White et al v. West Publishing Corporation et al

Filing 60

DECLARATION of Brett Bogan in Support re: 45 MOTION for Summary Judgment.. Document filed by Reed Elsevier Inc.. (Hough, James)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
EDWARD L. WHITE, P.C.,
Plaintiff,
v.

ECF CASE

Civil Action No. 12-CV-1340 (JSR)

WEST PUBLISHING CORPORATION
d/b/a “West,” and REED ELSEVIER INC.
d/b/a LexisNexis,
Defendants.

DECLARATION OF BRETT BOGAN IN SUPPORT OF DEFENDANT REED
ELSEVIER INC.’S MOTION FOR SUMMARY JUDGMENT
I, Brett Bogan, pursuant to 28 U.S.C. § 1746, hereby declare:
1. I submit this declaration in support of Defendant Reed Elsevier Inc.’s Motion for
Summary Judgment. The facts set forth herein are based upon my personal knowledge,
information supplied to me by those working at my direction in the ordinary course of business,
or my review of regularly kept, contemporaneously made business books and records of Reed
Elsevier Inc. If called as a witness, I could and would competently testify about the matters
stated herein.
2. I have been an employee of LexisNexis, a division of Reed Elsevier Inc. (“Lexis”)
since August 7, 2000 and, since April 2010, have been Manager, Security Investigations for
Reed Elsevier Inc.

ny-1060184