National Federation of the Blind et al v. Target Corporation

Filing 39

DECLARATION of Michael J. Bostrom Regarding Technical Failure of the Northern District's Electronic Filing Website filed byTarget Corporation. (Naeve, Robert) (Filed on 6/13/2006)

National Federation of the Blind et al v. Target Corporation

Doc. 39

Case 3:06-cv-01802-MHP

Document 39

Filed 06/13/2006

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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, 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.

C06-01802 MHP

DECLARATION OF MICHAEL J. BOSTROM REGARDING TECHNICAL FAILURE OF THE NORTHERN DISTRICT'S ELECTRONIC FILING WEBSITE [GENERAL ORDER 45 VI. E.] 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

la-863523
Dockets.Justia.com

Case 3:06-cv-01802-MHP

Document 39

Filed 06/13/2006

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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. Pursuant to stipulation and Order of this Court, Target's Opposition to

Plaintiffs' Motion for Preliminary Injunction ("Target's Opposition") was due on June 12, 2006. 2. Beginning at around 8:45 p.m. on June 12, 2006, my assistant and I attempted

to log into the Northern District of California's Electronic Case Filing Website (the "Website") in order to file Target's Opposition and supporting papers. The Website was not working and would not allow either my secretary or me to log in. Instead, the Website generated error messages. My assistant and I continued to attempt to log into the Website until shortly after 10:00 p.m., but to no avail. The Website continued to generate error messages. 3. In order to prevent Plaintiffs from suffering prejudice, I sent Plaintiffs counsel,

Laurence Paradis and Mazen Basrawi a PDF copy of Target's Opposition and supporting papers by e-mail at 9:44 p.m. 4. My assistant and I were not able to gain access to the Website until the morning

of June 13, 2006, at which time we electronically filed Target's Opposition and supporting papers. 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 13, 2006 in Los Angeles, California.

____________/S/_____________ Michael J. Bostrom
DECLARATION OF MICHAEL J. BOSTROM CASE NO. 06-01802 MHP

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