REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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STIPULATION AND [PROPOSED] ORDER RE JENNIFER SEPULVEDA 

John P. Zaimes (SBN 91933) 

jzaimes@reedsmith.com 

Roxanne M. Wilson (SBN 94627) 

rwilson@reedsmith.com

John H. Lien (SBN 222842) 

jlien@reedsmith.com

REED SMITH LLP

355 South Grand Avenue, Suite 2900 

Los Angeles, CA 90071-1514 

Telephone: +1 213 457 8000 

Facsimile: +1 213 457 8080 

Attorneys for Defendant 

Vector Marketing Corporation 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

ALICIA HARRIS, as an individual and on 

behalf of all others similarly situated, 

Plaintiffs,

vs. 

VECTOR MARKETING 

CORPORATION, a Pennsylvania 

corporation; and DOES 1 through 20, 

inclusive, 

 Defendants. 

No.: CV 08-5198 EMC 

STIPULATION AND [PROPOSED] 

ORDER RE JENNIFER 

SEPULVEDA 

Complaint Filed: October 15, 2008 

Trial Date: June 6, 2011 

Case 3:08-cv-05198-EMC Document 217 Filed 07/26/10 Page 1 of 3
REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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– 2 – US_ACTIVE-104160802.1

STIPULATION AND [PROPOSED] ORDER RE JENNIFER SEPULVEDA 

Plaintiff Alicia Harris (“plaintiff” or “Harris”) and Defendant Vector Marketing 

Corporation (“defendant” or “Vector”) enter into this stipulation with reference to the 

following facts: 

RECITALS

A. On or about July 16, 2010, Vector served plaintiff’s sister, Jennifer 

Sepulveda (“Sepulveda”), with whom plaintiff resided during the summer of 2008, 

with a subpoena to testify at a deposition set for July 28, 2010 and further requested 

the production of, among other things, documents and materials related to plaintiff’s 

services as a Sales Representative for defendant. 

B. In response to said subpoena for testimony and production of documents, 

plaintiff represents, pursuant to Federal Rule of Civil Procedure 26, that Sepulveda 

has not and does not have, within her possession, custody, or control: (i) any 

discoverable information, along with the subjects of that information, that plaintiff 

would use in support of her claims; and (ii) any information that may lead to the 

further discovery of any matter related to plaintiff’s claims or defendant’s defenses. 

STIPULATION

NOW, THEREFORE, it is hereby stipulated by the parties, through their 

respective counsel of record, as follows: 

1. Plaintiff shall not identify Sepulveda or call her to testify as a witness in 

this action. 

2. In connection with any pre-trial or other proceedings in this action, 

including, but not limited to written or oral discovery, any pleadings filed with the 

Court, or oral argument made by plaintiff’s counsel, plaintiff shall not: 

(i) identify Sepulveda as a witness in this action with information, either direct, 

indirect, or in any other derivative manner, related to the existence or non-existence of 

any fact relevant to plaintiff’s claims or defendant’s defenses in this action; or 

Case 3:08-cv-05198-EMC Document 217 Filed 07/26/10 Page 2 of 3
REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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– 3 – US_ACTIVE-104160802.1

STIPULATION AND [PROPOSED] ORDER RE JENNIFER SEPULVEDA 

(ii) introduce or rely upon any evidence directly, indirectly, or in any other 

derivative manner provided to plaintiff by Sepulveda. 

IT IS SO STIPULATED. 

Dated: July 21, 2010 REED SMITH LLP 

By /s/ 

Roxanne M. Wilson 

Attorneys for Defendant 

VECTOR MARKETING CORPORATION 

Dated: July 21, 2010 MARLIN & SALTZMAN LLP 

By /s/ 

Christina Humphrey Attorneys for Plaintiff 

ALICIA HARRIS 

ORDER

Based on the above stipulation, IT IS SO ORDERED. 

Dated: , 2010 

Honorable Edward M. Chen 

United States District Court Magistrate Judge 

Case 3:08-cv-05198-EMC Document 217 Filed 07/26/10 Page 3 of 3