Free Motion for Sanctions - District Court of Arizona - Arizona

Exhibit 2

Case 2:02-cv-02157-SRB

Document 59-4

Filed 06/23/2006

Page 1 of 2

Ernest Calderon,

P.L.C.

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LAW OFFICES

2020 N. Central Avenue, Suite 1110 Phoenix, AZ 85004 Phone: 602-265-0004 . Toll Free: 866-605-4537 . Fax: 602-251-2978 Website: www.azlex.com

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March 29,2006

Mark F. Brinton Law Office of Mark F. Brinton 1745 South Alma School Road Suite 100 Mesa, Arizona 85210
" I

Re:

Corrales v. Chase Bankcard Services, Inc. CV-02-02157 -SRB

Dear Mr. Brinton: At the deposition of Plaintiff Joyce Corrales on October 14, 2005, your client agreed to disclose the following items: 1) the names and phone numbers of all persons/companies who can verify her employment status during the time period following her resignation ITomChase Bank [po 19-20, lines 23-25, 1-3], 2) Joyce Corrales' unemployment records since the date of her resignation ITomChase [po 21, lines 21-25], 3) a copy of the letter she wrote telling Chase Bright "that what me and my friend talked about in private was none of her business" [p.100, lines 9-13], and; 4) information/documentation on her alleged treatment ITom "LifeWorks" and related records regarding her alleged treatment for depression after her resignation ITomChase [po155]. We have not received any of this documentation to date, although it has been more than five months since those requests were made. Please forward this information to us by 5:00 p.m. on April 7, 2006. This request is made pursuant to Fed. R. Civ. Pro26(e)(I).

Respectfully, CALDERON LAW OFFICES

[ibd2
cc: Ernest Calderon, Esq.

Faith C. Klepper

C((JJ

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Case 2:02-cv-02157-SRB

Document 59-4

Filed 06/23/2006

Page 2 of 2