Rupa Marya v. Warner Chappell Music Inc
Filing
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NOTICE OF MOTION AND MOTION for Appointment of Counsel Wolf Haldenstein as Interim Lead Class Counsel filed by plaintiffs Rupa Marya. Motion set for hearing on 9/9/2013 at 09:30 AM before Judge George H. King. (Attachments: # 1 Proposed Order, # 2 Declaration of Service)(Rickert, Rachele)
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FRANCIS M. GREGOREK (144785)
gregorek@whafh.com
BETSY C. MANIFOLD (182450)
manifold@whafh.com
RACHELE R. RICKERT (190634)
rickert@whafh.com
MARISA C. LIVESAY (223247)
livesay@whafh.com
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
750 B Street, Suite 2770
San Diego, CA 92101
Telephone: 619/239-4599
Facsimile: 619/234-4599
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Attorneys for Plaintiffs
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[Additional Counsel Appear on Signature Page]
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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RUPA MARYA, et al.,
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Plaintiffs,
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v.
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WARNER/CHAPPELL MUSIC,
INC.,
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Defendant.
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Lead Case No. CV 13-04460-GHK
(MRWx)
NOTICE OF MOTION AND MOTION
FOR APPOINTMENT OF WOLF
HALDENSTEIN ADLER FREEMAN
& HERZ LLP AS INTERIM LEAD
CLASS COUNSEL; MEMORANDUM
OF POINTS AND AUTHORITIES IN
SUPPORT THEREOF; AND
[PROPOSED] ORDER THEREON
Date:
Time:
Room:
Judge:
September 9, 2013
9:30 a.m.
650
Hon. George H. King,
Chief Judge
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that on or about September 9, 2013, at 9:30 a.m.,
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or as soon thereafter as this matter may be heard before the Honorable George H.
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King, Chief Judge, in Courtroom 650 of the Edward R. Roybal Federal Building,
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located at 255 E. Temple Street, Los Angeles, CA 90012, Plaintiffs Rupa Marya,
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Robert Siegel, and Good Morning To You Productions Corp. (“Plaintiffs”) will, and
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hereby do, move this Court for an order appointing Wolf Haldenstein Adler
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Freeman & Herz LLP as interim lead class counsel pursuant to Federal Rules of
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Civil Procedure 23(g)(1)(B).
This consolidated action involves a justiciable
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controversy over the claim of copyright for the world’s most popular English song,
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Happy Birthday To You, purportedly held by Defendant Warner/Chappell Music,
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Inc., a division of the Warner Music Group.
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This motion is based on this Notice of Motion and Motion, the accompanying
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Memorandum of Points and Authorities, the Declaration of Betsy C. Manifold filed
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concurrently herewith, all the pleadings and documents on file herein, such other
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oral and documentary evidence as may be presented at or before the hearing on this
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motion, and all facts of which this Court may take judicial notice.
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This motion is made following the conference of counsel pursuant to L.R.
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7-3, which took place on July 8 & 11, 2013 and August 1, 2013.
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Dated: August 5, 2013
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
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By:
/s/ Rachele R. Rickert
RACHELE R. RICKERT
FRANCIS M. GREGOREK
gregorek@whafh.com
BETSY C. MANIFOLD
manifold@whafh.com
RACHELE R. RICKERT
rickert@whafh.com
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MARISA C. LIVESAY
livesay@whafh.com
750 B Street, Suite 2770
San Diego, CA 92101
Telephone: 619/239-4599
Facsimile: 619/234-4599
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
MARK C. RIFKIN
rifkin@whafh.com
JANINE POLLACK
pollack@whafh.com
BETH A. LANDES
landes@whafh.com
GITI BAGHBAN (284037)
baghban@whafh.com
270 Madison Avenue
New York, NY 10016
Telephone: 212/545-4600
Facsimile: 212-545-4753
RANDALL S. NEWMAN PC
RANDALL S. NEWMAN (190547)
rsn@randallnewman.net
37 Wall Street, Penthouse D
New York, NY 10005
Telephone: 212/797-3737
HUNT ORTMANN PALFFY NIEVES
DARLING & MAH, INC.
KATHERINE J. ODENBREIT (184619)
odenbreit@huntortmann.com
TINA B. NIEVES (134384)
tina@nieves-law.com
301 North Lake Avenue, 7th Floor
Pasadena, CA 91101
Telephone 626/440-5200
Facsimile 626/796-0107
Facsimile: 212/797-3172
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DONAHUE GALLAGHER WOODS LLP
WILLIAM R. HILL (114954)
rock@donahue.com
ANDREW S. MACKAY (197074)
andrew@donahue.com
DANIEL J. SCHACHT (259717)
daniel@donahue.com
1999 Harrison Street, 25th Floor
Oakland, CA 94612-3520
Telephone: 510/451-0544
Facsimile: 510/832-1486
Attorneys for Plaintiffs
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MEMORANDUM OF POINTS AND AUTHORITIES
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I.
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INTRODUCTION
This is a consolidated class action against defendant Warner/Chappell Music,
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Inc. (“Warner/Chappell”).1
The Consolidated Complaint seeks to invalidate
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Warner/Chappell’s purported copyright of Happy Birthday to You, asserting claims
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for declaratory and corollary injunctive relief arising under the Copyright Act, 17
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U.S.C. §§ 101 et seq. (the “Copyright Act”) as well as a claim under California’s
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Unfair Competition Law, Business & Professions Code §§ 17200 et seq. (“UCL”)
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(the “HBTY Action”).
Specifically, the HBTY Action seeks, inter alia, (i) a
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declaration that Happy Birthday to You is in the public domain and dedicated to
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public use; (ii) an injunction to prevent Warner/Chappell from making additional
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representations of ownership of Happy Birthday to You; and (iii) an order requiring
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Warner/Chappell to return license fees unlawfully obtained from Plaintiffs and
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members of the proposed class as a result of Warner/Chappell’s wrongful assertion
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Pursuant to the parties’ stipulation and order issued by this Court on July 16,
2013, Siegel v. Warner/Chappell Music, Inc., No. 13-CV-04418 (GHK)(MRW) and
Marya v. Warner/Chappell Music, Inc., No. 13-CV-04460 (GHK)(MRW) were
consolidated for all purposes and plaintiffs were directed to file a consolidated
complaint on or before July 26, 2013. See Order on Stipulation, ECF No. 17, July
16, 2013 (“Consolidation Order”). In accordance with this Court’s Consolidation
Order, L.R. 15-1, and L.R. 3-2, on July 26, 2013, plaintiffs gave notice of manually
filing their Consolidated First Amended Complaint for Declaratory Relief; Injunctive
and Declaratory Relief; and Damages for (1) Invalidity of Copyright Act (17 U.S.C.
§§ 101 et seq.); and (2) Unfair Competition Laws (Cal. Bus. & Prof. Code §§ 17200
et seq.) (the “Consolidated Complaint”). The Consolidated Complaint was manually
filed because it added a new plaintiff and proposed class representative, Good
Morning To You Productions Corp. See Not. Of Manual Filing, ECF No. 21. On
July 26, 2013, the Clerk’s office issued a Notice of Document Deficiencies because
the caption on the Consolidated Complaint did not match the caption on the docket
due to the addition of the new party. As of the date of filing of this motion, the
Consolidated Complaint has not been accepted as filed in this action.
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of copyright ownership. Plaintiffs are also aware of a related action filed on or about
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July 17, 2013, Majar Productions, LLC v. Warner/Chappell Music, Inc., et al., Case
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No. CV 13-05164-GHK (MRWx).
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Plaintiffs in the HBTY Action now seek appointment of one of their counsel,
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Wolf Haldenstein Adler Freeman & Herz LLP (“Wolf Haldenstein”), as interim lead
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class counsel in accordance with the Manual for Complex Litigation (Fourth ed.
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2004) (the “MCL”) and Federal Rules of Civil Procedure 23(g).
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II.
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WOLF HALDENSTEIN SHOULD BE DESIGNATED INTERIM
LEAD CLASS COUNSEL
This action requires strong stewardship through experienced and well-
capitalized counsel.
In this regard, Rule 23(g)(2)(A) authorizes the Court to
“designate . . . class counsel to act on behalf of the putative class before determining
whether to certify the action as a class action.” As the Advisory Committee noted on
the 2003 amendments to Rule 23, designation of interim lead class counsel prior to
certification is appropriate because:
[I]t will usually be important for an attorney to take action
to prepare for the certification decision. The amendment to
Rule 23(c)(1) recognizes that some discovery is often
necessary for that determination. It may also be important
to make or respond to motions before certification. . . . Rule
23(g)(2)(A) authorizes the court to designate interim
counsel to act on behalf of the putative class before the
class certification decision is made.
Rule 23(g) Adv. Comm. note.
Specifically, Rule 23(g)(1)(B) directs the Court to appoint interim class
counsel who will “fairly and adequately represent the interests of the class.” In
appointing class counsel, the rule directs the Court to consider “any other matter
pertinent to counsel’s ability to fairly and adequately represent the interests of the
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class,” including the following factors described in Rule 23(g):
• the work counsel has done in identifying or
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investigating potential claims in the action;
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• counsel’s experience in handling class actions, other
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complex litigation, and claims of the type asserted in
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the action;
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• counsel’s knowledge of the applicable law; and
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• the resources counsel will commit to representing the
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class.
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Rule 23(g)(1)(A)(i)-(iv). Rule 23(g)(1) additionally provides that the Court may
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“consider any other matter pertinent to counsel’s ability to fairly and adequately
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represent the interests of the class.” Rule 23(g)(1)(B).
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As detailed below, Wolf Haldenstein amply satisfies the requirements of Rule
23(g)(1) and Rule 23(g)(3) for appointment as interim lead class counsel.
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A.
Wolf Haldenstein Has Performed Significant Work In This Case
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Working with its co-counsel, Randall S. Newman, Wolf Haldenstein has
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dedicated considerable time and resources and performed exhaustive research to
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independently investigate the claims asserted in this litigation. As a result of its
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considerable efforts, Wolf Haldenstein filed a highly-detailed complaint against
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Warner/Chappell after all the pertinent facts were uncovered. Among other things,
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Wolf Haldenstein met several times with a leading copyright scholar; parsed through
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scores of original copyright and assignment records; reviewed
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decades-old, previously-filed actions; performed an exacting review of the Copyright
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Act of 1909 and its legislative history; visited the Library of Congress, the United
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States Copyright Office, as well as various university libraries to collect research;
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and reviewed hundreds of books and articles on the subject available in print and
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online.
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researched and persuasively written. Declaration of Betsy C. Manifold In Support of
pleadings from
The original complaint that Wolf Haldenstein filed was meticulously
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Motion For Appointment of Wolf Haldenstein As Interim Lead Class Counsel
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(“Manifold Decl.”) at 1, ¶¶ 2-3.
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Furthermore, Wolf Haldenstein sought to coordinate the efforts of all
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plaintiffs’ counsel in the prosecution of this litigation by moving to consolidate and
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coordinate these actions to reduce duplication of efforts and streamline the
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prosecution of the actions on behalf of Plaintiffs. Wolf Haldenstein has sought to
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include other counsel in the organization of the litigation, and thus far has obtained
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the support of Donohue Gallagher Woods, which had independently researched the
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validity of Warner/Chappell’s copyright to Happy Birthday to You, to lead the
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prosecution for Plaintiffs. Manifold Decl. at 1-2, ¶ 4. Wolf Haldenstein proposes a
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streamlined organization for Plaintiffs’ counsel that will best ensure the efficient
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prosecution of the action.
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Wolf Haldenstein has acted to efficiently and meaningfully advance this
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litigation, and its efforts have proven successful to date. There is no doubt that the
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substantial work Wolf Haldenstein has expended in this litigation demonstrates its
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qualification to serve as interim lead class counsel.
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B.
Wolf Haldenstein Has Extensive Experience In Complex Class
Actions And Extensive Resources To Prosecute This Action
As reflected in its firm resume, attached as Exhibit A to the concurrently filed
Manifold Declaration, Wolf Haldenstein is among the most experienced class action
firms in the United States, having represented plaintiffs in nationwide class actions
and other complex, large-scale litigations.
The firm’s resume contains a
representative list of the many cases Wolf Haldenstein prosecuted as lead or primary
counsel. The resume also details the results achieved in those cases and numerous
published decisions from the cases in which Wolf Haldenstein served as class
counsel or in a significant role. Quite simply, Wolf Haldenstein’s achievements and
reputation are superb.
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Courts nationwide recognize Wolf Haldenstein’s qualifications to serve as
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class counsel. See, e.g., K.J. Egleston L.P. v. Heartland Industrial Partners, et al.,
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2:06-13555 (E.D. Mich.) (praising Wolf Haldenstein at the June 7, 2010 final
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approval hearing for doing “an outstanding job of representing [its] clients,” as lead
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counsel and further commenting that “the conduct of all counsel in this case and the
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result they have achieved for all of the parties confirms that they deserve the national
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recognition they enjoy.”); Parker Friedland v. Iridium World Communications, Ltd.,
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99-1002 (D.D.C.) (where the Firm was co-lead counsel, Judge Laughrey noted (on
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October 16, 2008), “[a]ll of the attorneys in this case have done an outstanding job,
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and I really appreciate the quality of work that we had in our chambers as a result of
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this case.”); In re Luxottica Group, S.p.A. Sec. Litig., 2004 WL 2370650, at *5
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(E.D.N.Y. Oct. 22, 2004) (selecting Wolf Haldenstein lead class counsel based on the
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firm’s “experience and expertise”); In re Comdisco Sec. Litig., 150 F. Supp. 2d 943,
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951 (N.D. Ill. 2001) (noting that Wolf Haldenstein’s credentials “are impeccable”);
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Manifold Decl., Ex. A at 7-8. Recently, in In Re Dynamic Random Access Memory
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Antitrust Litigation, MDL-02-1486 (N.D. Cal. filed Oct. 23, 2002), where the firm
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was co-lead counsel in a massive antitrust litigation involving many plaintiffs and
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many defendants, Judge Phyllis J. Hamilton stated (on August 15, 2007):
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I thought that you all did an exceptionally good job of
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bringing to me only those matters that really required the
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Court’s attention. You did an exceptionally good job at
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organizing and managing the case, assisting me in
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management of the case. There was excellent coordination
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between all the various different plaintiffs’ counsel with
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your group and the other groups that are part of this
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litigation. . . . So my conclusion is the case was well
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litigated by both sides, well managed as well by both sides.
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Manifold Decl., Ex. A at 7.
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Moreover, at the completion of a very contentious and complicated litigation,
Judge Milton Shadur paid the firm a great compliment:
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It has to be said . . . that the efforts that have been extended
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[by Wolf Haldenstein] on behalf of the plaintiff class in the
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face of these obstacles have been exemplary. And in my
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view
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professionalism that the critics of class actions . . . are
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never willing to recognize . . . . I really cannot speak too
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highly of the services rendered by class counsel in an
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[Wolf
Haldenstein]
reflected
the
kind
of
extraordinary difficult situation.
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In re Comdisco Sec. Litig., No. 01 C 2110 (N.D. Ill. July 14, 2005); Manifold Decl.,
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Ex. A at 7-8.
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In In re TXU Corp. Derivative Litigation, Consolidated Cause No. 07-1779
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(Dallas County, Tex. 44th Judicial Dist.), Judge Carlos Cortez of the 44th Judicial
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District in Dallas County, Texas, noted of Wolf Haldenstein and its co-lead counsel
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upon the successful conclusion of litigation:
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You are exactly, the people in this room are exactly what I
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try to tell people week in and week out who come to this
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court to serve as jurors, that the profession of law is still
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noble, and all of you are a credit to the bar, and I’m
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humbled to be in your presence.
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In re TXU Corp. Derivative Litigation, Consolidated Cause No. 07-1779 (Dallas
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Cnty., Tex. 44th Jud. Dist.) (April 18, 2008).
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Presently, Wolf Haldenstein is serving as lead counsel in Ardon v. City of Los
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Angeles, Los Angeles Superior Court, Case No. BC363959, a massive, $750 million
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class action which challenges the validity of the City of Los Angeles’s telephone
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users tax on behalf of the City’s taxpayers, and recently achieved the reversal in the
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California Supreme Court of the trial court’s dismissal of the class claims. See
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Ardon, 52 Cal. 4th 241 (2011).
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outstanding quality of Wolf Haldenstein’s work, but also the firm’s dogged
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perseverance and its ability to coordinate and lead the efforts of many plaintiffs’
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firms against a vigorous, no-holds-barred defense. See Manifold Decl., Ex. A at 25,
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40. See also id. (citing McWilliams v. City of Long Beach, 56 Cal. 4th 613 (2013), a
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similar class action where Wolf Haldenstein serves as lead counsel in an action
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challenging the City of Long Beach’s telephone users tax on behalf of Long Beach
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taxpayers).
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That case is strong evidence not only of the
Wolf Haldenstein Will Commit The Resources Necessary To
Represent The Class Properly
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As demonstrated by the firm’s long and distinguished record of success, Wolf
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Haldenstein possesses the ability and willingness to expend the financial and human
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resources necessary to prosecute this litigation on behalf of the proposed class.
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Indeed, throughout Wolf Haldenstein’s long and proud history, there has never been
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any question that the firm could and would devote millions of dollars (or more) of
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resources if necessary for the successful prosecution of a case.
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Wolf Haldenstein is a venerable and well-respected full-service law firm,
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tracing its roots to 1888, with practice groups in corporate/tax, pension/benefits, real
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estate, trusts and estates, healthcare, bankruptcy, limited partnerships, and civil and
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commercial litigation, with a particular specialty in complex class action litigation
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under both federal and state law. Wolf Haldenstein has offices in New York, New
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York; San Diego, California; and Chicago, Illinois. There can be no question that the
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proposed class would benefit from the unique depth and breadth of Wolf
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Haldenstein’s knowledge and expertise in a number of related areas of the law.
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The firm’s resources are not merely financial, but also include substantial
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expertise and work-product that it has developed in other class action cases that will
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be an obvious benefit to the Plaintiffs in this action. Wolf Haldenstein’s ability to
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draw from this well-developed bank of information in directing this litigation, and to
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use the resources of other plaintiffs’ counsel throughout the prosecution of the
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litigation, will allow it to streamline the litigation and create efficiency in the
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process.
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counsel to direct the litigation has the principal benefit of avoiding the unnecessary
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complication, duplication of effort, and waste which could result if no appointment
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of a lead counsel is made and all law firms present in the actions work collectively
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without leadership.
Moreover, the appointment of Wolf Haldenstein as interim lead class
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Accordingly, Plaintiffs respectfully ask this Court to appoint Wolf Haldenstein
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interim lead class counsel in this action and all subsequently-filed actions and then
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authorize Wolf Haldenstein to direct and supervise the activities of other firms that
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may represent plaintiffs in future related class actions. There can be no dispute that
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Wolf Haldenstein possesses more than sufficient capital and other resources to
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pursue this litigation vigorously on behalf of the class and it is committed to doing
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so.
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2.
Lead Counsel Is Also Appropriate To Direct And Manage
Complex Cases
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It is well-established that a court may appoint lead counsel to direct and
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manage complex cases. See Vincent v. Hughes Air West, Inc., 557 F.2d 759, 774-75
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(9th Cir. 1977); accord In re Bendectin Litigation, 857 F.2d 290, 297 (6th Cir. 1988).
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Appointment of lead counsel eliminates
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duplication and repetition and in effect the creation of a coordinator of
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diffuse plaintiffs through whom motions and discovery proceedings will
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be channeled, will most certainly redound to the benefit of all parties to
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the litigation. The advantages of this procedure should not be denied
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litigants in the federal courts because of misapplied notions concerning
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interference with a party’s right to his own counsel.
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MacAlister v. Guterma, 263 F.2d 65, 69 (2d Cir. 1958).
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In addition, the Manual for Complex Litigation recognizes the benefits of
appointing lead counsel in complex, multiparty litigation:
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Complex litigation often involves numerous parties with
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common or similar interests but separate counsel.
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Traditional procedures in which all papers and documents
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are served on all attorneys, and each attorney files motions,
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presents arguments, and examines witnesses, may waste
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time and money, confuse and misdirect the litigation, and
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burden the court unnecessarily.
Instituting special
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procedures for coordination of counsel early in the
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litigation will help to avoid these problems.
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MCL § 10.22.
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In appointing interim lead class counsel in this complex case, lead counsel
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should have the following duties and responsibilities: (1) authority to speak for the
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plaintiffs in matters regarding pretrial and trial procedure and settlement
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negotiations; (2) responsibility to make all work assignments in such manner as to
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facilitate the orderly and efficient prosecution of this litigation and to avoid
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duplicative or unproductive effort; (3) duty to coordinate all activities and
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appearances on behalf of plaintiffs and for the dissemination of notices and orders of
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this Court (i.e., no motion, request for discovery or other pretrial proceedings shall be
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initiated or filed by plaintiffs except through lead counsel); and (4) responsibility for
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communications to and from this Court and for the creation and maintenance of a
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master service list of all parties and their respective counsel. Finally, defendant’s
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counsel may rely upon all agreements made with interim lead class counsel, or other
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duly authorized representatives of plaintiffs, and such agreements shall be binding on
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all plaintiffs.
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III.
CONCLUSION
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Based on the foregoing, Plaintiffs respectfully request that the Court appoint
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Wolf Haldenstein as interim lead class counsel and grant such other relief as the
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Court may deem to be just and proper.
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Dated: August 5, 2013
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
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By:
/s/ Rachele R. Rickert
RACHELE R. RICKERT
FRANCIS M. GREGOREK
gregorek@whafh.com
BETSY C. MANIFOLD
manifold@whafh.com
RACHELE R. RICKERT
rickert@whafh.com
MARISA C. LIVESAY
livesay@whafh.com
750 B Street, Suite 2770
San Diego, CA 92101
Telephone: 619/239-4599
Facsimile: 619/234-4599
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
MARK C. RIFKIN
rifkin@whafh.com
JANINE POLLACK
pollack@whafh.com
BETH A. LANDES
landes@whafh.com
GITI BAGHBAN (284037)
baghban@whafh.com
270 Madison Avenue
New York, NY 10016
Telephone: 212/545-4600
Facsimile: 212-545-4753
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RANDALL S. NEWMAN PC
RANDALL S. NEWMAN (190547)
rsn@randallnewman.net
37 Wall Street, Penthouse D
New York, NY 10005
Telephone: 212/797-3737
Facsimile: 212/797-3172
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HUNT ORTMANN PALFFY NIEVES
DARLING & MAH, INC.
KATHERINE J. ODENBREIT (184619)
odenbreit@huntortmann.com
TINA B. NIEVES (134384)
tina@nieves-law.com
301 North Lake Avenue, 7th Floor
Pasadena, CA 91101
Telephone 626/440-5200
Facsimile 626/796-0107
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DONAHUE GALLAGHER WOODS LLP
DANIEL J. SCHACHT
WILLIAM R. HILL (114954)
rock@donahue.com
ANDREW S. MACKAY (197074)
andrew@donahue.com
DANIEL J. SCHACHT (259717)
daniel@donahue.com
1999 Harrison Street, 25th Floor
Oakland, CA 94612-3520
Telephone: 510/451-0544
Facsimile: 510/832-1486
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Attorneys for Plaintiffs
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WARNER/CHAPPELL:20115.MOT
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