Free Declaration in Support - District Court of California - California

Case 3:07-cv-06198-MHP

Document 52

Filed 07/10/2008

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HOWARD RICE NEMEKOVSK1 CANADY FALK KABKIN

GILBERT R. SEROTA (No. 75305) Email: [email protected] MARK A. SHEFT (No. 183732) Email: [email protected] MICHAEL L. GALLO (No. 220552) Email: [email protected] HOWARD RICE NEMEROVSKI CANADY FALK & RABKIN A Professional Corporation Three Embarcadero Center, 7th Floor San Francisco, California 94111-4024 Telephone: 415/434-1600 Facsimile: 415/217-5910 Attorneys for Plaintiffs THOMAS WEISEL PARTNERS LLC and THOMAS WEISEL INTERNATIONAL PRIVATE LIMITED UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

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THOMAS 'WEISEL PARTNERS LLC, a Delaware limited liability company, and THOMAS WEISEL INTERNATIONAL PRIVATE LIMITED, an Indian company, Plaintiffs, V. BNP PARIBAS, a French corporation, BNP PARIBAS SECURITIES (ASIA) LIMITED, a Hong Kong company, and PRAVEEN CHAKRAVARTY, an individual, Defendants.

No. C-07-6198 MHP Action Filed: December 6, 2007 DECLARATION OF KAREN SANTOS IN SUPPORT OF PLAINTIFFS' CONSOLIDATED OPPOSITION TO DEFENDANTS' MOTIONS TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT Date: Time: Place: Judge: August 18, 2008 2:00p.m. Courtroom 15 Hon. Marilyn Hall Patel

SANTOS DECL. ISO OPP. TO DEFS.' MOT. TO DISMISS FIRST AM. COMPL. C-07-6198 MHP

Case 3:07-cv-06198-MHP

Document 52

Filed 07/10/2008

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I, Karen Santos, declare: 2 3 4 5 6 7 8 9 10 11 12
HOWARD RICE NEMEROVSKI CANADY FALK KABKIN

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I am a Vice President in the Compliance Department at Thomas Weisel Partners,

LLC ("TWP LLC"). I have been employed in that position since September 24, 2003. Among my other responsibilities, I am the Central Registration Depository ("CRD") Administrator handling registration and licensing with regulatory bodies for TWP LLC, and all employees associated with TWP LLC. I make this Declaration upon personal knowledge and, if called upon to testify, could and would testify competently hereto. 2. Defendant Praveen Chakravarty, a Director of TWIPL and the head of Discovery

Research's Mumbai operation, was registered with U.S. regulatory authorities (F1NRA, the New York Stock Exchange and the State of California, for example) as an associated person of TWP LLC. Attached hereto as Exhibit A is a true and correct copy of information I retrieved from the FINRA website showing Chakravarty's registrations as an associated person of TWP LLC. 3. Although directly employed by TWIPL, the Discovery Research analysts were,

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like Chakravarty, registered with U.S. regulatory authorities (including FINRA, the NYSE and the State of California) as associated persons of TWP LLC. Attached hereto as Exhibit B are true and correct copies of information I retrieved from the FINRA website showing the Discovery Research analysts' registrations as associated persons of TWP LLC. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed thisow day of June 2008 at San Francisco, California
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SANTOS DECL. ISO OPP. TO DEFS.' MOT. TO DISMISS FIRST AM. COMPL. C-07-6198 MI-1P -1-