National Federation of the Blind et al v. Target Corporation

Filing 129

Declaration of Kristina Paszek in Support of 128 MOTION Briefing Schedule and Further Depositions Target Corporation's Administrative Motion Requesting a Briefing Schedule and Further Depositions filed byTarget Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Related document(s) 128 ) (Paszek, Kristina) (Filed on 5/29/2007)

National Federation of the Blind et al v. Target Corporation

Doc. 129

Case 3:06-cv-01802-MHP

Document 129

Filed 05/29/2007

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HAROLD J. McELHINNY (CA SBN 66781) MATTHEW I. KREEGER (CA SBN 153793) KRISTINA PASZEK (CA SBN 226351) [e-mail] [e-mail] [e-mail] MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant TARGET CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

NATIONAL FEDERATION OF THE BLIND, the NATIONAL FEDERATION OF THE BLIND OF CALIFORNIA, on behalf of their members, and Bruce F. Sexton, on behalf of himself and all others similarly situated, Plaintiffs, v. TARGET CORPORATION, Defendant.

Case No.

C 06-01802 MHP

DECLARATION OF KRISTINA PASZEK IN SUPPORT OF TARGET CORPORATION'S ADMINISTRATIVE MOTION REQUESTING A BRIEFING SCHEDULE AND FURTHER DEPOSITIONS Judge: Hon. Marilyn Hall Patel

PASZEK DECL. ISO TARGET'S ADMIN. MOTION FOR BRIEFING SCHEDULE AND FURTHER DEPOSITIONS CASE NO. C 06-01802 MHP sf-2328624
Dockets.Justia.com

Case 3:06-cv-01802-MHP

Document 129

Filed 05/29/2007

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I, Kristina Paszek, declare and state as follows: 1. I am an associate in the law firm of Morrison & Foerster LLP, counsel of

record for Defendant Target Corporation ("Target") in the above-entitled case. I am duly admitted to practice before all state courts and federal district courts in the State of California. I have personal knowledge of the facts set forth in this declaration and, if called as a witness, could and would competently testify to the matters set forth herein. 2. Attached hereto as Exhibit A is a true and correct copy of an email that I sent

on May 23, 2007 to counsel for Plaintiffs in the above-entitled case. The email follows up on a telephone conversation that I had earlier that day with Roger Heller, counsel for Plaintiffs. 3. Attached hereto as Exhibit B are true and correct copies of a fax and an email

that I received from counsel for Plaintiffs on May 24, 2007. 4. Attached hereto as Exhibit C is a true and correct copy of an email that I sent

to counsel for Plaintiffs on May 25, 2007. 5. Attached hereto as Exhibit D is a true and correct copy of a fax that I received

from counsel for Plaintiffs on May 25, 2007. 6. As the foregoing correspondence shows, despite multiple requests, Plaintiffs

neither consented to, nor definitively objected to, the relief sought in Target's administrative motion requesting a briefing schedule and further depositions. I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing is true and correct. Executed this 29th day of May, 2007, at San Francisco, California.

/s/ Kristina Paszek Kristina Paszek

PASZEK DECL. ISO TARGET'S ADMIN. MOTION FOR BRIEFING SCHEDULE AND FURTHER DEPOSITIONS CASE NO. C 06-01802 MHP sf-2328624

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