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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
:
:
similarly situated,
:

:


:
:
v.
:

BANK OF AMERICA CORPORATION, et al.,
:
:

:


:



Defendants.


Plaintiff,

















CIVIL ACTION NO.
11-CV-00733-WHP

CLASS ACTION

















DECLARATION OF MARK R. ROSEN IN SUPPORT

OF LEAD PLAINTIFF’S MOTION TO COMPEL



I, Mark R. Rosen, declare as follows:

1.

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

Privilege.

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







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