Free Declaration in Support - District Court of California - California

Case 3:07—cv—02933-SI Document 9 Filed 06/21/2007 Page 1 of 3 A
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I LINGEL H. WINTERS, ESQ. (SBN 37759)
2 LAW OFFICES OF LINGEL H. WINTERS
A PROFESSIONAL CORPORATION
3 One Maritime Plaza, Suite 400
San Francisco, CA 94111
4 Telephone: (415) 398-2941
· 5 Facsimile: (415) 393-9887
GIRARDI & KEESE
6 THOMAS V. GIRARDI (SBN 36603)
1126 Wilshire Blvd.
7 Los Angeles, CA 90017-1904
8 Telephone (213) 977-0211
9 Attorneys for Plaintiff and the Putative Class
1 UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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13 MDL N0. M:07-cv-01827 SI
IN RE TFT-LCD (FLAT
14 PANEL)ANTITRUST LITIGATION Case N0. 07-cv-2796 SI
15 CLASS ACTION
16 EMI/IC Inc. v. LG Phi/qos LCD CO., LTD et ol. DECLARATION IN SUPPORT
Case No. C-07-2796 SI OFMOT ION FOR ORDER SHORTENING
17 TIME
THIS DOCUMENT RELATES TO
18 Date: July 10, 2007
ALL INDIRECT PURCHASER ACTIONS Time: 10:00 am.
19 °
Hon. Susan Illston
20 Courtroom: 10
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DEC. WINTERS 1N SUPPORT OF MOTION TO APPOINT INTERIM CLASS COUNSEL FOR THE
CALIFORNIA INDIRECT PURCHASERS SUBGROUP

Case 3:07—cv—02933-SI Document 9 Filed 06/21/2007 Page 2 of 3
1 I, Lingel H. Winters, declare as follows:
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1. I am an attorney duly licensed to practice law by the State of California and admitted to
3 practice before this Court. I am principal and owner of the law firm of Lingel H. Winters
4 P.C. and my firm along with my co—counsel Thomas V. Girardi of the law firm of Girardi
5 & Keese serve as attorney of record for plaintiff EMW, Inc. The matters set forth herein
6 are within my personal knowledge, and if called upon and sworn as a witness I could
7 competently testify regarding them. I make this declaration pursuant to 28 U.S.C. sec.
8 1746.
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10 2. On April 17, 2007, the Panel on Multi—District Litigation transferred MDL Docket No.
ll 1827 In Re TF T-LCD (Flat Pat/zeb Antitrust Litigation to the Northern District of
12 California and assigned to the Honorable Susan Y. Illston. In its order, the MDL Panel
13 stated: "We conclude that the Northern District of California is an appropriate transferee
14 forum in this docket because over 50 of the actions of which the Panel has been notihed
15 have been brought in that district. . ."
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3. On May 30, 2007 Lingel H. Winters P.C. filed the related case of EMVIC [hc. on behalf of
17 itself and all others s imilarly situated v. LG. Philips LCD C O., LTD et al. Case No. C-
18 07-2796 SI in the Northern District of California alleging conspiracies to restrain trade in
the market for TFT-LCD products.
21 4. On June 4, 2007 plaintiff filed its Reply Memorandum Indirect Purchaser Leadership
22 Proposal of Lingel H. Winters P.C., in the belief that the June 8, 2007 hearing date for
23 motions was firm. L
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25 5. On June 5, this Court continued all pending motions herein to July 10, 2007
26 6. On June 7, 2007 Lingel H. Winters P.C. filed an Administrative Motion to Consider
27 Whether Cases Should Be Related.
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DEC. WINTERS IN SUPPORT OF MOTION TO APPOINT INTERIM CLASS COUNSEL FOR THE
CALIFORNIA INDIRECT PURCHASERS SUBGROUP

Case 3:07—cv—02933-SI Document 9 Filed 06/21/2007 Page 3 of 3
1 7. and found and calculated a combined population for the Repealer States of $8,041,000.
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3 t By contrast, said reference book stated that the population of the State of California was
4 31,431,000 personsor 35% of the total Repealer state populations are in California
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8. On June 19, 2007, Thomas V. Girardi, Esq. of Girardi & Keese agreed to join Lingel H.
6 Winters P.C. as co—counsel representing EMW, Inc. and the putative class of California
; Indirect Purchasers of TFT—LCD.
9 9. Lingel H. Winters P.C. was a member of the Executive Committee in In Re Microsrw
I0 J.C.C.P. No. 4106, 143 Cal. App. 4m 706 which resulted in a settlement for California
11 indirect Purchasers valued at $1.1 Billion, 2/3 of the unclaimed portions of which were
12 set aside for underprivileged California schools.
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10. I have diligently sought to place before the Court plaintiffs Motions, and to streamline
E the Court’s case management with an eye to judicial economy.
16 I declare under penalty of perjury under the laws of the State of California that the foregoing is
17 true and correct. Executed Juneglg, 2007 in San Francisco, California.
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20 /s/jL“ingeZf . hiters .
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DEC. WINTERS IN SUPPORT OF MOTION TO APPOINT INTERIM CLASS COUNSEL FOR THE
CALIFORNIA INDIRECT PURCHASERS SUBGROUP

Case 3:07-cv-02933-SI

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