No C1VDS 1502545 I 13 Plaintiff Hon Janet M Frangie Department S29 14 v DEFENDANT S OBJECTIONS TO 15 C R ENGLAND INC a Utah Corporation PLAINTIFF S AMENDED NOTICE OF ENGLAND GLOBAL LOGISTICS USA INTENT TO READ THE SWORN l6 INC a Utah Corporation LORENA TORRES TESTIMONY OF GLEN TAYLOR AT an individual and DOES 1 through 10 THE TIME OF TRIAL 1 inc usive Trial Readiness Conference April 9 2018 g Defendants Trial April 10 2018 19 20 21 22 23 TO THE COURT PLAINTIFF AND HER COUNSEL OF RECORD 24 Defendant C R England Inc objects to the deposition testimony of G en Taylor that is 25 offered by plaintiff Brianne Rigoli at trial 26 27 28 i 1 DEFENDANT S OBJECTIONS TO PLAINTIFF S AMENDED NOTICE OF INTENT SNYDERLAW I LP I 3R3HollisierAve Sui e 240 TO READ THE SWOIaN TESTIMONY OF GLEN TAYLOR AT THE TIME OF TRIAL S nlaBarbara CA 931 I I 1 Deposition of Christian Thurgaad Plaintiffs Defense Contested Excerpt Objection s Per 2 Testimony Designation Objection Evidence Code 11 17 12 1 1 Q Okay And excuse me do you Vague and ambiguous feel you re up to speed about what as to what 4 happened happened especially 5 MS DORRIS 1 ll object that that s vague in light of his and ambiguous as to what happened testimony at 97 5 9 6 when you re referring to a lawsuit that has 7 numerous allegations in it MR DIDAK Okay g THE WITNESS I do 44 18 20 2 Q Okay You don t believe that C R Argumentative 9 England tries to whitewash complaints do 10 you 11 A Absolutely not 51 12 52 9 3 Q And it doesn t matter whether the Cumulative 12 complaint is substantiated or not still you can t retaliate against the employee 13 1V4S DORRIS Again it lacks foundation 14 It calls for speculation It s overbroad It s vague Ambiguous And its an incomplete 15 hypothetical 6 THE WITNESS And again it really I mean I guess I mean I ve whatever the 1 context would be I mean I can you ask that question again please g Mr DIDAK Sure 19 Could you read it back please THE WITNESS Thanks 20 21 MS DORRIS Same objections THE WITNESS Again our procedure 22 it doesn t matter what the complaint is it s 23 going to HR That s our procedure Once they have that what they do with it is what 24 they do with it It s not something that 1 would deal with at that point 25 52 14 4 Q But you understand that whatever HR Cumulative 26 does with it they shouldn t be retaliated against because they made the complaint 27 MS DORRIS Again it lacks Zg foundation It calls for speculation It s vague Ambiguous lt s overbroad and it SNYDERLAW LLP DEFENDANT S OBJECTIONS TO PLAINTIFF S AMENDED NOTICE OF INTENT 53A3HoIlis Suile 240 erA e TO READ THE SWORN TESTIMONY OF GLEN TAYLOR AT THE TIME OF TRIAL Sanla Barbara CA 931 I I