Fallon Declaration — In re Carvana Securities

Record facts

U.S. District Court for the District of Arizona · No. 2:22-cv-02126-MTL · Doc. 303 · 2026-02-05 · Docket on CourtListener

Full text

4923-6636-1485.v1 
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
ROBBINS GELLER RUDMAN 
 & DOWD LLP 
DANIEL S. DROSMAN (CA 200643) 
TOR GRONBORG (CA 179109) 
ERIKA L. OLIVER (CA 306614) 
RACHEL A. COCALIS (CA 312376) 
MATTHEW J. BALOTTA (CA 310303) 
SARAH A. FALLON (CA 345821) 
655 West Broadway, Suite 1900 
San Diego, CA  92101 
Telephone:  619/231-1058 
619/231-7423 (fax) 
ddrosman@rgrdlaw.com 
torg@rgrdlaw.com 
eoliver@rgrdlaw.com 
rcocalis@rgrdlaw.com 
mbalotta@rgrdlaw.com 
sfallon@rgrdlaw.com 
Lead Counsel for Lead Plaintiffs 
 
UNITED STATES DISTRICT COURT 
DISTRICT OF ARIZONA 
 
In re Carvana Co. Securities Litigation 
This Document Relates To: 
All Actions. 
) 
) 
) 
) 
) 
) 
) 
) 
No. CV-22-2126-PHX-MTL 
DECLARATION OF SARAH A. 
FALLON IN SUPPORT OF LEAD 
PLAINTIFFS’ MOTION TO COMPEL 
THE PRODUCTION OF DOCUMENTS 
IMPROPERLY WITHHELD AS 
PRIVILEGED BY THE CARVANA 
DEFENDANTS
 
 
 
Case 2:22-cv-02126-MTL     Document 303     Filed 02/05/26     Page 1 of 3

 
- 1 - 
4923-6636-1485.v1 
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1. 
I am an attorney duly licensed to practice before all of the courts of the State of 
California.  I am an associate of the law firm of Robbins Geller Rudman & Dowd LLP, one 
of the counsel of record for Plaintiffs in the above-entitled action.  I have personal 
knowledge of the matters stated herein and, if called upon, I could and would competently 
testify thereto. 
2. 
Attached are true and correct copies of the following exhibits: 
Exhibit 1: 
Ernest Garcia III’s Responses and Objections to Lead Plaintiffs’ First 
Set of Requests for Admission, dated June 9, 2025; 
Exhibit 2: 
Mark Jenkins’s Responses and Objections to Lead Plaintiffs’ First Set 
of Requests for Admission, dated June 9, 2025; 
Exhibit 3: 
Stephen Palmer’s Responses and Objections to Lead Plaintiffs’ First 
Set of Requests for Admission, dated June 9, 2025; 
Exhibit 4: 
Michael Maroone’s Responses and Objections to Lead Plaintiffs’ First 
Set of Requests for Admission, dated June 9, 2025; 
Exhibit 5: 
Neha Parikh’s Responses and Objections to Lead Plaintiffs’ First Set of 
Requests for Admission, dated June 9, 2025; 
Exhibit 6: 
Ira Platt’s Responses and Objections to Lead Plaintiffs’ First Set of 
Requests for Admission, dated June 9, 2025; 
Exhibit 7: 
Greg Sullivan’s Responses and Objections to Lead Plaintiffs’ First Set 
of Requests for Admission, dated June 9, 2025; 
Exhibit 8: 
Carvana’s Amended Responses and Objections to Lead Plaintiffs’ First 
Set of Interrogatories to the Carvana Defendants, dated July 18, 2025; 
Exhibit 9: 
Defendant Ernest Garcia III’s Amended Responses and Objections to 
Lead Plaintiffs’ First Set of Interrogatories to the Carvana Defendants, 
dated July 18, 2025; 
Exhibit 10: 
Defendant Mark Jenkins’s Amended Responses and Objections to Lead 
Plaintiffs’ First Set of Interrogatories to the Carvana Defendants, dated 
July 18, 2025; 
Exhibit 11: 
Carvana Defendants’ Rule 26(a)(1) Initial Disclosures, dated February 
18, 2025; 
Exhibit 12: 
Carvana Defendants’ Amended Rule 26(a)(1) Initial Disclosures, dated 
March 21, 2025; 
Exhibit 13: 
Carvana Defendants’ Amended Rule 26(a)(1) Initial Disclosures, dated 
August 19, 2025; 
Exhibit 14: 
Email chain ending with a January 6, 2026 email to Tor Gronborg from 
Christian Word; 
Case 2:22-cv-02126-MTL     Document 303     Filed 02/05/26     Page 2 of 3

 
- 2 - 
4923-6636-1485.v1 
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Exhibit 15: 
Carvana Defendants’ Categorical Privilege Log, dated October 31, 
2025 (FILED UNDER SEAL); and 
Exhibit 16: 
Email chain ending with a January 28, 2026 email to Christian Word 
from Sarah Fallon. 
I declare under penalty of perjury that the foregoing is true and correct.  Executed on 
February 5, 2026, at San Diego, California. 
 
SARAH A. FALLON 
 
Case 2:22-cv-02126-MTL     Document 303     Filed 02/05/26     Page 3 of 3

File and source

File

gov.uscourts.azd.1319766.303.0.pdf

Size

121,919 bytes

SHA-256

960765a5a63a1909345ad0d356dae61d4288cc40997eba8ba94ed291f9d7ac52

Our copy

gov.uscourts.azd.1319766.303.0.pdf

Original

archive.org