Free Declaration in Support - District Court of California - California


File Size: 128.4 kB
Pages: 3
Date: December 31, 1969
File Format: PDF
State: California
Category: District Court of California
Author: unknown
Word Count: 908 Words, 5,693 Characters
Page Size: Letter (8 1/2" x 11")
URL

https://www.findforms.com/pdf_files/cand/193052/44-1.pdf

Download Declaration in Support - District Court of California ( 128.4 kB)


Preview Declaration in Support - District Court of California
Case 3:O7—cv-O3114—SI Document 44 Filed O9/O5/2008 Page 1 of 3
1 SEYFARTH SHAW LLP
Dana L. Peterson (SBN 178499) [email protected]
2 Jonathan D. Martin (SBN 188744) [email protected]
Andrew M. McNaught (SBN 209093) [email protected]
3 560 Mission Street, Suite 3100
San Francisco, California 94105
4 Telephone: (415) 397-2823
Facsimile: (415) 397—8549
5
Attorneys for Defendant
6 KAISER FOUNDATION HEALTH PLAN, INC.
7
8
9 UNITED STATES DISTRICT COURT
10 IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA
11 FERNANDO DAROSA, ) Case No. C07-03114 SI
)
12 Plaintiff, ) DECLARATION OF JONATHAN D.
) MARTIN IN SUPPORT OF
13 v. ) DEFENDANT KAISER FOUNDATION
) HEALTH PLAN, INC.’S MOTION FOR
14 KAISER FOUNDATION HEALTH PLAN, ) SUMMARY JUDGMENT OR IN THE
INC., ) ALTERNATIVE SUMMARY
15 ) ADJUDICATION
Defendant. )
16 ) Date: October 31, 2008
) Time: 9:00 AM
17 ) Location: Courtroom 10, 19th Floor
) Judge: The Honorable Susan Illston
18 )
...._ .---2-LL. ..... M- .... ..... -...-3---.r-v ..,........... -LJ
19
20 I, Jonathan D. Martin, declare as follows:
2] 1. I am an associate at the law firm of Seyfarth Shaw LLP, counsel of record for
22 defendant Kaiser Foundation Health Plan, Inc. I make this declaration based on my own
23 personal knowledge, and in support of defendant’s motion for summary judgment, or in the
24 alternative summary adjudication. If called as a witness, I could and would competently testify
2 5 to the facts set forth herein.
Q6 2. Attached hereto as Exhibit A is a true and correct copy of relevant portions of the
27 deposition transcript of plaintiff Fernando daRosa.
28
'i5i€iTFtWE5@`tT§i— 77+ iiiii

Case 3:O7—cv-O3114—SI Document 44 Filed O9/O5/2008 Page 2 of 3
1 3. Attached hereto as Exhibit B is a true and correct copy ofthe document marked as
2 Exhibit 2 at Plaintiff s deposition. The document was authenticated by Plaintiff at his deposition
3 as part ofthe testimony attached hereto as Exhibit A (page and line numbers are referenced in
4 the accompanying motion).
5 4. Attached hereto as Exhibit C is a true and correct copy of the document marked as
6 Exhibit 5 at Plaintiffs deposition. The document was authenticated by Plaintiff at his deposition
7 as part of the testimony attached hereto as Exhibit A (page and line numbers are referenced in
8 the accompanying motion).
9 5. Attached hereto as Exhibit D is a true and correct copy of relevant portions of the
10 deposition transcript of Dr. Frank Dustin.
1 1 6. Attached hereto as Exhibit E is a true and correct copy of the document marked as
12 Exhibit 7 at the deposition of Dr. Dustin. The document was authenticated by Dr. Dustin at his
13 deposition as part ofthe testimony attached hereto as Exhibit D (page and line numbers are
14 referenced in the accompanying motion).
15 7. Attached hereto as Exhibit F is a true and correct copy of the document marked as
16 Exhibit 8 at Plaintiffs deposition. The document was authenticated by Plaintiff at his deposition
17 as part ofthe testimony attached hereto as Exhibit A (page and line numbers are referenced in
18 the accompanying motion).
19 8. Attached hereto as Exhibit G is a true and correct copy of relevant portions of the
20 deposition transcript of Anastacia Freitas.
21 9. Attached hereto as Exhibit H is a true and correct copy of the document marked
22 as Exhibit 3 at the deposition ofMs. Freitas. The document was authenticated by Ms. Freitas at
23 her deposition as part ofthe testimony attached hereto as Exhibit G (page and line numbers are
24 referenced in the accompanying motion).
25 IO. Attached hereto as Exhibit I is a true and correct copy of the document marked as
26 Exhibit 9 at Plaintiff s deposition. The document was authenticated by Plaintiff at his deposition
27 as part ofthe testimony attached hereto as Exhibit A (page and line numbers are referenced in
28 the accompanying motion).
..2_w_é__._.-._-._k__--.___..__h2__-___,____a+~*.a_%_
DECLARATION OF JONATHAN D. MARTIN A- CASE NO. CO7—()31 14 SI

Case 3:O7—cv-O3114—SI Document 44 Filed O9/O5/2008 Page 3 of 3
l l 1. Attached hereto as Exhibit J is a true and correct copy of relevant portions of the
2 deposition transcript of Margie Roper.
3 12. Attached hereto as Exhibit K is a true and correct copy of the document marked
4 as Exhibit 9 at the deposition of Dr. Dustin. The document was authenticated by Dr. Dustin at
5 his deposition as part ofthe testimony attached hereto as Exhibit D (page and line numbers are
6 referenced in the accompanying motion).
7 13. Attached hereto as Exhibit L is a true and correct copy of Plaintiffs Initial
8 Disclosures in this case, which were received by Defendant in November 2007. Defendant has
9 not received any amendment, update or supplementation ofPlaintiff` s Initial Disclosures.
10 I declare under penalty of perjury under the laws ofthe United States of America that the
11 foregoing is true and correct.
12 Executed this 5th day of September, 2008 at San Francisco, CA.
13 Z _
M % 42 Aide
15 JONATHAN D. MARTIN
16
17
18
19
20
21
22
23
24
25
26
27
28 sri zxssssoxi
M_(.__..--__-_-.-._ c._....._ 3 ..__..... 3.... 2 ,...,.. ,t.., Q ..... ,--”
DECLARATION OF JONATHAN D. MARTIN 7 CASE NO. C07—03 1 14 SI

Case 3:07-cv-03114-SI

Document 44

Filed 09/05/2008

Page 1 of 3

Case 3:07-cv-03114-SI

Document 44

Filed 09/05/2008

Page 2 of 3

Case 3:07-cv-03114-SI

Document 44

Filed 09/05/2008

Page 3 of 3