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1 TIMOTHY J. LONG (STATE BAR NO. 137591)
tJlong@orrick.com
2 ORRICK, HERRINGTON & SUTCLIFFE LLP 010J^H 23 PM 3:
400 Capitol Mall, Suite 3000
3 Sacramento, CA 95814-4497
Telephone: +1 916 447 9200
4 Facsimile: +1 916 329 4900
5 STEPHANIE GAIL LEE (STATE BAR NO. 285379)
stephanie.lee@orrick.com
6 ORRICK, HERRINGTON & SUTCLIFFE LLP
777 South Figueroa Street, Suite 3200
7 Los Angeles, CA 90017-5855
Telephone: +1-213-629-2020
8 Facsimile: +1-213-612-2499
9 Attorneys for Defendant
HEALTH NET OF CALIFORNIA, INC.
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11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 COUNTY OF SACRAMENTO
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ANDREA SPEARS, an individual, on behalf Consolidated Case No. 34-2017-00210560-
14 of herself and on behalf of all persons similarly CU-OE-GDS
situated,
DECLARATION OF IAN G. STEWART
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15 PlainUff,
IN SUPPORT OF DEFENDANT'S
16 MOTION TO SEQUENCE DISCOVERY
17 HEALTH NET OF CALIFORNIA, INC., a Dale: February 15,2018
Califomia Corporation; and Docs 1 through 50, Time: 9:30 a.m.
18 inclusive, Judge: Mon. Alan G. Perkins
Dept.: 35
19 Defendanls.
Complaint Filed: April 5,2017
20 FAC Filed: June 29, 2017
Consolidated Complaint Filed: Dec. 21,2017
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22 TOMAS R. ARANA, on behalf of himself, all Complaint Filed: August 1,2017
others similarly situated,
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PlainUff,
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V.
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HEALTH NET OF CALIFORNIA, INC., a
26 California corporation; and DOES 1-50,
inclusive,
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Defendanl.
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DJ.'CLAKATION OF IAN G. S IliWART IN SUPI'ORi OP DCi^ENDAN PS MOTION IO SnQUI^NCK DISCOVIIR Y
1 I, Ian G. Stewart, declare:
2 1. Effective January 22, 2018, 1 was promoted to Manager for the Threat and
3 Vuhicrability team at Centene Corporation ("Centene"). Before that, I was a Project Lead for
4 Centene's Cyber Security Incident Response Team. I started in lhat role in July 2014 - fti'st as an
5 employee of Health Net, Inc. ("HNI") and, following HNI's merger with Centene, ns an
6 employee of Centene. As part of my job duties, I am generally familiar wiUi data retrievable from
7 the computers within Centene and its various companies, including HNI and its subsidiary, Health
8 Net of Califomia, Inc. ("Health Net"). All of the mformation conlaiiicd in this dcclaraUon is
9 based upon my personal knowledge or, where context indicates, review of the records described
10 herein. If called and swom as a witness, I could and would competently testily to the matters in
11 this declaration.
12 2. I understand that, in the abovc-rcfcrcnccd matter, Plaintiff Tomas Ai-anu has
13 requested that Hcallh Net provide, for neariy 5,000 current and Ibmicr employees, all documents
14 rcflccUng each time he or she logged into and out of his or her computer between April 5, 2013
15 and the present. It is not possible to obtain such data dating back to April 5,2013. Rather, such
16 data is retrievable dating back to approximately November 2016 only.
17 3. Employees' computer log-on and log-off data between approximately November
18 2016 and November 2017 is archived in raw textfilesstored by day, not by person. Therefore, in
19 order to filler the data for a select 5,000 or so employees, I would need to devise a query for my
20 computer lo search for them by their unique idcntificaUon number, then cxtracl oui just their data,
21 and then put just their data into a new file,
22 4. All such data bct\vccn November 2017 and the present is stored in a computer
23 application called Splunk. In order to gather the data for these 5,000 or so employees, I would
24 similariy need lo devise an appropriate quciy.
25 5. Taking these slcps lo comply wilh Mr. Arana's request vvould be very lime
26 consuming. Even assuming that I (or someone on my tciini) could dedicate 100% of niy Umc to
27 this task, I eslimalc (hat il would take rouglily one month complete. However, given my und my
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DECLARATION OF lAN 0. STEWART IN SUPPORT OF DEFENDANT'S MOTION TO SEQUENCE DISCOVHR Y
1 team's limited resources und many oUiCr ongoing day-to-duy tasks, 100% dedication - or
2 anything even close - is not feasible. Compliance would undoubtedly lake much longer.
3 I declare under penalty of perjury under the laws of the State of California and these
4 Untied States that the foregoing is true and correct.
5 Executed this day of January, 2018 in 'Psav»tg^Wo C^Ab'ib< , Califomio.
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lan G. Slcwart
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DECLARATION 01' IAN G. STEWART IN SUPl'ORT OF DEFENDANT'S MOriON TO SEQUENCE DISCOVERY
1 PROOF OF PERSONAL SERVICE
2 I am more lhan eighteen years old and not a party to this action. My business address is Orrick,
3 Herrington & Sutcliffe LLP, 777 South Figueroa Street, Suite 3200, Los Angeles, CA 90017. On
4 January 23,2018,1 caused to be served the following document(s):
5 DECLARATION OF IAN G. STEWART IN SUPPORT OF DEFENDANT'S
^ MOTION TO SEQUENCE DISCOVERY
7 on lhe interested parties by delivering true and correct copies Ihereof in sealed envelope(s) to the
8 following address(es):
^ Shaun Setareh, Esq. Norman B. Blumenthal, Esq
,^ Setareh Law Group Blumenthal, Nordrehaug & Bhowmik
9454 Wilshire Blvd, Suile 907 2255 Calle Clara
11 Beveriy Hills, CA 90212 La Jolla, CA 92037
Tel: (310)888-7771 Phone: (858)551-1223
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]3 I declare under penally of peijury under the laws of the Slate of Califomia that the above is
14 true and correct.
15 Executed on January 23,2018, at Los Angeles, Califomia.
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17 A\U/:'a^
Susan Totin
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PROOF OP PERSONAL SERVICE
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1 TIMOTHY J. LONG (STATE BAR NO. 137591) tJlong@orrick.com 2 ORRICK, HERRINGTON & SUTCLIFFE LLP 010J^H 23 PM 3: 400 Capitol Mall, Suite 3000 3 Sacramento, CA 95814-4497 Telephone: +1 916 447 9200 4 Facsimile: +1 916 329 4900 5 STEPHANIE GAIL LEE (STATE BAR NO. 285379) stephanie.lee@orrick.com 6 ORRICK, HERRINGTON & SUTCLIFFE LLP 777 South Figueroa Street, Suite 3200 7 Los Angeles, CA 90017-5855 Telephone: +1-213-629-2020 8 Facsimile: +1-213-612-2499 9 Attorneys for Defendant HEALTH NET OF CALIFORNIA, INC. 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SACRAMENTO 13 ANDREA SPEARS, an individual, on behalf Consolidated Case No. 34-2017-00210560- 14 of herself and on behalf of all persons similarly CU-OE-GDS situated, DECLARATION OF IAN G. STEWART 3 15 PlainUff, IN SUPPORT OF DEFENDANT'S 16 MOTION TO SEQUENCE DISCOVERY 17 HEALTH NET OF CALIFORNIA, INC., a Dale: February 15,2018 Califomia Corporation; and Docs 1 through 50, Time: 9:30 a.m. 18 inclusive, Judge: Mon. Alan G. Perkins Dept.: 35 19 Defendanls. Complaint Filed: April 5,2017 20 FAC Filed: June 29, 2017 Consolidated Complaint Filed: Dec. 21,2017 21 22 TOMAS R. ARANA, on behalf of himself, all Complaint Filed: August 1,2017 others similarly situated, 23 PlainUff, 24 V. 25 HEALTH NET OF CALIFORNIA, INC., a 26 California corporation; and DOES 1-50, inclusive, 27 Defendanl. 28 DJ.'CLAKATION OF IAN G. S IliWART IN SUPI'ORi OP DCi^ENDAN PS MOTION IO SnQUI^NCK DISCOVIIR Y 1 I, Ian G. Stewart, declare: 2 1. Effective January 22, 2018, 1 was promoted to Manager for the Threat and 3 Vuhicrability team at Centene Corporation ("Centene"). Before that, I was a Project Lead for 4 Centene's Cyber Security Incident Response Team. I started in lhat role in July 2014 - fti'st as an 5 employee of Health Net, Inc. ("HNI") and, following HNI's merger with Centene, ns an 6 employee of Centene. As part of my job duties, I am generally familiar wiUi data retrievable from 7 the computers within Centene and its various companies, including HNI and its subsidiary, Health 8 Net of Califomia, Inc. ("Health Net"). All of the mformation conlaiiicd in this dcclaraUon is 9 based upon my personal knowledge or, where context indicates, review of the records described 10 herein. If called and swom as a witness, I could and would competently testily to the matters in 11 this declaration. 12 2. I understand that, in the abovc-rcfcrcnccd matter, Plaintiff Tomas Ai-anu has 13 requested that Hcallh Net provide, for neariy 5,000 current and Ibmicr employees, all documents 14 rcflccUng each time he or she logged into and out of his or her computer between April 5, 2013 15 and the present. It is not possible to obtain such data dating back to April 5,2013. Rather, such 16 data is retrievable dating back to approximately November 2016 only. 17 3. Employees' computer log-on and log-off data between approximately November 18 2016 and November 2017 is archived in raw textfilesstored by day, not by person. Therefore, in 19 order to filler the data for a select 5,000 or so employees, I would need to devise a query for my 20 computer lo search for them by their unique idcntificaUon number, then cxtracl oui just their data, 21 and then put just their data into a new file, 22 4. All such data bct\vccn November 2017 and the present is stored in a computer 23 application called Splunk. In order to gather the data for these 5,000 or so employees, I would 24 similariy need lo devise an appropriate quciy. 25 5. Taking these slcps lo comply wilh Mr. Arana's request vvould be very lime 26 consuming. Even assuming that I (or someone on my tciini) could dedicate 100% of niy Umc to 27 this task, I eslimalc (hat il would take rouglily one month complete. However, given my und my 28 DECLARATION OF lAN 0. STEWART IN SUPPORT OF DEFENDANT'S MOTION TO SEQUENCE DISCOVHR Y 1 team's limited resources und many oUiCr ongoing day-to-duy tasks, 100% dedication - or 2 anything even close - is not feasible. Compliance would undoubtedly lake much longer. 3 I declare under penalty of perjury under the laws of the State of California and these 4 Untied States that the foregoing is true and correct. 5 Executed this day of January, 2018 in 'Psav»tg^Wo C^Ab'ib< , Califomio. 6 7 8 ^^^>6 —y lan G. Slcwart 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- DECLARATION 01' IAN G. STEWART IN SUPl'ORT OF DEFENDANT'S MOriON TO SEQUENCE DISCOVERY 1 PROOF OF PERSONAL SERVICE 2 I am more lhan eighteen years old and not a party to this action. My business address is Orrick, 3 Herrington & Sutcliffe LLP, 777 South Figueroa Street, Suite 3200, Los Angeles, CA 90017. On 4 January 23,2018,1 caused to be served the following document(s): 5 DECLARATION OF IAN G. STEWART IN SUPPORT OF DEFENDANT'S ^ MOTION TO SEQUENCE DISCOVERY 7 on lhe interested parties by delivering true and correct copies Ihereof in sealed envelope(s) to the 8 following address(es): ^ Shaun Setareh, Esq. Norman B. Blumenthal, Esq ,^ Setareh Law Group Blumenthal, Nordrehaug & Bhowmik 9454 Wilshire Blvd, Suile 907 2255 Calle Clara 11 Beveriy Hills, CA 90212 La Jolla, CA 92037 Tel: (310)888-7771 Phone: (858)551-1223 12 ]3 I declare under penally of peijury under the laws of the Slate of Califomia that the above is 14 true and correct. 15 Executed on January 23,2018, at Los Angeles, Califomia. 16 ^' y 17 A\U/:'a^ Susan Totin 18 19 20 21 22 23 24 25 26 27 28 -I- PROOF OP PERSONAL SERVICE