Free Uncategorized - District Court of Arizona - Arizona

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EXHIBIT C
1
Case 2:04-cv-00790-EHC Document 159-5 Filed 06/07/2006 Page 1 014

B One Renaissance Square Attorneys at Law in:
my Two North Central Avenue Phoenix and Tucson, Arizona
’ nr ·,Ar· 85004-251 zv a damn: ,r1oa1u
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Fax 602.229.5690 Milwaukee amlMuaHson, Wisconsin
www.quarles.com
Writer’s Direct Dial: 602.229.529l
E-Mail: [email protected]
November ll, 2005
VIA EMAIL AND REGULAR MAIL
Christopher Mason
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 Chris and Michelle:
I called you today asking for your client’s position regarding Ms. Johnson’s discovery
requests. As I explained, knowledge of your client’s position with regard to those requests could
expedite resolution of these issues. You said that you needed to talk to Chris about it and that he
would likely want to discuss it further. We do not understand why or what you need to discuss.
You and your client have had over two months to evaluate Ms. J ohnson’s discovery requests.
Indeed, we understood that you requested additional time to respond to Ms. J ohnson’s discovery
so that your client could locate and produce responsive information.
As you well know, the rules require your client to respond to interrogatories and
production requests to the extent that those requests are not objectionable. Our November 3,
2005, request for supplementation was made on that basis and we still have not received
responses to several of those requests. Additionally, to the extent privilege documents exist, we
ask that you provide a privilege log. We ask that your client provide the supplemental responses
no later than Tuesday November 15, 2005.
truly yours,
Dawn C. Valdivia
DCV:lmy
QBPHX\1 l5637.00002\l 862653.14
Case 2:04-cv-00790-EHC Document 159-5 Filed 06/07/2006 Page 2 of 4

EXHIBIT D
Case 2:04-cv-00790-EHC Document 159-5 Filed 06/O7/2006 Page 3 of 4

One Renaissance Square Attorneys at Law in:
S ' hz 0 Norqitpenulaisslihnilisai frhozmzznd Mm, mgm
oemx, mma a Bocak .I·`b da
gmc dngmp Tel 6022295200 6%, Illinozs mm M
Fax 6022295690 Milwaukee andMua'1Lson, Wisconsin
www.quarles.c0m
Writer’s Direct Dial: 602.229.529l
E-Mail: [email protected]
November 28, 2005
VIA EMAIL AND US MAHJ
Christopher Mason
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 Chris and Michelle:
In response to your letters dated November ll and 14, 2005, I did not flat out refuse to
engage in a meet in confer. I simply asked you and your client to comply with the Federal Rules
and provide us the information to the extent it is not objectionable. See Fed. R. Civ. P. 33(b)(1).
We are wasting time and you and your client are engaging in undue delay in this process. You
have known for over two months what information and documents we are seeking, but have still .
failed to provide us with any responsive information to several of our requests. When can we
expect the information you agreed to provide in your November 11, 2005, letter?
Very truly yours,
ES & BRADY STREICH LANG LLP
awn C. Valdivia
DCV:lmy
QBPI-D(\1l5637.00002\l862653.l6
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