Free Reply - District Court of Arizona - Arizona

EXHIBIT A
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Case 2:03-cv-02262-ROS Document 212-2 Filed 12/29/2005 Page 1 of 3

1
2 STATE OF CALIFORNIA
§ ss. AFFIDAVIT OF SHARON FONG
3 COUNTY OF SAN FRANCISCO
4
Before me this date appeared Sharon Fong, known to me to be over the age of
2 2l and upon her oath deposes and says:
7 1. My name is Sharon Fong. I have personal knowledge of the
8 facts stated herein and ain competent to testify to them.
9 2. In January 2002 and since that time I have been empioyed as a
10 paraiegai in the iegai department of the Bank of America
2; iocated in San Francisco, California. Among others I provide
13 support to Jay Price.
14 3. In that capacity and at the direction of Mr. Price, I obtained
I5 information from Paul, Hastings, Janofsky and Walker
I6 consisting of an advice letter from Linda Edwards The
17 information was provided to me on January 7, 2002 by fax
18 from Deborah Weiser, an attorney with Paul Hastings.
éi I Included with the advice letter was four pages of notes taken
21 by Barbra Davis in May of 2000 during the course of a
22 conversation, which I am told took place and therefore believe
23 took place, invoiving Lloyd Aubry, Jay Price, Linda Edwards
24 and Ms, Davis. Those notes have remained in the files of the
25 Bank of America legai department and under my possession
26
sense.:
sezatee-ev-02262-Ros Document 212-2 Filed 12/29/2005 Page 2 of 3

{ and control since that date. I made copies of the advice letter
2 and those notes and caused them to be delivered to Charles Li
3 Chester at Ryley Carlock and Applewhite to assist him in
4 defending Bank of America in Hutton v, Bari/c of America. I
2 have reviewed my notes and based upon that review, am
7 confident that I did not deliver the notes to any other person
g with the possible exception of delivering the notes and the
9 advice letter to Davis Wright Tremain LLP in Seattle,
10 Washington for use by its attorneys in the defense of Luciano
11 v,. Bank of America. The Lucfcmo case was a case which I
ii supported as I do the Hutton case. The Luciano case involved
14 allegations of misclassiiication of Client Managers in the state
15 . of Washington in violation o the federal wage and hour laws.
16
17 Share Fong p
ig Subscribed and sworn to before ine this 22nd day of December, 2005.
19
20 l `
21 Netérygibiic
22
23 My commission expires: .,9../57/‘;.»,(;J‘3’
24
25 r ' i i 1
gs § "~¤r¤~ PUb1lC—C¤I!feinr¤ g
_ Son Francisco County
or ‘a`a yyc j
assess:
s°e2·2%‘i93—cv-02262-ROS Document 212-2 Filed 12/29/2005 Page 3 of 3

Case 2:03-cv-02262-ROS

Document 212-2

Filed 12/29/2005

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Case 2:03-cv-02262-ROS

Document 212-2

Filed 12/29/2005

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Case 2:03-cv-02262-ROS

Document 212-2

Filed 12/29/2005

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