Free Motion for Sanctions - District Court of Arizona - Arizona

CERTIFICATION OF FAITH C. KLEPPER I, Faith C. Klepper, am the attorney for Defendant Chase Bankcard Services, Inc. in the civil action known as Joyce A. Corrales v. Chase Bankcard Services, CIV 02-2157-PHX-SRB and certify as follows:

1. I have in good faith conferred or attempted to confer with the party not making the disclosure in an effort to secure the disclosure without court action. That effort was made orally at Plaintiff's deposition (with counsel present) in October 2005 and again in writing in March 2006 by letter to Plaintiff's attorney.

2. The first substantive response to the request for disclosure was not made until after the discovery deadline on May 31, 2006 and was incomplete.

3. I informed Plaintiff's counsel after reviewing the incomplete disclosure that we would seek redress for the late disclosure. I have received no further disclosure or response from Plaintiff since May 31.

DATED this 23rd day of June, 2006. CALDERÓN LAW OFFICES

____s/Faith C. Klepper______________________ Faith C. Klepper 2020 North Central Avenue, Suite 1110 Phoenix, Arizona 85003 Attorney for Chase Bankcard Services, Inc.

Case 2:02-cv-02157-SRB

Document 59-2

Filed 06/23/2006

Page 1 of 1