Wallace et al v. ConAgra Foods, Inc.

Filing 1

NOTICE OF REMOVAL by ConAgra Foods, Inc. from Dakota County District Court, case number Unknown. ( Filing fee $ 350 receipt number 3-009652) assigned to Judge Donovan W. Frank per Master List and referred to Magistrate Judge Franklin L. Noel, filed by ConAgra Foods, Inc. (Attachments: # 1 Exhibit 1: Complaint, Summons; Exhibits A - K, # 2 Declaration of Matt Russell, # 3 Notice of Filing of Notice of Removal to Federal Court, # 4 Civil Cover Sheet, # 5 Certificate of Service). (lmb)

ConAgra’s
Notice of Removal
EXHIBIT 2

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
MELVIN WALLACE, et al., individually
and on behalf of others similarly situated,
Case No. __________________
Plaintiffs,
DECLARATION OF
MATT RUSSELL

vs.
CONAGRA FOODS, INC.,
Defendant.

I, Matt Russell, declare pursuant to 28 U.S.C. § 1746 as follows:
1.

I am currently a Director of Finance at ConAgra Foods, Inc. My duties

include reviewing past and current financial information relating to Hebrew National
branded products.
2.

Defendant ConAgra Foods, Inc. is a corporation organized under the laws

of the State of Delaware with its principal place of business at One ConAgra Drive,
Omaha, Nebraska. The Hebrew National branded products are owned by ConAgra Foods
Packaged Foods, LLC, which is an indirect wholly owned subsidiary of ConAgra Foods,
Inc. ConAgra Foods Packaged Foods, LLC is a limited liability company organized
under the laws of the State of Delaware with its principal place of business at One
ConAgra Drive, Omaha, Nebraska.
3.

In fiscal year 2012 (the most recent year for which annual revenue

information is available) the annual revenues from sales of Hebrew National branded
products in the United States exceeded $5,000,000.