National Federation of the Blind et al v. Target Corporation

Filing 91

Declaration of Matthew I. Kreeger in Support of 90 MOTION for Summary Judgment Target Corporation's Notice of Motion and Motion for Summary Judgment; Supporting Memorandum of Points and Authorities Declaration of Matthew I. Kreeger in Support of Target Corporation's Motion for Summary Judgment filed byTarget Corporation. (Attachments: # 1 Exhibit Exhibit A# 2 Exhibit Exhibit B# 3 Exhibit Exhibit C# 4 Exhibit Exhibit D# 5 Exhibit Exhibit E)(Related document(s) 90 ) (Kreeger, Matthew) (Filed on 3/8/2007)

National Federation of the Blind et al v. Target Corporation

Doc. 91

Case 3:06-cv-01802-MHP

Document 91

Filed 03/08/2007

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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 MATTHEW I. KREEGER IN SUPPORT OF TARGET CORPORATION'S MOTION FOR SUMMARY JUDGMENT Date: April 16, 2007 Time: 2:00 PM Judge: Hon. Marilyn Hall Patel

DECL. OF MATTHEW I. KREEGER IN SUPPORT OF TARGET'S MOTION FOR SUMMARY JUDGMENT CASE NO. C 06-01802 MHP sf-2278442
Dockets.Justia.com

Case 3:06-cv-01802-MHP

Document 91

Filed 03/08/2007

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I, Matthew I. Kreeger, declare: 1. I am a partner in the law firm of Morrison & Foerster LLP, counsel of record for

Defendant Target Corporation ("Target") in the above-captioned case. I am admitted to practice before the United States District Court for the Northern District of California. I have personal knowledge of the facts set forth in this declaration. 2. Attached as Exhibit A is a true and correct copy of the Court's September 6, 2006

Order on Defendant's Motion to Dismiss and Plaintiffs' Motion for Preliminary Injunction [Docket 62]. 3. Attached as Exhibit B is a true and correct copy of the Declaration of Bruce F.

Sexton, dated April 12, 2006, filed in support of Plaintiffs' Motion for Preliminary Injunction. 4. Attached as Exhibit C is a true and correct copy of the Declaration of Trish Perry in

Support of Target's Opposition to Plaintiffs' Motion for Class Certification. 5. Attached as Exhibit D is a true and correct copy of the Reply Declaration of Bruce F.

Sexton, dated July 10, 2006, filed in support of Plaintiffs' Motion for Preliminary Injunction. 6. Attached as Exhibit E is a true and correct copy of the transcript of the deposition of

Plaintiff Bruce F. Sexton, taken May 23, 2006. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed this 8th day of March, 2007, at San Francisco, California.

_/s/ Matthew I. Kreeger Matthew I. Kreeger

_____

DECL. OF MATTHEW I. KREEGER IN SUPPORT OF TARGET'S MOTION FOR SUMMARY JUDGMENT CASE NO. C 06-01802 MHP sf-2278442

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