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Stanford University Law School - Securities Class Action Clearinghouse

STEVEN M. SCHATZ, State Bar # 118356
TIMOTHY T. SCOTT, State Bar # 126971
DANIEL W. TURBOW, State Bar # 175015
WILSON, SONSINI, GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road
Palo Alto, California 94304-1050
Telephone: (415) 493-9300

Attorneys for Defendants
VINITA GUPTA, DANIEL L. PALMER,
TIMOTHY K. MONTGOMERY, STANLEY E.
KAZMIERCZAK, TONI BELLIN, BENJAMIN W.
BERRY, MOREY R. SCHAPIRA, GREGORY M. AVIS,
CHARLES R. MOORE and DIGITAL LINK CORPORATION

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION


 
GEORGE GENNA, On Behalf of Himself
and All Others Similarly Situated,

                      Plaintiff,

           v.

DIGITAL LINK CORPORATION, et al.,

                      Defendants.
 
 
 
 
 
 

________________________________________

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)		 CASE NO.: C-96-20867-RMW (EAI)
[filed Mar. 13, 1998]

CLASS ACTION

DECLARATION OF DANIEL W.
TURBOW IN SUPPORT OF
DEFENDANTS' MEMORANDUM
REGARDING PROPRIETY OF
TAKING CLASS DISCOVERY OR,
IN THE ALTERNATIVE,
CONDITIONALLY CERTIFYING
THE ACTION AS A CLASS
ACTION

Date: Submitted
Time: Submitted
Judge: Ronald M. Whyte

I, Daniel W. Turbow, declare:

1. I am an attorney duly licensed to practice law in the State of California. I am an associate with the law firm of Wilson, Sonsini, Goodrich & Rosati, counsel of record for defendants in the above captioned-action. I submit this declaration based on personal knowledge, and if called as a witness, could and would competently testify to the matters set forth herein.

2. Attached hereto as Exhibit A are true and correct copies of pages 1, 31-32, and 37 of the Conference Report H.R. Conf. Rep. No. 104-369, 104th Cong., 1st Sess. 31-32 (1995).

3. Attached hereto as Exhibit B is a true and correct copy of a letter I sent to plaintiff's counsel on February 24, 1998, attaching a draft proposed stipulation regarding class certification.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed in Palo Alto, California on March 13, 1998.
 
_______________________________
Daniel W. Turbow

 

Source: File to epost from Wilson Sonsini Goodrich & Rosati