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Case 2:10-cv-09198-JVS -RNB Document 361 Filed 12/12/12 Page1of3 Page ID #:16282
Jonathan A. Shapiro (257199)
WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road
Palo Alto, California 93304
Tel: (650) 858-6101
Fax: (650) 858-6100
jonathan.shapiro @ wilmerhale.com
Andrea J. Robinson (pro hac vice)
Timothy J. Perla (pro hac vice)
Joel Fleming (281264)
WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street
Boston, Massachusetts 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.: CV 10-9198-JVS(RNBx)
HOWLETT, and MURIEL SPOONER, on behalf of themselves and all others
similarly situated, DECLARATION OF JOEL FLEMING IN SUPPORT OF LSW’S Plaintiffs, OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL AND FOR AN VS. ORDER REGARDING DEPOSITIONS
LIFE INSURANCE COMPANY OF THE SOUTHWEST, a Texas corporation, and DOES 1-50
Defendant.
DECLARATION OF JOEL FLEMING, 10-09198-JVS(RNBx) ActiveUS 104017655v.1
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Case 2:10-cv-09198-JVS -RNB Document 361 Filed 12/12/12 Page2of3 Page ID #:16283
DECLARATION OF JOEL FLEMING
I, Joel Fleming, declare as follows:
1. I am an attorney duly licensed to practice law in the Commonwealth of Massachusetts, 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 have personal knowledge of the facts stated herein and, if called as a witness, I could and would testify competently thereto.
on Attached hereto as Exhibit A is a true and accurate copy of an April 26, 2012 letter sent by counsel for LSW to counsel for Plaintiffs.
3. Attached hereto as Exhibit B is a true and accurate copy of excerpts of the transcript of the deposition of Susan Rusnock.
4. Attached hereto as Exhibit C is a true and accurate copy of a June 7, 2012 letter sent by counsel for LSW to counsel for Plaintiffs.
a Attached hereto as Exhibit D is a true and accurate copy of excerpts of the transcript of the deposition of Victoria McDonald.
6. Attached hereto as Exhibit E is a true and accurate copy of excerpts of the transcript of the deposition of Stephanie Burmester.
Vs Attached hereto as Exhibit F is a true and accurate copy of excerpts of the transcript of the deposition of Joyce Walker.
2. DECLARATION OF JOEL FLEMING, 10-09198 JVS(RNBx) ActiveUS 104017655v.1
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Case 2:10-cv-09198-JVS -RNB Document 361 Filed 12/12/12 Page3of3 Page ID #:16284
8. Attached hereto as Exhibit G is a true and accurate copy of excerpts of the transcript of the second day of deposition of Kim Bruce Howlett.
9. Attached hereto as Exhibit H is a true and accurate copy of excerpts of the transcript of the first day of deposition of Kim Bruce Howlett. I declare under the penalty of perjury that the foregoing is true and correct.
Executed this 11th day of December, 2012, at Boston, Massachusetts.
By: /s/ Joel Fleming Joel Fleming
oe DECLARATION OF JOEL FLEMING, 10-09198 JVS(RNBx) ActiveUS 104017655v.1