Free Motion for Sanctions - District Court of Arizona - Arizona

Exhibit 5

Case 2:02-cv-02157-SRB

Document 59-7

Filed 06/23/2006

Page 1 of 3

MAY

31

2006

1:28PM

RICHARDSON

& RICHARDSON

P

480

464

0602

p. 1

Mark

F. Brinton (SBA

7674)

Law Office ofMarkF. Brinton
1745 South Alma School Road, Suite 100 Mesa, AZ 85210-3010 (480) 756-2256 Counsel for Plaintiff

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF ARIZONA

Joyce Corrales,

Plaintiff,
VS.

CV 02 02157 PHX
-

- SRB

FIRST SUPPLEMENTAL DISCLOSURE STATEMENT

Chase Bankcard Services, Inc. Defendant

Plaintiff

Joyce COlTales hereby submits her First

Supplemental

Disclosw'e Statement as follows: Witnesses 1) Joyce COlTales will testify that a) Raquel Ledesma can verify Ms. Corrales's post-Chase Bank employment. Ms. Ledesma's telephone number is 480421-6400 at LakeShore Staffing, 6991 East Camelback Road, Scottsdale 85251 ; b) she lacks a copy of any unemployment compensation records, and although she has requested a copy of all such records, the Arizona Department of Economic Security has yet to produce them; c) she never made a copy of the letter she wrote to Chase,

Case 2:02-cv-02157-SRB

Document 59-7

Filed 06/23/2006

Page 2 of 3

MAY

31

2006

1:28PM

RICHARDSON

& RICHARDSON

P

480

464

0602

p.2

but because

he refers to it in his "affidavit,"

as does

Derek

Cheu,

it is apparent

that

Chase

Bank,

at least at one

time,

had

a copy

of the letter; d) regarding

her

three

therapy

sessions

with
them

Life Works,

Ms.

Corrales has requested the records and
time she will share them with

anticipates having Defendant.

before June

12, at which

Dated

this

~I~

day of May

2006,

Law

Office

of Mark

F. Brinton

B~V~
Mark F. Brinton
.

Counsel

for PlaintiffCOlTales

COpy of the foregoing sent via facsimile and U.S. Mail this
'3{!!day of May 2006 to:
Faith C. Klepper

2020 North Central Avenue, Suite 1110

Phoenix, AZ 85004 Counsel for Defe;?nt /

~r(~

2

Case 2:02-cv-02157-SRB

Document 59-7

Filed 06/23/2006

Page 3 of 3