Free Response in Opposition to Motion - District Court of Arizona - Arizona

V ~!q!qxtl

Case 2:02-cv-02157-SRB

Document 43-4

Filed 08/19/2005

Page 1 of 4

-- -. u-

. ..-...

'''0:

: C.-'-,

1 II Joyce A. Corrales

3318 West Sierra Vista Drive

2 3
4 5
6

II

Phoenix, AZ 85017- '443
Phone: (602) 595-3475 Plaintiff

II

Fax: (602) 8'64-3389
Pro Per

UNITED

STATES DISTRICT OF ARIZONA

COURT

DISTRICT

7 II Joyce A. Corrales,
8 9 10 11 12 13

NO. CV 02-2157-PHX-SRB PLAINTIFFS INITIAL DISCLOSURES

Plaintiff, vs.
Chase Bankcard Services Inc., a Delaware corporation, d.b.a. Chase Manhatfan Bank, N.A. Defendant.

14 II

Plaintiff Joyce A. Corrales (pro Per) provides to the Defendant her Initial

15 II Disclosures pursuant to Federal Rules of Civil Procedure, Rule 26(a)1 and the
16 17 Scheduling Order:

A. 1.

POTENTIAL

WITNESSES to testify as to all matters set forth in her

18 II

Joyce A. Corrales, Plaintiff,

19 II First Amended Complaint, these Initial Disclosures, and her prior deposition 20
II

taken by the Defendant on November 12, 2004.
2.

21 II 22 23 24
II

Brooke King, 4101 West Krall St., Phoenix, AZ 85019-1220, phone

(623) 486-3227, former employee of Defendant, to testify as to all matters set
forth in (1) First Amended Complaint paragraphs

II

5, 6, 8, and 11-14, and (2) the including her

II

pleadings

and
taken

discovery in King v. Chase Bank Card Services, Inc., U.S. case # CIV-02-1843-PHX-RGS,
10, 2003. on October

25 II District

Court for Arizona

26 II deposition 27 II
28 II forth

3.

Chase Bright, employee of Defendant, to testify as to all matters set

in (1) First Amended Complaint paragraphs

6-15, (2) his deposition given

Case 2:02-cv-02157-SRB

Document 43-4

Filed 08/19/2005

Page 2 of 4

0, -, - --

- -.

,- --,

,,-

--

u - --

-

1 2

in case of King v. Chase Bank Card, supra, (3) his training, education, and

experience in investigating

and preventing

employment discrimination

and

3 4 5

sexual harassment, and (4) other claims against the Defendant nature that he is aware of.

of a similar

4. James Rowlins, current or former employee of Defendant, to testify as to all matters set forth in (1) First Amended Complaint paragraph investigation into the allegations of sexual harassment Brooke King. 5. Amended policies Traci Mott, employee of Defendant, Complaint paragraphs and practices re sexual harassment to testify regarding education, reporting First and 5, and the

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

against him made by

2-7 and 12-13, and about the Defendant's

investigating. 6. Michelle Ransom, employee of Defendant, to testify as to same matters as Traci Mott, witness 5 supra. 7. Derek Cheu, Defendant's employee, to testify as to the matters set forth in the Defendant's Initial Disclosure Statement at page 2, lines 8-12, and about other similar claims and charges against the Defendant.

8.

Custodian Records, United States Equal Employment Opportunity

Commission, Suite 690, 3300 North Central Avenue, Phoenix, AZ 85012-2504, to provide and authenticate the EEOC file on Corrales' charge of discrimination against Defendant Chase BankCard Services, Inc. ("CBSI"), charge #350-Al1601.

9.

CBSI Treasurer,
financial

CFO or Custodian of Records: to provide and
and SEC filings of CBSI to show to punitive damages). to testify as to damages

24 IIauthenticate

records and statements

25 IIits net worth and recent net income (relevant 26 II
27 II witness

10.

Antonio Corrales,

husband

of the Plaintiff,

- see First

Amended Complaint paragraphs

10, 11 and 14.

28

IIII -2-

Case 2:02-cv-02157-SRB

Document 43-4

Filed 08/19/2005

Page 3 of 4

~, -, -- -,

- - -..

-- ---

-

~~-

,_nn,

n~'

~~OO

--~

~-

-

1 2

11. Shannon Warner, Defendant's supervisor, to testify as to the matters alleged in First Amended Complaint paragraphs 2, 3, 5, and 13-15, and 17.

3 4
5 6 7 8 9 10

12. Terri L. Storey, current or former employee of Defendant, to testify about prevalence and toleration of sexual harassment of women at Defendant's Tempe workplace, as alleged in her case reported as Storey v. Chase BankCard Services, Inc., 970 F. Supp. 722 (D. Ariz. 1997). 13. Martha G. Sanchez, former employee of Defendant, clo Mark F.

Brinton, Attorney at Law, Suite 100, 1745 South Alma School Road, Mesa, AZ 85210-3010, phone (480) 756-2256, to testify as to the same matters as Terri L.
Storey, witness #12 supra, and her allegations lawsuit against the Defendant, U.S. District in her own sexual harassment for Arizona Case # CV 04 Court

11 12 13 14
15 16
17 18 19 20 21
II

1269 PHX ROS. B. 1. 2. 3. 4. DOCUMENTS AND EXHIBITS

The EEOC file on Corrales' charge #350-AI-1601. The Court file, including deposition transcripts The Court file, including deposition transcripts The Court file, including deposition transcripts and the EEOC file, and the EEOC file, and the EEOC file,

in the case of Brooke King v. the Defendant, witness #2 supra. in the case of Terri L. Storey v. the Defendant, witness #12 supra. in the case of Martha G. Sanchez, witness #13 supra. 5. All documents previously provided by the Defendant in the Maricopa

22 IICounty Superior Court action between the Plaintiff and Defendant, case # CV 23 II2004-007776, including (A) documents Bates numbered DBSJC 0001 through Motion for

24 II0225, and (B) the exhibits and transcripts 25 IISummary 26 II
28 II IIII -3-

attached to the Defendants

Judgment

and the (later) Reply. transcript of the deposition of the Plaintiff the exhibits attached taken by the thereto.

6. The reporter's on November

27 IIDefendant

12, 2004 including

Case 2:02-cv-02157-SRB

Document 43-4

Filed 08/19/2005

Page 4 of 4