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  1  FICTIONAL SAMPLE. NOT A REAL CASE OR REAL PEOPLE.
  2  ALVAREZ v. NORTHGATE LOGISTICS (fictional)
  3  DEPOSITION OF DANA PRUITT
  4  BY MR. HALE:
  5  Q.   Ms. Pruitt, what was your job at Northgate in March 2025?
  6  A.   I was the day-shift supervisor for the east
  7  warehouse, docks 1 through 6.
  8  Q.   Were you working on March 14, 2025?
  9  A.   Yes. I worked the day shift, 6 a.m. to 2:30.
 10  Q.   Did Mr. Alvarez fall that day?
 11  A.   He did, at dock 4.
 12  Q.   What time did he fall?
 13  A.   Around 2:15 in the afternoon. It was right at
 14  the end of my shift, because I remember I was doing
 15  the handover paperwork.
 16  Q.   Before Mr. Alvarez fell, had anyone told you
 17  about a hydraulic leak at dock 4?
 18  A.   No. No one told me about any leak before the
 19  fall.
 20  Q.   Not Mr. Okafor?
 21  A.   No. Marcus never said anything to me about a
 22  leak that day.
 23  Q.   How do you handle a spill when it is reported?
 24  A.   We put cones out right away and call
 25  maintenance. That is the rule.
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  1  Q.   Were there cones at dock 4 on March 14?
  2  A.   Yes, there were cones at dock 4 that day. I
  3  saw them when I went over after he fell.
  4  Q.   Which forklift was working dock 4?
  5  A.   Unit 7. It was the only lift on that dock.
  6  Q.   Did Unit 7 have any maintenance problems that
  7  week?
  8  A.   I believe there was a ticket open on it, but I
  9  don't recall the number.
 10  Q.   Do you recall who opened the ticket?
 11  A.   I don't recall.
 12  MR. HALE: I'm handing you what has been marked as
 13  Exhibit 3.
 14  (Exhibit 3 marked for identification.)
 15  Q.   Do you recognize Exhibit 3?
 16  A.   Yes. That is the incident report I wrote.
 17  Q.   When did you write it?
 18  A.   The next morning, March 15.
 19  Q.   Your report says the floor was checked at the
 20  start of the shift. Who checked it?
 21  A.   I did the walk-through myself at 6 a.m. The
 22  floor was dry then.
 23  MS. REYES: Objection, form.
 24  Q.   You can answer.
 25  A.   The floor was dry at 6. I'm sure of that.
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  1  Q.   Did you take photographs of dock 4 after the
  2  fall?
  3  A.   No. Security has cameras there, but I did not
  4  take any photos.
  5  Q.   Did Mr. Alvarez say anything to you after he
  6  fell?
  7  A.   He said his back hurt and that he had slipped on
  8  something wet. I called the nurse.
  9  Q.   Did you see anything wet on the floor?
 10  A.   There was a small patch near the lift. Maybe a
 11  foot across.
 12  Q.   Was that hydraulic fluid?
 13  A.   I couldn't say. It looked like oil.
 14  MR. HALE: Nothing further.
