Free Uncategorized - District Court of Arizona - Arizona

EXHIBIT A
Case 2:04-cv-00790-EHC Document 161-2 Filed 06/19/2006 Page1 012

One Renaissance Square Attorneys at Law in:
_ Two North Central Avenue Phoenix and Tucson, Arizona
ni yn 8500421 Nksnd . ·
6'M/rleew it rr
Fax 6022295690 Milwaukee undMad11s0n, Wisconsin
www.quarles.com
Writer’s Direct Dial: 602.229.5i29l
E-Mail: [email protected]
December 1, 2005
VIA EMAIL AND US MAIL
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:
I agree to a conference call at 2 p.m. on Friday, I will call your office at that time.
I am going to ignore your comments regarding Ms. J o1mson's deposition given that you
have still not provided us with a date for the 30(b)(6) and you waited until the last minute to
obj ect to that deposition. We are not required to wait for the court's ruling on your motion.
Please provide dates for the necessary individuals so that we may schedule that deposition. If the
Court denies your motion, we can schedule additional depositions if necessary. This case has
been delayed long enough. Please also provide us with dates to depose the following
individuals: Tammy Kornegay-Hodges, Cheri Melle, and Joel Price.
I have spoken with Ms. J olmson and will provide you dates for her deposition tomorrow
during our call. As I previously stated, Lonnie and I are in trial in January. The court is_ ruling
on our motion for summary judgment tomorrow. That ruling will have a significant impact on
our availability in December and January and I will be able to provide firmer dates tomorrow
aftemoon after the court’s ruling.
Very truly yours,
QUARLES & BRADY STREICH LANG LLP
C-
Dawn C. Valdivia
DCV:l
QBPHX\Iiii,637.00002\1974693.1
Case 2:04-cv-00790-EHC Document 161 -2 Filed 06/19/2006 Page 2 of 2

Case 2:04-cv-00790-EHC

Document 161-2

Filed 06/19/2006

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Case 2:04-cv-00790-EHC

Document 161-2

Filed 06/19/2006

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