Kardonick v. JP Morgan Chase & Co. et al

Filing 464

REPLY to Response to Motion re 456 Defendant's MOTION for Order to Show Cause and Supporting Memorandum of Law filed by Chase Bank USA, N.A.. (Attachments: # 1 Exhibit Declaration of R. Wick, # 2 Exhibit Responses & Objections to Request for Production, # 3 Exhibit Responses & Objections to Interrogatories, # 4 Exhibit Correspondence to counsel, # 5 Exhibit Correspondence to counsel, # 6 Exhibit E-mail between counsel, # 7 Exhibit Transcript of hearing)(Campbell, Dennis)

IN THE CIRCUIT COURT OF MASON COUNTY, WEST VIRGINIA
STATE OF WEST VIRGINIA ex reL
DARRELL V. MCGRAW, JR., ATTORNEY
GENERAL,
Case No. 11-C4)94-N

Plaintiff,

Hon. David Nibert
V.

JPMORGAN CHASE & CO. and CHASE
BANK USA, N.A.,
Defendants.
RESPONSES AND OBJECTIONS TO
PLAINTIFF’S FIRST SET OF INTERROGATORIES
TO JPMORGAN CHASE & CO. AND CHASE BANK USA, N.A.

Pursuant to Rule 33 of the West Virginia Rules of Civil Procedure, Defendants
JPMorgan Chase & Co. (“JPMorgan”) and Chase Bank USA, N.A. (“Chase”)
submit the
following responses and objections to Plaintiff’s First Set of Interrogatories to
JPMorgan and
Chase (the “Interrogatories”).
The responses and objections contained herein are made without in any way
waiving or intending to waive, but on the contrary reserving and intending to reserve,
the right at
any time to revise, supplement, correct, or add to these objections and responses, and
to revise,

supplement, correct, or add to any production of information.
SPEciFIc RESPONSES AND OBJEcrIoNs

All responses provided below, and all information produced in response to these
Interrogatories, are stated and made subject to and without waiving the General
Objections set

I1
EXHIBIT

forth herein, which are specifically incorporated in each response below. JPMorgan and Chase
further respond and object to the Interrogatories as follows:
INTERROGATORY NO.1:
Identify all person or persons responsible for responding, or contributing to the response, to each
of the interrogatories contained herein by name, address, telephone number, and relationship to
you.
RESPONSE:
These responses have been prepared by Chase’s counsel. Chase’s response to
Intern) gatory No. 3 identifies Chase employees who contributed to these responses.
To the extent a further response may be sought, Defendants object to this
interrogatory on the ground that it seeks information protected by privileges, including without
limitation attorney-client privilege and work product immunity.

INTERROGATORY NO.2:
Identify all person or persons responsible for responding, or contributing to the response, to each
of the Plaintiffs First Set of Requests for Production of Documents to JPMorgan Chase & Co.
and Chase Bank USA, N.A.
RESPONSE:
Defendants’ responses to Plaintiffs document requests have been prepared by
Chase’s counsel.

Chase’s response to Interrogatory No. 3 identifies Chase employees who

contributed to Defendants’ responses to Plaintiff’s document requests.
To the extent a further response may be sought, Defendants object to this
interrogatory on the ground that it seeks information protected by privileges, including without
limitation attorney-client privilege and work product immunity.

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INTERROGATORY NO.3:

Identify all persons known to you to have knowledge of Plaintiffs claims or your
defenses in
this lawsuit and, for each such person, provide a brief summary of their knowledge
and produce
all documents in your possession, custody, or control that reflect such knowledge.
RESPONSE:
Subject to and without waiving their objections, Defendants state as follows:
Marc Fink has knowledge concerning Chase’s defenses in this lawsuit. Mr. Fink
is a marketing
director for Chase, and his responsibilities include managing Chase’s payment protect
ion plans.
To the extent a further response may be sought at this time, Defendants object to
this interrogatory on the ground that it is prematare. Defendants have filed a motion
to dismiss
the Attorney General’s claims, which if granted would eliminate the need for
or substantially
narrow the scope of discovery. Chase will supplement this response if approp
riate after the

Court rules on Defendants’ pending motion.
Defendants further object to this interrogatory on the ground that it seeks
information protected by privileges, including without limitation attorney-clien
t privilege and
work product immunity.
Defendants further object that the request to identify all persons who have
knowledge of claims or defenses, to summarize all of such persons’ knowle
dge, and to produce

all documents reflecting such knowledge is vague, overbroad, unreasonably burden
some. not a
proper request in an interrogatory, and not reasonably calculated to lead to
the discovery of
relevant, admissible evidence.

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INTERROGATORY NO.4:
Identify each person you expect to call as a fact witness at the trial of this action
by name,
address, borne telephone, cell phone, business telephone, last known employment title
and
,
position, and nature and dates of affiliation with any party to this litigation. Descri
be each
person’s expected testimony in detail and produce, for each, any statements in your posses
sion,
custody, or control authorized by that person that relate to the subject matter of this action,
RESPONSE:
Chase anticipates calling Marc Fink as a witness at trial, and Chase will produce
all affidavits executed by Mr. Fink to date concerning the subject matter of this case. Chase
also
reserves the right to call any witnesses necessary to provide testimony for the purpos
e of
admitting documents into evidence.
To the extent a further response may be sought at this time, Defendants object to
this interrogatory on the ground that it is premature. Defendants have filed a motion
to dismiss
the Attorney General’s claims, which if granted would eliminate the need for or
substantially
narrow the scope of discovery. Chase will supplement this response if approp
riate after the
Court rules on Defendants’ pending motion.
Defendants further object to this interrogatory on the ground that it seeks
information protected by privileges, including without limitation attorneyclient privile
ge and
work product immunity.
Defendants farther object that the interrogatory is overbroad, unreasonably
burdensome, and not reasonably calculated to lead to the discovery of relevant, admiss
ible
evidence, and makes a request that is not a proper request in an interrogatory

INTERROGATORY NO.5:
identify each person whom you expect to call as an expert witness at the trial of this
action and,
for each, provide the sukiect matter to which said expert is expected to testii’, the substan
ce of

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the facts and opinions to which said expert is expected to testify, and
a summary of the grounds
for each opinion held by said expert and produce the following documents:
a.

a copy of his or her report(s) pertaining to this matter;

b.
a list of each civil action in which he or she has been retained and/or
testified
either on behalf of a defendant or plaintiff and, for each, state the court,
docket number, and
names of the litigants involved; and
c.
all documents, reports, records, treatises, or other information in
any form
examined by or referred to by said expert in the formulation of his or
her opinions.
RESPONSE:
Subject to and without waiving their objections, Defendants state that
they have
not determined whether they will retain an expert witness to
testifS’ at trial. If Defendants elect to
do so, they will supplement this response at an appropriate time.
To the extent a further response may be sought at this time, Defendants
object to
this interrogatory on the ground that it is premature. Defendants have
filed a motion to dismiss
the Attorney General’s claims, which if granted would eliminate the
need for or substantially
narrow the scope of discovery.
Defendants further object to this interrogatory on the ground that
it seeks
information protected by privileges, including without limitation attome
yclient privilege and
work product immunity.

INTERROGATORY NO.6:
List all Ancillary Services you have marketed and/or sold to West Virgin
ia consumers. With
respect to each Ancillary Service:

a.
state the dates that the Ancillary Service has been marketed and/or availab
le for
purchase by West Virginia consumers;
b.
behalf;

identify who marketed the Ancillary Service to West Virginia consum
ers on your

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c.
state the amount of revenue you received each year
from West Virginia
consumers for each year that you sold this Ancillary Servic
e to West Virginia consumers;
d.
state the amount of profit you received each year as a result
of sales of this
Ancillary Service to West Virginia consumers;
e.
state the number of West Virginia consumers who paid for
the Ancillary Service
during each year; and
1.
state the number of West Virginia consumers who are currently enrolle
d in or for
the Ancillary Service.
RESPONSE:
Chase’s payment protection plans were marketed to West Virgin
ia consumers
from a date that pre-dates the statute of limitations period throug
h 2011. As of August 31, 2007,
approximately 27,000 West Virginia consumers were enrolle
d in Chase’s payment protection
plans. About 16,500 additional West Virginia consumers have
enrolled since that date. As of
November 30, 2011, approximately 13,000 West Virginia
consumers were enrolled in Chase’s
payment protection plans. Chase will provide reason
ably available information about the
amount of payment protection fees charged to West Virginia
consumers during the statute of
limitations period upon entry of an appropriate protective order.
Chase further states that it does
not track the profit it receives from West Virginia consumers who
paid payment protection fees.
To the extent that further information may be requested, Defend
ants object to this
interrogatory on the ground that it is premature. Defendants
have filed a motion to dismiss the
Attorney General’s claims, which if granted would eliminate the
need for or substantially narrow
the scope of discovery.
Because the Complaint contains only minimal and conchisory allegat
ions about
products other than payment protection plans, Defendants
object to producing information
concerning such products. Defendants further object to provid
ing information for the period

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before August 1, 2007, in light of limitations issues. Defendants further object
to providing
additional information on the ground that the interrogatory is vague, ambiguous, unreasonably
burdensome, overbroad, and not reasonably calculated to lead to the discovery
of relevant,
admissible evidence.

INTERROGATORY NO.7:
For each of your Payment Protection Plans, state the number of West Virginia consumers who
have paid for the Payment Protection Plan at any time and for whom you do not have a signature
or other written consent to be enrolled in the Payment Protection Plan.
RESPONSE:
Defendants object to this interrogatory on the ground that the phrase “signature or
other written consent” is vague, ambiguous, and irrelevant to this litigation. Under federal
regulations, Chase did not need to obtain “a signature or other written consent”
to enroll
consumers in payment protection plans. Consumers may provide their consent to enroll
through
many means. For example, customers may provide consent over the phone, either
in response to
an automated script or during a conversation with a customer service representative;
they may
enroll in payment protection plans online; and they may enroll in payment protection
plans by
signing and returning direct mail. Shortly after customers enroll in a payment protection
plan,
they are maIled documents

—

such as welcome kits and billing statements

—

which further

establish their consent to enroll in and be charged for payment protection plans.
Defendants further object to this Request on the ground that it is vague,
ambiguous, unreasonably burdensome, and not reasonably calculated to lead to the discovery
of
relevant, admissible evidence, Chase cannot determine the number of West Virginia
enrollees
who did not submit a written signature in connection with their enrollment in
a payment

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protection plan without an unreasonably burdensome account-by-account manual review of
the
accounts that enrolled in payment protection plans.
To the extent further information may be requested, Defendants object to this
interrogatory on the ground that it is premature. Defendants have filed a motion to dismiss
the
Attorney General’s claims, which if granted would eliminate the need for or substantially narrow
the scope of discovery.
Defendants further object to providing any information from before August 1,
2007, in light of [imitations issues.

INTERROGATORY NO.8:

Identify and describe all marketing materials you have used to market your Payment Protection
Plans and other Ancillary Services to your West Virginia credit card holders.
RESPONSE:
Subject to and without waiving their objections, Defendants state as follows:
Chase has marketed payment protection plans to West Virginia credit card holders
through, among other things, telephone offers, direct mail solicitations (both stand-alone
mailings and information included with customers’ monthly billing statements), on-line offers,
and information provided to cardholders when they apply for credit cards.
To the extent further information is requested, Defendants object to this
interrogatory on the ground that it is premature. Defendants have tiled a motion to dismiss the

Attorney General’s claims, which if granted would eliminate the need for or substantially narrow
the scope of discovery.
Because the Complaint contains only minimal and conclusory assertions about
products other than payment protection plans, Defendants object to producing information
-8CONflDENTAL

concerning such products. Defendants further object to providing any inform
ation from before
August 1, 2007, in light of limitations issues.
Defendants further object to this interrogatory on the ground that the request to
identify and describe “all” marketing materials used to market payment
protection plans is
vague, ambiguous, overbroad, unreasonably burdensome, and not reasonably
calculated to lead
to the discovery of relevant, admissible evidence.

INTERROGATORY NO.9:
State the name and address of all third-party telemarketing companies or
entities who marketed
your Payment Protection Plan(s) to West Virginia consumers.
RESPONSE:
Defendants object to this interrogatory on the ground that it is premat
ure.
Defendants have filed a motion to dismiss the Attorney General’s claims, which
if granted would
eliminate the need for or substantially narrow the scope of discovery. Defend
ants further object
to this interrogatory on the ground that it is vague and ambiguous, overly
broad, and unlikely to
lead to the discovery of relevant, admissible evidence.

The use of the term “marketed” is

particularly vague and ambiguous.

INTERROGATORY NO. 10:
Identify all persons who trained telemarketers to market your Payme
nt Protection Plan(s) to
West Virginia consumers.
RESPONSE:
Defendants object to this interrogatory on the ground that it is premat
ure.
Defendants have filed a motion to dismiss the Attorney General’s claims
, which if granted would

-9.
CONFiDENTIAL

eliminate the need for or substantially narrow the scope of discovery.
Chase will supplement this
response if appropriate after the Court rules on Defendants’ pendin
g motion.
Defendants further object to this interrogatory on the ground that
it is vague,

ambiguous, overbroad, unreasonably burdensome, and not reasonably
calculated to lead to the
discovery of relevant, admissible evidence.
Defendants further object to this interrogatory on the ground
that it seeks
information protected by privileges, including without limitation
attorney-client privilege and
work product immunity.

INTERROGATORY NO. 11:
Identify all persons with knowledge about the recording of calls
to West Virginia customers, or
calls from West Virginia customers, relating to Payment Protec
tion. This interrogatory seeks the
names of persons in management as well as technical suppor
t managers and key staff members
with management duties related to recording the telephone calls.
RESPONSE:
Apart from counsel, Marc Fink has knowledge about the record
ing of calls to or
from West Virginia customers relating to payment protection.
To the extent additional information may be requested, Defendants
object to this
interrogatory on the ground that it is premature. Defendants have
filed a motion to dismiss the
Attorney General’s claims, which if granted would eliminate the need
for or substantially narrow
the scope of discovery, Chase will supplement this response if approp
riate after the Court rules
on Defendants’ pending motion.
Defendants further object to this interrogatory on the ground that it
is vague,
ambiguous, overbroad, unreasonably burdensome, and not reason
ably calculated to lead to the
discovery of relevant, admissible evidence.
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Defendants further object to this interrogatory on the ground that it
seeks
information protected by privileges, including without limitation attorne
y-client privilege and
work product immunity.

INTERROGATORY NO. 12:

State your policy for recording calls to and from West Virginia consumers who
were subjected to
marketing of Payment Protection by you or by anyone on your behalf.
RESPONSE:
Chase records portions of sales calls between Chase customer service
representatives and customers relating to enrollment in payment protect
ion plans Chase is
preserving all telephone call recordings that it has been able to identify
as calls relating to sales
of payment protection plans to West Virginia consumers.
To the extent further information may be requested, Defendants object
to this
interrogatory on the ground that it is premature, Defendants have tiled
a motion to dismiss the
Attorney General’s claims, which if granted would eliminate the need for
or substantially narrow
the scope of discovery, Chase will supplement this response if approp
riate after the Court rules
on Defendants’ pending motion.
Defendants further object to providing any information unrelated to West
Virginia
consumers. Defendants further object to this interrogatory to the extent
it seeks information
protected by privileges, including without limitation attorney-client privile
ge and work product

immunity,

Defendants further object to this interrogatory on the ground that it
is vague,

ambiguous, overbroad, and not reasonably calculated to lead to relevant, admiss
ible evidence.

ii

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CONFDEN11AL

INTERROGATORY NO. 13
Describe any quantitative analysis which was performed to determ
ine the profitability of your
Ancillary Services, including, but not limited to, Payment Protection, and
a.
with respect to each such analysis, identify the person who performed it and
his or
her address and job title;
b.
with respect to each such analysis, identify the person who superv
ised the
analysis; and
c.
identify any report which describes the quantitative analysis regard
ing the
marketing, selling and administration of your Ancillary Servic
es, Including but not limited to
Payment Protection.
RESPONSE:
Defendants object to this interrogatory on the ground that it is premat
ure.
Defendants have filed a motion to dismiss the Attorney General’s claims
, which if granted would
eliminate the need for or substantially narrow the scope of discovery.
Chase will supplement this
response if appropriate after the Court rules on Defendants’ pendin
g motion.
Because the Complaint contains only minimal and oonclusory asserti
ons about
products other than payment protection plans, Defendants object
to producing information
concerning such products. Defendants further object to providing inform
ation unrelated to West
Virginia consumers.
Defendants further object to this interrogatory to the extent it seeks
information
protected by privileges, including without limitation attorney-client privile
ge and work product
immunity.
Defendants further object to this interrogatory on the ground that it is vague,
ambiguous, overbroad, and seeks information not reasonably calcula
ted to lead to relevant,
admissible evidence. The phrase “quantitative analysis” is particularly
ambiguous. Furthermore,
Plaintiff is barred from seeking discovery in aid of claims released by
the Kardonick settlement
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and has disavowed any intent to challenge the reasonableness of
the fees charged by Chase,
rendering a request for profitability analysis irrelevant.

GENzi1 OI3JEcrloNs ANI) OBJEcTIoNs TO DEFINm0Ns
AND INSTRUCTIONS

1.

The following General Objections and Objections to Definitions
and

Instructions are incorporated in fin into all of the specific responses
set forth above.
2.

Defendants object to the Interrogatories to the extent they seek to litigate

claims released by the nationwide class action settlement in Kardon
iclc et a!. v. JPMorgan
Chase & Co., eta!., No. l0-cv-2323 (S.D. Fla.), which was approv
ed on September 16, 2011.
The injunction in connection with the approval of that settlement
prohibits the Attorney General
and his counsel from litigating released claims, including seeking
discovery with respect to those

claims.
3.

Defendants object to the Interrogatories on the ground that
they are

premature in light of Defendants’ pending motion to dismis
s the Attorney General’s claims on
preemption grounds. The Court’s ruling on the motion to dismis
s may eliminate all or some of
the Attorney General’s claims, and thus may eliminate the need
for or significantly narrow the
scope of discovery. There is no need to provide the requested
discovery at this point, especially
since providing all of the requested discovery would impose signifi
cant expenses and burdens on
the Defendants.
4.

Defendants object to the Interrogatories on the ground that
they are

premature in light of Defendants’ pending motion to disqualify the Attorn
ey General’s outside
counsel. The Interrogatories were promulgated, signed, and issued
by counsel that Defendants
contend should be disqualified from representing the Attorney Genera
l. In addition, Defendants

13

-

CONFOENT AL

should not be required to meet-and-confer about discovery dispute with
s
counsel that are subject
to disqualification.
5.

Defendants object to the Interrogatories as premature prior to the entry of

an appropriate protective order.
6.

If the Court denies Defendants’ two pending motions, Defendants will

supplement these responses and objections within a reasonable period of
time after the Court
rules. Defendants will also supplement these responses and objecti
ons as may be required by the

West Virginia Rules of Civil Procedure.
7.

Defendants object to the Interrogatories to the extent they call for

information from anyone other than Chase and its employees. JPMor
gan had no involvement in
the payment protection plans or the alleged conduct at issue in the Compl
aint and has no
responsive information. Furthermore, Chase is not required to produce inform
ation that is not in
its possession, custody, or control, such as information maintained by third parties
.
8.

Defendants object to the Interrogatories to the extent they call for

information from before August 2007, in light of statute of limitations issues,
Defendants’
responses generally will cover the period from August 2007 to the presen
t.
9.

Because the Complaint contains only minimal and conclusory assertions

about products other than payment protection plans, Defendants object to produc
ing information
concerning such products. The Attorney General has not articulated ground
s for any claims
targeting products beyond payment protection plans.

Indeed, the only direct reference to

products beyond payment protection plans appears in Paragraph 20 of the Compl
aint. All claims
involving products beyond payment protection plans are pleaded in conclu
sory fashion, and the
Comp!aint fails to provide sufficient notice about the Attorney General’s
claims.

-

14

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CONFIDENTIAL

10.

Defendants object to the definitions associated with the terms ‘Payment

Protection” and “Payment Protection Plans.” For purposes of responding to
the Interrogatories,
Defendants have construed those terms to refer to Chase’s debt cancellation contrac
ts and debt
suspension agreements which are offered to West Virginia consumers.
1.

Defendants object to the Interrogatories to the extent that the definitions,

instructions, and specific questions incorporated therein are vague, ambiguous,
overbroad, or
unreasonably burdensome, do not describe the information sought with reason
able particularity,

or otherwise exceed or fail to comply with the requirements imposed by the West
Virginia Rules
of Civil Procedure.
12.

Defendants object to the Interrogatories to the extent they seek disclosure

of infonnation protected by attorney-client privilege, the work-product immun
ity doctrine, or
any other applicable privilege or protection. Defendants do not waive intend
or
to waive any
such privileges or protections, and any production of privileged or protect
ed information is
inadvertent.
13,

Defendants object to the Interrogatories to the extent they ask Defendants

to produce confidential, proprietary, or other sensitive information. Defend
ants also object to the
Interrogatories to the extent they seek private information relating to
Chase cardholders,
personally identifying information, or infonnation about individual dispute
s that is subject to
confidentiality obligations. Defendants also object to producing any inform
ation relating to or
about its non-West Virginia consumers.
14.

Defendants object to the Jnterrogatories to the extent they ask Defendants

to provide home and business addresses, telephone numbers, or dates of
employment for Chase

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employees. Any efforts by the Attorney General to contact such person should
s
be made through
Chase’s counsel.
15.

Defendants object to instruction No, 5 to the extent it asserts that any

“omission of any name, fact or other item of information form the respon
se shall be deemed a
representation that such name, fact or other item was not known to JPMor
gan Chase & Co. or
Chase Bank USA, N.A., their counsel, or their other representatives at the time
of service of the
answer.” No such inference is contemplated by the West Virginia Rules
of Civil Procedure.
16.

Defendants object to Instruction Nos. 6 and 9, which make requests for the

production of documents and a log of privileged documents that are
not appropriate in the
context of interrogatories.
17.

Defendants object to the defined term “identifS’” to the extent it

(1) purports to require Defendants to provide the requested detaile
d information about a
document, (2) purports to require Defendants to provide the reques
ted detailed information about
a fact witness or a fact witnesses’ proffered testimony, (3) purpor
ts to require Defendants to
provide the requested detailed information about a business entity, and
(4) purports to require
Defendants to provide the requested detailed information about a conver
sation, communication,
transaction, meeting, or conference. No such requirements are impose
d by the West Virginia
Rules of Civil Procedure, and providing all the requested information would
be unreasonably
burdensome.
18.

Defendants object to the defined terms “state the full factual basis,”

“describe,” and “state” to the extent they purport to require Defendants to provid the
e
requested
detailed information. No such requirement is imposed by the West Virgin
ia Rules of Civil
Procedure, and providing all the requested information would be unreasonably
burdensome.

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19.

Defendants object to the Interrogatories to the extent they purport to

impose requirements that exceed the requirements of the West Virginia Rules of Civil Proced
ure.
20,

Subject to and without waiving its objections, Chase has provided

information as indicated above. In addition, Chase remains willing to confer with
the Attorney
General’s counsel to the extent some Interrogatories could be made less objecti
onable by being
narrowed or reformulated.

-

17CONFlDNTLAL

______

VERIFICATION
STATE OF

-,

COUNTY OF

,

TO-WIT:

J, Marc Fink, a Marketing Director at Chase Bank USA, N.A., state that 1 have read the
foregoing RESPONSES AND OBJECTIONS TO PLAINTIFF’S FIRST
SET OF
INTERROGATORIES TO JPMORGAN CHASE & CO. AND CHASE BANK
USA, N.A.
and that the facts contained therein are true, except insofar as they are therein stated
to be upon
information and belief, and, insofar as they are therein stated to be upon inform
ation and beIief I
believe them to be true.

4p

Name:

(.-k%N2 3

Thle:

€1th

Taken, subscribed and sworn to before this

‘Lk GJ
air)
3
P V\fl

in

C_PThJ2_

his/her
.,

capacity

F..

day of 11

,

2012 by

as

for

on behalf of said defendant.
0)

My commission expires:

NCETAR’Y PUBLIC
FAYE D. SUTTON
NOTARY PUBUC
STATE OF DELAWARE

KMISSiON EXPIRES 09-244012

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Signed as to objections:
DATED: May 18, 2012

Thomas H. Eng (WVSB H 9655)
KAY CASTO & CHANEY PLLC
1500 Chase Tower
707 Virginia Street, East
Charleston, W.V 25301
Tel: [phone]
Fax: [phone]
Email: wbookerJkaycastocom
tewingkaycastocom
Robert D. Wick
Andrew Ruffino
Andrew Soukup
COVINGTON & BURUNG LIP
1201 Pennsylvania Avenue, NW
Washington, DC 20004-2401
Tel: [phone]
Fax: [phone]
Email: [e-mail]

[e-mail]
[e-mail]
Attorneys for Defendants .JPMorgan Chase
& Cia. & Chase Bank USA, NA.

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CERTIFICATE OF SERVICE

22v ay of May, 2012, 1 served a copy of Responses

I hereby certify that on the

and Objections to Plaintiff’s First Set of Interrogatorics to JPMorgan Chase & Co. and Chase
Bank USA, N.A. via first-class mail, postage prepaid and/or electronic mail to the following
individuals at the addresses listed below:

Frances A. Hughes
Chief Deputy of the Attorney General
Office of the Attorney General
State Capitol Complex
Building 1, Room E-26
Charleston, WV 25305

Guy Bucci
Timothy Bailey
Lee Javins
Special Assistant Attorneys General
BUCCI BAILEY & JAVENS LC
213 Hale Street
Charleston, WV 25301

William Drucknian
Special Assistant Attorney General
THE LAW OFFICES OF DRUCKMAN &
ESTEP
606 Virginia Street East, Suite 100
Charleston, WV 25301

Laura Baughman
Sherri Ann Saucer
Special Assistant Attorney General
BARON&BUDD,P.C.
3102 Oak Lawn Ave., Suite 1100
Dallas, TX 75219

William W.

o er

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