Jeff Jonah v. Kimberly-Clark Corporation et al

Northern District of California, cand-4:2015-cv-03243

Declaration of Darlene Cho In Support of Defendants' Opposition to Plaintif

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1 Amy P. Lally, SBN 198555 alally@sidley.com 2 Darlene M. Cho, SBN 251167 dcho@sidley.com 3 SIDLEY AUSTIN LLP 1999 Avenue of the Stars, 17th Fl. 4 Los Angeles, California 90067 Telephone: (310) 595-9500 5 Facsimile: (310) 595-9501 6 Naomi A. Igra, SBN 269095 nigra@sidley.com 7 SIDLEY AUSTIN LLP 555 California Street, Suite 2000 8 San Francisco, CA 94104 Telephone: (415) 772-1200 9 Facsimile: (415) 772-7400 10 Sheri Porath Rockwell, SBN 165726 sheri.rockwell@sidley.com 11 SIDLEY AUSTIN LLP 555 W. Fifth Street, Suite 4000 12 Los Angeles, CA 90013 Telephone: (213) 896-6000 13 Facsimile: (213) 896-6600 14 Attorneys for Defendants KIMBERLY-CLARK CORPORATION; 15 KIMBERLY-CLARK GLOBAL SALES, LLC; and KIMBERLY-CLARK 16 WORLDWIDE, INC. 17 UNITED STATES DISTRICT COURT 18 FOR THE NORTHERN DISTRICT OF CALIFORNIA 19) Case No. 15-cv-03243-PJH 20 JEFF JONAH, an individual, on behalf of) (Related to Case No. 4:14-CV-01783-PJH) himself, the general public and those similarly) 21 situated,) Assigned to: Hon. Phyllis J. Hamilton) 22 Plaintiff,) DECLARATION OF DARLENE M. CHO) IN SUPPORT OF DEFENDANTS' 23 v.) OPPOSITIONS TO PLAINTIFFS') MOTION FOR LEAVE TO FILE 24 KIMBERLY-CLARK CORPORATION;) CONSOLIDATED AMENDED KIMBERLY-CLARK WORLDWIDE, INC.;) COMPLAINT AND TO INTERVENORS' 25 KIMBERLY-CLARK GLOBAL SALES) MOTION TO INTERVENE LLC; and DOES 1 through 50) 26) Complaint Filed: June 9, 2015 Defendants.) Trial Date: None Set 27) 28 DECLARATION OF DARLENE M. CHO CASE NOS. 15-CV-03243- PJH; 4:14-CV-01783-PJH 1 JENNIFER DAVIDSON, an individual, on) behalf of herself, the general public and) 2 those similarly situated,)) 3 Plaintiff,) v.) 4) KIMBERLY-CLARK CORPORATION;) 5 KIMBERLY-CLARK WORLDWIDE, INC.;) KIMBERLY-CLARK GLOBAL SALES) 6 LLC; and DOES 1 through 50,)) 7 Defendants.) 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ii DECLARATION OF DARLENE M. CHO CASE NOS. 15-CV-03243- PJH; 4:14-CV-01783-PJH 1 DECLARATION OF DARLENE M. CHO 2 I, Darlene M. Cho, declare as follows: 3 1. I am an attorney at Sidley Austin LLP, counsel of record for defendants Kimberly- 4 Clark Global Sales LLC, Kimberly-Clark Corporation and Kimberly-Clark Worldwide, Inc. 5 ("Defendants") in the above-captioned action. I am admitted to practice before this Court. This 6 Declaration is made in support of Defendants' Opposition to Plaintiffs' Motion for Leave to File the 7 Proposed Consolidated Amended Complaint. I have personal knowledge of the following facts and, 8 if called and sworn as a witness, could and would competently testify thereto. 9 2. To date, the parties have engaged in the following discovery: 10 • Plaintiff Jennifer Davidson ("Davidson") propounded and Defendants responded to 11 Davidson's First Set of Requests for Production, First Set of Interrogatories, and Second 12 Set of Requests for Production. 13 • Defendants propounded and Davidson responded to Defendants' First Set of Requests for 14 Production, First Set of Interrogatories, First Set of Request for Admissions, Second Set 15 of Requests for Production, Second Set of Interrogatories, Second Set of Request for 16 Admissions. Defendants also served a Third Set of Request for Admissions, responses to 17 which are due on March 4, 2019. 18 • Defendants propounded and Plaintiff Jeff Jonah ("Jonah") responded to Defendants' First 19 Set of Requests for Production, First Set of Interrogatories, First Set of Request for 20 Admissions, Second Set of Requests for Production, Second Set of Interrogatories, Second 21 Set of Request for Admissions. Defendants also served a Third Set of Request for 22 Admissions, responses to which are due on March 4, 2019. 23 • To date, Defendants have produced over 16,000 documents, totaling over 100,000 pages, 24 in response to Plaintiffs' discovery requests. 25 • To date, Jonah and Davidson have produced 50 documents, totaling just over 1,000 26 pages. 27 3. As of the date of filing this Declaration, document discovery is winding down and 28 Defendants are nearing completion of their document production. 1 DECLARATION OF DARLENE M. CHO CASE NOS. 15-CV-03243- PJH; 4:14-CV-01783-PJH 1 4. Prior to Feb. 15, 2019, Defendants and Plaintiffs were in the midst of scheduling 2 depositions. 3 I declare under penalty of perjury under the laws of the United States of America that the 4 foregoing is true and correct. Executed this 18th day of February, 2019, at Los Angeles, California. 5 6 /s/ Darlene M. Cho 7 Darlene M. Cho 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 DECLARATION OF DARLENE M. CHO CASE NOS. 15-CV-03243- PJH; 4:14-CV-01783-PJH