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

Filing 90

OPPOSITION by Eric Grant to 77 Motion to Transfer. (Attachments: # 1 Appendix of Non-Standard Authorities, # 2 Declaration of Eric Grant, # 3 Declaration of James J. Banks)(Grant, Eric)

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1 Eric Grant (Bar No. 151064) Attorney at Law 2 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 3 Telephone: (916) 388-0833 Facsimile: (916) 691-3261 4 E-Mail: grant@eric-grant.com 5 James J. Banks (Bar No. 119525) Banks & Watson 6 Hall of Justice Building 813 6th Street, Suite 400 7 Sacramento, California 95814 Telephone: (916) 325-1000 8 Facsimile: (916) 325-1004 E-Mail: jbanks@bw-firm.com 9 Counsel for Plaintiff and 10 Counter-Defendant ERIC GRANT ERIC GRANT, ATTORNEY AT LAW 11 12 13 14 ERIC GRANT, UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA No. 2:08-cv-00672-FCD-KJM DECLARATION OF JAMES J. BANKS IN SUPPORT OF PLAINTIFF AND COUNTERDEFENDANT ERIC GRANT'S OPPOSITION TO KSBE DEFENDANTS' MOTION TO TRANSFER TO DISTRICT OF HAWAII PURSUANT TO 28 U.S.C. § 1404 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: (916) 388-0833 ) ) 15 Plaintiff, ) ) 16 v. ) ) 17 KAMEHAMEHA SCHOOLS/BERNICE ) PAUAHI BISHOP ESTATE; J. DOUGLAS ) 18 ING, NAINOA THOMPSON, DIANE J. ) PLOTTS, ROBERT K.U. KIHUNE, and ) 19 CORBETT A.K KALAMA, in their ) capacities as Trustees of the Kamehameha ) 20 Schools/Bernice Pauahi Bishop Estate; ) JOHN DOE; and JANE DOE, ) 21 ) Defendants. ) 22 ) ) 23 JOHN DOE and JANE DOE, ) ) 24 Counter-Claimants, ) ) 25 v. ) ) 26 KAMEHAMEHA SCHOOLS/BERNICE ) PAUAHI BISHOP ESTATE, et al., ) 27 ) Counter-Defendants. ) 28 ) Hearing Date: Time: Courtroom: Judge: Oct. 31, 2008 10:00 a.m. 2 Hon. Frank C. Damrell, Jr. Declaration of James J. Banks in Support of Plaintiff's Opposition to KSBE Defendants' Motion to Transfer 1 2 I, James J. Banks, declare as follows: 1. I am co-counsel for Plaintiff and Counter-Defendant Eric Grant ("Grant") in the 3 above-entitled case. I make this declaration in support of Grant's opposition to the Kamehameha 4 Schools Defendants and Cross-Claim Defendants' Motion to Transfer to District of Hawaii Pursu5 ant to 28 U.S.C. § 1404 (doc. 77, filed Aug. 22, 2008). I make the statements of fact in this declar6 ation of my own personal knowledge. If called as a witness in this proceeding, I could and would 7 competently testify to the facts set forth herein. 8 2. In its capacity as counsel to Grant in the action styled Grant v. Goemans then pend- 9 ing in Sacramento Superior Court, my firm on September 4, 2008 sent a facsimile communication 10 to Goemans at the facsimile number (707) 964-8925. Later that day, my firm received a facsimile ERIC GRANT, ATTORNEY AT LAW 11 communication from Goemans at the same number. A true and correct copy of the communication 12 to Goemans, with first page shifted downward to enable viewing of the header, is attached hereto 13 as Exhibit 1; and a true and correct copy of the communication from Goemans, reduced in size to 14 enable viewing of the header and the footer, is attached hereto as Exhibit 2. 15 I declare under penalty of perjury under the laws of the United States of America that the 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: (916) 388-0833 16 foregoing is true and correct. Executed on October 17, 2008. 17 18 19 20 21 22 23 24 25 26 27 28 1 Declaration of James J. Banks in Support of Plaintiff's Opposition to KSBE Defendants' Motion to Transfer /s/ James J. Banks JAMES J. BANKS Exhibit 1 Exhibit 2

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