In Re: Webloyalty.com, Inc., Marketing and Sales Practices Litigation

Filing 32

DECLARATION re 30 MOTION for Sanctions, 31 Memorandum in Support of Motion by Webloyalty.com, Inc., Fandango, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7)(Abaid, Kim)

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In Re: Webloyalty.com, Inc., Marketing and Sales Practices Litigation Doc. 32 Case 1:07-md-01820-JLT Document 32 Filed 02/20/2007 Page 1 of 2 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS JOE W. KUEFLER, Individually and on Behalf of All Others Similarly Situated, Plaintiff, v. WEBLOYALTY.COM, INC. and FANDANGO, INC. d/b/a FANDANGO.COM, Defendants. CIVIL ACTION NO. 06-cv-11620-JLT DECLARATION OF GABRIELLE R. WOLOHOJIAN I, Gabrielle R. Wolohojian, declare as follows: 1. I am a Partner at the law firm of Wilmer Cutler Pickering Hale and Dorr LLP, counsel of record for Webloyalty.com, Inc. and Fandango, Inc. d/b/a Fandango.com, in the above-captioned action. I am an attorney in good standing admitted to the bars of the Commonwealth of Massachusetts, the State of New York, and this Court. 2. Attached hereto as Exhibit 1 is a true and accurate copy of a November 20, 2006, Letter from Gabrielle Wolohojian to David George. 3. Attached hereto as Exhibit 2 is a true and accurate copy of a January 30, 2007 Email from David George to Gabrielle Wolohojian. 4. Attached hereto as Exhibit 3 is a true and accurate copy of an email string sent by Elizabeth A. Alquist of Day Pitney LLP to Gabrielle Wolohojian on January 31, 2007, which 1 Dockets.Justia.com Case 1:07-md-01820-JLT Document 32 Filed 02/20/2007 Page 2 of 2 forwards email communications among counsel for the Connecticut Better Business Bureau, counsel for the Plaintiff, and the Connecticut Better Business Bureau. 5. Attached hereto as Exhibit 4 is a true and accurate copy of a January 31, 2007 Email from Gabrielle Wolohojian to David George. 6. Attached hereto as Exhibit 5 is a true and accurate copy of a February 1, 2007 Letter from David George to Gabrielle Wolohojian (without exhibits to avoid duplication). 7. Attached hereto as Exhibit 6 is a true and accurate copy of a February 5, 2007 Letter from Gabrielle Wolohojian to David George. 8. Attached hereto as Exhibit 7 is a true and accurate copy of a February 6, 2007 Letter from David George to Gabrielle Wolohojian. SIGNED UNDER THE PAINS AND PENALTIES OF PERJURY, THIS 20th DAY OF FEBRUARY, 2007. ___/s/ Gabrielle R. Wolohojian_______ Gabrielle R. Wolohojian 2 US1DOCS 6070376v1

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