National Federation of the Blind et al v. Target Corporation

Filing 147

Declaration of Kristina Paszek in Support of 146 MOTION for Leave to File Administrative Motion for Leave to File Statement of Recent Decision filed byTarget Corporation. (Related document(s) 146 ) (Paszek, Kristina) (Filed on 9/21/2007)

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National Federation of the Blind et al v. Target Corporation Doc. 147 Case 3:06-cv-01802-MHP Document 147 Filed 09/21/2007 Page 1 of 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 HAROLD J. McELHINNY (CA SBN 66781) MATTHEW I. KREEGER (CA SBN 153793) KRISTINA PASZEK (CA SBN 226351) HMcElhinny@mofo.com MKreeger@mofo.com KPaszek@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: (415) 268-7000 Facsimile: (415) 268-7522 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. Case No. C 06-01802 MHP DECLARATION OF KRISTINA PASZEK IN SUPPORT OF TARGET CORPORATION'S ADMINISTRATIVE MOTION FOR LEAVE TO FILE STATEMENT OF RECENT DECISION Judge: Hon. Marilyn Hall Patel TARGET CORPORATION, Defendant. PASZEK DECL. ISO TARGET'S ADMIN. MOTION FOR LEAVE TO FILE STMT. OF RECENT DECISION CASE NO. C 06-01802 MHP sf-2393086 Dockets.Justia.com Case 3:06-cv-01802-MHP Document 147 Filed 09/21/2007 Page 2 of 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, 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 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. On September 20 and September 21, 2007, I conferred with counsel for Plaintiffs regarding Target's intention to file an administrative motion seeking leave to file a statement of recent decision. Although Plaintiffs' counsel stated that Plaintiffs would not oppose this motion, we were unable to reach an agreement regarding the phrasing of a stipulation. 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 21st day of September, 2007, at San Francisco, California. /s/ Kristina Paszek Kristina Paszek PASZEK DECL. ISO TARGET'S ADMIN. MOTION FOR LEAVE TO FILE STMT. OF RECENT DECISION CASE NO. C 06-01802 MHP sf-2393086 1

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