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Title Page
1 STATE OF NEW YORK

2 THOMAS JONES, )
)
3 Plaintiff, )
) Cause No. 1295-B
4 vs. )
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5 ABC CORPORATION, )
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6 Defendant. )

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DEPOSITION OF ASHLEY JONES
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(Pages 1 through 11)
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Taken on Wednesday, October 25, 2023,
15 at 2:50 p.m.

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25 Reported by: LARRY THOMAS

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Appearance
Page 1 Deposition of ASHLEY JONES, taken before LARRY

2 THOMAS, commencing at 2:50 p.m., Wednesday,

3 October 25, 2023 at 142 Main Street, Chicago, Illinois.

5 APPEARANCES OF COUNSEL:

7 For the Plaintiff:

8 SMITH & SMITH

Attorneys at Law
9 BY: RAY HADLEY
8592 First Street
10 Suite B
Chicago, IL 88005
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12 For the Defendant:

13 LANDRY & LANDRY

Attorneys at Law
14 BY: Andre Rogers
78776 Travis Street
15 Suite 1B
Austin, TX 79584
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Index and
Exhibits 1 I N D E X
Page
2 EXAMINATIONS PAGE

3 ASHLEY JONES
BY MR. HADLEY 5
4

6 E X H I B I T S

8 EXHIBIT NO. DESCRIPTION PAGE

9 1 Photograph of Accident scene 7

10 2 Insurance form 8

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First transcript
body page 1 Wednesday, October 25, 2023

2 2:50 p.m.

3 -oOo-
Parenthetical
14:50:35 4 (On the record at 2:50 p.m.)
Example
14:50:35 5 THE REPORTER: This is the discovery

14:50:46 6 deposition of Ashley Jones, taken pursuant notice and

14:50:52 7 the Illinois Rules of Civil Procedure.

14:50:55 8 At this time, would you raise your right

14:50:56 9 hand to be sworn?

14:50:59 10 Do you so swear or affirm that the testimony

14:51:02 11 you're about to give in this matter will be the truth

14:51:05 12 under penalty of perjury?

14:51:07 13 THE WITNESS: I do.

14:51:09 14 THE REPORTER: Thank you.

14:51:10 15 Will all parties present please state your

14:51:12 16 name and who you represent.

14:51:15 17 MR. HADLEY: Hello. My name is Ray Hadley

14:51:17 18 representing the plaintiff.

Example of
14:51:20 19 MR. ROGERS: Hi. I'm Andre Rogers
Colloquy
14:51:21 20 representing the witness, Ashley Springer, who is also

14:51:25 21 present.

14:51:29 22 THE REPORTER: Thank you. You may proceed.

23 ASHLEY JONES,

24 called as a witness, was examined and testified as

25 follows:
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1 EXAMINATION
Example of
a By Line 2 BY MR. HADLEY:

14:51:33 3 Q. Ms. Jones, do you understand that you are under

14:51:37 4 oath and that being under oath means you are sworn to

14:51:40 5 tell the truth?

14:51:41 6 A. Yes.

14:51:43 7 Q. Do you understand that your responses here have

14:51:46 8 the same force as in a courtroom with a judge and jury?

Example
14:51:50 9 A. Yes, I am aware.
of Q&A
14:51:52 10 Q. Okay. Are you prepared to answer my questions

14:51:54 11 today?

14:51:55 12 A. I believe so.

14:51:57 13 Q. Are you under the care of a doctor at this time?

14:51:57 14 A. I see Dr. Hasserman (phonetic) for allergies.

14:51:57 15 Q. And will you let me know if you don't understand

14:52:00 16 one of my questions?

14:52:02 17 A. Yes.

14:52:04 18 Q. Okay. Ms. Jones, please state your name and

14:52:07 19 spell it for the record?

14:52:09 20 A. Ashley Jones, A-S-H-L-E-Y, J-O-N-E-S.

14:52:21 21 Q. Thank you. And can you please provide your

14:52:22 22 residential address?

14:52:24 23 A. Yes. That is 2626 North Main Road, Downers

14:52:30 24 Grove, Illinois 60515.

14:52:37 25 Q. Now, Ms. Jones, do you own a business?

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14:52:39 1 A. Yes.

14:52:41 2 Q. And have you ever given a deposition before?

14:52:43 3 A. I have.

14:52:45 4 Q. So, we're here today to find out more information

14:52:47 5 about breach of contract; is that correct?

Speaker names
14:52:51 6 MR. ROGERS: Objection. Alleged breach of
in ALL CAPS
14:52:52 7 contract.

14:52:54 8 You may answer.

14:52:58 9 THE WITNESS: Yes, for the breach of

14:52:58 10 contract, allegedly.

14:53:01 11 BY MR. HADLEY:

14:53:01 12 Q. Okay. What is the name of your company?

14:53:04 13 A. It's called My Corp.

14:53:07 14 Q. What state is your company based in?

14:53:10 15 A. Illinois, the state that I live in.

14:53:14 16 Q. And is your residential address the same as your

14:53:16 17 business address?

14:53:17 18 A. No, it is not.

14:53:19 19 Q. All right. Do you have a Web address?

14:53:19 20 A. Yes. [Link].

Dashes for false starts
14:53:22 21 Q. And have you -- you received a breach of contract
and interruptions
14:53:24 22 notice in the past 90 days, correct?

14:53:26 23 A. Yes.

14:53:30 24 Q. And has your attorney walked you through standard

14:53:33 25 pretrial procedures?

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14:53:35 1 A. Yes. My mom was present with me.

14:53:39 2 Q. Your mom was present when your attorney went over

14:53:39 3 the procedures?

Spelling for
14:53:39 4 A. Uh-huh.
affirmative slang
14:53:39 5 Q. Are you currently under contract with a company

14:53:41 6 called Merchandise Creations, Inc.?

14:53:44 7 A. Yes.

14:53:48 8 Q. Do you understand why you have been sent a breach

14:53:51 9 of contract notice?

14:53:54 10 A. Not entirely.

Spell out numbers from
14:53:57 11 Q. Okay. Let's change gears. Give me just one
one to ten in text
14:54:02 12 moment to upload a couple of exhibits.

14:54:10 13 Now I'm going to share and stamp a document,

14:54:15 14 marking it as Exhibit 1.

14:54:15 15 (Exhibit No. 1 marked for identification.)

By Line16
14:54:15 BY MR. HADLEY:

14:54:18 17 Q. Have you seen the document that I'm introducing

14:54:21 18 as Exhibit 1 before?

14:54:23 19 A. Yes, I have.

14:54:25 20 Q. All right. I'll direct your attention to page 3,

14:54:32 21 and I'm going to highlight a couple specific sections.

14:54:32 22 A. Okay.

14:54:38 23 Q. Please let me know once you've read through

14:54:40 24 Section 4, the "use of depositions at trial."

14:54:47 25 A. Okay. I have read through it.

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14:54:49 1 Q. You were familiar with that section before

14:54:52 2 today's deposition; is that correct?

14:54:53 3 A. Yes. My attorney showed it to me.

14:54:57 4 Q. Thank you. I don't have any further questions

14:54:59 5 about that exhibit.

14:55:02 6 Let me share Exhibit 2, for the record.

Parenthetical
14:55:02 7 (Exhibit No. 2 marked for identification.)
Example
14:55:02 8 BY MR. HADLEY:

14:55:12 9 Q. Please let us know once you have read through --

14:55:12 10 A. Okay.

14:55:14 11 Q. -- this document in its entirety.

14:55:20 12 A. I've read it.

14:55:23 13 Q. Is this the letter you previously received in the

14:55:28 14 past 90 days?

14:55:28 15 A. Yes, it is.

14:55:30 16 Q. And is this the only breach of contract letter

14:55:33 17 you have received in the past 90 days?

14:55:36 18 A. No, it is not.

14:55:43 19 Q. Okay. Do you understand the contents of this

14:55:47 20 letter?

14:55:50 21 A. For the most part, yes.

14:55:54 22 Q. I have no further questions about this exhibit.

14:56:07 23 Ms. Jones, does your company have articles of

14:56:09 24 incorporation?

14:56:11 25 A. Yes, it does.

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14:56:15 1 Q. I'm going to direct your page -- strike that.

14:56:17 2 I'm going to direct you to page 10 of Exhibit 1.

Use "okay" as
depicted
14:56:17 3
here, A. Okay.
never "OK"4
14:56:19 Q. And please let me know if you're familiar with

14:56:28 5 the underlined Article 10 indemnification clause.

14:56:34 6 A. Yes, I am.

14:56:36 7 Q. Okay. And could you read the first sentence that

14:56:43 8 I have highlighted?

14:56:46 9 A. Yeah. "A director of this corporation shall not

14:56:49 10 be personally liable to the corporation or its

14:56:52 11 shareholders for monetary damages for conduct as

14:56:57 12 director."

14:56:59 13 Q. Thank you. And are you listed as a director for

14:57:03 14 this corporation?

14:57:04 15 A. Yes, I am.

14:57:07 16 Q. Is it your understanding that this indemnifies

14:57:09 17 you from lawsuits?

14:57:11 18 A. That's correct.

14:57:12 19 MR. ROGERS: Okay. We're taking a break.

14:57:16 20 MR. HADLEY: Agreed. I have no further

14:57:17 21 questions, so we can end this proceeding.

14:57:22 22 THE REPORTER: We are off the record.

23 (The proceeding concluded at 2:57 p.m.)

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Errata Page
1 NAME OF CASE: THOMAS JONES vs. ABC CORPORATION

2 DATE OF DEPOSITION: October 25, 2023

3 DEPONENT: ASHLEY JONES

4 1. To clarify the record.

2. To conform to the facts.
5 3. To correct transcription error.

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20 SIGNATURE:_______________________DATE:___________
ASHLEY JONES
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Reporter's
Certificate 1 REPORTER'S CERTIFICATE
Page
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3 The undersigned does hereby certify:

4 That the foregoing deposition of ASHLEY JONES was

5 taken before me at the time and place therein set forth

6 at which time the witness was duly sworn by me;

7 That the testimony of the witness and all objections

8 made at the time of the examination were recorded

9 stenographically by me and were thereafter transcribed,

10 said transcript being a true copy of my shorthand notes

11 thereof.

12 That the dismantling of the original transcript will

13 void the reporter's certificate.

14 I further declare that I have no interest in the

15 outcome of the action.

16 In witness whereof, I have subscribed my name this

17 26th day of October, 2023.

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___________________________________
21 LARRY THOMAS

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