Free Response in Opposition to Motion - District Court of California - California

Case 3:07-cv-02301-JLS-POR

Document 37-5

Filed 07/31/2008

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LYNN HUBBARD III, SBN 69773 SCOTTLYNN J HUBBARD IV, SBN 212970 LAW OFFICES OF LYNN HUBBARD 12 Williamsburg Lane Chico, CA 95926 Telephone: (530) 895-3252 Facsimile: (530) 894-8244 Attorneys for Plaintiff

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

) ) ) Plaintiff, ) ) ) vs. ) RALPHS GROCERY COMPANY ) ) dba FOOD 4 LESS #780; CYPRESS ) ) CREEK CO., LP dba PTC ) INVESTMENTS COMPANY, ) ) Defendants. ) ) ) ) A. J. OLIVER,

No. 07cv2301 JLS (POR) DECLARATION OF MERRY M. LOWE IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT RALPH GROCERY COMPANY'S MOTION FOR SANCTIONS

Oliver v. Ralphs Grocery Company, et al. Case No. 07cv2301 JLS (POR) Declaration of Merry M. Lowe in Support of Opposition to Defendant's Motion for Sanctions

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Case 3:07-cv-02301-JLS-POR

Document 37-5

Filed 07/31/2008

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I, MERRY M. LOWE, declare: 1. 2. 3. I have been a legal assistant for almost 17 years. I am employed by the Disabled Advocacy Group, APLC. On or about June 4, 2008, Steve Wedel, one of my attorneys,

asked me to contact opposing counsel Michael Chilleen to request an extension for our Plaintiff A. J. Oliver's responses to Ralphs Grocery Company's discovery requests. 4. extension. 5. 6. 7. deposition. I hereby declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. DATED: July 30, 2008 /s/ Merry M. Lowe MERRY M. LOWE, Legal Assistant At that time, I spoke with Melissa, Mr. Chilleen's assistant. She At no time during that conversation did she inform me of any Had they done so I would have immediately checked Mr. Hubbard's granted my request and gave our office an additional week to respond. upcoming deposition. calendar to insure he had ample time to review Mr. Oliver's responses before his On or about June 4, 2008, I phoned Mr. Chilleen to request said

Oliver v. Ralphs Grocery Company, et al. Case No. 07cv2301 JLS (POR) Declaration of Merry M. Lowe in Support of Opposition to Defendant's Motion for Sanctions

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