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ase 2:10-cv-09198-JVS -RNB Document 204-1 Filed 04/17/12 Page 1of2 Page ID #:8210
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 REVIEW OF MAGISTRATE JUDGE Plaintiffs, BLOCK’S MARCH 20, 2012 ORDER DENYING PLAINTIFFS’ MOTION TO VS. COMPEL IN PART AND GRANTING DEFENDANT’S MOTION FOR PROTECTIVE LIFE INSURANCE COMPANY OF ORDER IN PART THE SOUTHWEST, a Texas corporation, and DOES 1-50, Judge James V. Selna Defendant. Courtroom: 10C
DECLARATION OF JOEL FLEMING IN OPPOSITION TO PLAINTIFF’ MOTION FOR REVIEW OF MAGISTRATE JUDGE BLOCK’S MARCH 20, 2012 ORDER DENYING PLAINTIFFS’ MOTION TO COMPEL IN PART AND GRANTING DEFENDANT’S MOTION FOR PROTECTIVE ORDER IN PART, 10-09198 JVS(RNBx)
ase 2:10-cv-09198-JVS -RNB Document 204-1 Filed 04/17/12 Page 2of2 Page ID #:8211
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 Review of Magistrate Judge Block’s March 20, 2012 Order Denying Plaintiffs’ Motion to Compel in Part and Granting Defendant’s Motion for Protective Order in part. 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 A is a true and correct copy of excerpts from the transcript of the March 20, 2012 discovery hearing before Magistrate Judge Block.
a: Attached hereto as Exhibit B is a true and correct copy of an email chain between Stephan Mayr, Elizabeth MacGowan, Nancy Winings, and Matthew DeSantos between October 29 and October 30, 2009, produced by LSW to Plaintiffs as LSW- E00043997-8.
I declare under the penalty of perjury that the foregoing is true and correct. Executed this
17th day of April, 2012, at Palo Alto, California.
By: /s/ Joel Fleming
Joel Fleming
ec DECLARATION OF JOEL FLEMING IN OPPOSITION TO PLAINTIFF’ MOTION FOR REVIEW OF MAGISTRATE JUDGE BLOCK’S MARCH 20, 2012 ORDER DENYING PLAINTIFFS’ MOTION TO COMPEL IN PART AND GRANTING DEFENDANT’S MOTION FOR PROTECTIVE ORDER IN PART, 10-09198 JVS(RNBx)