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DECLARATION OF PAULA L. ZECCHINI IN SUPPORT OF DEFENDANT GODADDY.COM, LLC’S 

MOTION FOR SUMMARY JUDGMENT

Paula L. Zecchini, AZ Bar No. 031880

Aaron M. McKown (admitted pro hac vice)

COZEN O’CONNOR

999 Third Avenue, Suite 1900

Seattle, WA 98104

Telephone: (206) 340-1000

Facsimile: (206) 621-8783

E-Mail: pzecchini@cozen.com

 amckown@cozen.com

Attorneys for Defendant

GODADDY.COM, LLC

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

JOHN HERRICK, individually and as the 

representative of a class of similarly situated 

persons,

Plaintiff,

v.

GODADDY.COM, LLC,

Defendant.

Case No.: 2:16-cv-00254-DJH

DECLARATION OF PAULA L. 

ZECCHINI IN SUPPORT OF 

DEFENDANT GODADDY.COM, 

LLC’S MOTION FOR SUMMARY 

JUDGMENT OR, IN THE 

ALTERNATIVE, MOTION TO STAY 

[Concurrently filed with Notice of 

Motion and Motion for Summary 

Judgment, Separate Statement of 

Undisputed Material Fact, and Request 

for Judicial Notice]

Complaint Filed: January 28, 2016

Trial Date: None Set.
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1

DECLARATION OF PAULA L. ZECCHINI IN SUPPORT OF DEFENDANT GODADDY.COM, LLC’S 

MOTION FOR SUMMARY JUDGMENT

I, Paula L. Zecchini, declare:

1. I am an attorney duly licensed to practice law before all state and federal courts 

of the State of Arizona. I am currently a member with the law firm of Cozen O’Connor, 

counsel of record for Defendant GoDaddy.com, LLC (“GoDaddy”). I have personal

knowledge of the matters set forth in this Declaration and if called upon to testify in court, I 

could and would competently do so.

2. Attached hereto as Exhibit A is a true and correct copy of the full transcript of 

the deposition of John Wright, in his capacity as corporate representative of non-party 

3Seventy, Inc., taken pursuant to Federal Rule of Civil Procedure 30(b)(6) on October 5, 

2016.

I declare under penalty of perjury under the laws of the United States of America that 

the facts set forth above are true and correct.

Executed this 31st day of March, 2017, at Cordova, Alaska.

Dated: March 31, 2017 COZEN O’CONNOR

Aaron M. McKown

Paula L. Zecchini

By: /s Paula L. Zecchini

Paula L. Zecchini

Attorneys for Defendant

GODADDY.COM, LLC
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2

DECLARATION OF PAULA L. ZECCHINI IN SUPPORT OF DEFENDANT GODADDY.COM, LLC’S 

MOTION FOR SUMMARY JUDGMENT

CERTIFICATE OF SERVICE

The undersigned hereby certifies, under penalty of perjury under the laws of the State 

of Arizona that I electronically filed the foregoing document with the Clerk of the Court 

using the CM/ECF system which will send notification of such filing to the following:

Phillip A. Bock

Tod A. Lewis

James M. Smith

BOCK, HATCH, LEWIS & 

OPPENHEIM, LLC

134 N LaSalle Street, Suite 1000

Chicago, IL 60602

phil@classlawyers.com

tod@classlawyers.com

jim@classlawyers.com

Counsels for Plaintiff John Herrick

Trinette G. Kent

KENT LAW OFFICES

10645 N Tatum Boulevard, Suite 

200-192

Phoenix, AZ 85028

tkent@kentlawpc.com

SIGNED AND DATED this 31st day of March, 2017 at Seattle, Washington.

COZEN O'CONNOR

By: /s/ Paula L. Zecchini 

Paula L. Zecchini