Avvo Inc et al v. Westchester Fire Insurance Company

Filing 2

DECLARATION OF BENJAMIN J. STONE IN SUPPORT OF DEFENDANT'S NOTICE OF REMOVAL by Defendant Westchester Fire Insurance Company. (DJ)

Avvo Inc et al v. Westchester Fire Insurance Company

Doc. 2

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DECLARATION OF BENJAMIN J. STONE IN SUPPORT OF DEFENDANT'S NOTICE OF REMOVAL - 1
LAW OFFICES OF

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE AVVO, INC., a Washington corporation, and MARK BRITTON, an individual, Plaintiffs, v. WESTCHESTER FIRE INSURANCE COMPANY, a New York Corporation, Case No.: DECLARATION OF BENJAMIN J. STONE IN SUPPORT OF DEFENDANT'S NOTICE OF REMOVAL

Benjamin J. Stone declares as follows: 1. 2. I represent Defendant Westchester Fire Insurance Company in this litigation. In communications with Ms. Tricia S. Boerger, counsel for Plaintiffs, she has

stated to me that Plaintiff Avvo, Inc. incurred approximately $134,000 in costs and legal expenses defending a lawsuit brought in this Court entitled Browne v. Avvo, Case No. 2:2007cv00920. Here, Avvo seeks to recover these costs and legal expenses, among other things, from Westchester Fire Insurance Company. I declare under penalty of perjury that the foregoing is true and correct. Dated: October 30, 2008 /s/ Benjamin J. Stone

COZEN O'CONNOR
A PROFESSIONAL CORPORATION SUITE 5200 W ASHINGTON MUT UAL TOW ER 1201 THIRD AVENUE SEATTLE, W ASHINGTON 98101-3071

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CERTIFICATE OF SERVICE I hereby certify that on October 30, 2008, I electronically filed the following documents with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following: Tricia S. Boerger, Esq., Savitt & Bruce, LLP, 1325 Fourth Avenue, Suite 1410, Seattle, WA 98101-2509. DECLARATION OF BENJAMIN J. STONE IN SUPPORT OF DEFENDANT'S NOTICE OF REMOVAL DATED this 30th day of October, 2008. COZEN O'CONNOR

By: /s/ Lisa Heusler, Legal Assistant to Benjamin J. Stone, WSBA No. 33436 COZEN O'CONNOR 1201 Third Avenue, Suite 5200 Seattle, Washington 98101 Telephone: [phone] Facsimile: 206.621.8783 E-mail: [e-mail] [e-mail]

DECLARATION OF BENJAMIN J. STONE IN SUPPORT OF DEFENDANT'S NOTICE OF REMOVAL - 2

LAW OFFICES OF

COZEN O'CONNOR
A PROFESSIONAL CORPORATION SUITE 5200 W ASHINGTON MUT UAL TOW ER 1201 THIRD AVENUE SEATTLE, W ASHINGTON 98101-3071

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