National Federation of the Blind et al v. Target Corporation

Filing 30

Declaration of Michael J. Bostrom In Support of 29 Target Corporation's Opposition to Plaintiffs' Motion for Preliminary Injunction filed byTarget Corporation. (Attachments: # 1 Exhibit Exhibit A to Bostrom Declaration# 2 Exhibit Exhibit B to Bostrom Declaration# 3 Exhibit Exhibit C to Bostrom Declaration# 4 Exhibit Exhibit D to Bostrom Declaration# 5 Exhibit Exhibit E to Bostrom Decl.# 6 Exhibit Exhibit F to Bostrom Decl.# 7 Exhibit Exhibit G to Bostrom Decl.# 8 Exhibit Exhibit H to Bostrom Decl.# 9 Exhibit Exhibit I to Bostrom Decl.# 10 Exhibit Exhibit J to Bostrom Decl.# 11 Exhibit Exhibit K to Bostrom Decl.# 12 Exhibit Exhibit L to Bostrom Decl.)(Naeve, Robert) (Filed on 6/13/2006) Modified on 6/14/2006 (gba, COURT STAFF).

National Federation of the Blind et al v. Target Corporation

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ROBERT A. NAEVE (CA SBN 106095) [e-mail] MORRISON & FOERSTER LLP 19900 MacArthur Blvd. Irvine, California 92612-2445 Telephone: [phone] Facsimile: [phone] DAVID F. MCDOWELL (CA SBN 125806) SARVENAZ BAHAR (CA SBN 171556) MICHAEL J. BOSTROM (CA SBN 211778) [e-mail] [e-mail] [e-mail] MORRISON & FOERSTER LLP 555 West Fifth Street, Suite 3500 Los Angeles, California 90013-1024 Telephone: [phone] Facsimile: [phone] STUART C. PLUNKETT (CA SBN 187971) [e-mail] MORRISON & FOERSTER LLP 425 Market Street San Francisco, CA 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.

C06-01802 MHP

DECLARATION OF MICHAEL J. BOSTROM IN SUPPORT OF TARGET CORPORATION'S OPPOSITION TO PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION Date: July 24, 2006 Time: 2:00 p.m. Judge: The Honorable Marilyn Hall Patel

DECLARATION OF MICHAEL J. BOSTROM CASE NO. 06-01802 MHP

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DECLARATION OF MICHAEL J. BOSTROM I, Michael J. Bostrom, declare as follows: I am an attorney licensed to practice law in the state of California, and admitted to the United States District Court for the Northern District of California. I am an associate in the law firm of Morrison & Foerster LLP, counsel for Defendant Target Corporation ("Target") in this action. I have personal knowledge of the facts set forth herein. If called as a witness, I would and could competently testify as follows: 1. Attached hereto as Exhibit A is a true and correct copy of relevant portions of the

transcript from the deposition of Ken Volonte taken on May 25, 2006. 2. Attached hereto as Exhibit B is a true and correct copy of relevant portions of the

transcript from the deposition of Terri Uttermohlen taken on May 25, 2006. 3. Attached hereto as Exhibit C is a true and correct copy of relevant portions of the

transcript from the deposition of Bob Ayala taken on May 31, 2006. 4. Attached hereto as Exhibit D is a true and correct copy of relevant portions of the

transcript from the deposition of Bruce Sexton taken on May 23, 2006. 5. Attached hereto as Exhibit E is a true and correct copy of relevant portions of the

transcript from the deposition of Steve Jacobson taken on May 31, 2006 . 6. Attached hereto as Exhibit F is a true and correct copy of relevant portions of the

transcript from the deposition of Tina Thomas taken on May 26, 2006. 7. Attached hereto as Exhibit G is a true and correct copy of relevant portions of the

transcript from the deposition of Robert Stigile taken on May 26, 2006. 8. Attached hereto as Exhibit H is a true and correct copy of relevant portions of the

transcript from the deposition of Tim Elder taken on May 24, 2006. 9. Attached hereto as Exhibit I is a true and correct copy of relevant portions of the

transcript from the deposition of Dr. James Thatcher taken on June 2, 2006. 10. Attached hereto as Exhibit J is a true and correct copy of Exhibit 11 to the

deposition of Dr. James Thatcher taken on June 2, 2006.

DECLARATION OF MICHAEL J. BOSTROM CASE NO. 06-01802 MHP

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11.

Attached hereto as Exhibit K is a true and correct copy of the Order Granting

Summary Judgment and Order on Plaintiff's Motion to Vacate and Set Aside Judgment entered in the action entitle Hooks v. OKbridge, SA-99-CA-214-EP (W.D. Tex. 1999). 12. Attached hereto as Exhibit L are relevant portions from Volume 1 of 3 of the

Legislative History of the Unruh Act, California Civil Code Section 50. Included are (a) Worksheet, with attachments, of AB 181 as introduced, from the bill file of the Assembly Committee on Judiciary, four pages (pages 148-151); (b) Senate Committee on Judiciary Analysis of AB 181 as amended 5-27-87 prepared for hearing 6-2-87 (page 182); (c) Letter dated April 25, 1986 from the bill file of the author, one page (page 247); and (d) Documents regarding AB 4260 as amended March 31 from the bill file of the author, six pages (pages 251-256). I declare under penalty of perjury under the laws of California and the United States of America that the foregoing is true and correct, and that this declaration was executed on June 12, 2006 in Los Angeles, California.

____________/S/_____________ Michael J. Bostrom

DECLARATION OF MICHAEL J. BOSTROM CASE NO. 06-01802 MHP

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