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    D J R. M G O T D ' A M T E T P L Case No: 4:10-cv-00257-SBA Pa-1390310

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    This document is a declaration by James R. McGuire in support of plaintiff Karen Golinski's opposition to the United States Office of Personnel Management's administrative motion for leave to file an opposition brief exceeding the page limit. McGuire declares that he met and conferred with OPM's counsel regarding the court's standing order, but OPM waited until the day before its brief was due to request a stipulation to exceed the page limit, in violation of the court's requirement to request an extension at least 7 days in advance. McGuire provides supporting documentation of his communications with OPM's counsel regarding the page limit and timing requirements.

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    D J R. M G O T D ' A M T E T P L Case No: 4:10-cv-00257-SBA Pa-1390310

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    Equality Case Files
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    This document is a declaration by James R. McGuire in support of plaintiff Karen Golinski's opposition to the United States Office of Personnel Management's administrative motion for leave to file an opposition brief exceeding the page limit. McGuire declares that he met and conferred with OPM's counsel regarding the court's standing order, but OPM waited until the day before its brief was due to request a stipulation to exceed the page limit, in violation of the court's requirement to request an extension at least 7 days in advance. McGuire provides supporting documentation of his communications with OPM's counsel regarding the page limit and timing requirements.

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    3:10-cv-00257 #27

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    This document is a declaration by James R. McGuire in support of plaintiff Karen Golinski's opposition to the United States Office of Personnel Management's administrative motion for leave to file an opposition brief exceeding the page limit. McGuire declares that he met and conferred with OPM's counsel regarding the court's standing order, but OPM waited until the day before its brief was due to request a stipulation to exceed the page limit, in violation of the court's requirement to request an extension at least 7 days in advance. McGuire provides supporting documentation of his communications with OPM's counsel regarding the page limit and timing requirements.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    32 views8 pages

    D J R. M G O T D ' A M T E T P L Case No: 4:10-cv-00257-SBA Pa-1390310

    Uploaded by

    Equality Case Files
    This document is a declaration by James R. McGuire in support of plaintiff Karen Golinski's opposition to the United States Office of Personnel Management's administrative motion for leave to file an opposition brief exceeding the page limit. McGuire declares that he met and conferred with OPM's counsel regarding the court's standing order, but OPM waited until the day before its brief was due to request a stipulation to exceed the page limit, in violation of the court's requirement to request an extension at least 7 days in advance. McGuire provides supporting documentation of his communications with OPM's counsel regarding the page limit and timing requirements.

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    of 8

    Case3:10-cv-00257-JSW Document27 Filed03/02/10 Page1 of 2

    1 JAMES R. McGUIRE (CA SBN 189275)


    [email protected]
    2 GREGORY P. DRESSER (CA SBN 136532)
    [email protected]
    3 RITA F. LIN (CA SBN 236220)
    [email protected]
    4 GRACE Y. PARK (CA SBN 239928)
    [email protected]
    5 MORRISON & FOERSTER LLP
    425 Market Street
    6 San Francisco, California 94105-2482
    Telephone: 415.268.7000
    7 Facsimile: 415.268.7522
    8 JENNIFER C. PIZER (CA SBN 152327)
    [email protected]
    9 LAMBDA LEGAL, Western Regional Office
    3325 Wilshire Boulevard, Suite 1300
    10 Los Angeles, CA 90010-1729
    Telephone: 213.382.7600
    11 Facsimile: 213.351.6050
    12 Attorneys for Defendant
    KAREN GOLINSKI,
    13

    14 UNITED STATES DISTRICT COURT

    15 NORTHERN DISTRICT OF CALIFORNIA

    16 OAKLAND DIVISION

    17

    18 KAREN GOLINSKI, Case No. 4:10-cv-00257-SBA

    19 Plaintiff, DECLARATION OF JAMES R.


    MCGUIRE IN SUPPORT OF
    20 v. PLAINTIFF’S OPPOSITION TO
    DEFENDANT’S
    21 UNITED STATES OFFICE OF PERSONNEL ADMINISTRATIVE MOTION
    MANAGEMENT, FOR LEAVE TO FILE AN
    22 OPPOSITION BRIEF OF 36
    Defendant. PAGES
    23

    24

    25

    26

    27

    28
    DECLARATION OF JAMES R. MCGUIRE ISO OPP TO DEF’S ADMIN MTN TO EXCEED THE PAGE LIMIT
    Case No: 4:10-cv-00257-SBA
    pa-1390310
    Case3:10-cv-00257-JSW Document27 Filed03/02/10 Page2 of 2

    1 I, James R. McGuire, hereby declare and state as follows:


    2 1. I am a partner of the law firm of Morrison & Foerster LLP, co-counsel of record for
    3 plaintiff Karen Golinski. I am licensed to practice law in the State of California and am admitted
    4 to practice before this Court. I make this declaration of my own personal knowledge, and, if
    5 called as a witness, could and would testify competently to the matters stated herein.
    6 2. This declaration is submitted in support of Ms. Golinski’s opposition to defendant
    7 United States Office of Personnel Management’s (“OPM”) request to file an oversized 36-page
    8 opposition brief to her 13-page preliminary injunction motion.
    9 3. Plaintiff filed her Complaint in this action on January 20, 2010. Along with her
    10 Complaint, Plaintiff served a copy of this Court’s standing order on OPM.
    11 4. From January 25 to January 27, 2010, pursuant to this Court’s standing order, I
    12 met and conferred at length with counsel for OPM, Steven Bressler, Assistant United States
    13 Attorney. In a January 25, 2010 e-mail exchange with Mr. Bressler, I specifically referenced this
    14 Court’s standing order. A true and correct copy of the January 25 e-mail exchange between
    15 Mr. Bressler and me is attached hereto as Exhibit A.
    16 5. OPM waited until the day before its brief was due to request a joint stipulation
    17 from plaintiff’s counsel and to seek leave from the Court to file an oversized opposition brief. A
    18 true and correct copy of OPM’s March 1 e-mail to Plaintiff’s counsel requesting a stipulation to
    19 file an oversized brief is attached hereto as Exhibit B.
    20 6. Plaintiff’s counsel specifically pointed out the seven-day requirement when
    21 meeting and conferring with OPM about its request to file an oversized brief. Nonetheless, OPM
    22 proceeded with its late request in violation of this Court’s order. A true and correct copy of the
    23 March 1 e-mail exchange between Mr. Bressler and me is attached hereto as Exhibit C.
    24 I declare under penalty of perjury under the laws of the United States that the foregoing is
    25 true and correct. Executed on March 1, 2010, at San Francisco, California.
    26

    27 /s/ James R. McGuire


    JAMES R. MCGUIRE
    28
    DECLARATION OF JAMES R. MCGUIRE ISO OPP TO DEF’S ADMIN MTN TO EXCEED THE PAGE LIMIT
    Case No. 4:10-cv-00257-SBA
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