Roehm v. Wal-Mart Stores, Incorporated

Filing 18

Attachment 7

RESPONSE to 12 MOTION to Remand filed by Wal-Mart Stores, Incorporated. (Attachments: # 1 Index of Exhibits Index of Exhibits to Brief in Response to Plaintiff's Motion to Remand# 2 Exhibit A - Nagalingam v. Wilson# 3 Exhibit B - LEXIS search results showing Plaintiff is registered to vote in Michigan# 4 Exhibit C - Cited portions of transcript and exhibits for May 11, 2007 deposition of Julie Ann Roehm# 5 Exhibit D - Copy of Plaintiff's Michigan driver's license, along with cover letter from Plaintiff's counsel# 6 Exhibit E - E-mail from SIRVA Relocation discussing the suggested list price for Plaintiff's Michigan home, and the actual list price# 7 Exhibit F - Declaration of Karl G. Nelson) (McCulloch, Debra)

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Roehm v. Wal-Mart Stores, Incorporated Doc. 18 Att. 7 Case 2:07-cv-10168-LPZ-RSW Document 18-8 Filed 05/17/2007 Page 1 of 3 ee Xii Dockets.Justia.com Case 2:07-cv-10168-LPZ-RSW Document 18-8 Filed 05/17/2007 Page 2 of 3 UNITED STATES DISTRICT COURT IN THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION JULIE ANN ROEHM, Plaintiff, v. CASE NO. 2:07-cv-IOI68 W AL-MART STORES, INC., Judge Lawrence P. Zatkoff Mag. Judge R. Steven Whalen Defendant. THE LAW FIR OF JOHN F. SCHAEFER JOHN F. SCHAEFER, (P-19948) ANDREW RIFKIN, (P-46147) Attorneys for Plaintiff 380 North Old Woodward, Suite 320 Birmingham, Michigan 48009 (248) 642-6665 DYKMA GOSSETT PLLC DEBRA M. MCCULLOCH (P-31995) JOSEPH A. RITOK, JR. (P-25472) Attorneys for Defendants 39577 Woodward Avenue, Suite 300 Bloomfield Hills, MI 48304 (248) 203-0785 SOMMERS SCHWARTZ, P.C. SAM G. MORGAN, (P-36694) KEVIN J. STOOPS, (P-64371) Co-Counsel for Plaintiff 2000 Town Center, Suite 900 Southfield, Michigan 48075 (248) 355-0300 GIBSON, DUN & CRUTCHER LLP EUGENE SCALIA KAL G. NELSON DAVID J. DEBOLD (P-39278) Of Counsel for Defendant 1050 Connecticut Avenue, N.W. Washington, D.C. 20036 (202) 955-9500 DECLARTION OF KA G. NELSON I, Karl G. Nelson, declare as follows: 1. I am counsel of record in the above-captioned action. 2. I respectfully submit this declaration in support of Defendant's Brief in Response to Plaintiff s Motion to Remand. Case 2:07-cv-10168-LPZ-RSW Document 18-8 Filed 05/17/2007 Page 3 of 3 3. The exhibits attached to Defendant's Brief in Response to Plaintiffs Motion to Remand are true and correct copies of those documents, except for portions containing potentially sensitive information regarding Plaintiff, which have been redacted for Plaintiff s benefit. 4. Attached as Exhibit B to Defendant's Brief in Response to Plaintiff s Motion to Remand are the results of a LexisNexis search conducted by Defendant, which contain records pertaining to Plaintiff s voter registration. 5. Attached as Exhibit E to Defendant's Brief in Response to Plaintiffs Motion to Remand is a May 8, 2007 e-mail from SIRV A Relocation regarding the suggested and actual list prices for Plaintiff s home in Michigan. I declare under the penalty of peijury that the foregoing is true and correct. Executed on this J"7 i' day of May, 2007. 7 Karl G. N�on dtL 100226 i 13 -iDOC 2

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