RUDOVSKY et al v. WEST PUBLISHING CORPORATION et al

Filing 101

Memorandum Reply Brief In Further Support of Motion For Judgment As A Matter Of Law re 92 MOTION for Judgment as a Matter of Law or, in the alternative, for a new trial filed by THOMPSON LEGAL AND REGULATORY INC., WEST PUBLISHING CORPORATION, WEST SERVICES INC.. (Attachments: # 1 Affidavit, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D)(BORGER, MATTHEW)

RUDOVSKY et al v. WEST PUBLISHING CORPORATION et al

Doc. 101 Att. 1

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ______________________________________ DAVID RUDOVSKY and LEONARD SOSNOV, Plaintiffs, v. WEST PUBLISHING CORPORATION, WEST SERVICES INC., AND THOMSON LEGAL AND REGULATORY INC. t/a THOMSON WEST, Defendants. ______________________________________ : : : : : : : : : : : : : CIVIL ACTION

NO. 09-CV-727

REPLY DECLARATION OF AARON M. ZEISLER

AARON M. ZEISLER, hereby declares under penalty of perjury: 1. I am a member of the firm of Satterlee Stephens Burke & Burke LLP, attorneys

for defendants West Publishing Corporation, West Services Inc., and Thomson Reuters (Legal) Inc. (formerly known as Thomson Legal and Regulatory Inc.) d/b/a Thomson West (together "West"), and submit this Reply Declaration in further support of West's renewed motion for judgment as a matter of law, pursuant to Fed. R. Civ. P. 50(b), or, in the alternative, for a new trial, pursuant to Fed. R. Civ. P. 59, following the jury verdict returned on December 16, 2010, and the judgment entered thereon on December 17, 2010. 2. Annexed hereto as Exhibit A is a true and correct copy of Plaintiffs' Amended

Complaint, with exhibits, as filed with the Court. 3. Annexed hereto as Exhibit B is a true and correct copy of selected pages of the

December 14, 2010 transcript of trial in this action. 4. Annexed hereto as Exhibit C is a true and correct copy of selected pages of the

December 15, 2010 transcript of trial in this action.

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Dockets.Justia.com

5.

Annexed hereto as Exhibit D is a true and correct copy of selected pages of the

December 16, 2010 transcript of trial in this action. I declare under penalty of perjury that the foregoing statements are true and correct. Executed: February 25, 2011

/s/ Aaron M. Zeisler Aaron M. Zeisler

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