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contention as to EAPR’s control over the manufacturing process is
not a genuine issue as to a material fact.
iii. Supervision Over Lease Employees
Respondent contends as follows:
1. There is a factual dispute as to whether the one EAPR
employee (i.e., Willie Zamora, Jose Cruz, or Miguel
Orlando Alvarado) supervised or controlled the PPI
employees who manufactured the video games or the EA
employees who performed all of EAPR’s daily operations.
Respondent relies primarily on Alvarado’s declaration, which
respondent offered in support of respondent’s opposition to
petitioners’ motion. Alvarado’s declaration indicates that he
was EAPR’s manager for most of the period before the Court.
Alvarado’s declaration states that
(1) he oversaw the transferring of raw materials, work
in process, and finished goods, and in this capacity he “had
two or three PPI employees under me in the materials
management function”; and
(2) he--
also oversaw the PPI employees who worked on inventory
control, which meant that I had to make sure that they were
doing the cycle counts and that they entering [sic] the
correct data onto paper inventory reports. I was
responsible for entering the data into the computer. I
oversaw that the correct data was entered into the computer
for [MRP System] on the Puerto Rican end. * * *
In general I did not deal directly with assembly line
operation, since this was handled by PPI. However, if I saw
a mistake being made, then I would see that it got
corrected. My basic function in regard to the assembly work
was to watch out for EA’s interests. However, PPI handled
the daily production requirements and PPI scheduled the
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