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  1  FICTIONAL SAMPLE. NOT A REAL CASE OR REAL PEOPLE.
  2  ALVAREZ v. NORTHGATE LOGISTICS (fictional)
  3  DEPOSITION OF MARCUS OKAFOR
  4  BY MR. HALE:
  5  Q.   Mr. Okafor, what was your job in March 2025?
  6  A.   Forklift operator, east warehouse, day shift.
  7  Q.   Which forklift did you drive on March 14, 2025?
  8  A.   Unit 7, on dock 4.
  9  Q.   Did you notice anything wrong with Unit 7 that
 10  morning?
 11  A.   Yes. It was dripping fluid from under the mast.
 12  Hydraulic fluid, I think.
 13  Q.   What did you do about it?
 14  A.   I told Dana about the drip at dock 4 that
 15  morning, around 9. I told her in person by the
 16  time clock.
 17  Q.   What did Ms. Pruitt say?
 18  A.   She said she would call maintenance.
 19  Q.   Did anyone put cones out at dock 4?
 20  A.   There were no cones out there. None. I would
 21  have seen them, I was on that dock all day.
 22  Q.   Did you see Mr. Alvarez fall?
 23  A.   Yes. I was maybe twenty feet away.
 24  Q.   What time was that?
 25  A.   It was before lunch, maybe 11:30. I know because
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  1  I went to lunch right after they took him to the
  2  nurse.
  3  Q.   Where did he fall?
  4  A.   Right by the lift, at dock 4, where the drip
  5  was.
  6  Q.   How big was the wet area?
  7  A.   Bigger than a foot. Maybe three feet long. It
  8  had spread under the pallets.
  9  MS. REYES: Objection, form.
 10  Q.   You can answer.
 11  A.   It was about three feet.
 12  Q.   Was there a maintenance ticket on Unit 7?
 13  A.   I don't know. I never saw a ticket.
 14  Q.   Had Unit 7 leaked before that week?
 15  A.   Once, maybe a month earlier. They fixed it.
 16  Q.   Did you see anyone check the floor at the start
 17  of the shift?
 18  A.   I saw Dana walking the docks around 6. That is
 19  normal.
 20  Q.   Did you speak with Mr. Alvarez after he fell?
 21  A.   He said he slipped on the oil. He was holding his
 22  back.
 23  Q.   I'm showing you Exhibit 3, the incident report.
 24  Have you seen it before?
 25  A.   No. This is the first time.
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  1  Q.   Were you ever interviewed about the fall?
  2  A.   No one from the company asked me about it.
  3  MR. HALE: Nothing further.
