William Richert

“Throughout history it has been the inaction of those who could have acted, the indifference of those who should have known better, the silence of the voice of justice when it mattered, that has made it possible for evil to triumph.” Halle Salassie

Friday, March 13, 2009

WGA SETTLEMENT AGREEMENT FOR FOREIGN LEVIES

PLEASE NOTICE TO ALL AMERICAN WRITERS: THIS APPLIES TO YOU
IN A SENSE, IF THIS PASSES, YOU'RE IN THE UNION NOW

SETTLEMENT AGREEMENT AND RELEASE
This Settlement Agreement and Release (the "Settlement Agreement") is entered into
between each of William Richert, the estate of Pearl Retchin, and Ann Jamison (individually and
collectively "Plaintiff(s)"), as representatives of the settlement class hereinafter described (the
"Settlement Class"), and all members of the Settlement Class, on the one hand, and defendant
Writers Guild of America, west, Inc., a California non-profit corporation ("WGA W"), on the
other hand.
Plaintiffs and WGA Ware sometimes collectively referred to herein as the "Settling
Parties" and individually as a "Settling Party". This Settlement Agreement is entered into as of
the date of the last Settling Party to sign this Settlement Agreement. The Settlement Agreement
is made with reference to the following facts:
WHEREAS, on September 16,2005, William Richert filed an action in the Superior
Court of the State of California for the County of Los Angeles styled William Richert, an
individual and on behalf of those similarly situated v. Writers Guild of America, west, Inc. and
Does 1 through 20, Case No. BC339972, after which WGA W removed the matter to federal
court;
WHEREAS, on August 22, 2006, a First Amended Complaint was filed in United States
District Court for the Central District styled William Richert, an individual; Pearl Retchin, an
individual; Ann Jamison, an individual; and on behalf of those similarly situated v. Writers
Guild of America, West, Inc.; and Does 1 through 20, Case No. CV 05-8257 MMM (PJWx) (the
"Action"), after which the Action was remanded back to the Superior Court of the State of
California for the County of Los Angeles (the "Court");
WHEREAS, during the 1980s, various European countries began to adopt laws imposing
levies on home video rentals, blank cassettes, and recording equipment, which were designed to
provide compensation to rights holders, including writers, of the motion pictures and television
programs exhibited within each country and which were subject to copying. These countries
collected the levies through foreign collection societies. The funds from such levies that were
collected by foreign collection societies shall be collectively referred to in this Settlement
Agreement as the "Foreign Levy Funds";
WHEREAS, in the early 1990s the WGAW and the Directors Guild of America, Inc. (the
"DGA") entered into various agreements with various producers, production companies and
distributors regarding the division between them of the Foreign Levy Funds. Pursuant to these
agreements, certain of the Foreign Levy Funds were and are collected by the WGAW. The
Guilds and the Companies also agreed, based upon a condition initially imposed by the German
patent office, that the Guilds would distribute levies collected for all U.S. writers and directors
regardless of whether a writer or director was a member of the Guilds and regardless of whether
the motion picture was covered by a collective bargaining agreement.;
-1-

WHEREAS, the Action alleges, in essence, that the WGA W has collected substantial
amounts, and earned interest thereon, of the Foreign Levy Funds, but has failed to properly or
adequately account for and pay them to the persons entitled to them;
WHEREAS, the WGA W denies any wrongdoing;
WHEREAS, the Plaintiffs and the WGA W have engaged in five separate days of
mediation before Mediator Joel M. Grossman, Esq.; and,
WHEREAS, Plaintiffs, on behalf of themselves and members of the Settlement Class, on
the one hand, and WGA W, on the other hand, now seek to comprehensively resolve the Action
and the disputes between them covered by the Action.
NOW THEREFORE, in consideration of the preceding recitals and the mutual promises
and consideration set forth below, the sufficiency and adequacy of which are hereby
acknowledged, the Settling Parties agree as follows:
1. The Settlement Class. For settlement purposes only, the Settling Parties
stipulate to certification of the following Settlement Class:
All writers, including members of the WGAW and non-members
of the WGAW, whose works, whether or not written under any
WGAW collective bargaining agreement, earned Foreign Levy
Funds that were paid to the WGA W by foreign collection societies.
This class definition includes the lawful heirs of any such writer
who is no longer living.
2. Certain Obligations To Be Carried Out Only After the Effective Date. Each
and all of the Settling Parties' future obligations and duties under Paragraphs 3, 4, 5, 6 and 7 of
this Settlement Agreement shall be carried out or effectuated as expeditiously as possible after
the "Effective Date," as that term is defined below in Paragraph 10.a. None of obligations and
duties under Paragraphs 3, 4, 5, 6 and 7 of this Settlement Agreement need be carried out or
effectuated prior to the Effective Date.
3. One- Time Review by "Big Four" Accounting Firm.
a. The Settling Parties shall jointly select a "big four" accounting firm (i.e.,
Pricewaterhouse Coopers; Deloitte Touche Tohmatsu; Ernst & Young; or, KPMG) (the
"Selected Accounting Firm").
b. The Selected Accounting Firm shall review the WGAW's foreign levies
program, from inception to the present, according to Generally Accepted Accounting Principles
(GAAP) and shall determine and issue a report analyzing and setting forth the following:
-2-

1. on an annual basis, the amount of Foreign Levy Funds collected by
the WGAW from the inception of the WGAW's foreign levies
program to the present, including all interest earned on the Foreign
Levy Funds while in the possession or control of the WGAW;
2. on an annual basis, the amount of Foreign Levy Funds distributed
by the WGA W to writers (or their heirs, successors or other proper
parties) from the inception of the WGA W' s foreign levies program
to the present, including any distributed interest on the Foreign
Levy Funds;
3. on an annual basis, the amount of Foreign Levy Funds currently
held by the WGAW, including all interest earned on the Foreign
Levy Funds while in the possession or control of the WGAW.
c. The comprehensive report will be posted and published on the WGAW's
website and remain so posted and published for a period of five (5) consecutive years.
4. Annual Review of WGA W's Foreign Levies Program.
a. For fiscal year 2009 and all subsequent fiscal years in which WGAW
maintains its foreign levies program, the WGA W shall, as part of its annual financial review,
have a review performed of the foreign levies program. Said review of the foreign levies
program shall be performed by the same accounting firm that WGA W selects for its overall
annual review.
b. WGA W currently posts and publishes on its website annual reports in
their entirety, including full financial statements and notes. The review of the foreign levies
program will be included in this full and complete posting and publication.
5. Evaluation of the WGA W's Foreign Levies Program by Consultants.
a. The WGA W shall engage consultants to provide a one-time review and to
make recommendations to improve the processing and distribution of Foreign Levy Funds to
members of the Settlement Class, including Plaintiffs.
b. Counsel for the Plaintiffs shall select one or two consultants, and the
WGA W may also select additional consultants.
c. The consultants shall prepare and issue a report(s) which shall include
recommendations on how the WGAW can improve the processing and distribution of Foreign
Levy Funds. The report(s) will be provided only to plaintiffs' counsel and the WGAW and will
not be published.
-3-

d. Counsel for the Plaintiffs and representatives of the WGA W shall meet, if
possible with the consultants present, to review the report( s) and discuss implementation of some
or all of the consultants' recommendations. Following this meeting(s), the WGAW shall
implement whichever of the proposals it deems, in good faith, to be appropriate. , If counsel for
the Plaintiffs believe that the WGA W has not acted in good faith in failing to implement any of
the consultants' recommendations, then counsel for the Plaintiffs and the WGA W shall first seek
to resolve by mediation pursuant to Paragraph 14.a. of this Settlement Agreement, and, if
mediation fails, then by binding arbitration pursuant to Paragraph 14.b. of this Settlement
Agreement.
6. Publication Of and Registration Under WGA W's Foreign Levies Program.
a. For a period of three (3) years after the Effective Date (as defined below),
on an annual basis, WGAW shall publicize the existence and availability of Foreign Levy Funds
and the WGAW's foreign levies program to writers in industry and non-industry publications.
The decision as to which publications to utilize for these purposes shall be jointly decided by
Plaintiffs and the WGA W.
b. To further publicize the existence and availability of Foreign Levy Funds
to writers and to further the implementation of the WGA W' s foreign levies program, the
WGAW's website (currently, www.wga.org) will contain the following content, which shall be
published and maintained after the Effective Date and periodically updated, all as follows:
1. the WGAW will report on the status of collection of Foreign Levy
Funds and operation of the foreign levies program, including the
status of any particular issues that may arise which may impact the
payment or collection of Foreign Levy Funds. This report shall be
updated on an annual basis. Each such report shall be maintained
on the WGAW's website for at least a two (2) year period after it
is issued;
2. a description and explanation of the genesis, nature and operation
of the foreign levies program, the sources of Foreign Levy Funds,
and the procedure for a writer or other appropriate person (e.g., a
writer's lawful heir) to submit a claim to the WGAW for the
payment of Foreign Levy Funds. This content will be reviewed,
and if necessary, updated by the WGA W on an annual basis and
shall be continuously maintained on the WGA W' s website;
3. all titles the WGAW is aware of for which Foreign Levy Funds
have been collected but for which a writer (or writers) has not been
identified. Such listing(s) will be reviewed, and if necessary,
updated by the WGA W on an annual basis and continuously
maintained on the WGA W' s website;
-4-

IV. the names of all writers who may be eligible for payment of
Foreign Levy Funds but who have not been paid because the
WGAW cannot locate them or their lawful heirs. Such listing(s)
will be reviewed, and if necessary, updated by the WGA W on an
annual basis and shall be continuously maintained on the
WGA W' s website;
v. an online mechanism for writers to register titles of works for
which payment of Foreign Levy Funds may become due.
c. In addition to registration via its website, the WGA W will create a
registration alternative, other than online registration, for writers to register titles of works for
which payment of Foreign Levy Funds may become due.
d. For all publication and website content called for under this Paragraph 6,
the WGA W shall assign and provide, via its website, the names and contact information of the
person or persons it assigns as contact persons for writers in connection with the WGA W' s
foreign levies program and the payment of Foreign Levy Funds to writers. This information
shall be continuously maintained on the WGA W' s website.
7. Payment of Foreign Levy Funds in WGAW's Possession as of the Effective
Date.
a. The WGAW will use its best efforts to pay all Foreign Levy Funds in its
possession as of the Effective Date to the proper recipients within three (3) years of the Effective
Date (as defined below). Plaintiffs acknowledge that some of these Foreign Levy Funds will not
be able to be distributed.
b. Plaintiffs and WGA W shall discuss in good faith and shall establish the
circumstances and facts under which Foreign Levy Funds in the possession of the WGAW shall
be deemed incapable of distribution, such as the passage of a certain amount of time or the poor
quality of information provided by the collection society. If the parties cannot reach agreement
on this, the matter shall be submitted to mediation pursuant to Paragraph 14.a. of this Settlement
Agreement.
c. Plaintiffs and WGA W shall discuss in good faith and shall establish what
shall be done with Foreign Levy Funds in the possession of the WGAW that have been
determined to be incapable of distribution, including whether such Foreign Levy Funds may be
used to provide enhanced payments to writers whose payments of Foreign Levy Funds were
previously delayed. If the parties cannot reach agreement on this, the matter shall be submitted
to mediation pursuant to Paragraph 14.a. of this Settlement Agreement.
-5-

8. Payment for Administrative Costs of the WGA W's Foreign Levies Program.
a. The cost of administering the WGA W' s foreign levies program, including
the cost of annual reviews, consultants, notices, and publicity called for by this Settlement
Agreement, shall be paid for from interest earned on collected Foreign Levy Funds and from an
administrative fee charged by the WGAW to writers who receive payments of Foreign Levy
Funds.
b. The administrative fee called for under this Paragraph 8 may not exceed
ten percent (10%) of the Foreign Levy Funds paid to writers.
c. The amount of the administrative fee called for under this Paragraph 8
shall be reasonable and any administrative fees collected in excess of the costs of administration
will carry over to offset future costs of the foreign levies program. The reasonableness of the
administrative fee shall be judged by fees charged for similar services by other organizations,
such as the Independent Film & Television Alliance, Canadian Screenwriters Collection Society,
Directors Rights Collective of Canada, and the Directors and Producers' Rights Society of Great
Britain ("DPRS").
9 . Joint Press Release.
The parties shall issue a joint press release in the form of Exhibit _ hereto.
10. No Obligation to Collect.
Nothing herein shall be construed to obligate WGAW to continue to receive and
distribute foreign levies, from any jurisdiction or collecting society. WGA W may elect at any
time not to receive, retain, and distribute foreign levies from some or all jurisdictions and
collecting societies, and may so instruct or agree with any foreign collecting society. Provided,
however, that to the extent WGA W does receive and retain foreign levies, it shall handle such
foreign leviesas set forth in this agreement. In the event WGA W elects at any time not to receive,
retain, and distribute foreign leviesfrom any foreign country, it will provide notice to that effect
by means of a posting on the WGA W website, a single advertisement in Daily Variety and The
Hollywood Reporter, and a letter to each writer to whom it previously has actually paid foreign
levies.
11. Released Claims.
a. As of the Effective Date, and excepting the ongoing and future obligations
and duties called for under this Settlement Agreement, Plaintiffs and the members of the
Settlement Class, on behalf of themselves, their heirs, and their past, present and future spouses,
agents, attorneys, trusts, beneficiaries, devisees, legatees, predecessors- and successors-in-
interest and assigns (all collectively referred to as "Releasors"), hereby release, discharge and
dismiss WGA W, including each of its predecessor and successor firms, affiliated companies,
-6-

current and former parents and subsidiaries, and all of their respective shareholders, directors,
officers, employees, agents, attorneys, insurers and assigns (all collectively referred to as the
"Releasees") of and from any and all "Released Claims." "Released Claims" shall mean any and
all known and unknown claims for relief, causes of action, suits, rights of action, or demands, at
law or in equity, whether sounding in contract, tort or equity, including, without limitation,
claims for equitable or injunctive relief, damages, indemnity, contribution, or for costs, expenses
and attorneys' fees, which Releasors now or at any past or present time have, own or hold
against the Releasees based upon and/or arising out of the facts and circumstances alleged in the
Action.
b. Plaintiffs and the Settlement Class expressly, knowingly and voluntarily
waive any and all rights and/or benefits conferred upon them by Section 1542 of the California
Civil Code. Section 1542 of the California Civil Code reads in its entirety as follows:
A general release does not extend to claims which the creditor
does not know or suspect to exist in his or her favor at the time of
executing the release, which if known by him or her must have
materially affected his or her settlement with the debtor.
12. Class Certification and Court Approval of Settlement.
a. This Settlement Agreement is conditioned on the Court certifying the
Settlement Class described in Paragraph 1 hereof and approving all of the terms of settlement
stated in this Settlement Agreement. The conditions set forth in this Paragraph shall be deemed
satisfied upon the "Effective Date," which is defined as the expiration of (a) the time for any
person to appeal the Judgment of Dismissal giving final approval to the class settlement reflected
in this Settlement Agreement; or (b) if timely appeal of the Judgment of Dismissal is taken, upon
issuance of the remittitur, or upon dismissal or other termination of the appellate proceedings
that affirms the Court's certification of the Settlement Class and approval of all of the terms of
settlement stated in this Settlement Agreement. Plaintiffs shall not hereafter object to the
settlement and shall not appeal the Judgment of Dismissal.
b. Class Certification and Preliminary Approval Order. The Plaintiffs, as
representatives of the Settlement Class, shall file a motion with the Court requesting certification
of the Settlement Class described in Paragraph 1 hereof and a preliminary approval order
providing for:
1. a finding that mailing of a class notice to the members of the
Settlement Class at the last known address to the extent such
information is available to WGA W through its records in the form
attached hereto as Exhibit "1" (mail) and Exhibit "2" (publication)
are the only notices required of the settlement to members of the
Settlement Class and that such notice satisfies the requirements of
due process and applicable state law;
-7-

11. a finding preliminarily that the terms of settlement set forth in this
Settlement Agreement are fair, reasonable and adequate to the
Settlement Class; and
12. the setting of schedules for mailing and publication of notice to the
Settlement Class, Right to Object, Hearing on Fairness and Final
Approval of Settlement, and Hearing on Attorneys' Fees and
Costs.
The WGA W shall approve the form and content of the class certification and preliminary
approval order, after which it shall not oppose this motion and shall file a joinder requesting that
the Court grant the motion in all its particulars.
c. Notice o[Preliminary Approval Order and Final Fairness Hearing. If the
Court certifies the Settlement Class and enters the preliminary approval order described in
Paragraph 10.b. above:
1. within twenty (20) days of the entry of such Order, the
Administrator (as defined below in Paragraph 12) shall cause to be
delivered by First Class U.S. Mail the Notice approved by the
Court and attached hereto as Exhibit" 1" to each member of the
Settlement Class at his or her last known address to the extent such
information is available to WGA W through its records;
2. as soon as practicable, the Administrator (as defined below in
Paragraph 12) shall cause publication of the Notice approved by
the Court and attached hereto as Exhibit "2" in the publications
and at the frequency approved by the Court in the Preliminary
Approval Order.
d. Final Approval/Fairness Hearing/Judgment. The final approval hearing
shall be on , 2008, or at such later time as the Court may order. If
the Court orders final approval of the settlement of the Action as outlined in this Settlement
Agreement, then at the same final approval hearing the Settling Parties shall immediately request
the Court for a final judgment. The judgment shall:
1. find that the previously given notices to the Settlement Class
satisfy the requirements of due process and the requirements of
applicable state law;
2. find that the terms of the settlement set forth in this Settlement
Agreement are fair, reasonable and adequate to the Settlement
Class under applicable state law;
-8-

111. find that each member of the Settlement Class shall be bound by
this Settlement Agreement, including the release set forth at
Paragraph 11 hereof, and conclude that the settlement provided in
this Settlement Agreement should be and is approved;
IV. enter judgment;
v. retain jurisdiction over all matters relating to the interpretation,
administration, implementation, effectuation and enforcement of
this Settlement Agreement;
VI. as further discussed in and in accordance with Paragraph 15
hereof, determine reasonable legal fees and costs for counsel for
Plaintiffs and the Settlement Class in the Action;
V11. provide for enhanced compensation to each Plaintiff in the amount
of Dollars and No Cents ($?,???OO) as and for the time
and expense each Plaintiff has incurred and will incur in serving as
representative for the Settlement Class herein, with such enhanced
compensation to be paid by WGA W; and
V111. enter such other and further orders as the Court deems necessary
and appropriate to carry out the agreements of the Settling Parties
expressed in this Settlement Agreement.
e. Ifmore than ten percent (10%) of the putative members of the Settlement
Class properly and timely opt-out of the settlement provided in this Settlement Agreement, then
the WGA W, at its sole discretion, may void such settlement and this Settlement Agreement.
WGA W shall have the burden of establishing that ten percent (10%) of the putative members of
the Settlement Class, in fact, properly and timely opted-out of the settlement stated in this
Settlement Agreement. If Plaintiffs and the WGA W disagree in this regard, then either party
may file a motion for determination by the Court.
13. Judgment. The Settling Parties shall submit a proposed Judgment in the form
attached as Exhibit "3" and the Court shall retain jurisdiction to enforce the terms of this
Settlement Agreement pursuant to California Rules of Court, Rule 1859(h).
14. The Administrator. The coordination and giving of notices in accordance with
the terms of this Settlement Agreement and ultimate orders of the Court will be administered by
a third party administrator. The third party administrator shall also receive and track the number
of persons properly opting-out of the settlement stated in this Settlement Agreement. The
Settling Parties agree that the third party administrator shall be _
WGA W shall be responsible for the third party administrator's fees and costs.
-9-

15. Attorneys' Fees and Costs.
a. The allowance, disallowance, or modification by the Court of the
application by plaintiffs' counsel for an award of attorneys' fees and costs are not part of this
Settlement Agreement and are to be considered by the Court separately from the Court's
consideration of the fairness, reasonableness, adequacy, and good faith of the settlement.
WGAW will not oppose a request by plaintiffs' counsel for attorneys' fees in an amount which
equals _% of actual fees (but not costs) based on time and expense records provided by
plaintiffs' counsel, but which in no event will exceed $ __ , including costs. Plaintiffs'counsel
may further apply for additional reasonable attorneys' fees incurred to the extent necessary to
prevail on any appeal filed by a third party on an issue other than attorneys' fees. Any award of
attorneys' fees to plaintiffs' counsel in connection with this Settlement Agreement shall be the
sole award payable to plaintiffs' counsel in connection with (i) the subject matter, allegations,
and causes of action asserted in this Action, (ii) any foreign levies distributed by WGA W or
deposited/remitted to any governmental authority at any time, and (iii) any claim under Section
1021.5 of the California Code of Civil Procedure, and all undersigned counsel for plaintiffs agree
that they shall be barred from seeking any fee recovery in connection with the foregoing.
b. Any order or proceedings relating to the application by plaintiffs' counsel
for an award of attorneys' fees and costs, or any appeal from any order relating thereto or
reversal or modification thereof, shall not operate to terminate or cancel the Settlement
Agreement, or affect or delay the finality of the judgment approving the Settlement Agreement
and the settlement of this action, as set forth herein.
16. Mediation and Binding Arbitration.
a. Any mediation called for under this Settlement Agreement shall be before
Joel M. Grossman, Esq. Mr. Grossman was the mediator during the previous mediation sessions
between the Settling Parties. Mr. Grossman's current business address and telephone are: ADR
Services, Inc., 1900 Avenue of the Stars, Suite 250, Los Angeles, CA 90067-4304; (323)933-
1916.
b. Any binding arbitration called for under this Settlement Agreement shall
be before Bernard Gold, Esq. The arbitration shall be conducted pursuant to the Commercial
Rules (Complex) of the American Arbitration Association. Mr. Gold's current business address
and telephone are: Proskauer Rose LLP, 2049 Century Park East, Suite 3200, Los Angeles, CA
90067; (310)557-2900. Each party participating in binding arbitration hereunder shall bear its
own fees and costs, including attorneys' fees.
17. No Admission. This Settlement Agreement is entered into for purposes of
settlement and compromise only. Neither this Settlement Agreement nor anything contained
herein, nor any act or thing done in connection herewith, is intended to be nor shall be construed
or deemed to be an admission by any party to this Settlement Agreement of any liability, fault or
wrongdoing, or an admission by any such party of any fact, allegation or claim whatsoever.
-10-

18. Integrated Agreement. This Settlement Agreement constitutes and contains the
entire agreement and understanding between Plaintiffs and WGA Wand supersedes and replaces
all prior statements, representations, negotiations and agreements, proposed or otherwise,
whether written or oral, concerning the subject matter hereof. This is an integrated document.
This Settlement Agreement may only be modified by a writing approved and executed by all
parties and their counsel.
19. Independent Legal Advice and Authority. Each of the Settling Parties has
received independent legal advice from his, her or its counsel regarding the meaning and legal
effect of this Settlement Agreement, the advisability of making the agreements provided for
herein, and the execution of this Settlement Agreement, and fully understand the same. The
Settling Parties executing this Settlement Agreement have the full right and authority to enter
into this Settlement Agreement on behalf of himself, herself, or itself, or any person or entity on
behalf of whom it enters into this Settlement Agreement in a representative capacity, to bind
fully such person or entity to the terms and obligations of this Settlement Agreement. The
Settling Parties executing this Settlement Agreement have full power to enter into this
Settlement Agreement and have not heretofore assigned, transferred or encumbered, or purported
to assign, transfer or encumber, voluntarily or involuntarily, to any person or entity, all or any
portion of the obligations or rights which are the subject of this Settlement Agreement.
20. No Reliance On Representations By Other Settling Parties. In making their
decision to enter into this Settlement Agreement, none of the Settling Parties are relying on any
representation, express or implied, of any kind by any other Settling Party, or any representative
of any Settling Party, and all Settling Parties have read the contents hereof, have been fully
advised by counsel as to the consequences thereof, and have signed the same as a free act.
21. Counterparts. This Settlement Agreement may be executed in counterparts,
each of which shall be deemed an original and all of which taken together shall constitute a
single instrument. Photographic or facsimile copies of signed counterparts may be used in lieu
of originals for any purpose and shall have the same force and effect as an original ink signature.
22. California Law. This Settlement Agreement shall be interpreted in accordance
with the laws of the State of California.
23. Notices to Counsel. All notices and communications called for under this
Settlement Agreement to Plaintiffs or WGA W, or their respective counsel, shall be addressed as
follows:
If to Plaintiffs:
Neville L. Johnson, Esq.
Johnson & Johnson, LLP
439 North Cannon Drive, Suite 200
Beverly Hills, CA 90210
-11-

Phone: (310)975-1080
FAX: (310)975-1095
and
Paul R. Kiesel, Esq.
Kiesel Boucher Larson LLP
8648 Wilshire Boulevard
Beverly Hills, CA 90211
Phone: (310)854-4444
FAX: (310)854-0812
If to WGAW:
Emma Leheny, Esq.
Rothner, Segal & Greenstone
510 South Marengo Avenue
Pasadena, CA 91101
Phone: (626)796-7555
FAX: (626)577-0124
IN WITNESS WHEREOF, the Settling Parties have caused this Settlement Agreement
to be executed by each Plaintiff, WGA Wand their respective duly authorized attorneys:
-12-

0 Comments:

Post a Comment

Subscribe to Post Comments [Atom]

<< Home