FR EA

Contract analysis

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Contract analysis / deposition-notice-halloran.docx
deposition-notice-halloran.docx
1017-00004 · 7 clauses
High · 1 Medium · 0 Standard · 0
1. All personal calendars, day planners, scheduling records, or appointment books reflect
1. All personal calendars, day planners, scheduling records, or appointment books reflecting or relating to Halloran's work schedule, work hours, shift times, or break times during his employment with AMA.
2. All text messages, instant messages, emails, direct messages, and other electronic com
2. All text messages, instant messages, emails, direct messages, and other electronic communications between Halloran and any other current or former AMA employee regarding working conditions, meal periods, rest periods, work hours, timekeeping, off-the-clock work, compensation, or any other wage-and-hour issue at AMA.
3. All text messages, instant messages, emails, and other electronic communications betwe
3. All text messages, instant messages, emails, and other electronic communications between Halloran and any putative class member regarding this litigation, the claims alleged herein, or the decision to participate as a named plaintiff.
4. All personal diaries, journals, notes, logs, or other records maintained by Halloran t
4. All personal diaries, journals, notes, logs, or other records maintained by Halloran that reflect, memorialize, or relate to his actual work hours, break times, arrival times, departure times, or work activities during his employment with AMA.
5. All wage statements, pay stubs, pay advices, W-2 forms, 1099 forms, and other document
5. All wage statements, pay stubs, pay advices, W-2 forms, 1099 forms, and other documents reflecting compensation received by Halloran from AMA at any time during his employment.
6. All documents reflecting Halloran's employment and income since his separation from AM
6. All documents reflecting Halloran's employment and income since his separation from AMA on or about November 30, 2022, including pay stubs, offer letters, employment agreements, and W-2 forms from any subsequent employer.
7. All documents reflecting any complaint, grievance, or report made by Halloran to AMA r High
⚑ Penalty / liquidated damages
7. All documents reflecting any complaint, grievance, or report made by Halloran to AMA regarding meal periods, rest periods, timekeeping, off-the-clock work, compensation, or any other wage-and-hour issue. Halloran is further requested to bring to the deposition any other documents that he may refer to, rely upon, or use to refresh his recollection in the course of his testimony. PROCEDURAL PROVISIONS This depositio