`
`
`Christopher Keegan (SBN 232045)
`Anna Terteryan (SBN 300368)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, California 94104
`Telephone: (415) 439-1400
`Facsimile: (415) 439-1500
`Email: chris.keegan@kirkland.com
`Email: anna.terteryan@kirkland.com
`
`John Hartmann (pro hac vice motion
`forthcoming)
`KIRKLAND & ELLIS LLP
`300 North LaSalle
`Chicago, Illinois 60654
`Telephone: (312) 862-2000
`Facsimile: (312) 862-2200
`Email: jhartmann@kirkland.com
`
`Attorneys for Defendant
`Deloitte Consulting LLP, erroneously
`sued as “Deloitte Consulting LLP,
`a Delaware limited liability company”
`
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`04/25/2022
`Clerk of the Court
`BY: SANDRA SCHIRO
`Deputy Clerk
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`COUNTY OF SAN FRANCISCO
`UNLIMITED JURISDICTION
`VIMO, INC., d/b/a GETINSURED, a
`Case No. CGC-22-598715
`Delaware corporation;
`
`DECLARATION OF CHRISTOPHER
`
`KEEGAN IN SUPPORT OF
`Plaintiff,
`DEFENDANT DELOITTE
`CONSULTING LLP’S,
`ERRONEOUSLY SUED AS
`“DELOITTE CONSULTING LLP, A
`DELAWARE LIMITED LIABILITY
`COMPANY,” DEMURRER
`
`Hearing Date: 05/24/2022
`Time: 9:30 a.m.
`
`Department: 302
`Judge: Hon. Richard B. Ulmer Jr.
`Complaint Filed: March 15, 2022
`
`
`v.
`
`DELOITTE CONSULTING LLP, a
`Delaware limited liability company, and
`DOES 1-25 inclusive,
`
`Defendant.
`
`
`
`
`
`
`
`))))))))))))))))
`
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`KEEGAN DECLARATION IN SUPPORT OF DEMURRER
`
`
`
`
`
`
`I, Christopher Keegan, declare as follows:
`1.
`I am a Partner at Kirkland & Ellis LLP, counsel of record for Defendant Deloitte
`Consulting LLP, erroneously sued as “Deloitte Consulting LLP, a Delaware limited liability company”
`(“Deloitte”) in the above-captioned action. I am a member in good standing of the State of California
`Bar.
`
`2.
`I provide this declaration in support of Deloitte’s Demurrer, filed contemporaneously
`herewith. The statements in this declaration are based upon my personal knowledge. If called upon to
`testify as a witness, I could provide testimony competently under oath as follows:
`3.
`On April 15, 2022, I met and conferred by telephone with counsel for Plaintiff.
`4.
`The parties were unable to reach an agreement resolving the objections raised in
`Deloitte’s Demurrer.
`5.
`Deloitte made a good faith attempt to resolve the grounds for its Demurrer to the
`Complaint.
`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 on April 25, 2022, in San Francisco, California.
`
`DATED: April 25, 2022
`
`/s/ Christopher Keegan
`Christopher Keegan
`
`
`
`
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`2
`KEEGAN DECLARATION IN SUPPORT OF DEMURRER
`
`
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