North American Karaoke-Works Trade Association, Inc. v. Entral Group International, LLC

Filing 33

North American Karaoke-Works Trade Association, Inc. v. Entral Group International, LLC

Doc. 33

Case 1:06-cv-05158-LTS-MHD

Document 33

Filed 01/26/2007

Page 1 of 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK NORTH AMERICAN KARAOKE-WORKS TRADE ASSOCIATION, INC. Plaintiff and Counterclaim Defendant, v. ENTRAL GROUP INTERNATIONAL, LLC, Case No. 06-CV-5158 (LTS)(MHD) Defendant and Counterclaim Plaintiff, v. SAM CHAN and RAY YIM, Counterclaim Defendants. DECLARATION OF ROBERT E. HANLON IN SUPPORT OF DEFENDANT AND COUNTERCLAIM PLAINTIFF'S REPLY MEMORANDUM IN SUPPORT OF THE STRIKING OF PLAINTIFF'S AND COUNTERCLAIM DEFENDANTS' PLEADINGS ROBERT E. HANLON, pursuant to 28 U.S.C. § 1746, hereby declares under penalty of perjury: 1. I am partner in the law firm of Alston & Bird LLP ("A&B") and am a

member in good standing of the Bars of the States of New York and New Jersey, the United States District Courts for the Southern and Eastern Districts of New York and the Districts of New Jersey and Arizona, the United States Court of Appeals for the Second Circuit and the United States Supreme Court. circumstances in this action. 2. My firm and I presently serve as counsel to Entral Group International, LLC I am familiar with the facts and

("EGI"), Defendant and Counterclaim Plaintiff in this action.

LEGAL02/30081979v2

Dockets.Justia.com

Case 1:06-cv-05158-LTS-MHD

Document 33

Filed 01/26/2007

Page 2 of 2

3.

Attached hereto are true and accurate copies of the following orders issued

by the Court in connection with the above referenced matter and referenced in Defendant and Counterclaim Plaintiff's Reply Memorandum in Support of the Striking of Plaintiff's and Counterclaim Defendants' Pleadings: a. Exhibit A ­ Initial Conference Order dated July 25, 2006. b. Exhibit B ­ Order dated October 16, 2006. c. Exhibit C ­ Docket reflecting Minute Order dated December 1, 2006. 4. Attached hereto are courtesy copies of the following unreported cases cited

in Defendant and Counterclaim Plaintiff's Reply Memorandum in Support of the Striking of Plaintiff's and Counterclaim Defendants' Pleadings: a. Exhibit D ­ Pastorello v. City of New York, No. 95 Civ. 470, 2003 WL 22118972 (S.D.N.Y. Sept. 11, 2003); and b. Exhibit E ­ Yeboah v. U.S., No. 99 Civ. 4923, 2000 WL 1576886 (S.D.N.Y. Oct. 20, 2000). I hereby declare under penalty of perjury that the foregoing is true and correct. Dated: New York, New York January 26, 2007

s/ Robert E. Hanlon Robert E. Hanlon, Esq.

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