National Federation of the Blind et al v. Target Corporation

Filing 48

AMENDED Declaration of Laurence Paradis in Support of Motion for Preliminary Injunction by National Federation of the Blind, Bruce Frank Sexton, the National Federation of the Blind of California. Amendment to 42 Reply to Opposition . (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12 # 13 # 14 # 15)(Paradis, Laurence) (Filed on 7/11/2006) Modified on 7/21/2006 (gba, COURT STAFF).

National Federation of the Blind et al v. Target Corporation

Doc. 48

Case 3:06-cv-01802-MHP

Document 48

Filed 07/11/2006

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DISABILITY RIGHTS ADVOCATES 2001 CENTER STREET, THIRD FLOOR BERKELEY, CALIFORNIA 94704-1204 510.665.8644

LAURENCE W. PARADIS (California Bar No. 122336) [e-mail] MAZEN M. BASRAWI (California Bar No. 235475) [e-mail] DISABILITY RIGHTS ADVOCATES 2001 Center Street, Third Floor Berkeley, California 94704 Telephone: [phone] Facsimile: [phone] TTY: [phone] TODD M. SCHNEIDER (California Bar No. 158253) [e-mail] JOSHUA KONECKY (California Bar No. 182897) [e-mail] SCHNEIDER & WALLACE 180 Montgomery Street, Suite 2000 San Francisco, CA 94104 Telephone: [phone] Fax: [phone] TTY: [phone] DANIEL F. GOLDSTEIN (pro hac vice) [e-mail] BROWN, GOLDSTEIN & LEVY, LLP 120 E. Baltimore St., Suite 1700 Baltimore, MD 21202 Telephone: [phone] Fax: [phone] 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 CLASS ACTION AMENDED DECLARATION OF LAURENCE PARADIS IN SUPPORT OF PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION Hearing Date: July 24, 2006 Time: 2:00 p.m. Judge: The Honorable Marilyn Hall Patel

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Dockets.Justia.com

Case 3:06-cv-01802-MHP

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DISABILITY RIGHTS ADVOCATES 2001 CENTER STREET, THIRD FLOOR BERKELEY, CALIFORNIA 94704-1204 510.665.8644

I, Laurence Paradis, declare as follows:

1.

I am an attorney at the firm of Disability Rights Advocates, counsel for plaintiffs 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: 2. Exhibits were inadvertently omitted from the filing of my declaration on July 10, 2006

and have now been added to this amended declaration. Please reference the corrected exhibit list below. 3. These pages were also inadvertently omitted and have now been added to the following

exhibits: Page 113, Exhibit 1; Pages 116 through 117, Exhibit 3. 4. Attached hereto as Exhibit 1 is a true and correct copy of excerpts from the deposition of

Charles Letourneau, taken July 5, 2006. 5. Attached hereto as Exhibit 2 is a true and correct copy of excerpts from the deposition of

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Robert Stigile, taken May 26, 2006. 6. Attached hereto as Exhibit 3 is a true and correct copy of excerpts from the deposition of

Gregg Bodnar, taken July 6, 2006. 7. Attached hereto as Exhibit 4 is a true and correct copy of excerpts from the deposition of

James Thatcher, taken June 2, 2006. 8. Attached hereto as Exhibit 5 is a true and correct copy of excerpts from the deposition of

Tim Elder, taken May 24, 2006. 9. Attached hereto as Exhibit 6 is a true and correct copy of excerpts from the deposition of

Steve Jacobson, taken May 31, 2006. 10. Attached hereto as Exhibit 7 is a true and correct copy of excerpts from the deposition of

Chris Polk, taken June 19, 2006. 11. Attached hereto as Exhibit 8 is a true and correct copy of excerpts from the deposition of

Bruce Sexton, taken May 23, 2006. 12. Attached hereto as Exhibit 9 is a true and correct copy of excerpts from the deposition of

Christina Thomas, taken May 26, 2006.
National Federation of the Blind, et al. v. Target Corporation Case No.: C 06-01802 MHP Amended Declaration of Laurence Paradis 1

Case 3:06-cv-01802-MHP

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DISABILITY RIGHTS ADVOCATES 2001 CENTER STREET, THIRD FLOOR BERKELEY, CALIFORNIA 94704-1204 510.665.8644

13.

Attached hereto as Exhibit 10 is a true and correct copy of excerpts from the deposition

of Teresa Uttermohlen, taken May 25, 2006. 14. Attached hereto as Exhibit 11 is a true and correct copy of excerpts from the deposition

of Suzanne Tritten, taken June 30, 2006. 15. Attached hereto as Exhibit 12 is a true and correct copy of selected pages from

Starlingweb.com, a website authored by Target's expert Charles Letourneau. Mr. Letourneau authenticated this document during his deposition. See Letourneau Dep. at 18:9-12. 16. Attached hereto as Exhibit 13 is a true and correct copy of excerpts from the deposition

of Dawn Wilkinson, taken June 21, 2006. 17. Attached hereto as Exhibit 14 is a true and correct copy of excerpts from the deposition

of David Wilkinson, taken June 21, 2006.

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I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. Executed on July 11, 2006, in Berkeley, California.

__/s/ Laurence Paradis________ Laurence Paradis

National Federation of the Blind, et al. v. Target Corporation Case No.: C 06-01802 MHP Amended Declaration of Laurence Paradis 2