Free Reply Brief - District Court of Delaware - Delaware

Case 1 :04-cv-01488-JJF Document 82-2 Filed 06/14/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ROBERT V. TOWNES, IV, )
Individually and on behalf of all )
Persons similarly situated, )
)
Plaintiff, )
)
v. ) C.A. N0.: O4-1488-JJF
)
TRANS UNION, LLC and )
TRUELINK, INC., )
)
Defendant, )
)
STEVEN G. MILLETT and )
MELODY J. MILLETT, )
Individually and on behalf of all )
Persons similarly situated, )
)
Intervenors )
DECLARATION OF MICHAEL W. BLANTON
IN SUPPORT OF MOTION FOR LEAVE TO INTERVENE
Michael W. Blanton, pursuant to 28 U.S.C. § 1746, declares as follows:
l. I am a member of the Missouri Bar. I have been admitted pro hac vice in the action
designated Millett v. Truelink, Inc., Case No. 05-599—SLR, District of Delaware
("Millett Action"). I have also been admitted pro hac vice in the Townes Action. I
serve as counsel for Steven G. Millett and Melody J. Millett ("Intervenors") and the
putative class of persons that Intervenors seek to represent in the Millett Action. I
submit this declaration in support of Inte1venors’ Motion for Leave to Inteivene.
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Case 1 :04-cv-01488-JJF Document 82-2 Filed 06/14/2007 Page 2 of 3
2. The statements made herein are based upon my personal knowledge and I am competent
to testify to the statements set forth herein.
3. Intervenors’ counsel have deposed three individuals in Illinois and currently have two
additional depositions in California scheduled at the end of June, 2007.
4. Intervenors’ counsel have reviewed over 18,000 pages of documents in the process of
litigating the Millett Action.
5. Intervenors’ counsel have served multiple rounds of discovery on Truelink in the Millett
Action.
6. Intervenors’ counsel are in the final stages of securing expert witnesses for designation
in the Millett Action.
7. Counsel for Intervenors have incurred over $44,000 in expenses to date in the Millett
Action, and anticipate incurring an additional $17,000, at minimum, for depositions and
experts prior to the filing of their motion for certification on August 15, 2007.
8. Discovery in the Millett Action closes on July 15 , 2007 and counsel for Intervenors will
have completed discovery by that date.
9. Expert reports in the Millett Action are due on July 30, 2007 and counsel for Intervenors
will have secured the requisite reports by that date.
10. The motion for class certification in the Millett Action is due on August 15, 2007 and
counsel for Intervenors will be filing a motion for certification by that date.
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Case 1:04-cv-01488-JJF Document 82-2 Filed 06/14/2007 Page 3 of 3
I declare under penalty of perjury that the foregoing is true and correct and that this
Declaration was executed on June 14, 2007, at Kansas City, Missouri.
By¤
Michael W. Blanton
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