Free Declaration - District Court of Arizona - Arizona

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SUSAN MARTIN (AZ#014226) DANIEL L. BONNETT (AZ#014127) JENNIFER KROLL (AZ#019859) MARTIN & BONNETT, P.L.L.C. 3300 N. Central Avenue, Suite 1720 Phoenix, Arizona 85012-2517 Telephone: (602) 240-6900 [email protected] [email protected] [email protected] Attorneys for Plaintiffs

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Barbara Allen, Richard Dippold, Melvin Jones, Donald McCarty, Richard Scates and Walter G. West, individually and on behalf of all others similarly situated, Plaintiffs, vs. Honeywell Retirement Earnings Plan, Honeywell Secured Benefit Plan, Honeywell Savings and Ownership Plan, Plan Administrator of Honeywell Retirement Earnings Plan, Plan Administrator of Honeywell Secured Benefit Plan, and Plan Administrator of Honeywell Savings and Ownership Plan, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. CV04-0424 PHX ROS Declaration of Jennifer Kroll In Support of Plaintiffs Brief Regarding Discovery Dispute On Defendants Claim of AttorneyClient and Work Product Privilege

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Pursuant to 28 U.S.C. § 1746, Jennifer Kroll affirms under penalty of perjury:
1.

I am an attorney for the Plaintiff in the above entitled action. I am fully

familiar with the file in this case. I am of legal age, under no legal disability and if called as a witness could competently testify to the matters set forth herein from my own personal knowledge. 2. I have reviewed Defendants Opposition to Plaintiffs Motion to

Compel Production Of Privileged Documents and the exhibits thereto. Attached

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hereto as Exhibit A is a chart I compiled showing the documents Plaintiffs seek in chronological order by date of document as listed on Defendants Amended Log of Documents Withheld As Privileged and Defendants Supplemental Log of Documents Withheld As Privileged, (Declaration of Azeez Hayne, (Exhibit A to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents),
Exhibits 3 and 4).

3.

The chart attached hereto as Exhibit A also indicates the individuals, if

any, for whom Defendants submitted a supporting declaration with respect to any of the documents sought by Plaintiffs. The following are names used on the chart under the column Supporting Declarations: O Neill = Declaration of Harry J.J. O Neill, Exhibit B to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents Shea = Declaration of Richard Shea, Exhibit C to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents Denlinger = Declaration of Kurt Denlinger, Exhibit D to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents Vine = Declaration of John M. Vine, Exhibit E to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents Gangone = Declaration of Marie Gangone, Exhibit F to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents Gordon = Declaration of David M. Gordon, Esq., Exhibit G to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents Sandstrom = Declaration of Frederick G. Sandstrom, Exhibit H to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents

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Huvelle = Declaration of Jeffrey G. Huvelle, Exhibit I to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents Sonnenschein = Declaration of Eric R. Sonnenschein, Exhibit J to Defendants Opposition to Plaintiffs Motion to Compel Production Of Privileged Documents

Respectfully submitted this 18th day of September, 2006.

s/Jennifer Kroll Jennifer Kroll

CERTIFICATE OF SERVICE I hereby certify that on July 20, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Michael L. Banks, Esq. William J. Delany, Esq. John G. Ferreira, Esq. Azeez Hayne, Esq. Morgan Lewis & Bockius LLP 1701 Market Street Philadelphia, PA 19103 David B. Rosenbaum Dawn L. Dauphine OSBORN MALEDON, P.A. 2929 North Central Ave., Suite 2100 Phoenix, AZ 85012-2794 Amy Covert Proskauer Rose LLP One Newark Center, 18th Floor Newark , NJ 07102-5211

s/T. Mahabir

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