National Federation of the Blind et al v. Target Corporation Doc.

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Case 3:06-cv-01802-MHP Document 129 Filed 05/29/2007 Page 1 of 2

1 HAROLD J. McELHINNY (CA SBN 66781)

MATTHEW I. KREEGER (CA SBN 153793)
2 KRISTINA PASZEK (CA SBN 226351)
HMcElhinny@mofo.com
3 MKreeger@mofo.com
KPaszek@mofo.com
4 MORRISON & FOERSTER LLP
425 Market Street
5 San Francisco, California 94105-2482
Telephone: (415) 268-7000
6 Facsimile: (415) 268-7522
7 Attorneys for Defendant
TARGET CORPORATION
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9 UNITED STATES DISTRICT COURT

10 NORTHERN DISTRICT OF CALIFORNIA

11 SAN FRANCISCO DIVISION

12

13 NATIONAL FEDERATION OF THE BLIND, Case No. C 06-01802 MHP

the NATIONAL FEDERATION OF THE
14 BLIND OF CALIFORNIA, on behalf of their DECLARATION OF KRISTINA
members, and Bruce F. Sexton, on behalf of PASZEK IN SUPPORT OF TARGET
15 himself and all others similarly situated, CORPORATION’S
ADMINISTRATIVE MOTION
16 Plaintiffs, REQUESTING A BRIEFING
SCHEDULE AND FURTHER
17 v. DEPOSITIONS

18 TARGET CORPORATION, Judge: Hon. Marilyn Hall Patel

19 Defendant.

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PASZEK DECL. ISO TARGET’S ADMIN. MOTION FOR BRIEFING SCHEDULE AND FURTHER DEPOSITIONS
CASE NO. C 06-01802 MHP
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 Case 3:06-cv-01802-MHP Document 129 Filed 05/29/2007 Page 2 of 2

1 I, Kristina Paszek, declare and state as follows:

2 1. I am an associate in the law firm of Morrison & Foerster LLP, counsel of
3 record for Defendant Target Corporation (“Target”) in the above-entitled case. I am duly
4 admitted to practice before all state courts and federal district courts in the State of
5 California. I have personal knowledge of the facts set forth in this declaration and, if called
6 as a witness, could and would competently testify to the matters set forth herein.
7 2. Attached hereto as Exhibit A is a true and correct copy of an email that I sent
8 on May 23, 2007 to counsel for Plaintiffs in the above-entitled case. The email follows up on
9 a telephone conversation that I had earlier that day with Roger Heller, counsel for Plaintiffs.
10 3. Attached hereto as Exhibit B are true and correct copies of a fax and an email
11 that I received from counsel for Plaintiffs on May 24, 2007.
12 4. Attached hereto as Exhibit C is a true and correct copy of an email that I sent
13 to counsel for Plaintiffs on May 25, 2007.
14 5. Attached hereto as Exhibit D is a true and correct copy of a fax that I received
15 from counsel for Plaintiffs on May 25, 2007.
16 6. As the foregoing correspondence shows, despite multiple requests, Plaintiffs
17 neither consented to, nor definitively objected to, the relief sought in Target’s administrative
18 motion requesting a briefing schedule and further depositions.
19 I declare under penalty of perjury under the laws of the State of California and the
20 United States that the foregoing is true and correct.
21 Executed this 29th day of May, 2007, at San Francisco, California.
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23 /s/ Kristina Paszek

Kristina Paszek
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PASZEK DECL. ISO TARGET’S ADMIN. MOTION FOR BRIEFING SCHEDULE AND FURTHER DEPOSITIONS
CASE NO. C 06-01802 MHP
1
sf-2328624