Free Motion for Sanctions - District Court of Arizona - Arizona

Exhibit 4

Case 2:02-cv-02157-SRB

Document 59-6

Filed 06/23/2006

Page 1 of 2

MAY

31

2006

11:14AM

RICHARDSON

& RICHARDSON

P

480

464

0602

p. 1

LAW

OFFICE OF

MARK

F. BRI

NTON

.

ATTORNEY

AT LAW

MARK

F.

BRINTON

Telephone (480) 756-2256

Facsimile (480) 464-0602

,

,

1745 South Alma School Road Suite 100 Mesa, AZ 85210-3010

31 May 2006 Faith
C. Klepper Calderon Law Offices

2020 North Central Avenue, Suite 110 Phoenix, AZ 85004
Re: Corrales v. Chase Bankcard Services, Inc. CIV 02-2157 PHX SRB

Dear Faith:
I would much appreciate your stipulating today that Plaintiff may have an extension of 21 days to file her response to your client's Motion for Summary Judgment. I've been occupied with preparing an opening brief in ail appeal to the Ninth Circuit Court of Appeals, and will be in Michican and Washington starting early tomorrow morning until Monday afternoon, June 5, and would appreciate this additional time. As I was considering this need to request your stipulation, I realized that I owe you responses to several discovery questions. Therefore, I will work on those now and expect to get them to you before 1:00 pm. In the meantime, please consider this request for stipulation.

-n:;;::~~
Mark F. Brinton MFB:ms
Case 2:02-cv-02157-SRB Document 59-6 Filed 06/23/2006 Page 2 of 2