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employees, assigned positions to them, handled things on the
assembly floor, took care of sick leave and other personnel
problems. If things were going wrong, then PPI would call
me in for assistance. Otherwise, PPI handled everything.
Respondent also relies on Cruz’ declaration, which is as
follows, in entirety:
1. I reside at Calle Leonor AV 21, 4th Extension,
Levittown Lakes, Puerto Rico 00949.
2. I was employed by Electronic Arts Puerto Rico for a
period of 3 � weeks in the summer of 1993.
3. I was hired about two weeks before the death of Mr.
Zamora as his assistant.
4. I never held the position of General Manager nor did I
ever carry out the duties of General Manager.
5. The focus of my work as assistant to Mr. Zamora was
with inventory control, particularly counting
inventory, communicating with Electronic Art [sic] in
California in regard to inventory needs, and I also had
some responsibilities with regard to shipping.
6. My employment was terminated 1 � weeks after Zamora
died.
Respondent further contends that “Absent first hand evidence
of the business practices prior to Cruz and Alvarado, Respondent
is entitled to the inference that the same business practices
were in effect while Zamora was employed at EARP [sic].”
As we have noted supra (in note 6, and in the description in
II. A. In General, of the affidavits and declarations that the
parties submitted), for purposes of the instant partial summary
judgment motion, we have treated the statements as to matters of
fact in the Alvarado declaration as though (1) they accurately
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