Case 1:11-cv-00733-WHP Document 293 Filed 03/02/15 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
PENNSYLVANIA PUBLIC SCHOOL
EMPLOYEES’ RETIREMENT SYSTEM,
individually and on behalf of all others
BANK OF AMERICA CORPORATION, et al.,
CIVIL ACTION NO.
DECLARATION OF MARK R. ROSEN IN SUPPORT
OF LEAD PLAINTIFF’S MOTION TO COMPEL
I, Mark R. Rosen, declare as follows:
I am a member of the law firm, Barrack, Rodos & Bacine, the Lead Counsel and
counsel for the Lead Plaintiff Pennsylvania Public School Employees’ Retirement System
(hereafter “Lead Plaintiff”) in this action. I make this Declaration in support of Lead Plaintiff’s
Motion to Compel Discovery Withheld Based Upon the Assertion of the Bank Examination
2. Attached to this declaration as Exhibit A is a true and correct copy of Plaintiff’s
Deposition Exhibit 536 in this matter, “Bank of America Corporation Foreclosure and Claims
Process Review Charlotte, NC,” dated March 12, 2012.
3. Attached to this declaration as Exhibit B is a true and correct copy of excerpts from
the Deposition of Mark Ulmer, dated November 21, 2014.
Case 1:11-cv-00733-WHP Document 293 Filed 03/02/15 Page 2 of 2
I declare, under penalty of perjury, that the foregoing facts are true and correct.
Executed on February 23, 2015.
/s/ Mark R. Rosen
Mark R. Rosen