Case 2:10-cv-09198-JVS -RNB Document 179 _ Filed 03/26/12 Page 1of2 Page ID #:7578
JONATHAN A. SHAPIRO (257199)
WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road
Palo Alto, CA 94304
Tel: (650) 858-6101
Fax: (650) 858-6100
jonathan.shapiro @ wilmerhale.com
ANDREA J. ROBINSON (PRO HAC VICE) TIMOTHY J. PERLA (PRO HAC VICE) WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street
Boston, MA 02109
Tel: (617) 526-6000
Fax: (617) 526-5000 andrea.robinson @ wilmerhale.com timothy.perla@ wilmerhale.com
Attorneys for Defendant Life Insurance Company of the Southwest
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION JOYCE WALKER, KIM BRUCE Case No.: 10-09198 JVS(RNBx) HOWLETT, and MURIEL SPOONER on behalf of themselves and all others DECLARATION OF JOEL FLEMING IN similarly situated, OPPOSITION TO PLAINTIFFS’ MOTION FOR LEAVE TO FILE SECOND AMENDED Plaintiffs, COMPLAINT VS. Judge James V. Selna LIFE INSURANCE COMPANY OF Courtroom: 10C
THE SOUTHWEST, a Texas corporation, and DOES 1-50,
Defendant.
DECLARATION OF JOEL FLEMING IN OPPOSITION TO PLAINTIFF’ MOTION FOR LEAVE TO FILE SECOND
AMENDED COMPLAINT, 10-09198 JVS(RNBx)
Case 2:10-cv-09198-JVS -RNB Document 179 _ Filed 03/26/12 Page 2of2 Page ID #:7579
DECLARATION OF JOEL FLEMING I, Joel Fleming, declare as follows:
1. I am an attorney duly licensed to practice law in the State of California and before this Court. I am an associate at the law firm of Wilmer Cutler Pickering Hale and Dorr LLP, counsel for Defendant Life Insurance Company of the Southwest (“LSW?’’) in the above-entitled action. I respectfully submit this Declaration in opposition to Plaintiffs’ Motion for Leave to File a Second Amended Complaint. I have personal knowledge of the facts stated herein and, if called as a witness, I could and would testify competently thereto.
2. Attached hereto as Exhibit 1 is a February 13, 2012 letter sent by LSW to Plaintiffs.
3. Attached hereto as Exhibit 2 is a June 8, 2011 letter sent by Plaintiffs to LSW.
I declare under the penalty of perjury that the foregoing is true and correct. Executed
this 26th day of March, 2012, at Palo Alto, California.
By: /s/ Joel Fleming Joel Fleming
Pe DECLARATION OF JOEL FLEMING IN OPPOSITION TO PLAINTIFF’ MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT, 10-09198 JVS(RNBx)