Party Statement: Andrea Spears vs. Health Net of California Inc

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                                1   TIMOTHY J. LONG (STATE BAR NO. 137591)
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     tjlong@orrick.com
     NICHOLAS J. HORTON (STATE BAR NO. 289417)
                                                           FILED/ENDORSED
     nhorton@orrick.com
3    ORRICK, HERRINGTON & SUTCLIFFE LLP                           FEB 1 5 2019
     400 Capitol Mall, Suite 3000
4    Sacramento, CA 95814-4497
     Telephone: +1 916 447 8299                           By:       M. Rubalcaba
                                                                      Deputy Clefk
5    Facsimile:    +1 916 3 29 4900
6    Attomeys for Defendant
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     HEALTH NET OF CALIFORNIA, INC.

 8                       SUPERIOR COURT OF THE STATE OF CALIFORNL\
9                                      COUNTY OF SACRAMENTO
10   ANDREA SPEARS, an individual, onbehalf          Consolidated Case No. 34-2017-00210560-
     of herself and on behalf of all persons         CU-OE-GDS
11   similarly situated.
                         Plaintiff,
12                                                   DECLARATION OF SHEENA BOEHL
                                                     Judge: Hon. Alan G. Perkins
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     HEALTH NET OF CALIFORNIA, INC., a.              Complaint .Filed: April 5,2017
14   Califomia Corporation; and Does 1 through      ^FAC Filed:      " June 29, 2017
     50, inclusive.
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                        Defendants.
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17   TOMAS R. ARANA, on behalf of himself, all
     others similarly situated.                      Complaint Filed: August 1, 2017
                                                     Consolidated Complaint Filed: Dec. 21, 2017
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                        Plaintiff, .
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              V.

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     HEALTH NET OF CALIFORNLA, INC., a
21   Califomia corporation; and DOES 1-50,
     inclusive.
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                        Defendant.
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                                       DECLARATION OF SHEENA BOEHL
     4137-7621-1481.1
 1            I, Sheena Boehl, declare as follows:
 2            1.        I was employed by Health Net ofCalifomia, Inc., [Defendant] as a claims examiner,
 3   in Rancho Cordova, California, from approximately August of 2015 through February of 2016.
 4            2.        I understand and have been told there is a lawsuit between Health Net and two
 5   current or former employees, who seek to represent all current and former hourly or non-exempt
 6   Health Net employees in Califomia from April 5, 2013 through the present, as well as certain
 7   exempt employees during the same time period.
 8            3.        I further understand that the Plaintiffs in this case are seeking to represent a class of
 9   employees that may include me. I know that I may be eligible to participate as a member of the
10   class, if certified. I understand that the attomey who spoke with me regarding this declaration
11   represents Health Net and does not represent my personal interests. 1 am making this statement
12   volimtarily and without coercion.
13            4.        On November 26, 2018, I signed a declaration in support of Plaintiffs' Motion for
a4   Class Certification. On .January -17, 2019,1 was contacted by aii attorney representing Health Net
15   about scheduling a deposition date to investigate the statements I made in my declaration. She
16   offered to work around my schedule and current constraints. I was recently a surrogate and just
17   had a baby six weeks ago. I have no time off available since my paid time off was drained for
18   matemity leave.
19            5.        Rather than moving forward as a witness in this class action lawsuit, I choose to
20   withdraw my November 26, 2018 declaration filed in support of Plaintiffs' Motion for Class
21   Certification. 1 do not recall many of the details of my time at Health Net and do not feel
22   comfortable moving forward as a wimess because I want to be sure I can give tmthful testimony.
23            I declare tmder the penalty of perjury under the laws of the United States and the State of
24   Califomia that the foregoing is true and correct. Executed on January              ,2019 at Rancho
25   Cordova, Califomia.
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                                          DECLARATION OF SHEENA BOEHL
     4137-7621-1481.1