On March 02, 2015 a
Party Discovery
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 A Rager Esq SBN 185216
Jeffrey
James Y Yoon Esq SBN 289906
2 THE RAGER LAW FIRM SUPERIOR
CouRr oF IFORNIA
COUNTY OF SAN BERNARDINO
h
970 West 190 Street Suite 340 SAN BERNARDINO DISTRICT
3 Torrance California 90502
Telephone 310 527 6994 APR b 2018
4 Email jeff c ragerlawoffices com
ames a
rag erlawoffices com
gY
5
DANIEL ERI EIN DEPUTY
Melanie Savarese SBN 216950
6 Savarese Law Firm
37 W Sierra Madre Blvd
7 Sierra Madre CA 91024
Phone 626 355 3264
8 Facsimile 626 355 3491
Email melanie savareselawfirm com
9 Attorneys for Plaintiff BRIANNE RIGOLI
10
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN BERNARDINO
13
14
BRIANNE RIGOLI CASE No CNDS 1502545
15
Assigned To Hon Janet M Frangie Dept
16 Plaintiff S29
17 vs
PLAINTIFF S OBJECTIONS TO
1g
DEFENDANT S DESIGNATION OF
C R ENGLAND INC a Utah Corporation
DEPOSITION TESTIMONY OF
19 ENGLAND GLOBAL LOGISTICS USA INC CHRISTIAN THURGOOD
a Utah Corporation LORENA TORRES an
20 individual and DOES 1 through 10 inclusive
Trial Readin s en rence
21 Date pril 5 2018
Defendants T e 8 30 am
22
23 Trial April 9 2018
24
25
26
27
28
PLAINTIFF S OBJECTIONS TO DEFENDANT S DESIGNATION OF DEPOSITION
TESTIMONY OF CHRISTIAN THURGOOD
1 TO THE COURT DEFENDANT AND THEIR COUNSEL OF RECORD
2 Plaintiff objects to the deposition of Christian Thurgood that is offered by Defendant C R
3 England at Trial
4
5
Defendant Portion
s
Testimony Basis for Objection
6
Designation objected to
27 15 29 3 27 22 23 And a travel
itinerary and some notes The evidence should
g that I that some handwritten notes be excluded as it was
9 that I took never produced during
10
Overrule discovery Evidence
11 Code 352
12 29 9 34 18 30 21 31 9 How often were the newsletters
Q The evidence should
13 published back in 2014 be excluded as it was
14 A I think it was
monthly never produced during
15 Q And was that
something that was e
discovery Evidence
16 to
mailed each and
every employee Code 352
17 A Yes The other thing is that there was a There is also no
1 g newspaper publication that was foundation that
actually
19 given to It
each office was a physical Plaintiff ever received
20 newspaper And in those papers human said information
21 had an
resources always article and we Evidence Code 403
22 would address various issues within the
23 human resources realm And I do
Sustain
24 remember I don t remember who wrote
25 it It might have been myself I don t
26 remember but talking about retaliation
27 or discrimination for retaliation
28 29 9 34 18 33 14 23 Q And how how did you ensure that the Lacks foundation and
PLAINTIFF S OBJECTIONS TO DEFENDANT S DESIGNATION OF DEPOSITION
TESTIMONY OF CHRISTIAN THURGOOD
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 A Rager Esq SBN 185216 Jeffrey James Y Yoon Esq SBN 289906 2 THE RAGER LAW FIRM SUPERIOR CouRr oF IFORNIA COUNTY OF SAN BERNARDINO h 970 West 190 Street Suite 340 SAN BERNARDINO DISTRICT 3 Torrance California 90502 Telephone 310 527 6994 APR b 2018 4 Email jeff c ragerlawoffices com ames a rag erlawoffices com gY 5 DANIEL ERI EIN DEPUTY Melanie Savarese SBN 216950 6 Savarese Law Firm 37 W Sierra Madre Blvd 7 Sierra Madre CA 91024 Phone 626 355 3264 8 Facsimile 626 355 3491 Email melanie savareselawfirm com 9 Attorneys for Plaintiff BRIANNE RIGOLI 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF SAN BERNARDINO 13 14 BRIANNE RIGOLI CASE No CNDS 1502545 15 Assigned To Hon Janet M Frangie Dept 16 Plaintiff S29 17 vs PLAINTIFF S OBJECTIONS TO 1g DEFENDANT S DESIGNATION OF C R ENGLAND INC a Utah Corporation DEPOSITION TESTIMONY OF 19 ENGLAND GLOBAL LOGISTICS USA INC CHRISTIAN THURGOOD a Utah Corporation LORENA TORRES an 20 individual and DOES 1 through 10 inclusive Trial Readin s en rence 21 Date pril 5 2018 Defendants T e 8 30 am 22 23 Trial April 9 2018 24 25 26 27 28 PLAINTIFF S OBJECTIONS TO DEFENDANT S DESIGNATION OF DEPOSITION TESTIMONY OF CHRISTIAN THURGOOD 1 TO THE COURT DEFENDANT AND THEIR COUNSEL OF RECORD 2 Plaintiff objects to the deposition of Christian Thurgood that is offered by Defendant C R 3 England at Trial 4 5 Defendant Portion s Testimony Basis for Objection 6 Designation objected to 27 15 29 3 27 22 23 And a travel itinerary and some notes The evidence should g that I that some handwritten notes be excluded as it was 9 that I took never produced during 10 Overrule discovery Evidence 11 Code 352 12 29 9 34 18 30 21 31 9 How often were the newsletters Q The evidence should 13 published back in 2014 be excluded as it was 14 A I think it was monthly never produced during 15 Q And was that something that was e discovery Evidence 16 to mailed each and every employee Code 352 17 A Yes The other thing is that there was a There is also no 1 g newspaper publication that was foundation that actually 19 given to It each office was a physical Plaintiff ever received 20 newspaper And in those papers human said information 21 had an resources always article and we Evidence Code 403 22 would address various issues within the 23 human resources realm And I do Sustain 24 remember I don t remember who wrote 25 it It might have been myself I don t 26 remember but talking about retaliation 27 or discrimination for retaliation 28 29 9 34 18 33 14 23 Q And how how did you ensure that the Lacks foundation and PLAINTIFF S OBJECTIONS TO DEFENDANT S DESIGNATION OF DEPOSITION TESTIMONY OF CHRISTIAN THURGOOD