Albritton v. Cisco Systems, Inc. et al

Filing 169

MOTION to Quash Trial Subpoenas to Non Party Witnesses by Bart Showalter, Kevin Meek, Douglas Kubehl, Kurt Pankratz, Jillian Powell. (Attachments: # 1 Declaration of Joseph D. Cheavens in Support of Motion to Quash Trial Subpoenas, # 2 Exhibits 1-4 to Motion to Quash Trial Subpoenas)(Cheavens, Joseph) (Additional attachment(s) added on 2/12/2009: # 3 Text of Proposed Order) (mjc, ).

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION

ERIC M. ALBRITTON
V.

§ § § § §

CASE NO. 6:08CV89

CISCO SYSTEMS, INC., ET AL

DECLARATION OF JOSEPH D. CHEAVENS IN SUPPORT OF THE MOTION TO QUASH TRIAL SUBPOENAS
TO THE HONORABLE DISTRICT JUDGE:

I, JOSEPH D. CHEAVENS, declare and state as follows:

1. My name is Joseph D. Cheavens. I am over twenty-one years of age,
competent in all respects and authorized to execute this Declaration.

2. I am Deputy General Counsel of Baker Botts L.L.P. and a senior counsel of
that firm. I was admitted to practice law in Texas in 1965 and have been admitted to practice in

the Southern, Eastern, and Northern Districts of Texas, before the Fifth Circuit and the United
States Supreme Court. I was a trial parner in the firm of Baker Botts L.L.P. from 1973 until my
retirement as a partner in 2005.

All of the matters stated herein are true and correct and are within my personal
knowledge.
Executed on February 9,2009.

HOU02:116206S.l