Jeff Jonah v. Kimberly-Clark Corporation et al

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

Declaration of Kristen Simplicio

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1 GUTRIDE SAFIER LLP 2 ADAM J. GUTRIDE (State Bar No. 181446) SETH A. SAFIER (State Bar No. 197427) 3 KRISTEN G. SIMPLICIO (State Bar No. 263291) 4 100 Pine Street, Suite 1250 San Francisco, CA 94111 5 Telephone: (415) 271-6469 Facsimile: (415) 449-6469 6 7 Attorneys for Plaintiffs and Proposed Plaintiffs in Intervention 8 UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 JENNIFER DAVIDSON, an individual, on behalf of CASE NO. 4:14-CV-01783 11 herself, the general public and those similarly situated (PJH) 12 Plaintiff, DECLARATION OF KRISTEN SIMPLICIO IN 13 v. SUPPORT OF MOTION TO INTERVENE AND MOTION 14 KIMBERLY-CLARK CORPORATION; KIMBERLY- FOR LEAVE TO FILE A 15 CLARK WORLDWIDE, INC.; KIMBERLY-CLARK CONSOLIDATED AMENDED GLOBAL SALES LLC; AND DOES 1 THROUGH 50 COMPLAINT 16 Defendants Date: March 13, 2019 17 Time: 9:00 a.m. Courtroom 3, 3rd Floor 18 19 Judge: Hon. Phyllis J. Hamilton 20 21 22 23 24 25 26 27 28 SIMPLICIO DECLARATION IN SUPPORT OF MOTIONS TO AMEND/INTERVENE 1 I, Kristen Simplicio, declare and state that: 2 1. I am an attorney licensed to practice law in the State of California and in this 3 Court, and am counsel of record for Plaintiff in the above captioned matter, as well as for Jeff 4 Jonah in his related case, and the four Plaintiffs-in-Intervention. I submit this declaration in 5 support of the Motion to Intervene filed by four Plaintiffs-in-Intervention and in support of 6 Jennifer Davidson and Jeff Jonah's Motion for Leave to File a Consolidated Amended Complaint. 7 Unless otherwise noted, I have personal knowledge of the facts set forth in this declaration and 8 could and would testify competently to them if called upon to do so. 9 2. Attached hereto as Exhibit 1 is a copy of the Consolidated Amended Complaint 10 that the Plaintiffs and Plaintiffs-in-Intervention wish to be filed. 11 3. Attached hereto as Exhibit 2 is a redline comparing the Consolidated Amended 12 Complaint with the operative First Amended Complaint, filed at Dkt. # 26. 13 4. Attached hereto as Exhibit 3 is a redline comparing the Consolidated Amended 14 Complaint with the operative First Amended Complaint, filed in the related case Jonah v. 15 Kimberly-Clark, et al, Case No. 15-cv-3243 at Dkt. # 24. 16 5. I declare under penalty of perjury under the laws of the state of California that the 17 foregoing is true of my own personal knowledge. 18 Executed at Berkeley, California, this 29th day of January 2019. 19 /s/ Kristen Simplicio 20 Kristen Simplicio, Esq 21 22 23 24 25 26 27 28 1 SIMPLICIO DECLARATION IN SUPPORT OF PLAINTIFFS' MOTIONS TO AMEND/INTERVENE