EXHIBIT 14. Case 2:09-cv LA Filed 06/09/15 Page 1 of 8 Document

Transcription

1 EXHIBIT 14 Case 2:09cv00852LA Filed 06/09/15 Page 1 of 8 Document 68814

2 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN Fond Du Lac Bumper Exchange, Inc., and Roberts Wholesale Body Parts, Inc. on Behalf of Themselves and Others Similarly Situated, Case No. 2:09cv00852LA v. Plaintiffs, Jui Li Enterprise Company, Ltd., et al., Defendants. DECLARATION OF JOSEPH M. BARTON IN SUPPORT OF DIRECT PURCHASER PLAINTIFFS MOTION FOR ATTORNEYS FEES AND REIMBURSEMENT OF EXPENSES FILED ON BEHALF OF THE LAW OFFICES OF JOSEPH M. BARTON I, Joseph M. Barton, declare and state as follows: 1. I am the owner and principal attorney at the Law Offices of Joseph M. Barton. I submit this declaration in support of Direct Purchaser Plaintiffs motion for an award of attorneys fees and reimbursement of expenses in connection with the services rendered in this litigation. I make this declaration based on my personal knowledge and if called as a witness, I could and would competently testify to the matters stated herein. 2. My firm has served as counsel to the Direct Purchaser Class during the course of this litigation. The background and experience of the Law Offices of Joseph M. Barton is summarized in the résumé attached hereto as Exhibit The Law Offices of Joseph M. Barton has prosecuted this litigation solely on a contingentfee basis, and has been at risk that it would not receive any compensation for prosecuting claims against the Defendants. Case 2:09cv00852LA Filed 06/09/15 Page 2 of 8 Document 68814

3 4. During the course of this litigation, the Law Offices of Joseph M. Barton has been involved in the following activities on behalf of the Direct Purchaser Class at the request or under the direction of CoLead Counsel: The Law Offices of Joseph M. Barton communicated regularly with its client, direct purchaser named plaintiff Roberts Wholesale Body Parts, Inc. ("Roberts Wholesale"), regarding case matters including, inter alia, the status of the ongoing litigation, Court hearings and orders, pending motions, and written discovery requests propounded by Defendants on Roberts Wholesale. The Law Offices of Joseph M. Barton participated in analyzing and responding to document requests and interrogatories directed to Roberts Wholesale. This included consulting with Roberts Wholesale regarding the discovery requests, undertaking appropriate investigations, and preparing written responses. In addition, the Law Offices of Joseph M. Barton prepared for and participated in a series of depositions in Taipei, Taiwan in November 2014, including taking the deposition of Y.K. Lin of defendant API. 5. Attached hereto as Exhibit 2 is a summary of my firm s total hours and lodestar, computed at historical rates, from case inception through April 30, Excluded from this summary is time expended in preparing this fee and expense declaration. Exhibit 2 provides the names of the attorneys and professional support staff who worked on this case, bar admission year for each attorney, and each timekeeper s respective hours and lodestar at historical rates. This summary was prepared from contemporaneous, daily time records regularly prepared and maintained by my firm. 6. The total number of hours expended on this litigation by my firm from case inception through April 30, 2015 is hours. The total lodestar for my firm is 88, Case 2:09cv00852LA Filed 06/09/15 Page 3 of 8 Document 68814

4 Case 2:09cv00852LA Filed 06/09/15 Page 4 of 8 Document 68814

5 EXHIBIT 1 THE LAW OFFICES OF JOSEPH M. BARTON 628 Manzanita Avenue Corte Madera, CA joebartonesq@gmail.com Case 2:09cv00852LA Filed 06/09/15 Page 5 of 8 Document 68814

6 FIRM OVERVIEW The Law Offices of Joseph M. Barton specializes in providing individuals and businesses with personal and aggressive legal representation in securities, antitrust and consumer class action litigation. Joseph M. Barton ATTORNEY PROFILE Joseph M. Barton is the principal and founder of the Law Offices of Joseph M. Barton. Since admission to the California Bar in 1997, Mr. Barton has worked on many successful major class actions throughout the United States. Those cases in which Mr. Barton played a leadership role as a member of the Courtappointed Plaintiffs' Lead or CoLead counsel team include: In re Rubber Chemicals Antitrust Litigation, (N.D. Cal.) (320 million settlement on behalf of direct purchasers of rubber chemicals); In re Methionine Antitrust Litigation, (N.D. Cal.) (107 million settlement on behalf of direct purchasers of methionine); In re EPDM Antitrust Litigation, (D. Conn.) (106 million settlement on behalf of direct purchasers of ethylene propylene diene monomer); In re Polyester Staple Antitrust Litigation (W.D. N.C.)(63.5 million settlement on behalf of direct purchasers of polyester staple); In re CR Antitrust Litigation (D. Conn.) (62 million settlement on behalf of direct purchasers of chloroprene rubber); In re Plastics Additives Antitrust Litigation, (E.D. Pa.) (46.8 million settlement on behalf of direct purchasers of plastics additives); In re High Pressure Laminates Antitrust Litigation (S.D.N.Y.) (40.5 million settlement on behalf of direct purchasers of high pressure laminates); In re Organic Peroxides Antitrust Litigation, (D.D.C.) (37 million settlement on behalf of direct purchasers of organic peroxides); In re NBR Antitrust Litigation, (W.D. Pa.) (35 million settlement on behalf of direct purchasers of nitrile rubber; In re CBT Group PLC Securities Litigation, (N.D. Cal.) (32 million settlement on behalf of purchasers of CBT Group PLC common stock); and In re HPL Technologies Securities Litigation, (N.D. Cal.) (25.5 million settlement on behalf of purchasers of HPL Technologies common stock); and In re Korean Airlines Antitrust Litigation, (C.D. Cal.) (86 million settlement on behalf of direct purchasers of airline tickets for travel between the US and Korean). Mr. Barton has an undergraduate degree in political science from the California Polytechnic State University, San Luis Obispo and a J.D. from Golden Gate University School of Law in San Francisco. Mr. Barton is admitted to practice law in California (Cal. Bar No ), including the Courts for the State of California, the United States District Courts for the Central, Northern and Eastern Districts of California and the Ninth Circuit Court of Appeals. Case 2:09cv00852LA Filed 06/09/15 Page 6 of 8 Document 68814

7 EXHIBIT 2 Law Offices of Joseph M. Barton Time and Lodestar Summary Case Inception through April 30, 2015 Name Title Year of Bar Admission Hours Historical Rate/Hr. Lodestar Attorneys Joseph M. Barton Principal , Total Attorney Time , NonAttorneys Total NonAttorney Time 0.00 TOTALS , Case 2:09cv00852LA Filed 06/09/15 Page 7 of 8 Document 68814

8 EXHIBIT 3 Law Offices of Joseph M. Barton Expense Summary Case Inception through April 30, 2015 Disbursements Total Computer Research Court Fees Court Reporter Food and Beverage Photocopying Inhouse Photocopying Commercial Postage/Express Delivery/Messenger Outside Professional Services Telephone/Facsimile Travel (Air, Ground Travel, Meals, Lodging, etc.) 3, Witness/Service Fees Misc. (Describe) TOTAL 4, Assessment Payments to the Litigation Fund Case 2:09cv00852LA Filed 06/09/15 Page 8 of 8 Document 68814