Grant v. Kamehameha Schools/Bernice Pauahi Bishop Estate et al

Filing 78

DECLARATION of Louise K. Y. Ing in Support of 77 Motion to Transfer to District of Hawaii. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Ing, Louise) Modified on 8/25/2008 (Benson, A).

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ALSTON HUNT FLOYD & ING PAUL ALSTON (Admitted Pro Hac Vice) LOUISE K. Y. ING (Admitted Pro Hac Vice) CLYDE J. WADSWORTH (SBN 118928) palston@ahfi.com ling@ahfi.com cwadsworth@ahfi.com American Savings Bank Tower 1001 Bishop Street, 18th Floor Honolulu, HI 96813 Telephone: (808) 524-1800 Facsimile: (808) 524-4591 BINGHAM McCUTCHEN LLP CHARLENE S. SHIMADA (SBN 91407) JOHN D. PERNICK (SBN 155468) ROBERT BRUNDAGE (SBN 159890) charlene.shimada@bingham.com john.pernick@bingham.com robert.brundage@bingham.com Three Embarcadero Center San Francisco, CA 94111-4067 Telephone: (415) 393-2000 Facsimile: (415) 393-2286 Attorneys for Defendants and Cross-claim Defendants KAMEHAMEHA SCHOOLS/BERNICE PAUAHI BISHOP ESTATE; J. DOUGLAS ING, NAINOA THOMPSON, DIANE J. PLOTTS, ROBERT K.U. KIHUNE, and CORBETT A.K. KALAMA, in their capacities as Trustees of the Kamehameha Schools/Bernice Pauahi Bishop Estate UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ERIC GRANT, Plaintiff, v. KAMEHAMEHA SCHOOLS/BERNICE PAUAHI BISHOP ESTATE; et al., Defendants. And Related Cross and Counterclaims. CASE NO. 2:08-cv-00672-FCD-KJM DECLARATION OF LOUISE K. Y. ING IN SUPPORT OF KAMEHAMEHA SCHOOLS DEFENDANTS AND CROSS-CLAIM DEFENDANTS' MOTION TO TRANSFER TO DISTRICT OF HAWAI`I PURSUANT TO 28 U.S.C. 404; EXHIBITS A-C___________ Date: October 31, 2008 Time: 10:00 a.m. Courtroom: 2 Before: Hon. Frank C. Damrell, Jr. 686,465/ 8348-4 DECLARATION OF LOUISE K. Y ING IN SUPPORT OF KAMEHAMEHA SCHOOLS DEFENDANTS AND CROSS-CLAIM DEFENDANTS' MOTION TO TRANSFER TO DISTRICT OF HAWAI`I PURSUANT TO 28 U.S.C. 404 -1- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF LOUISE K. Y. ING IN SUPPORT OF KAMEHAMEHA SCHOOLS DEFENDANTS AND CROSS-CLAIM DEFENDANTS' MOTION TO TRANSFER TO DISTRICT OF HAWAI`I PURSUANT TO 28 U.S.C. 404 I, LOUISE K. Y. ING, declare as follows: 1. I am a shareholder and director in the law firm of Alston Hunt Floyd & Ing, co-counsel in this action for defendants and cross-claim defendants Kamehameha Schools/Bernice Pauahi Bishop and J. Douglas Ing, Nainoa Thompson, Diane J. Plotts, Robert K.U. Kihune, and Corbett A.K. Kalama in their capacities as Trustees of the Kamehameha Schools/Bernice Pauahi Bishop Estate (collectively "KS"). 2. I make this declaration based upon personal knowledge and am competent to testify to the matters stated in this declaration. 3. Attached as Exhibit A is a true and correct copy of the Complaint which my firm filed on behalf of KS against John Doe and Jane Doe in the Third Circuit Court of the State of Hawaii, on August 6, 2008. The Complaint arises out of the Does' breach of the confidentiality provisions of their settlement agreement with KS, the same settlement agreement which is the subject of this pending suit filed by Eric Grant. 4. Attached as Exhibit B is a true and correct copy of the Declaration of James Banks in Support of Motion to Compel Further Response to Request for Production, etc., filed April 22, 2008, in Grant v. Goemans, Case No. 07AS04172 (Cal. Sup'r Ct) ("Grant v. Goemans"). As part of our case preparation, our co-counsel in California at the Bingham McCutchen firm obtained relevant court filings from Mr. Grant's California state court suit against John Goemans and sent us a set, including Exhibit B. 5. Attached as Exhibit C is a true and correct copy of excerpts from the Memorandum in Support of Motion to Compel Further Response to Request for Production, etc., filed April 22, 2008, in Grant v. Goemans. We obtained the full copy of this Memorandum from our California co-counsel at the Bingham McCutchen firm. / / / 686,465/ 8348-4 DECLARATION OF LOUISE K. Y ING IN SUPPORT OF KAMEHAMEHA SCHOOLS DEFENDANTS AND CROSS-CLAIM DEFENDANTS' MOTION TO TRANSFER TO DISTRICT OF HAWAI`I PURSUANT TO 28 U.S.C. 404 -2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I declare under penalty of perjury of law that the foregoing is true and correct. DATED: Honolulu, Hawai`i, August 22, 2008. _____/s/Louise K. Y. Ing__________________ LOUISE K. Y. ING (original signature retained by Louise K. Y. Ing) 686,465/ 8348-4 DECLARATION OF LOUISE K. Y ING IN SUPPORT OF KAMEHAMEHA SCHOOLS DEFENDANTS AND CROSS-CLAIM DEFENDANTS' MOTION TO TRANSFER TO DISTRICT OF HAWAI`I PURSUANT TO 28 U.S.C. 404 -3-

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