8:24-cv-00148•Spaan v. Wells Fargo & Company
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1 Kayla Hathcote From: Patrick M. Flood <PFlood@pheblaw.com> Sent: Tuesday, November 25, 2025 2:08 PM To: carson@ned.uscourts.gov Cc: Crowell, Bradley; Carroll, Tom; Sydney M. Grad Subject: Joel Spaan v. Wells Fargo; Case No. 8:24-cv-148 Follow Up Flag: Follow up Flag Status: Flagged CAUTION - EXTERNAL: Judge Carson: I represent the PlaintiƯ in the above-referenced case. The parties currently have a discovery dispute. The PlaintiƯ has requested available dates from Defendant’s counsel for the deposition of an employee of Defendant whose name is Sophia Garcia. Ms. Garcia was an employee in the “Employee Care” Division of Wells Fargo who had communications with the PlaintiƯ at the time he was considering signing a severance agreement and made certain representations to PlaintiƯ about what his Job ClassiƱcation Code was. Since severance was tied to a Job ClassiƱcation Code, Ms. Garcia’s representations had a direct impact on PlaintiƯ’s decision to accept the severance agreement oƯered to him or not. In a nutshell, Ms. Garcia told PlaintiƯ that Job ClassiƱcation Code was a “1” , but it turned out to be a “5”. There are at least two important emails which PlaintiƯ’s counsel who would like to question Ms. Garcia about, as well as a phone conversation which she had with PlaintiƯ concerning the topic of his job classiƱcation code. Defendant has Ʋatly objected to producing Ms. Garcia for a deposition, contending that her deposition is irrelevant or that the burden and expense of preparing and defending this deposition clearly outweigh the value of her testimony. PlaintiƯ contends that her testimony is important because she made certain admissions important to PlaintiƯ’s case. PlaintiƯ also wants to inquire what training Ms. Garcia had before Ʊelding calls and communications from inquiring employees (like from PlaintiƯ) and what instructions she was given by her superiors regarding employees’ job classiƱcation codes. PlaintiƯ believes its questioning of Ms. Garcia will be reasonably calculated to lead to the discovery of admissible evidence at trial. In terms of expense, we cannot imagine that a company like Wells Fargo would endure that much expense for preparing this witness for a deposition and attending the deposition. PlaintiƯ would be willing to take the deposition by zoom. Thank you, Pat Flood Patrick M. Flood Attorney Firm: 402.397.5500 8:24-cv-00148-JFB-RCC Doc # 42 Filed: 12/08/25 Page 1 of 2 - Page ID # <pageID>
2 Direct: 402-504-9446 Email: pƲood@pheblaw.com PANSING HOGAN ERNST & BUSER LLP | 10250 Regency Circle, Suite 300 |Omaha, NE 68114 __________________________________________________________________ This message and any attachments are conƱdential, may contain privileged information, and are intended solely for the recipient named above. If you are not the intended recipient, or a person responsible for delivery to the intended recipient, you are notiƱed that any review, distribution, dissemination or copying is prohibited. If you have received this email in error, you should notify the sender by return email and delete the message from your computer system. CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening attachments or clicking on links. 8:24-cv-00148-JFB-RCC Doc # 42 Filed: 12/08/25 Page 2 of 2 - Page ID # <pageID>
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