Rupa Marya v. Warner Chappell Music Inc

Filing 305

DECLARATION of Tiffaney Janowicz in Support of NOTICE OF MOTION AND MOTION for Settlement Approval of Preliminary Approval of Proposed Class Action Settlement ; Memorandum of Points and Authorities in Support Thereof 301 filed by Plaintiffs Good Morning to You Productions Corp, Majar Productions LLC, Rupa Marya, Robert Siegel. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Manifold, Betsy)

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2 3 4 UNITED STATES DISTRICT COURT 5 CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 6 7 GOOD MORNING TO YOU PRODUCTIONS CORP., et al., Lead Case No. CV 13-04460-GHK (MRWx) 8 Plaintiffs, 9 10 v. 11 WARNER/CHAPPELL MUSIC, INC., et al., 12 Defendants. 13 14 15 DECLARATION OF TIFFANEY JANOWICZ IN SUPPORT OF PRELIMINARY APPROVAL OF PROPOSED SETTLEMENT Judge: Hon. George H. King, Chief Judge Date: Feb.29, 2016 Time: 9:30 a.m. Room: 650 Judge: Hon. George H. King Chief Judge 16 17 I, Tiffaney Janowicz, hereby declare as follows: 18 1. I am a Senior Vice President of Rust Consulting, Inc. ("Rust"). I submit 19 this declaration in connection with the above-captioned matter at the request of 20 Counsel. l make this declaration based upon my own personal knowledge and, if 21 called as a witness in this action, I would be able to competently testify as to the facts 22 set fo1th herein. Attached as Exhibit A is my C.V., which outlines my experience and 23 qualifications. 24 2. 25 With nearly 30 years of class action settlement administration experience, Rust is among the industry's leaders. Rust has administered more than 5,200 class 26 action settlements, judgments, and similar administrative programs, 2,000 of which 27 28 were in the past five years alone. Rust employs a permanent staff of approximately JANOW ICZ DECL. C ASE NO. CV 13-04460-GHK (MRWX) 300 people working in offices nationwide. 2 3 A C.V. outlining Rust's services and experience is attached as Exhibit B. 3. Rust handles the claims administration process for class actions of all 4 sizes and types, including consumer, antitrust, securities, insurance, healthcare, labor 5 and employment, property, finance, telecom, and products liability class actions. In 6 the past, Rust has handled claims administration in, among many other matters, the 7 $1.l billion settlement in Microsoft 1-VCases, J.C.C.P. No. 4106 (Cal. Super. Ct. San 8 Francisco County); the $65 million settlement in In re Lawn Mower Engine 9 Horsepower Marketing and Sales Practices Litig., No. 2:08-md-1999, MDL No. 1999 10 (E.D. Wisc.); the $316 million direct purchasers settlement in In re TFT-LCD (Flat 11 Panel) Antitrust Litigation, MDL No. 1827 (N.D. Cal.); the $166 million settlement in 12 Jn re Electronic Books Antitrust litigation, No. 11-md-2293 (S.D.N.Y.); and the $125 13 million settlement in Jn re Pharmaceutical Industry Average Wholesale Price 14 litigation 15 01-CV-12257-PBS, MDL No. 16 administering class action settlements of all types and sizes and will use this 17 experience to develop and implement the claims administration process for this action. 18 4. (All Class Actions Relating to 1456. Track Two Defendants), No. Rust has considerable experience in I have reviewed the Settlement Agreement, the notice provisions therein, 19 and the Settlement Class Member Address List. I believe that the proposed settlement 20 notice and administration is typical to programs that Rust Consulting has implemented 21 in similar matters, as well as other such programs I am aware of. 22 5. Based on the proposed notice and administration plans outlined in the 23 Settlement Agreement, I estimate the cost of the entire program to be approximately 24 $120,000. [am aware that, subject to the Court's approval, the first $100,000 of notice 25 and administration expenses will be paid from the Settlement Fund. Rust has made 26 satisfactory arrangements with the Defendants to satisfy any additional notice and 27 28 2 JANO WI CZ DECL. CASE NO. CV 13-04460-G HK(MRW x) administration expenses that may be incurred to comply with the notice and 2 administration plans set forth in the Settlement Agreement. 3 I declare under penalty of perjury that the foregoing is true and correct. 4 Executed this 23rd day of February, 2016. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JANOWICZ DECL. CAS E NO. CV 13-04460-G HK (MRWx)

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