DOCSLIB.ORG

The Sedona Conference Full Journal 2014.Pdf

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
The Sedona Conference Full Journal 2014.Pdf The Sedona ® Conference Journal Volume 15 v Fall 2014 A RTICLES In Memoriam: Richard G. Braman . Craig W. Weinlein Responding to the Government’s Civil Investigations . David C . Shonka What’s the Problem with Google? . Daniel R . Shulman Technology-Assisted Review: The Judicial Pioneers . Paul E . Burns & Mindy M . Morton The Sedona Conference Commentary on Patent Damages & Remedies . The Sedona Conference The Sedona Conference Commentary on Information Governance . The Sedona Conference The Sedona Conference Database Principles Addressing the Preservation & Production of Databases & Database Information in Civil Litigation . The Sedona Conference The Sedona Conference Best Practices Commentary on the Use of Search & Information Retrieval Methods in E-Discovery . The Sedona Conference The Sedona Conference Commentary on Achieving Quality in the E-Discovery Process . The Sedona Conference The Sedona Conference Glossary: E-Discovery & Digital Information Management (Fourth Edition) . The Sedona Conference ANTITRUST LAW, COMPLEX LITIGATION AND INTELLECTUAL PROPERTY RIGHTS THE SEDONA CONFERENCE JOURNAL® V OLUME 1 5 n F ALL 2 0 1 4 The Sedona Conference Journal® (ISSN 1530-4981) is published on an annual basis, containing selections from the preceding year’s Conferences and Working Group efforts. The Journal is available on a complementary basis to courthouses and public law libraries and by subscription to others ($95; $45 for Conference participants and Working Group members). Send us an email ([email protected]) or call (1-602-258-4910) to order or for further information. Check our website for further information about our Conferences, Working Groups, and publications: www.thesedonaconference.org. Comments (strongly encouraged) and requests to reproduce all or portions of this issue should be directed to: The Sedona Conference, 5150 North 16th Street, Suite A-215, Phoenix, AZ 85016 or call 1-602-258-4910; fax 602-258-2499; email [email protected]. The Sedona Conference Journal® designed by MargoBDesign.com – [email protected] Cite items in this volume to “15 Sedona Conf. J. _____ (2014).” Copyright 2014, The Sedona Conference. All Rights Reserved. PUBLISHER'S NOTE Welcome to Volume 15 of The Sedona Conference Journal (ISSN 1530-4981), an annual collection of articles originally presented at our Conferences, and commentaries prepared by our Working Groups, over the past year. The Sedona Conference was founded in 1997 to provide a forum for advanced dialogue by the nation’s leading attorneys, academics and jurists of cutting-edge issues of law and policy in the areas of antitrust, intellectual property rights, and complex litigation. We host Regular Season Conferences, international programmes, TSCI conferences and several Working Group meetings each year, providing unique and rewarding opportunities to seriously explore the boundaries of various areas of the law with those who are creating them. This volume of the Journal contains two articles from The Sedona Conference Institute (TSCI) Program (March 2014), one article from our regular season conference on antitrust law and litigation (July 2014) and six Working Group commentaries that have been published since the printing of The Sedona Conference Journal, Volume 14, in 2013. We hope that you will find that the papers in this Journal reflect the same mix of theory and experience found at our Conferences and Working Group Meetings, including the creativity and constructive irreverence required to challenge traditional thinking. The views expressed herein are those of the authors, and we encourage the submission of counterpoint pieces. Submissions can be sent electronically to [email protected], or by mail to The Sedona Conference, 5150 North 16th Street, Suite A-215, Phoenix, AZ 85016, USA. If you are interested in participating in one of our Regular Season Conferences, our TSCI conferences or international programmes, or in joining our Working Group Series, please visit our website for further information (www.thesedonaconference.org). Craig Weinlein Executive Director The Sedona Conference November 2014 The Sedona Conference gratefully acknowledges the substantial contributions of its Conference faculties, Working Group Series Sustaining and Annual Sponsors, participants, members and observers, and our Advisory Board members, whose volunteer efforts and contributions make The Sedona Conference a “thought-provoking and inspiring” experience providing content of immediate benefit to the Bench and Bar. i IN MEMORIAM Richard G. Braman Richard Braman was the visionary founder and Executive Director Emeritus of The Sedona Conference. His passing on June 9, 2014 was a loss to The Sedona Conference and to the legal profession. Richard was a pathfinder and an agent of change. When he saw a need he found a solution. He found ways to foster cooperation and bridge gaps, and his natural leadership attracted others to join him in crafting solutions and finding a better way. Richard was active as a leader and agent of change as early as high school, where he graduated at the top of his class. He was president of the thespians, the debate team, vice president of the student council, and president of the student federation. Richard created the federation as an alternative to a student council that was not responsive to the needs of students. He saw a need and, with the help of others, crafted a solution. Richard attended the University of Minnesota, completed his course work in three years, and graduated summa cum laude in 1975. He then attended the University of Minnesota Law School and graduated magna cum laude. His professional career began in the antitrust group of the law firm of Brobeck, Phleger & Harrison in San Francisco. A year later, he realized that a large California law firm was not a good fit for his independence. He moved back to Minnesota and joined the boutique plaintiffs’ class action firm of Opperman & Paquin. In 1984, Richard took the first of two sabbaticals and opened Gabriel’s, a Minnesota jazz club that quickly acquired national renown. He then resumed his law career and joined the law firm of Gray, Plant, Mooty, Mooty & Bennett (currently known as Gray Plant Mooty) in its plaintiffs’ antitrust practice. He would co-chair the Antitrust Practice Group before taking his second sabbatical to create The Sedona Conference. Richard founded The Sedona Conference in December 1997 because he was dissatisfied with traditional continuing legal education (CLE) programs. He knew there was a better way than “talking heads” delivering lectures to passive unengaged attendees who were collecting CLE credits while solving crossword puzzles or reading the paper. Richard wanted to replicate the college seminar, with a small group of people interested in the advanced subject matter and engaging in real dialogue on an issue. The result was The Sedona Conference regular season conferences on antitrust law, complex litigation, and intellectual property rights. From the beginning, these regular season conferences have been advanced level, dialogue-based mini sabbaticals with limited attendance for the nation’s leading jurists, lawyers, and experts to examine cutting edge issues of law and policy. To encourage the dialogue leaders at the regular season conferences to create superior written materials to accompany and support the sessions at the conferences, Richard created The Sedona Conference Journal to publish the best papers from The Sedona Conference regular season conferences. At the regular season conferences, leading practitioners were discussing possible solutions to cutting edge issues and wanted to follow-up by drafting principles, guidelines, or best practices to move the law forward. This naturally led to the formation of The Sedona Conference Working Groups. Working Group 1 produced The Sedona Principles: Best Practices Recommendations & Principles Addressing Electronic Document Production (March 2003 version), which had an ii immediate and substantial impact. Within a few weeks they were cited by the Discovery Subcommittee of the Civil Rules Advisory Committee of the Judicial Conference of the United States. Less than a month later they were cited by Judge Shira Scheindlin of the United States District Court for the Southern District of New York in Zubulake v. UBS Warburg, the groundbreaking case on eDiscovery. Because of Richard’s energy and passion for the mission of The Sedona Conference, the organization has grown greatly in the past fifteen years. The Sedona Conference now has eleven Working Groups addressing issues in eDiscovery, antitrust, complex litigation, intellectual property rights, cyber security, and international electronic information management. Collectively, the Working Groups have published a total of 47 nonpartisan consensus commentaries, principles, guidelines, or best practices designed to move the law forward in a reasoned and just way. The newest Working Group is identifying and commenting on trends in data security and privacy law, in an effort to help organizations prepare for and respond to data breaches, and to assist attorneys and judicial officers in resolving questions of legal liability and damages. As a result of Richard’s work in the field of eDiscovery, in 2013 he was selected as one of the top six eDiscovery pioneers by Law Technology News and The American Lawyer. He was also named one of the 50 most innovative people in Big Law in the past 50 years by The American Lawyer. Richard also is remembered for his revolutionary
Load more

Recommended publications
  • Members by Circuit (As of January 3, 2017)
    Federal Judges Association - Members by Circuit (as of January 3, 2017) 1st Circuit United States Court of Appeals for the First Circuit Bruce M. Selya Jeffrey R. Howard Kermit Victor Lipez Ojetta Rogeriee Thompson Sandra L. Lynch United States District Court District of Maine D. Brock Hornby George Z. Singal John A. Woodcock, Jr. Jon David LeVy Nancy Torresen United States District Court District of Massachusetts Allison Dale Burroughs Denise Jefferson Casper Douglas P. Woodlock F. Dennis Saylor George A. O'Toole, Jr. Indira Talwani Leo T. Sorokin Mark G. Mastroianni Mark L. Wolf Michael A. Ponsor Patti B. Saris Richard G. Stearns Timothy S. Hillman William G. Young United States District Court District of New Hampshire Joseph A. DiClerico, Jr. Joseph N. LaPlante Landya B. McCafferty Paul J. Barbadoro SteVen J. McAuliffe United States District Court District of Puerto Rico Daniel R. Dominguez Francisco Augusto Besosa Gustavo A. Gelpi, Jr. Jay A. Garcia-Gregory Juan M. Perez-Gimenez Pedro A. Delgado Hernandez United States District Court District of Rhode Island Ernest C. Torres John J. McConnell, Jr. Mary M. Lisi William E. Smith 2nd Circuit United States Court of Appeals for the Second Circuit Barrington D. Parker, Jr. Christopher F. Droney Dennis Jacobs Denny Chin Gerard E. Lynch Guido Calabresi John Walker, Jr. Jon O. Newman Jose A. Cabranes Peter W. Hall Pierre N. LeVal Raymond J. Lohier, Jr. Reena Raggi Robert A. Katzmann Robert D. Sack United States District Court District of Connecticut Alan H. NeVas, Sr. Alfred V. Covello Alvin W. Thompson Dominic J. Squatrito Ellen B.
    [Show full text]
  • (“ERISA”) Decisions As They Were Reported on Westlaw Between January 1, 2016 and December 31, 2016
    DRAFT * This document is a case summary compilation of select Employee Retirement Income Security Act of 1974 (“ERISA”) decisions as they were reported on Westlaw between January 1, 2016 and December 31, 2016. Nothing in this document constitutes legal advice. Case summaries prepared by Michelle L. Roberts, Partner, Roberts Bartolic LLP, 1050 Marina Village Parkway, Suite 105, Alameda, CA 94501. © Roberts Bartolic LLP I. Attorneys’ Fees .................................................................................................................. 11 A. First Circuit ..................................................................................................................................... 11 B. Second Circuit ................................................................................................................................. 11 C. Third Circuit .................................................................................................................................... 14 D. Fourth Circuit .................................................................................................................................. 14 E. Fifth Circuit ..................................................................................................................................... 15 F. Sixth Circuit .................................................................................................................................... 16 G. Seventh Circuit ...............................................................................................................................
    [Show full text]
  • ALI-ABA Course of Study Civil Practice and Litigation Techniques in Federal and State Courts
    ALI-ABA Course of Study Civil Practice and Litigation Techniques in Federal and State Courts Sponsored with the cooperation of the Federal Judicial Center July 11 - 13, 2007 Santa Fe, New Mexico TABLE OF CONTENTS Page PROGRAM xiii FACULTY PARTICIPANTS xvii FACULTY BIOGRAPHIES xxi STUDY MATERIAL VOLUME 1 1. The Restyled Federal Rules of Civil Procedure 1 Submitted by Lee H. Rosenthal 2. Supplemental Rules for Admiralty or Maritime and Asset Forfeiture 211 Claims Submitted by John K. Rabiej 3. Techniques and Potential Conflicts in the Handling of Depositions 247 By Victoria E. Brieant Study Material 249 Presentation Slides 286 4. Complex Case Management 299 By Ronald J. Hedges Table of Contents 301 Study Material 302 5. Rules of Professional Conduct, Ethical Conflicts Facing Litigators, and 401 Guidelines for Settlement Negotiations By Steve Morris and Akke Levin Table of Contents 403 Table of Authorities 408 Study Material 437 6. The Rules of Digital Evidence 501 By Howard L. Nations Table of Contents 502 Study Material 503 Appendix A: Amendments to Federal Rules of Civil Procedure 535 vii Appendix B: Texas Rules of Evidence 540 Appendix C: Federal Rules of Evidence 545 7. Protecting Confidential Legal Information 549 By Jerold S. Solovy, Robert L. Byman, Michael T. Brody, David M. Geenwald, Blair R. Zanzig, Marek H. Badyna, Kristen L. Mercado, and Adam A. Hachikian Introduction 550 Table of Contents 551 Study Material 557 8. Electronic Spoliation 821 By Gregory P. Joseph Submitted by Alvin K. Hellerstein 9. Expert Spoliation 829 By Gregory P. Joseph Submitted by Alvin K. Hellerstein 10. Recent Developments in Domestic and International Arbitration Involving 839 Issues of Arbitrability, Consolidation of Claims and Discovery of Non-Parties By Joseph T.
    [Show full text]
  • Duke University 2012-2013 School of Law the Mission of Duke University
    bulletin of Duke University 2012-2013 School of Law The Mission of Duke University The founding Indenture of Duke University directed the members of the university to “develop our resources, increase our wisdom, and promote human happiness.” To these ends, the mission of Duke University is to provide a superior liberal education to undergraduate students, attending not only to their intellectual growth but also to their development as adults committed to high ethical standards and full participation as leaders in their communities; to prepare future members of the learned professions for lives of skilled and ethical service by providing excellent graduate and professional education; to advance the frontiers of knowledge and contribute boldly to the international community of scholarship; to foster health and well-being through medical research and patient care; and to promote a sincere spirit of tolerance, a sense of the obligations and rewards of citizenship, and a commitment to learning, freedom, and truth. By pursuing these objectives with vision and integrity, Duke University seeks to engage the mind, elevate the spirit, and stimulate the best effort of all who are associated with the university; to contribute in diverse ways to the local community, the state, the nation, and the world; and to attain and maintain a place of real leadership in all that we do. —Adopted by the Board of Trustees on February 23, 2001. LAW SCHOOL EDITOR Melinda Vaughn COORDINATING EDITOR Sarah Kibler PUBLICATION COORDINATOR Andrea Martin PHOTOGRAPHS Duke School of Law Department of Communications The information in this bulletin applies to the academic year 2012-2013 and is accurate and current, to the extent possible, as of December 2012.
    [Show full text]
  • NHPRC Minutes November 2011
    National Historical Publications and Records Commission Executive Summary Minutes of November 15, 2011 The meeting was called to order by David S. Ferriero, chairman, at 9:00 am in the Archivist’s Board Room of the National Archives Building in Washington, DC. Commission Members present: David S. Ferriero, Chairperson Edward Brynn James Ceaser Nancy Davenport Timothy Ericson Jeremy Fogel F. Gerald Handfield Stanley N. Katz Erin Mahan Deanna Marcum Raymond Smock Rodger Stroup NHPRC staff present: Kathleen Williams, Executive Director Lucy Barber Jeff de la Concepcion Timothy D.W. Connelly Keith Donohue Christine Dunham Alexander Lorch Nancy Melley Daniel A. Stokes National Archives Staff John Hamilton, Congressional Affairs Kate Slaugh Guests and Attendees Debbie Yamada (for Senator Cardin) Julia Marks Young, Council of State Archivists Bruce Ragsdale, Federal Judicial Center Charlene Bickford, First Federal Congress Project and Association for Documentary Editing Lee White, National Coalition for History C. James Taylor, Founding Fathers editorial projects Mark Saunders, UVA Press Penny Kaiserlian, UVA Press David Sewell, UVA Press November 2011 Minutes 1 I: Welcome, Announcements, Agenda Mr. Ferriero opened the meeting and greeted the Members, staff, and guests. He welcomed Judge Jeremy Fogel, representing the Federal judiciary, to the Commission. Following introductions, Mr. Ferriero reported on the October 21 launch at the National Archives of the Digital Public Library of America at the National Archives. The DPLA is an initiative to pull together a portal to cultural heritage in digital form. Funded with planning grants from foundations, the DPLA intends to go online in 2012, and it is important that the National Archives, Library of Congress, and the Smithsonian have a place at the table, representing the Federal government.
    [Show full text]
  • FBA Newsletter Summer 04
    SUMMER 2004 FEDERAL BAR ASSOCIATION of the Western District of Washington NEWS NEWS NEWS NEWS VOL. 27 NO. 1 SUMMER 2004 NEW U.S. COURTHOUSE GRACES SEATTLE SKYLINE FEDERAL BAR ASSOCIATION NEWS PRESIDENT’S MESSAGE A BUSY SUMMER IN THE WESTERN DISTRICT ’ll keep this short. There’s a lot going on in the Western District of Washington this spring and summer. For starters, we have Itwo new district judges and a new United States Courthouse. Things like that certainly don’t happen every year. Our new judges are profiled in this issue. several workstations with Internet complete and turn in your registration Perhaps the best reflection of their access for laptops, a copier, at least one form each year. Your membership dues stature is the fact that they were both desktop computer for anyone to use, a are not significant enough to be confirmed by the U.S. Senate without computer with access to the court’s memorable. But the budget to publish controversy in a time of extraordinary electronic docket, and some temporary this newsletter, present CLEs, support gridlock over judicial nominations. The lockable storage in which to leave a the activities of our various committees, Western District’s success in keeping its document case or other materials for an and plan other activities is based on federal bench fully staffed in polarized hour or two. Please make good use of member dues. If you can’t remember political times also reflects the these facilities, but take good care of whether you’ve registered for 2004, exceptional collegiality among the them too.
    [Show full text]
  • FBA Newsletter Fall 03
    FALL 2003 FEDERAL BAR ASSOCIATION of the Western District of Washington NEWS NEWS NEWS NEWS VOL. 26 NO. 2 FALL 2003 JUDGE BARBARA JACOBS ROTHSTEIN TAKES THE REINS AT THE FEDERAL JUDICIAL CENTER FEDERAL BAR ASSOCIATION NEWS PRESIDENT’S MESSAGE IMPROVING LEGAL REPRESENTATION FOR THE POOR e all know that the needs of Washington's poor people for legal representation in civil matters are not being Wmet. The Washington State Bar Association estimates that low-income persons experience more than 400,000 instances of unmet legal needs each year in this state. Moreover, over the past decade and more, funding cuts at the national level have weakened programs that provide civil legal aid to the poor. I would like to extend the Association's thanks to the members of the Task Force, who include a number of prominent local In 2002, then-President Jim Smith • Recruiting more attorneys to practitioners and Janet Bubnis of the established the Task Force on the participate in the bankruptcy Clerk's office, for their contributions in Availability of Legal Services for Low- assistance program and other pro creating the Task Force's report. In Income Litigants in Federal Court to bono projects. explore the nature of this problem and particular, Michele Gammer provided her what might be done about it. The Task • Expanding the existing Pro Bono usual exemplary and persistent Force, led by Michele Gammer, issued Panel program, including by having leadership, and Scott Collins authored a its report at our October quarterly Board the Pro Bono Committee consider detailed and compelling memo that of Trustees meeting.
    [Show full text]
  • Federal Judges Association Current Members by Circuit As of 10/8/2020
    Federal Judges Association Current Members by Circuit as of 10/8/2020 1st Circuit United States Court of Appeals for the First Circuit Jeffrey R. Howard 0 Kermit Victor Lipez (Snr) Sandra L. Lynch Ojetta Rogeriee Thompson United States District Court District of Maine D. Brock Hornby (Snr) 0 Jon David Levy George Z. Singal (Snr) Nancy Torresen John A. Woodcock, Jr. (Snr) United States District Court District of Massachusetts Allison Dale Burroughs 0 Denise Jefferson Casper Timothy S. Hillman Mark G. Mastroianni George A. O'Toole, Jr. (Snr) Michael A. Ponsor (Snr) Patti B. Saris F. Dennis Saylor Leo T. Sorokin Richard G. Stearns Indira Talwani Mark L. Wolf (Snr) Douglas P. Woodlock (Snr) William G. Young United States District Court District of New Hampshire Paul J. Barbadoro 0 Joseph N. Laplante Steven J. McAuliffe (Snr) Landya B. McCafferty Federal Judges Association Current Members by Circuit as of 10/8/2020 United States District Court District of Puerto Rico Francisco Augusto Besosa 0 Pedro A. Delgado Hernandez Daniel R. Dominguez (Snr) Jay A. Garcia-Gregory (Snr) Gustavo A. Gelpi, Jr. Juan M. Perez-Gimenez (Snr) United States District Court District of Rhode Island Mary M. Lisi (Snr) 0 John J. McConnell, Jr. William E. Smith 2nd Circuit United States Court of Appeals for the Second Circuit Jose A. Cabranes 0 Guido Calabresi (Snr) Denny Chin Christopher F. Droney (Ret) Peter W. Hall Pierre N. Leval (Snr) Raymond J. Lohier, Jr. Gerard E. Lynch (Snr) Jon O. Newman (Snr) Barrington D. Parker, Jr. (Snr) Reena Raggi (Snr) Robert D. Sack (Snr) John M.
    [Show full text]
  • February 2021
    Federal Judges Association Current Members by Circuit as of 3/3/2021 International Trade United States Court of International Trade Timothy Reif 0 1st Circuit United States Court of Appeals for the First Circuit Jeffrey R. Howard 0 Kermit Victor Lipez (Snr) Sandra L. Lynch Ojetta Rogeriee Thompson United States District Court District of Maine D. Brock Hornby (Snr) 0 Jon David Levy George Z. Singal (Snr) Nancy Torresen John A. Woodcock, Jr. (Snr) United States District Court District of Massachusetts Allison Dale Burroughs 0 Denise Jefferson Casper Timothy S. Hillman Mark G. Mastroianni George A. O'Toole, Jr. (Snr) Michael A. Ponsor (Snr) Patti B. Saris F. Dennis Saylor Leo T. Sorokin Richard G. Stearns Indira Talwani Mark L. Wolf (Snr) Douglas P. Woodlock (Snr) William G. Young United States District Court District of New Hampshire Paul J. Barbadoro 0 Federal Judges Association Current Members by Circuit as of 3/3/2021 Joseph N. Laplante Steven J. McAuliffe (Snr) Landya B. McCafferty United States District Court District of Puerto Rico Francisco Augusto Besosa 0 Pedro A. Delgado Hernandez Daniel R. Dominguez (Snr) Jay A. Garcia-Gregory (Snr) Gustavo A. Gelpi, Jr. United States District Court District of Rhode Island Mary M. Lisi (Snr) 0 John J. McConnell, Jr. William E. Smith 2nd Circuit United States Court of Appeals for the Second Circuit Joseph F. Bianco 0 Jose A. Cabranes Guido Calabresi (Snr) Denny Chin Christopher F. Droney (Ret) Peter W. Hall Pierre N. Leval (Snr) Raymond J. Lohier, Jr. Gerard E. Lynch (Snr) Jon O. Newman (Snr) Barrington D.
    [Show full text]
  • Board for Judicial Administration and Court Management Council
    BOARD FOR JUDICIAL ADMINISTRATION AND COURT MANAGEMENT COUNCIL MEETING PACKET FRIDAY, DECEMBER 12, 2014 9:00 A.M. AOC SEATAC OFFICE 18000 INTERNATIONAL BOULEVARD, SUITE 1106 SEATAC, WASHINGTON Board for Judicial Administration Membership VOTING MEMBERS: Chief Justice Barbara Madsen, Chair Judge Jeffrey Ramsdell, President Supreme Court Superior Court Judges' Association King County Superior Court Judge Kevin Ringus, Member Chair District and Municipal Court Judges' Association Judge Ann Schindler Fife Municipal Court Court of Appeals, Division I Judge Veronica Alicea-Galvan, President Judge Laurel Siddoway District and Municipal Court Judges' Association Court of Appeals, Division III Skagit County District Court Judge Scott Sparks Judge Thomas Bjorgen Superior Court Judges' Association Court of Appeals, Division II Kittitas County Superior Court Judge Bryan Chushcoff Superior Court Judges' Association NON-VOTING MEMBERS: Pierce County Superior Court Judge David Steiner, President-Elect Judge Janet Garrow District and Municipal Court Judges' Association District and Municipal Court Judges' Association King County District Court East Division - Bellevue King County District Court Judge Harold Clarke III, President-Elect Judge Judy Rae Jasprica Superior Court Judges’ Association District and Municipal Court Judges' Association Spokane County Superior Court Pierce County District Court Ms. Callie Dietz Judge Michael Lambo State Court Administrator District and Municipal Court Judges’ Association Kirkland Municipal Court Mr. Anthony Gipe, President Washington State Bar Association Judge John Meyer Superior Court Judges' Association Mr. William Hyslop, President-Elect Skagit County Superior Court Washington State Bar Association Judge Sean Patrick O’Donnell Judge Kevin Korsmo Superior Court Judges' Association Presiding Chief Judge King County Superior Court Court of Appeals, Division III Justice Susan Owens Ms.
    [Show full text]
  • Counsel for Plaintiffs and the Class Case 2:16-Cv-00881-KM-ESK
    Case 2:16-cv-00881-KM-ESK Document 299 Filed 09/14/20 Page 1 of 2 PageID: 8797 James E. Cecchi CARELLA, BYRNE, CECCHI, OLSTEIN, BRODY & AGNELLO, P.C. 5 Becker Farm Road Roseland, New Jersey 07068 Tel: (973) 994-1700 Counsel for Plaintiffs and the Class [Additional Counsel on Signature Page] UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY IN RE: MERCEDES-BENZ Civil Action No. 2:16-0881 (KM) (ESK) EMISSIONS LITIGATION NOTICE OF MOTION To: All Counsel by ECF COUNSEL: PLEASE TAKE NOTICE that at such date and time as the Court shall determine, Plaintiffs, by counsel, shall move under Rule 23 of the Federal Rules of Civil Procedure, for entry of the proposed preliminary approval Order that, among other things, will, (1) preliminarily approve the proposed Settlement; (2) certify the proposed Settlement Class, appoint Plaintiffs as Class representatives, and appoint Class Counsel for purposes of the Settlement; (3) approve the form and manner of giving notice of the proposed Settlement to the Class Members; and (4) schedule a hearing to consider the fairness of the Settlement. PLEASE TAKE FURTHER NOTICE that, in support of the motion, the 704539v1 Case 2:16-cv-00881-KM-ESK Document 299 Filed 09/14/20 Page 2 of 2 PageID: 8798 undersigned intends to rely on the accompanying Memorandum of Law and supporting declarations of Steve W. Berman and Jennifer M. Keough. PLEASE TAKE FURTHER NOTICE that a proposed form of Order is attached. Dated: September 14, 2020 Respectfully submitted, CARELLA BYRNE CECCHI OLSTEIN BRODY & AGNELLO, P.C. By /s/ James E.
    [Show full text]
  • Keller Rohrback L.L.P. Resume
    Case: 1:14-cv-01873 Document #: 156-2 Filed: 02/16/18 Page 1 of 37 PageID #:1696 EXHIBIT B to Declaration of Lynn Lincoln Sarko in Support of Plaintiffs’ Unopposed Motion for Preliminary Approval of Settlement Agreement (KELLER ROHRBACK L.L.P. RESUME) Case: 1:14-cv-01873 Document #: 156-2 Filed: 02/16/18 Page 2 of 37 PageID #:1697 ERISA LITIGATION SEATTLE PHOENIX NEW YORK SANTA BARBARA OAKLAND RONAN 800-776-6044 | [email protected] | www.krcomplexlit.com Case: 1:14-cv-01873 Document #: 156-2 Filed: 02/16/18 Page 3 of 37 PageID #:1698 ABOUT KELLER ROHRBACK Devoted to Justice “[Keller Rohrback] has performed an important public service in this action and has done so efficiently and with integrity…[Keller Rohrback] has also worked creatively and diligently to obtain a settlement from WorldCom in the context of complex and difficult legal questions…”In re WorldCom, Inc. ERISA Litigation, No. 02-4816 (S.D.N.Y.) (Cote, J.). Keller Rohrback’s lawyers excel by being prepared and persuasive. It’s a simple formula that combines our strengths: outstanding writing and courtroom skills, together with unparalleled passion and integrity. We have recovered billions of dollars for our clients, and have served as lead counsel in many prominent cases. Our lawyers are widely recognized as leaders in their fields who have dedicated their careers to combating corporate fraud and misconduct. We have the talent as well as the financial resources to litigate against Fortune 500 companies—and do so every day. Who We Are Keller Rohrback’s Complex Litigation Group has a national reputation as the go-to plaintiff’s firm for large-scale, complex individual and class action cases.
    [Show full text]