Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1 :05-cv-00891-SLR Document 28-2 Filed 11/21/2006 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LINDAJJ. BLOZIS : CIVIL ACTION NO. 05-891 (SLR)
Plaintiff, :
vs. :
MELLON TRUST OF DELAWARE, :
NATIONAL ASSOCIATION; MELLON
BANK, NATIONAL ASSOCIATION; i
MELLON FINANCIAL CORPORATION, _
Defendants.
DECLARATION OF STEPHANIE WILSON, ESQ.
I, Stephanie Wilson, of full age, hereby certify and declare as follows
based upon my own personal information:
1. I am a partner at Reed Smith and have been admitted pro hac vice in this
proceeding. I make this Declaration based on personal knowledge.
2. Prior to Plaintiff’s July 26 deposition Defendants served document and
interrogatory requests. They have subpoenaed documents from PIaintiff’s two Florida
employers, inclusive of her present employer, and have received them. Plaintiff has just
served document and interrogatory requests on November 16, 2006 and have not
noticed any depositions. Fact discovery is scheduled to end on December 29, 2006.
3. On July 26, 2006, I deposed Plaintiff, but did not complete Plaintiffs
deposition. As the Court can see, the deposition was conducted properly and
efliciently. A true and complete copy of the deposition transcript without exhibits is
attached hereto as Exhibit 1.

Case 1 :05-cv—00891-SLR Document 28-2 Filed 11/21/2006 Page 2 of 2
4. As part of discovery, Defendants have sought the medical records from
Plaintiff’s health providers. After receipt of Plaintiffs medical authorizations, Defendants
have subpoenaed sixteen (16) providers and to date have received all but one (1)
medical file.
5. Defendants anticipate, barring any unusual occurrence, needing one
additional day to complete Plaintiffs deposition.
Pursuant to 28 U.S.C. § 1746, I certify under penalty of perjury under the
laws of the United States of America that the foregoing statements made by me are true
and correct. I am aware that if any of the foregoing statements made by me are willfully
false, l am subject to punishment.
St phanie Wilson
Dated: November 21, 2006
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PRCLlB·42B362.1-SWILSON 11/20/05 5:20 PM