Free Motion for Sanctions - District Court of Arizona - Arizona

Exhibit 1

Case 2:02-cv-02157-SRB

Document 59-3

Filed 06/23/2006

Page 1 of 3

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DEPOSITION OF JOYCE ANN CORRALES

- 10/14/05
OF ;;oYCE "'~"N CORRi'.LES, 20C>5, at the Caldero"

IN THE mUTED ST!,TES DISTRICT COURT DISTRICT OF AHlZONA L

DEPOSITION

taloen
La".

at

10: 16 a.m.
2020 Ari~ona Reporter

0" October 1.4,
Cent.ral before the State

Offices,

North 85004, for

Avenue,

Suite 1110,
ALLEN, EPR,

JOYCE !L CORRALES, Plaintiff, Ne>. CV-02-02157-SRB

Phoni:<,

,-'ACQUELYN A. of Arizona.

5
6

Certified

-vsCHASE BA!i:-
8

;,PPEAAANCES: For the.. Plaintiff: LAW OFFICES OF ~gJL~ F. BRI~70N By: V~rk F. Brinton, Esq. 1745 S. Alma School Road, Suite Mesa, Ari=ona 85210-3010

Defendant.

9 10 11 12 13

H-I00

For the Defendant Cbase BankCard Servic"s, Inc.: CALDERONLAWOFFICES ~ I By: Faith C. Klepper, Esq. 2020 North Central Avenue, Suite 1110
Phoeni~, Arizona 85004

DEPOSITION OF JOYCE ANN CORRALES

14
Phoenix, Arizona

October 14, 2005
10: 16 a.m.

15 16 17
18 19 20

.!U.SO PRESENT:

Roger McKee, paralegal

REPORTED BY: Jacquelyn A. Allen, RPR AZ Certified Reporter No.

21 50151 22

23 24 25

2

INDEX 2
EXAMINATION

JOYCE 1'.NN CORRALES,

BY

PAGE

2 3

called as a wit"ess herein, having been first duly sworn, was examined and testified as follows:

--.......................... MS. KLEPPER MR.BRINTON -. . . . . -. . . . .. . ... . . . .. . -.. .. .. .
5

214
222

HS. KLEPPER... - . . . . . . . - - . . . . . . . . . . . . . . . . . - . . . . . . . ..

5 6
7 BY MS. KLEPPER:

EXAMINATION

EXHIBITS One-page

Q. please.

Could you state your full name for the record,

DESCRI PTI ON

PAGE

IDE.\'ITIFIED

8 docU!!lent, document, letter dated

March 23, 103
7, 9

2001,titled"Resignation otice" N 10 11 12 13
14 15 16 17 18 19 20 21 22 23 24 25 6

A.
Q.

Joyce A. Corrales.
.Zilld what

2

Two-page

O'Donnell

letterdated April 2001, to John J. Farrelland Larry document

10 109 11 12 13

does the "A" stand for?

.r,.. Ann. Q. How de you spell that?

3

Bates No. CBSOOO098 .'
Two-page document Bates Nos. CBSOO0100 and 101

One-page

. . . .. . . . ... - .. 124
133

A.

A-n-n.

14 15

Four-page document headed "Employment Application" Bates Nos. CESOOOI05 through 108 "'.""'" One-page document headed "Record Absence" Bates No. CBSOOOl16 ""'''.'''''''''''''''' Of

Q. How long have you lived in the Valley? 1'.. Since grade school.
Q. A. Q. A. Can you reme~ber what grade? Probably 1st. Where were you born? In Te:-:as. Where in Texas? Memphis. Where is Memphis, Texas? Memphi~ i~ towa~d the ?anhandle.

188

16 '"'

190

18 19 20
~" 22

Q.
A. Q.

23 24 25

A.
Q.

You are married now currently; is that correct?

.r,.. Yes.

Case 2:02-cv-02157-SRB

Driver and Nix 602-266-6525 Document 59-3 Filed 06/23/2006

Page 2 of 3

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DEPOSITION OF JOYCE ANN CORRALES
17

-

10/14/05

1 2 3

Q. A. Q. A.

On a weekly basis? Yes. And what would your dealings be with her? Meetings, group meetings, things like that. What did you do in the group meetings? Just talk about the direction of our team, our

1 2 3

A.

I really don't remember the first job that I I just remember that I started

had after I left Chase.

working through various agencies after I left Chase. Q. Do you have any records of your employment

5 6

Q. A.

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

since you left Chase? A. Q. A. Q. A. Of my employment? Yes. I qpn't have them with me. Do you have them? No.

7 8 9 10 11

goals, things like that. Q. A. What were your goals? Our goals in the retention unit and how we were

doing as a group. Q. A. Q. A. What were your goals? My specific goals for me? Yes. My specific goals for me was to do a good job.

Q. You don't have any record of employment since
you left Chase? A. I don't understand. What do ~qu mean by "do,

~ ~

12 13 14 15 16 17 18 19 20 21 22 23 24 25

you have a record"? Q. A. Q. Do you have pay stubs? No, I don't have any of those. Do you have any letters of employment, letters

Q. Well, what were the goals that were outlined in
this meeting for you to achieve?

A. 1 didn't have goals specifically outlined for
me in the meeting to achieve. The goals in the meetings were to achieve as a team.

offering you employment? A. Q. No, I don't have any of those. Do you have any names or phone numbers of

Q. And what were those goals that you had to
achieve as a team?

people we can contact to verify your employment since you left Chase? A. Q. A. Yes, I have that. Do you have that with you today? No, I don't have it with me today. 20

A. Has to do with the job.
Q. A. That's it? Yes.

Q. You had meetings telling you that your goal was
18

1 2 3

to do a good job?

1 2 3

Q. A. Q.

Can you give that to us later on? Yes, I can do that. So where was the first place that are these

A.

(No verbal response.)

Q. 1 need you to answer out loud, please. A. Yes.
Q. A. Q. Was there anything more specific ever said? I don't remember. Were there any particular numbers given to how

temporary places that you worked at after you left
5

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Chase? A. Peak Staffing was one, because I was signed up

7 8

with them for

--

since that time, but after I left

many customers you needed to retain? A. I don't remember that.

Chase, I went back working for them. And then when Peak went out of business, I went

Q. What was the objective of your work?
A. Q. Was to retain customers. And to your knowledge, you don't remember ever

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

and worked with a company called Lakeshore. Q. A. Q. When did Peak go out of business? I believe in 2004. So at what point did you go back to Peak after

being told that you needed to retain more customers? A. No.

you left Chase? A. Q. A. After I left Chase, I contacted Peak. When? Right after I left Chase, looking for work.

Q. After you left Chase, where did you work next? A. I worked for different agencies, employment
agencies.

Q. Which employment agency did you first work at?
A. One was Peak Staffing.

Q. When did you begin working at Peak Staffing?
A. It was either '98 or '99 is when I began working with Peak Staffing. Q. okay? No, I'm talking about after you left Chase,

Q. How soon after that? A. I don't understand the question. Li ke .Q. on what date did you contact Peak Staffing
to -/\,

I Qon't nave

an exact date.

It was after I

left Chase. Q. Do you have a month or a year?

What was the first jOb that you had after you

left Chase?

A. Probably within the same month.

Case 2:02-cv-02157-SRB

Driver and Nix Document 59-3 602-266-6525 Filed 06/23/2006

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