National Federation of the Blind et al v. Target Corporation

Filing 140

Declaration of Kristina Paszek in Support of 138 Brief in Opposition to Plaintiffs' Motion for Class Certification filed byTarget Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P# 17 Exhibit Q# 18 Exhibit R# 19 Exhibit S# 20 Exhibit T# 21 Exhibit U)(Related document(s) 138 ) (Paszek, Kristina) (Filed on 7/16/2007)

National Federation of the Blind et al v. Target Corporation

Doc. 140

Case 3:06-cv-01802-MHP

Document 140

Filed 07/16/2007

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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 SUPPLEMENTAL BRIEF IN OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION Date: July 31, 2007 Time: 2:00 PM Judge: Hon. Marilyn Hall Patel

PASZEK DECL. IN SUPP. OF TARGET'S SUPP. BRIEF IN OPP. TO PLAINTIFFS' MOT. FOR CLASS CERTIFICATION CASE NO. C 06-01802 MHP sf-2352812
Dockets.Justia.com

Case 3:06-cv-01802-MHP

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I, Kristina Paszek, declare and state as follows: 1. I am an attorney 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 courts of 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 the deposition of

Bernadette Jacobs taken in this matter on June 19, 2007. 3. Attached hereto as Exhibit B is a true and correct copy of the deposition of

Tim Elder taken in this matter on June 25, 2007. 4. Attached hereto as Exhibit C is a true and correct copy of the deposition of

Kenneth Metz taken in this matter on June 19, 2007. 5. Attached hereto as Exhibit D is a true and correct copy of the deposition of

Olga Peterkin taken in this matter on June 19, 2007. 6. Attached hereto as Exhibit E is a true and correct copy of the deposition of

Steven Jacobson taken in this matter on June 18, 2007. 7. Attached hereto as Exhibit F is a true and correct copy of the deposition of

Steven Booth taken in this matter on June 21, 2007. 8. Attached hereto as Exhibit G is a true and correct copy of the deposition of

Ronald Hildeshima taken in this matter on June 25, 2007. 9. Attached hereto as Exhibit H is a true and correct copy of the deposition of

Charlotte Czarnecki taken in this matter on June 18, 2007. 10. Attached hereto as Exhibit I is a true and correct copy of the deposition of

Daniel Frye taken in this matter on June 18, 2007. 11. Attached hereto as Exhibit J is a true and correct copy of the deposition of

Sharon Maneki taken in this matter on June 21, 2007.

PASZEK DECL. IN SUPP. OF TARGET'S SUPP. BRIEF IN OPP. TO PLAINTIFFS' MOT. FOR CLASS CERTIFICATION CASE NO. C 06-01802 MHP sf-2352812

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12.

Attached hereto as Exhibit K is a true and correct copy of a posting from

http://www.nfbnet.org/pipermail/electronics-talk/2007-May/003265.html, as it appeared on July 13, 2007. 13. Attached hereto as Exhibit L is a true and correct copy of a posting from

http://www.nfbnet.org/pipermail/electronics-talk/2007-May/003284.html, as it appeared on July 13, 2007. 14. Attached hereto as Exhibit M is a true and correct copy of the declaration of

Dawn Wilkinson, dated June 9, 2006, originally filed in opposition to Plaintiffs' motion for a preliminary injunction. 15. Attached hereto as Exhibit N is a true and correct copy of the declaration of

Dave Wilkinson, dated June 10, 2006, originally filed in opposition to Plaintiffs' motion for a preliminary injunction. 16. Attached hereto as Exhibit O is a true and correct copy of the declaration of

Suzanne Tritten, dated June 10, 2006, originally filed in opposition to Plaintiffs' motion for a preliminary injunction. 17. Attached hereto as Exhibit P is a true and correct copy of the declaration of

Polk, dated June 9, 2006, originally filed in opposition to Plaintiffs' motion for a preliminary injunction. 18. Attached hereto as Exhibit Q is a true and correct copy of an email to James

Gashel from Chris Danielson dated December 2, 2006 (Bates numbered NFB 0007). 19. Attached hereto as Exhibit R is a true and correct copy of a posting from

http://www.nfbnet.org/pipermail/electronics-talk/2007-May/003266.html, as it appeared on July 13, 2007. 20. Attached hereto as Exhibit S is a true and correct copy of a posting from

http://www.nfbnet.org/pipermail/gui-talk/2006-April/017280.html, as it appeared on July 13, 2007.

PASZEK DECL. IN SUPP. OF TARGET'S SUPP. BRIEF IN OPP. TO PLAINTIFFS' MOT. FOR CLASS CERTIFICATION CASE NO. C 06-01802 MHP sf-2352812

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21.

Attached hereto as Exhibit T is a true and correct copy of a posting from

http://www.nfbnet.org/pipermail/electronics-talk/2007-May/003269.html, as it appeared on July 13, 2007. 22. Attached hereto as Exhibit U is a true and correct copy of a posting from

http://www.nfbnet.org/pipermail/nfb-web/2006-April/001625.html, as it appeared on July 13, 2007.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 16th day of July, 2007, at San Francisco, California.

By: /s/ Kristina Paszek Kristina Paszek

PASZEK DECL. IN SUPP. OF TARGET'S SUPP. BRIEF IN OPP. TO PLAINTIFFS' MOT. FOR CLASS CERTIFICATION CASE NO. C 06-01802 MHP sf-2352812

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