Free Declaration in Support - District Court of California - California

Case 5:07-cv-04920-JF

Document 47

Filed 07/02/2008

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1 EDMUND G. BROWN JR. Attorney General of the State of California 2 DAVID S. CHANEY Chief Assistant Attorney General 3 FRANCEST.GRUNDER Senior Assistant Attorney General 4 THOMAS S. PATTERSON Supervising Deputy Attorney General 5 TRACE O. MAIORINO, State Bar No. 179749 Deputy Attorney General 6 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 7 Telephone: (415) 703-5975 Fax: (415) 703-5843 8 Email: [email protected] 9 Attorneys for Defendants Lemon, Ayers, Tilton, Ebert, Ortiz, Plymesser, Robinson, Ratliff, and Grannis 10
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IN THE UNITED STATES DISTRICT COURT 12 FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DNISION 14 15 16 17 18 19 20 21 22 I, TRACE O. MAIORINO, declare as follows: 1. I am an attorney admitted to practice before the courts of the State of California and

GREGORY TABAREZ,
Plaintiff,

C 07-4920 JF

DECLARATION OF TRACE

v.
JAMES TILTON, et aI.,
Defendants.

O.MAIORINO IN SUPPORT
OF DEFENDANTS' MOTION

FORASTAY OF

DISCOVERY PENDING RULING ON DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

23 before this Court. I am employed by the California Attorney General's Office as a Deputy 24 Attorney General in the Correctional Law Section. I am assigned to represent Defendants

25 Lemon, Ayers, Tilton, Ebert, Ortiz, Plymesser, Robinson, Ratliff, and Grannis in this case. I am 26 27 competent to testify to the matters as set forth herein, and if called to do so, I would and could so testify. I submit this declaration in support of Defendants' motion for a stay of discovery

28 pending a ruling on Defendants' motion for summary judgment.
Decl. MaiorinoSupp. Defs.' Mot. Stay Disc. Pending Defs.' Mot. Summ. J.

G. Tabarez v. 1. Tilton, et at.
C 07-4920 JF

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Case 5:07-cv-04920-JF

Document 47

Filed 07/02/2008

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2.

Plaintiff has served discovery requests on Defendants and they have provided timely

2 responses. On May 2,2008, Defendant Ortiz served his responses to Plaintiffs interrogatories, 3 request for production of documents, and requests for admissions. On May 30, 2008 Defendants 4 Tilton and Ebert served their responses to Plaintiffs interrogatories, request for production of 5 documents, and requests for admissions. On June 2, 2008, Defendant Plymesser served her 6 responses to Plaintiffs interrogatories, request for production of documents, and requests for 7 admissions. On June 23,2008, Defendants Ratliff, Robinson, Ayers, and Lemon served their 8 responses to Plaintiffs interrogatories, request for production of documents, and requests for 9 admissions. Defendant Grannis served her responses to Plaintiffs interrogatories and request for 10 admissions on June 23,2008. 11 I declare under penalty of perjury that the foregoing is true and correct to the best of my

12 knowledge and that this declaration is executed on July 2,2008 at San Francisco, California. 13 14 15 16 17 18 19 20 21 22 23 24
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Decl. Maiorino Supp. Defs.' Mot. Stay Disc. Pending Defs.' Mot. Summ. J.

G. Tabarez v. J. Tilton, et at.
C 07-4920 JF

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