Blaszkowski et al v. Mars Inc. et al

Filing 601

NOTICE by Natura Pet Products, Inc. re 600 MOTION to Dismiss Plaintiffs Cindy Tregoe and Jo-Ann Murphy of Filing Declaration of Kristen E. Caverly (Attachments: # 1 Declaration of Kristen E. Caverly)(York, Jeffrey)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. 07-21221-CIV-ALTONAGA/BROWN RENEE BLASZKOWSKI, et al., individually and on behalf of others similarly situated, Plaintiffs, vs. MARS, INCORPORATED, et al., Defendants. ___________________________________/ DECLARATION OF KRISTEN E. CAVERLY IN SUPPORT OF NATURA PET PRODUCTS, INC.'S MOTION TO DISMISS 1. I, Kristen E. Caverly, am over the age of 18 and have personal knowledge of the facts set forth herein or know of such facts from my review of the case files for this action, which are maintained by my office in the normal course of business. I am lead counsel for defendant Natura Pet Products, Inc., and admitted pro hac vice in this action. 2. On September 25, 2008 I took the Deposition of Plaintiff Cindy Tregoe in Washington, D.C. Attached as Exhibit `A' are true and correct copies of excerpts from Ms. Tregoe's deposition as follows: 33:1-19, 48:13-20, 72:1-3, 103:25-104:4, and 140:21-141:17. 3. On September 27, 2008 I took the Deposition of Plaintiff Jo-Ann Murphy in Washington, D.C. Attached as Exhibit `B' are true and correct copies of excerpts from Ms. Murphy's deposition as follows: 51:12-15, 61:13-66:17, 81:12-82:7, 90:5-93:4, 120:1-123:7, and 137:12-23. 4. On November 24, 2008, Ms. Tregoe served her responses to Natura Pet Product's Second Set of Special Interrogatories. A true and correct copy of Ms. Tregoe's verified responses is attached hereto as Exhibit `C'.