National Federation of the Blind et al v. Target Corporation

Filing 98

Declaration of Matthew I. Kreeger in Support of 96 Memorandum in Opposition Declaration of Matthew I. Kreeger in Support of Target Corporation's Opposition to Plaintiffs' Motion for Class Certification filed byTarget Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P)(Related document(s) 96 ) (Kreeger, Matthew) (Filed on 3/8/2007)

National Federation of the Blind et al v. Target Corporation

Doc. 98

Case 3:06-cv-01802-MHP

Document 98

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.

C06-01802 MHP

DECLARATION OF MATTHEW I. KREEGER IN SUPPORT OF TARGET CORPORATION'S OPPOSITION TO PLAINTIFFS' MOTION FOR CLASS CERTIFICATION Date: April 12, 2007 Time: 2:30 PM Judge: Hon. Marilyn Hall Patel

DECL. OF MATTHEW I. KREEGER IN SUPPORT OF TARGET'S OPP. TO PLS.' MOT. FOR CLASS CERTIFICATION CASE NO. 06-01802 MHP sf-2280416
Dockets.Justia.com

Case 3:06-cv-01802-MHP

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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 hereto as Exhibit A are true and correct copies of relevant excerpts from

the Deposition of Michelle Bruns taken in this matter on March 5, 2007. 3. Attached hereto as Exhibit B are true and correct copies of relevant excerpts from

the Deposition of Steven Jacobsen taken in this matter on May 31, 2006. 4. Attached hereto as Exhibit C are true and correct copies of relevant excerpts from

the Deposition of Christina Thomas taken in this matter on May 26, 2006. 5. Attached hereto as Exhibit D are true and correct copies of relevant excerpts from

the Deposition of Ken Volante taken in this matter on May 25, 2006. 6. Attached hereto as Exhibit E are true and correct copies of relevant excerpts from

the Deposition of Shannon Dillon taken in this matter on February 28, 2007. 7. Attached hereto as Exhibit F are true and correct copies of relevant excerpts from

the Deposition of Robert Ayala taken in this matter on May 31, 2006. 8. Attached hereto as Exhibit G is a true and correct copy of the Declaration of Trish

Perry in Support of Target Corporation's Opposition to Motion for Preliminary Injunction filed in this matter on June 13, 2006. 9. Attached hereto as Exhibit H is a true and correct copy of an email to James

Gashel from Chris Danielson dated December 2, 2006 (Bates numbered NFB 0007). 10. Attached hereto as Exhibit I is a true and correct copy of an email to Chairman

Mal and Dan Frye from Dan Frye dated April 29, 2006 (Bates numbered NFB 0006). 11. Attached hereto as Exhibit J is a true and correct copy of the Declaration of Dawn

Wilkinson in Support of Target Corporation's Opposition to Motion for Preliminary Injunction filed in this matter on June 13, 2006.

DECL. OF MATTHEW I. KREEGER IN SUPPORT OF TARGET'S OPP. TO PLS.' MOT. FOR CLASS CERTIFICATION CASE NO. 06-01802 MHP sf-2280416

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12.

Attached hereto as Exhibit K is a true and correct copy of the Declaration of Dave

Wilkinson in Support of Target Corporation's Opposition to Motion for Preliminary Injunction filed in this matter on June 13, 2006. 13. Attached hereto as Exhibit L is a true and correct copy of the Declaration of

Suzanne Tritten in Support of Target Corporation's Opposition to Motion for Preliminary Injunction filed in this matter on June 13, 2006. 14. Attached hereto as Exhibit M is a true and correct copy of the Declaration of Chris

Polk in Support of Target Corporation's Opposition to Motion for Preliminary Injunction filed in this matter on June 13, 2006. 15. Attached hereto as Exhibit N is a true and correct copy of an internet posting dated

April 13, 2006, which is Exhibit 2 from the Deposition of Marc Maurer taken in this matter on March 1, 2007. 16. Attached hereto as Exhibit O is a true and correct copy of an internet posting dated

March 31, 2006, which is Exhibit 1 from the Deposition of Marc Maurer taken in this matter on March 1, 2007. 17. Attached hereto as Exhibit P are true and correct copies of relevant excerpts and

exhibits from the Deposition of Marc Maurer taken in this matter on March 1, 2007. I declare under penalty of perjury under the laws of the State of California 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 OPP. TO PLS.' MOT. FOR CLASS CERTIFICATION CASE NO. 06-01802 MHP sf-2280416

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