1 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 2 3 FOR THE COUNTY OF EXAMPLE VALLEY 4 5 6 RIVERBEND SUPPLY COMPANY, ) 7 ) 8 Plaintiff, ) 9 ) Case No. 24-CV-000123 10 vs. ) 11 ) 12 HARBORLINE LOGISTICS, INC., ) 13 ) 14 Defendant. ) 15 ______________________________ 16 17 DEPOSITION OF JORDAN AVERY SAMPLE 18 19 March 7, 2024 20 21 Reported by: 22 Casey L. Stenwright, CSR No. 9021 23 24 25 2 1 APPEARANCES: 2 3 For the Plaintiff: 4 5 WHITFIELD & MARSH LLP, BY: MR. WHITFIELD 6 7 8 For the Defendant: 9 10 OKONKWO LEGAL GROUP, BY: MS. OKONKWO 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 1 I N D E X 2 3 4 WITNESS: JORDAN AVERY SAMPLE 5 6 EXAMINATION PAGE 7 8 BY MR. WHITFIELD 5 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 1 E X H I B I T S 2 3 EXHIBIT DESCRIPTION PAGE 4 5 Exhibit 1 Warehouse safety manual 6 6 7 Exhibit 2 Loading dock schedule 12 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 1 EXAMINATION BY MR. WHITFIELD 09:30:00AM 2 BY MR. WHITFIELD: 09:30:07AM 3 A. At the distribution center in Millbrook. 09:30:14AM 4 because the drivers needed a signature on each manifest 09:30:21AM 5 although nobody mentioned the scheduling change to me 09:30:28AM 6 MS. OKONKWO: Objection; vague as to time. 09:30:35AM 7 Q. Who supervised the dock on the night shift? 09:30:42AM 8 so I wrote the numbers down on the clipboard by the door 09:30:49AM 9 A. A shift lead named Parker handled the dock. 09:30:56AM 10 although nobody mentioned the scheduling change to me 09:31:03AM 11 so I wrote the numbers down on the clipboard by the door 09:31:10AM 12 MS. OKONKWO: Objection; vague as to time. 09:31:17AM 13 Q. Did anyone review the schedule with you? 09:31:24AM 14 and the paperwork went to the front office afterward 09:31:31AM 15 A. Yes, the coordinator went over it every Monday. 09:31:38AM 16 so I wrote the numbers down on the clipboard by the door 09:31:45AM 17 and the paperwork went to the front office afterward 09:31:52AM 18 MS. OKONKWO: Objection; vague as to time. 09:31:59AM 19 Q. How often was the forklift inspected? 09:32:06AM 20 because the drivers needed a signature on each manifest 09:32:13AM 21 A. Usually twice a week, sometimes more often. 09:32:20AM 22 and the paperwork went to the front office afterward 09:32:27AM 23 because the drivers needed a signature on each manifest 09:32:34AM 24 MS. OKONKWO: Objection; vague as to time. 09:32:41AM 25 Q. What did the maintenance log show for that week? 09:32:48AM 6 1 because the drivers needed a signature on each manifest 09:32:55AM 2 A. Usually twice a week, sometimes more often. 09:33:02AM 3 and the paperwork went to the front office afterward 09:33:09AM 4 (Marked Deposition Exhibit 1) 09:33:16AM 5 MS. OKONKWO: Objection; vague as to time. 09:33:23AM 6 Q. Please look at Exhibit 1 for a moment. 09:33:30AM 7 although nobody mentioned the scheduling change to me 09:33:37AM 8 A. It showed two repairs on the conveyor belt. 09:33:44AM 9 because the drivers needed a signature on each manifest 09:33:51AM 10 although nobody mentioned the scheduling change to me 09:33:58AM 11 MS. OKONKWO: Objection; vague as to time. 09:34:05AM 12 Q. When did you first notice the damaged pallet? 09:34:12AM 13 so I wrote the numbers down on the clipboard by the door 09:34:19AM 14 A. Right after the second truck arrived. 09:34:26AM 15 although nobody mentioned the scheduling change to me 09:34:33AM 16 so I wrote the numbers down on the clipboard by the door 09:34:40AM 17 MS. OKONKWO: Objection; vague as to time. 09:34:47AM 18 Q. Had you seen the manual before that day? 09:34:54AM 19 and the paperwork went to the front office afterward 09:35:01AM 20 A. I had read portions of it during orientation. 09:35:08AM 21 so I wrote the numbers down on the clipboard by the door 09:35:15AM 22 and the paperwork went to the front office afterward 09:35:22AM 23 MS. OKONKWO: Objection; vague as to time. 09:35:29AM 24 Q. Why was the north entrance closed that morning? 09:35:36AM 25 because the drivers needed a signature on each manifest 09:35:43AM 7 1 A. I had read portions of it during orientation. 09:35:50AM 2 so I wrote the numbers down on the clipboard by the door 09:35:57AM 3 and the paperwork went to the front office afterward 09:36:04AM 4 MS. OKONKWO: Objection; vague as to time. 09:36:11AM 5 Q. Why was the north entrance closed that morning? 09:36:18AM 6 because the drivers needed a signature on each manifest 09:36:25AM 7 A. They were repainting the loading area. 09:36:32AM 8 and the paperwork went to the front office afterward 09:36:39AM 9 because the drivers needed a signature on each manifest 09:36:46AM 10 MS. OKONKWO: Objection; vague as to time. 09:36:53AM 11 Q. Where were you employed in the spring? 09:37:00AM 12 although nobody mentioned the scheduling change to me 09:37:07AM 13 A. At the distribution center in Millbrook. 09:37:14AM 14 because the drivers needed a signature on each manifest 09:37:21AM 15 although nobody mentioned the scheduling change to me 09:37:28AM 16 MS. OKONKWO: Objection; vague as to time. 09:37:35AM 17 Q. Who supervised the dock on the night shift? 09:37:42AM 18 so I wrote the numbers down on the clipboard by the door 09:37:49AM 19 A. A shift lead named Parker handled the dock. 09:37:56AM 20 although nobody mentioned the scheduling change to me 09:38:03AM 21 so I wrote the numbers down on the clipboard by the door 09:38:10AM 22 MS. OKONKWO: Objection; vague as to time. 09:38:17AM 23 Q. Did anyone review the schedule with you? 09:38:24AM 24 and the paperwork went to the front office afterward 09:38:31AM 25 A. Yes, the coordinator went over it every Monday. 09:38:38AM 8 1 because the drivers needed a signature on each manifest 09:38:45AM 2 although nobody mentioned the scheduling change to me 09:38:52AM 3 MS. OKONKWO: Objection; vague as to time. 09:38:59AM 4 Q. Who supervised the dock on the night shift? 09:39:06AM 5 so I wrote the numbers down on the clipboard by the door 09:39:13AM 6 A. A shift lead named Parker handled the dock. 09:39:20AM 7 although nobody mentioned the scheduling change to me 09:39:27AM 8 so I wrote the numbers down on the clipboard by the door 09:39:34AM 9 MS. OKONKWO: Objection; vague as to time. 09:39:41AM 10 Q. Did anyone review the schedule with you? 09:39:48AM 11 and the paperwork went to the front office afterward 09:39:55AM 12 A. Yes, the coordinator went over it every Monday. 09:40:02AM 13 so I wrote the numbers down on the clipboard by the door 09:40:09AM 14 and the paperwork went to the front office afterward 09:40:16AM 15 MS. OKONKWO: Objection; vague as to time. 09:40:23AM 16 Q. How often was the forklift inspected? 09:40:30AM 17 because the drivers needed a signature on each manifest 09:40:37AM 18 A. Usually twice a week, sometimes more often. 09:40:44AM 19 and the paperwork went to the front office afterward 09:40:51AM 20 because the drivers needed a signature on each manifest 09:40:58AM 21 MS. OKONKWO: Objection; vague as to time. 09:41:05AM 22 Q. What did the maintenance log show for that week? 09:41:12AM 23 although nobody mentioned the scheduling change to me 09:41:19AM 24 A. It showed two repairs on the conveyor belt. 09:41:26AM 25 because the drivers needed a signature on each manifest 09:41:33AM 9 1 because the drivers needed a signature on each manifest 09:41:40AM 2 MS. OKONKWO: Objection; vague as to time. 09:41:47AM 3 Q. What did the maintenance log show for that week? 09:41:54AM 4 although nobody mentioned the scheduling change to me 09:42:01AM 5 A. It showed two repairs on the conveyor belt. 09:42:08AM 6 because the drivers needed a signature on each manifest 09:42:15AM 7 although nobody mentioned the scheduling change to me 09:42:22AM 8 MS. OKONKWO: Objection; vague as to time. 09:42:29AM 9 Q. When did you first notice the damaged pallet? 09:42:36AM 10 so I wrote the numbers down on the clipboard by the door 09:42:43AM 11 A. Right after the second truck arrived. 09:42:50AM 12 although nobody mentioned the scheduling change to me 09:42:57AM 13 so I wrote the numbers down on the clipboard by the door 09:43:04AM 14 MS. OKONKWO: Objection; vague as to time. 09:43:11AM 15 Q. Had you seen the manual before that day? 09:43:18AM 16 and the paperwork went to the front office afterward 09:43:25AM 17 A. I had read portions of it during orientation. 09:43:32AM 18 so I wrote the numbers down on the clipboard by the door 09:43:39AM 19 and the paperwork went to the front office afterward 09:43:46AM 20 MS. OKONKWO: Objection; vague as to time. 09:43:53AM 21 Q. Why was the north entrance closed that morning? 09:44:00AM 22 because the drivers needed a signature on each manifest 09:44:07AM 23 A. They were repainting the loading area. 09:44:14AM 24 and the paperwork went to the front office afterward 09:44:21AM 25 because the drivers needed a signature on each manifest 09:44:28AM 10 1 MS. OKONKWO: Objection; vague as to time. 09:44:35AM 2 Q. Why was the north entrance closed that morning? 09:44:42AM 3 because the drivers needed a signature on each manifest 09:44:49AM 4 A. They were repainting the loading area. 09:44:56AM 5 and the paperwork went to the front office afterward 09:45:03AM 6 because the drivers needed a signature on each manifest 09:45:10AM 7 MS. OKONKWO: Objection; vague as to time. 09:45:17AM 8 Q. Where were you employed in the spring? 09:45:24AM 9 although nobody mentioned the scheduling change to me 09:45:31AM 10 A. At the distribution center in Millbrook. 09:45:38AM 11 because the drivers needed a signature on each manifest 09:45:45AM 12 although nobody mentioned the scheduling change to me 09:45:52AM 13 MS. OKONKWO: Objection; vague as to time. 09:45:59AM 14 Q. Who supervised the dock on the night shift? 09:46:06AM 15 so I wrote the numbers down on the clipboard by the door 09:46:13AM 16 A. A shift lead named Parker handled the dock. 09:46:20AM 17 although nobody mentioned the scheduling change to me 09:46:27AM 18 so I wrote the numbers down on the clipboard by the door 09:46:34AM 19 MS. OKONKWO: Objection; vague as to time. 09:46:41AM 20 Q. Did anyone review the schedule with you? 09:46:48AM 21 and the paperwork went to the front office afterward 09:46:55AM 22 A. Yes, the coordinator went over it every Monday. 09:47:02AM 23 so I wrote the numbers down on the clipboard by the door 09:47:09AM 24 and the paperwork went to the front office afterward 09:47:16AM 25 MS. OKONKWO: Objection; vague as to time. 09:47:23AM 11 1 Q. Did anyone review the schedule with you? 09:47:30AM 2 and the paperwork went to the front office afterward 09:47:37AM 3 A. Yes, the coordinator went over it every Monday. 09:47:44AM 4 so I wrote the numbers down on the clipboard by the door 09:47:51AM 5 and the paperwork went to the front office afterward 09:47:58AM 6 MS. OKONKWO: Objection; vague as to time. 09:48:05AM 7 Q. How often was the forklift inspected? 09:48:12AM 8 because the drivers needed a signature on each manifest 09:48:19AM 9 A. Usually twice a week, sometimes more often. 09:48:26AM 10 and the paperwork went to the front office afterward 09:48:33AM 11 because the drivers needed a signature on each manifest 09:48:40AM 12 MS. OKONKWO: Objection; vague as to time. 09:48:47AM 13 Q. What did the maintenance log show for that week? 09:48:54AM 14 although nobody mentioned the scheduling change to me 09:49:01AM 15 A. It showed two repairs on the conveyor belt. 09:49:08AM 16 because the drivers needed a signature on each manifest 09:49:15AM 17 although nobody mentioned the scheduling change to me 09:49:22AM 18 MS. OKONKWO: Objection; vague as to time. 09:49:29AM 19 Q. When did you first notice the damaged pallet? 09:49:36AM 20 so I wrote the numbers down on the clipboard by the door 09:49:43AM 21 A. Right after the second truck arrived. 09:49:50AM 22 although nobody mentioned the scheduling change to me 09:49:57AM 23 so I wrote the numbers down on the clipboard by the door 09:50:04AM 24 MS. OKONKWO: Objection; vague as to time. 09:50:11AM 25 Q. Had you seen the manual before that day? 09:50:18AM 12 1 so I wrote the numbers down on the clipboard by the door 09:50:25AM 2 A. Right after the second truck arrived. 09:50:32AM 3 although nobody mentioned the scheduling change to me 09:50:39AM 4 (Marked Deposition Exhibit 2) 09:50:46AM 5 MS. OKONKWO: Objection; vague as to time. 09:50:53AM 6 Q. Please look at Exhibit 2 for a moment. 09:51:00AM 7 and the paperwork went to the front office afterward 09:51:07AM 8 A. I had read portions of it during orientation. 09:51:14AM 9 so I wrote the numbers down on the clipboard by the door 09:51:21AM 10 and the paperwork went to the front office afterward 09:51:28AM 11 MS. OKONKWO: Objection; vague as to time. 09:51:35AM 12 Q. Why was the north entrance closed that morning? 09:51:42AM 13 because the drivers needed a signature on each manifest 09:51:49AM 14 A. They were repainting the loading area. 09:51:56AM 15 and the paperwork went to the front office afterward 09:52:03AM 16 because the drivers needed a signature on each manifest 09:52:10AM 17 MS. OKONKWO: Objection; vague as to time. 09:52:17AM 18 Q. Where were you employed in the spring? 09:52:24AM 19 although nobody mentioned the scheduling change to me 09:52:31AM 20 A. At the distribution center in Millbrook. 09:52:38AM 21 because the drivers needed a signature on each manifest 09:52:45AM 22 although nobody mentioned the scheduling change to me 09:52:52AM 23 MS. OKONKWO: Objection; vague as to time. 09:52:59AM 24 Q. Who supervised the dock on the night shift? 09:53:06AM 25 so I wrote the numbers down on the clipboard by the door 09:53:13AM 13 1 REPORTER'S CERTIFICATE 2 3 4 I, the undersigned, a Certified Shorthand Reporter 5 of the State of California, do hereby certify: 6 7 That the foregoing proceedings were taken before me 8 at the time and place therein set forth, at which 9 time the witness was placed under oath by me; 10 11 That the testimony of the witness was recorded by 12 me in shorthand and transcribed under my direction; 13 14 I further certify that I am neither counsel for nor 15 related to any party to said action. 16 17 Dated: March 21, 2024 18 19 ______________________________ Casey L. Stenwright, CSR No. 9021 20 21 22 23 24 25 14 1 DECLARATION UNDER PENALTY OF PERJURY 2 3 4 I, the undersigned, declare under penalty of perjury 5 under the laws of the State of California that I have 6 read the foregoing transcript and that it is true and 7 correct, subject to any changes on the errata sheet. 8 9 10 Executed on the ____ day of ______________, 2024, 11 at ______________________, California. 12 13 14 ______________________________ JORDAN AVERY SAMPLE 15 16 17 18 19 20 21 22 23 24 25 15 1 ERRATA SHEET 2 3 Deposition of JORDAN AVERY SAMPLE 4 5 Page No.____Line No.____Change to:_________________ 6 7 Reason for change:_______________________________ 8 9 Page No.____Line No.____Change to:_________________ 10 11 Reason for change:_______________________________ 12 13 Page No.____Line No.____Change to:_________________ 14 15 Reason for change:_______________________________ 16 17 Page No.____Line No.____Change to:_________________ 18 19 Reason for change:_______________________________ 20 21 22 Signature: ______________________________ 23 24 25 16 1 ERRATA SHEET 2 3 Deposition of JORDAN AVERY SAMPLE 4 5 Page No.____Line No.____Change to:_________________ 6 7 Reason for change:_______________________________ 8 9 Page No.____Line No.____Change to:_________________ 10 11 Reason for change:_______________________________ 12 13 Page No.____Line No.____Change to:_________________ 14 15 Reason for change:_______________________________ 16 17 Page No.____Line No.____Change to:_________________ 18 19 Reason for change:_______________________________ 20 21 22 Signature: ______________________________ 23 24 25