Free Uncategorized - District Court of Arizona - Arizona

EXHIBITS
Exhibit A Letter from Michelle Ganz to Dawn C. Valdivia dated October 5, 2005
Exhibit B Letter Hom Dawn C. Valdivia to Michelle Ganz dated October 5, 2005
Exhibit C Schwab’s Response to Non-Uniform Interrogatory No. 9
Case 2:04-cv—OO790—EHC Document 65-2 Filed 12/O2/2005 Page 1 of 4 i

OGLETREE, DEAKINS, NASH,
0 SMOAK & STEWART, HC.
East CZ.H`IClbHCk Road
O sum soo
Phoenix, Arizona 85016
M..__ Telephone: 602.778.3700
m°*‘NEYSA“·*W racsimue; 6o2.77s.s7so
www.ogletreedeakins.com
Michelle I-l. Ganz
Direct: (602) 778-3708
[email protected]
VIA FACSIMILE and U.S. MAIL
October 5, 2005
Dawn C. Valdivia, Esq.
Quarles Brady Streich Lang, LLP
One Renaissance Square
Two North Central Avenue
Phoenix, AZ 85004
Re: Charles Schwab Corporation adv. Marcella Johnson .
Dear Ms. Valdivia:
As we discussed earlier today, we would appreciate a two-week extension of time. in which to
respond to Plaintiffs First Set of Requests for Production and `First Set of Non-Unifonn
lnterrogatories. The requests are voluminous and seek a broad range of information. The
current response deadline for both sets is Monday, October 10, 2005. The new deadline that we
propose is October 24, 2005. Please let me know right away whether you will be willing to
stipulate to an extension or whether we will need to file an expedited motion tomorrow.
Thank you in advance for your courtesy. n
V e yours,
ff { '
- M1chelle H. Ganz
MHG:mlb

Atlanta, GA · Austin, TX · Birmingham, AL · Charleston, SC - Charlotte, NC - Chicago, IL · Columbia, SC - Dallas, TX ~ Greensboro, NC · Greenville, SC ¤ Houston, TX · Indianapolis, IN
Kansas Cityg MO · Los Angeles, CA · Miami, FL - Morristown, N] · Nashville, TN · Phoenix, AZ ·· Raleigh, NC · St. 'I`homas,Vl · San Antonio, TX · Tampa, FL ¤ Torrance, CA · Washington, DC
Case 2:04-cv—OO790—EHC Document 65-2 Filed 12/O2/2005 Page 2 of 4

Writer’s Direct Dial: 602.229.529l
E-Mail: [email protected]
October 5, 2005
VIA EMAIL
Michelle H. Ganz
Ogletree, Deakins, Nash,
Smoak & Stewart, P.C.
2415 E. Camelback Road
Suite 800
Phoenix, AZ 85016
RE: Johnson v. Charles Schwab Corporation
Dear Michelle:
We are not inclined to grant your client’s request for a two-week extension of time to
respond to Ms. J ohnson’s discovery requests because we need to review those responses prior to
the deposition that is scheduled for October ll, 2005. Because your client’s request for an
extension is based the premise that the discovery requests are "voluminous and seek a broad
V range of information," it is our understanding that your client needs more time to gather and
produce responses and documents to Ms. Johnson’s discovery. Thus, we will agree to grant the
extension if your client agrees that it is going to produce the requested information and
documents or agrees to tell us what it will produce.
Very truly yours,
· QUARLES & BRADY STREICH LANG
S/DCV
Dawn C. Valdivia
DCV:lmy
QBPI-D(\l l5637.00002\l862653.l0
Case 2:04-cv—OO790—EHC Document 65-2 Filed 12/O2/2005 Page 3 of 4

1 lead to the discovery of admissible evidence; (4) the interrogatory is vague and
2 ambiguous because it contains various terms, including "regarding his or her
3 employment;" which are undefmed; (5) the interrogatory seeks the disclosure of
4 information that would invade the privacy rights of third parties; and (6) the interrogatory
5 seeks information that is confidential. Defendant is willing to meet and confer about the
6 appropriate scope of evidence concerning other "me too" claims. Defendant’s counsel
7 has unsuccessfully attempted to initiate a dialogue on this several times and is now
8 waiting to hear back from Plaintiffs counsel
9 INTERROGATORY N0. 9:
10 Identify each type of benefit to which Plaintiff would have been entitled from the
11 date of her termination to the present if Plaintiff had not been terminated and she had
_ g 12 remained in the same job position. For each type of benefit, state the amount Schwab
° 13 would have paid to provide the benefit for Plaintiff during this time period and the value
§ E °§ § 14 of the benefit to Plaintiff
E; 15 RESPONSE TO INTERROGATORY NO. 9:
gg 16 Defendant objects to this interrogatory on the following bases: (1) the
g 17 interrogatory asks Defendant to speculate to facts that may or may not have occurred in
18 the future and therefore is vague and ambiguous; (2) the interrogatory is overbroad as to
19 scope to the extent that it seeks documents based on speculative and uncertain facts or
20 future occurrences; (3) the interrogatory seeks information that is not reasonably
21 calculated to lead to the discovery of admissible evidence; and (4) the interrogatory seeks
22 information that is in the possession, custody or control of Plaintiff, to the extent that it
23 seeks information related to benefits Plaintiff received while employed with Schwab.
24 Subject to and without waiving these objections, Schwab responds as follows:
25 Defendant hereby incorporates documents identified as Bates Nos. Schwab 02715-02763
26 into this response pursuant to Rule 33(d) of the Federal Rules of Civil Procedure.
27 ///
28 ///
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