Ortiz v. Menu Foods, Inc. et al

Filing 19

REPLY re 9 MOTION to Remand to State Court filed by Yvonne Ortiz. (Attachments: # 1 Declaration of Thomas R. Grande# 2 Exhibit 1# 3 Exhibit 2# 4 COS)(Grande, Thomas)

Ortiz v. Menu Foods, Inc. et al

Doc. 19 Att. 1

Case 1:07-cv-00323-DAE-LEK

Document 19-2

Filed 08/09/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII YVONNE ORTIZ, individually and on behalf of all other similarly situated persons, Plaintiff, v. MENU FOODS, INC., a New Jersey Corporation; MENU FOODS HOLDINGS, INC., a Delaware Corporation, MENU FOODS INCOME FUND, an unincorporated Canadian business; DOE ENTITIES and INDIVIDUALS 1- 100, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil No. CV07-00323 DAE LEK (Class Action) DECLARATION OF THOMAS R. GRANDE

DECLARATION OF THOMAS R. GRANDE I, Thomas R. Grande, do hereby state and declare as follows: 1. I am a partner of Davis Levin Livingston Grande, Attorneys at Law,

one of the attorneys for Plaintiff in this lawsuit. 2. I am an attorney licensed to practice law in all of the Courts in the

State of Hawaii, and am the attorney for Plaintiff in the above-entitled action. I make this Declaration based upon my own personal knowledge of the matters herein set forth.

Dockets.Justia.com

Case 1:07-cv-00323-DAE-LEK

Document 19-2

Filed 08/09/2007

Page 2 of 2

3.

Attached hereto as Exhibit 1 is a true and correct copy of "Menu

Foods Income Fund Consolidated Balance Sheets" dated March 2007 obtained from http://www.menufoods.com/ir/sedar.html on August 8, 2007. 4. Attached hereto as Exhibit 2 is a true and correct copy of the

Transcript of FDA Press Conference on the Pet Food Recall (April 19, 2007) obtained from www.fda.gov/bbs/transcripts/transcript041907.pdf on August 9, 2007. 5. The conversion rate on August 7, 2007 was 0.948367 one US dollar

for one Canadian dollar. This information was obtained from http://www.xe.com/ucc/ on August 7, 2007. 6. As of 2006, the U.S. Census Bureau reports that the population of

Hawaii is 1,285,498. The U.S. Census Bureau reports that the population of the United States in 2006 was 299,398,484. Hawaii's population equals 0.0042 of the U.S. population. This information was obtained from http://www.census.gov/popest/estimates.php on August 8, 2007. I declare under penalty of perjury that the foregoing is true and correct. DATED: Honolulu, Hawaii, August 9, 2007. /s/ Thomas R. Grande THOMAS R. GRANDE Attorney for Plaintiff

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