On January 16, 2019 a
Exhibit,Appendix
was filed
involving a dispute between
Duckels Construction Inc,
and
Susan Cheryl Driggers,
for Fraud
in the District Court of Routt County.
Preview
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1 DISTRICT COURT, COUNTY OF ROUTT, STATE OF COLORADO
DATE FILED: June 29, 2020 1:44 PM
2 Case Number: 2019-CV-30008 FILING ID: CEDDCD2DD4779
CASE NUMBER: 2019CV30008
3 ---------------------------------------------------
4 VIDEOCONFERENCE DEPOSITION OF:
5 SUSAN CHERYL DRIGGERS - 05/22/2020
6 ---------------------------------------------------
7 Plaintiff:
8 DUCKELS CONSTRUCTION, INC., a Colorado corporation,
9 v.
10 Defendant:
11 SUSAN CHERYL DRIGGERS.
12 ---------------------------------------------------
13 The deposition of SUSAN CHERYL
14 DRIGGERS was taken by the Plaintiff on May 22, 2020
15 at Sharp, Sherman & Engle, LLC, 401 Lincoln Street,
16 in Steamboat Springs, Colorado, commencing at the
17 hour of 9:01 a.m., before ROSIE STAHL, Shorthand
18 Reporter and Notary Public within and for the State
19 of Colorado.
20
21
22
23
24
25
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1 the forms, and everyone was supposed to fill out
2 the forms and give them to me. That's the whole
3 purpose for having the forms. That's why they got
4 their packages. If they didn't fill out the forms,
5 the forms didn't get filled out.
6 Q What forms are you referring to
7 within the foreman package?
8 A There was all sorts of forms.
9 Disciplinary forms. There were raise forms. There
10 were -- anything that could happen on a job, there
11 was a form for it.
12 Q And from 2004 -- and the foreman did
13 that because the foreman supervised the employees
14 under them, right?
15 A Yes.
16 Q Who was your supervisor?
17 A Fred Duckels.
18 Q Was there anybody else who
19 supervised your work, other than Fred Duckels, from
20 2004 to 2018?
21 A No.
22 Q From 2010 to 2018, was there anybody
23 else who performed any accounting duties within the
24 office at Duckels?
25 A What dates?
35
1 Q I'm sorry. 2010, when you said you
2 took over and nobody else worked for you at the
3 office or you were the last person at the office,
4 until 2018, when you were terminated, was there
5 anybody else who performed any accounting duties in
6 the office at Duckels?
7 A Stacey Spector came in and did
8 payroll one day. Nicholle started in July of 2018,
9 and she worked in the office. Other than that, no.
10 Q To be clear, Ms. Spector came in for
11 one day, right? Not one day here and there, you
12 mean literally one time within that eight-year
13 period?
14 A Well, it actually was a day that I
15 was out sick, and she worked the next morning, when
16 I came back to work, as well. So for a day and a
17 half.
18 Q Okay.
19 A But that's it.
20 Q And that was specific to assist with
21 payroll, correct?
22 A Yes.
23 Q And other than that and until
24 Ms. Douglas was hired in July of 2018, nobody else
25 at Duckels worked on payroll except for you from
36
1 2010 to 2018, right?
2 A No.
3 Q Meaning my statement is incorrect or
4 nobody else worked on it?
5 A Nobody else worked on it.
6 Q And you were the person from 2010 to
7 2018 who handled payroll for everybody, including
8 yourself, right?
9 A Yes.
10 Q Do you have the paper printouts of
11 the various exhibits that we have sent with you?
12 A Yes.
13 Q I would like you to take out
14 Exhibit 13, please.
15 A Okay.
16 Q You've seen this before, correct?
17 A Yes.
18 Q And Exhibit 13 is the -- is a
19 complete copy of your employment file at
20 Duckels Construction, right?
21 MR. ENGLE: Object to form and
22 foundation.
23 THE DEPONENT: If that's what was in
24 it, that's the complete file that -- I mean, I
25 don't know that -- if that's what you gave copies
Preview
1 7 1 DISTRICT COURT, COUNTY OF ROUTT, STATE OF COLORADO DATE FILED: June 29, 2020 1:44 PM 2 Case Number: 2019-CV-30008 FILING ID: CEDDCD2DD4779 CASE NUMBER: 2019CV30008 3 --------------------------------------------------- 4 VIDEOCONFERENCE DEPOSITION OF: 5 SUSAN CHERYL DRIGGERS - 05/22/2020 6 --------------------------------------------------- 7 Plaintiff: 8 DUCKELS CONSTRUCTION, INC., a Colorado corporation, 9 v. 10 Defendant: 11 SUSAN CHERYL DRIGGERS. 12 --------------------------------------------------- 13 The deposition of SUSAN CHERYL 14 DRIGGERS was taken by the Plaintiff on May 22, 2020 15 at Sharp, Sherman & Engle, LLC, 401 Lincoln Street, 16 in Steamboat Springs, Colorado, commencing at the 17 hour of 9:01 a.m., before ROSIE STAHL, Shorthand 18 Reporter and Notary Public within and for the State 19 of Colorado. 20 21 22 23 24 25 34 1 the forms, and everyone was supposed to fill out 2 the forms and give them to me. That's the whole 3 purpose for having the forms. That's why they got 4 their packages. If they didn't fill out the forms, 5 the forms didn't get filled out. 6 Q What forms are you referring to 7 within the foreman package? 8 A There was all sorts of forms. 9 Disciplinary forms. There were raise forms. There 10 were -- anything that could happen on a job, there 11 was a form for it. 12 Q And from 2004 -- and the foreman did 13 that because the foreman supervised the employees 14 under them, right? 15 A Yes. 16 Q Who was your supervisor? 17 A Fred Duckels. 18 Q Was there anybody else who 19 supervised your work, other than Fred Duckels, from 20 2004 to 2018? 21 A No. 22 Q From 2010 to 2018, was there anybody 23 else who performed any accounting duties within the 24 office at Duckels? 25 A What dates? 35 1 Q I'm sorry. 2010, when you said you 2 took over and nobody else worked for you at the 3 office or you were the last person at the office, 4 until 2018, when you were terminated, was there 5 anybody else who performed any accounting duties in 6 the office at Duckels? 7 A Stacey Spector came in and did 8 payroll one day. Nicholle started in July of 2018, 9 and she worked in the office. Other than that, no. 10 Q To be clear, Ms. Spector came in for 11 one day, right? Not one day here and there, you 12 mean literally one time within that eight-year 13 period? 14 A Well, it actually was a day that I 15 was out sick, and she worked the next morning, when 16 I came back to work, as well. So for a day and a 17 half. 18 Q Okay. 19 A But that's it. 20 Q And that was specific to assist with 21 payroll, correct? 22 A Yes. 23 Q And other than that and until 24 Ms. Douglas was hired in July of 2018, nobody else 25 at Duckels worked on payroll except for you from 36 1 2010 to 2018, right? 2 A No. 3 Q Meaning my statement is incorrect or 4 nobody else worked on it? 5 A Nobody else worked on it. 6 Q And you were the person from 2010 to 7 2018 who handled payroll for everybody, including 8 yourself, right? 9 A Yes. 10 Q Do you have the paper printouts of 11 the various exhibits that we have sent with you? 12 A Yes. 13 Q I would like you to take out 14 Exhibit 13, please. 15 A Okay. 16 Q You've seen this before, correct? 17 A Yes. 18 Q And Exhibit 13 is the -- is a 19 complete copy of your employment file at 20 Duckels Construction, right? 21 MR. ENGLE: Object to form and 22 foundation. 23 THE DEPONENT: If that's what was in 24 it, that's the complete file that -- I mean, I 25 don't know that -- if that's what you gave copies