Kim v. Coach, Inc, et al

Filing 45

DECLARATION of R. Omar Riojas in Support of Defendants' Motion to Strike Class Allegations filed by Defendants Coach Services Inc, Coach, Inc., Counter Claimant Coach, Inc. re 42 SEALED MOTION to Strike Class Allegations; re 40 MOTION to Seal Defendants' Motion to Strike Class Allegations and Declarations of John Macaluso and Nancy Axilrod ; SEALED MOTION to Strike Class Allegations; re 40 MOTION to Seal Defendants' Motion to Strike Class Allegations and Declarations of John Macaluso and Nancy Axilrod ; (Keehnel, Stellman)

THE HONORABLE RICARDO S. MARTINEZ

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

8
9
10
11

GINA KIM, on behalf of a class consisting
of herself and all other persons similarly
situated,

12
13
14
15

v.

Plaintiffs, and as to Ms.
Kim, counterclaim
defendant,

COACH, INC., a Maryland corporation,
and COACH SERVICES, INC., a
Maryland corporation,

No. 2:11-cv-00214-RSM

DECLARATION OF R. OMAR RIOJAS
IN SUPPORT OF DEFENDANTS’
MOTION TO STRIKE CLASS
ALLEGATIONS

16
Defendants, and, as to
Coach, Inc., counterclaim
plaintiff.

17
18
19
20
21
22
23
24
25
26

I, R. Omar Riojas, declare as follows:
1.

Declarant: I am an attorney licensed to practice law in the state of Washington

and am admitted to practice before this Court. I work in the Seattle office of DLA Piper LLP
(US). I am one of the attorneys representing defendants in the above-captioned lawsuit. I have
personal knowledge of the facts stated below and am competent to testify thereto.
2.

On March 31, 2011, plaintiff’s counsel Jay Carlson and Christopher Carney and

defense counsel (Messrs. Keehnel and Eagan and myself) held a Rule 26(f) conference via a
conference call. During the Rule 26(f) conference, plaintiff’s counsel represented defense
DECLARATION OF R. OMAR RIOJAS IN
SUPPORT OF MOTION TO STRIKE CLASS
ALLEGATIONS - 1
No. 2:11-cv-00214-RSM

DLA Piper LLP (US)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104-7044 | Tel: [phone]

1

counsel that plaintiff Ms. Kim is seeking damages for emotional distress as part of the above-

2

captioned lawsuit.

3
4
5
6

I declare under the penalties for perjury under the laws of the United States that the
foregoing is true and correct.
Signed at Seattle, Washington, on April 14, 2011.

7
8
9
10

s/ R. Omar Riojas
____
R. Omar Riojas WSBA No. 35400

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
DECLARATION OF R. OMAR RIOJAS IN
SUPPORT OF MOTION TO STRIKE CLASS
ALLEGATIONS - 2
No. 2:11-cv-00214-RSM

DLA Piper LLP (US)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104-7044 | Tel: [phone]

CERTIFICATE OF SERVICE

1

I hereby certify that on April 14, 2011, I electronically filed the foregoing, under seal,

2
3

with the Clerk of the Court using the CM/ECF System.
Copies of the foregoing document were served on counsel of record via email, by

4
5
6

agreement, at the following email addresses:


Jay S Carlson
[e-mail]



Christopher Robert Carney
[e-mail]



Jason Moore
[e-mail]

7
8
9
10
11
12

Dated this 14th day of April, 2011.

13

s/ Stellman Keehnel
Stellman Keehnel, WSBA No. 9309

14
15
16

WEST\223367007.1

17
18
19
20
21
22
23
24
25
26
DECLARATION OF R. OMAR RIOJAS IN
SUPPORT OF MOTION TO STRIKE CLASS
ALLEGATIONS - 3
No. 2:11-cv-00214-RSM

DLA Piper LLP (US)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104-7044 | Tel: [phone]