Professional Documents
Culture Documents
VIA ECF
This firm, along with our co-counsel, represents Plaintiffs in In re Insulin Pricing
Litigation, No. 3:17-cv-00699(BRM)(LHG). Pursuant to the parties joint report, which was
submitted in accordance with Judge Goodmans text order of April 10, 2017 (Dckt. No. 45),
enclosed please find a joint application supporting appointment of Steve W. Berman and myself
as interim co-lead counsel for the putative consumer class pursuant to Rule 23(g). Since this is a
joint application on behalf of two applicants, it is formatted as a double-spaced brief rather than a
single-spaced letter and is 19 pages.
Thank you for your attention to this matter. If the Court has any questions, we are
available at your convenience.
Respectfully submitted,
JAMES E. CECCHI
Barnett, et al. v. Novo Nordisk Inc., et al., No. Hon. Magistrate Judge Lois M. Goodman
3:17-cv-01580 (D.N.J.); Boss, et al. v. CVS
Health Corp. et al., No. 3:17-cv-01823
(D.N.J.); Christensen, et al. v. Novo Nordisk
Inc., et al., No. 3:17-cv-02678 (D.N.J.)
TABLE OF CONTENTS
I. INTRODUCTION ...............................................................................................................1
3. Hagens Berman and Carella Byrne have substantial knowledge of the applicable law. .. 13
4. Hagens Berman and Carella Byrne will devote all resources necessary to this action..... 14
5. Other factors demonstrate counsels fitness to serve as interim co-lead counsel. ............ 16
a. Hagens Berman and Carella Byrne will ensure that any recovery reaches the class
................................................................................................................... 16
b. Hagens Berman and Carella Byrne have built strong plaintiff relationships........ 16
-i-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 3 of 23 PageID: 528
TABLE OF AUTHORITIES
Cases Page(s)
Sheinberg v. Sorensen,
606 F.3d 130 (3d Cir. 2010).......................................................................................................4
Statutes
Other Authorities
- ii -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 4 of 23 PageID: 529
I. INTRODUCTION
This Court has extraordinary power and discretion under Rule 23(g). In cases like this
one, involving price gauging and collusion in the market for life-saving drugs, the Courts
decision will have far reaching consequences, for better or worse. This matter holds significant
public policy implications beyond the narrow interests of the respective lawyers. Each of the law
firms seeking to lead this case is capable and distinguished in many ways. But not every law
firm can lead this case. And not every law firmirrespective of their talents in any particular
practice areashould lead a national class action in the complex field of pharmaceutical pricing.
Hagens Berman and Carella Byrne submit that in this specialized area they are uniquely qualified
to represent the class of injured insulin consumers. In addition to their past experience, these
firms alone pioneered this case, developing the theories and claims that underlie each of the
complaints before the Court. These twin factorsexperience and originationtip the scales
Hagens Berman served as lead counsel in one of the most important drug pricing class
actions tried in the past decade. That case, In re Pharmaceutical Industry Average Wholesale
Price Litigation, MDL No. 1456 (D. Mass.) (Average Wholesale Pricing), bears many
similarities to the present suit. The baseline of knowledge and experience Hagens Berman
gained in litigating Average Wholesale Pricing (as well as the numerous Average Wholesale
Pricing cases that followed) cannot be underestimated in terms of its value to the present
putative class of insulin consumers. None of the other firms before the Court has a comparable
depth of expertise in the area of pharmaceutical pricing. It is also beyond question that Hagens
Berman and Carella Byrne originated this case after conducting a proprietary investigation.
These firms made significant investments to acquire the data and expert analysis necessary to
-1-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 5 of 23 PageID: 530
piece together the gross collusion and price gauging at the heart of this conspiracydata and
research that the other applicants have simply copied in their own complaints. And it is not
surprising that Hagens Berman was the first to investigate this racket and take action: Hagens
Bermans experience litigating Average Wholesale Pricing gave the firm, together with Carella
Byrne, the insight they needed to investigate this case, to invest the resources necessary, and to
file first, paving the way for each complaint that followed. Put simply, Hagens Berman and
Carella Byrne view this case as a proprietary one and Rule 23(g) supports their appointment as
lead as the lawsuits originators. Indeed, it would be a disincentive for lawyers to investigate and
develop important cases if others could take over with follow-complaints that add nothing of
Finally, Hagens Berman and Carella Byrne have spent months cultivating close
relationships with the vast majority of named plaintiffs as well as supportive advocacy groups.
As a result, we are in the best position to serve their interests. When viewed as a whole, Hagens
Berman and Carella Byrne respectfully submit that their past work in the pharmaceutical filed,
their original investigation in bringing this important lawsuit, and their commitment to seeing it
through to a successful conclusion demonstrate that their application should be granted under
Rule 23(g).
In re Insulin Pricing Litigation and the related cases allege that Sanofi, Novo Nordisk,
and Eli Lilly have violated the Racketeer Influenced and Corrupt Organizations Act (RICO), 18
U.S.C. 1961-1968, and various state consumer protection laws. The defendants have done so
by unlawfully manipulating the benchmark prices of their rapid- and long-acting analog insulin
drugs for the benefit of the three largest Pharmacy Benefit Managers (PBMs)CVS Health,
-2-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 6 of 23 PageID: 531
Express Scripts, and Optum Rx. More specifically, the defendant insulin makers publicly publish
one pricethe benchmark pricewhile secretly offering a much lower pricethe real priceto
the largest PBMs in exchange for favorable formulary status. This practice has enabled the drug
makers to secure the big PBMs business without significantly reducing their real prices. But the
scheme has a victim: patients who must pay for significant portions of their drugs out-of-pocket
based on benchmark prices. Defendants benchmark-price arms race has forced people living
with diabetes into an unconscionable Catch-22: the very medicine keeping them alive renders
After an extensive investigation, Hagens Berman and Carella Byrne filed the proposed
putative class action on behalf of such injured patient-consumers in the District of New Jersey on
February 2, 2017. Shortly thereafter, on March 8 and March 17, 2017, two copycat actions were
filed virtually duplicating the factual and legal allegations in the original Hagens Berman and
Carella Byrne complaint. The only meaningful difference is these follow-on complaints named
III. ARGUMENT
Rule 23(g)(3) provides that [t]he court may designate interim counsel to act on behalf of
the putative class before determining whether to certify the action as a class action. 1
Designation of interim counsel is appropriate if necessary to protect the interests of the putative
class.2 When selecting interim class counsel, courts apply the factors set forth in Rule 23(g),3
examining:
1
Fed. R. Civ. P. 23(g)(3).
2
Courts selecting interim class counsel apply the same standards set forth in Fed. R. Civ. P. 23(g)(1) for the
appointment of counsel for a certified class. See Waudby v. Verizon Wireless Services, Inc., 248 F.R.D. 173, 175-76
(D.N.J. 2008).
-3-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 7 of 23 PageID: 532
Additionally, the courts may consider any other matter pertinent to counsels ability to fairly
and adequately represent the interests of the class.5 These factors strongly support appointment
Hagens Berman and Carella Byrne have exceptional experience handling complex civil
litigation and consumer class-action lawsuits.6 In the specialized field of drug pricing litigation,
the expertise of proposed interim co-lead counsel is unparalleled. These firms regularly bring
class action lawsuits to trial,7 including the single most germane pharmaceutical class actionIn
re Pharmaceutical Industry Average Wholesale Price Litigation, MDL No. 1456 (D. Mass.).
3
See Waudby, 248 F.R.D. at 175-76.
4
Fed. R. Civ. P. 23(g)(1)(A); see Sheinberg v. Sorensen, 606 F.3d 130, 133 n.1 (3d Cir. 2010); Rivet v. Office
Depot, Inc., 207 F. Supp. 3d 417, 432 (D.N.J. 2016); Galicki v. New Jersey, No. 14-cv-00169, 2014 WL 4979499, at
*1 (D.N.J. Oct. 6, 2014); Waudby, 248 F.R.D. at 175-76.
5
Fed. R. Civ. P. 23(g)(1)(B); see Sheinberg, 606 F.3d at 133 n.1 (quoting this language); Santos v. Carrington
Mortg. Servs., LLC, No. 2:15-cv-00864, 2017 WL 215969, at *1 (D.N.J. Jan. 18, 2017).
6
Hagens Berman and Mr. Bermans rsums are available at:
http://www.hbsscreative.com/firm_resume/Hagens_Berman_Firm_Resume.pdf. Carella Byrne and Mr. Cecchis
rsums are available upon the Courts request.
7
Class action cases that Hagens Berman has tried include: In re Neurontin Marketing & Sales Practices
Litigation, MDL No. 1629 (D. Mass.); Williams v. The Boeing Co., No. 98-cv-761 P (W.D. Wash.); In re Burlington
Northern & Santa Fe Railway Co. Employee Settlement Agreements Litigation (W.D. Wash.); In re Pharmaceutical
Industry Average Wholesale Price (AWP) Litigation, MDL No. 1456, No. 01-12257 (D. Mass.), and Kucera v. The
State of Washington Department of Transportation & Washington State Ferries, No. 99-2-01161-1 (Wash. King
Cty. Super. Ct.).
-4-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 8 of 23 PageID: 533
Members of these two firms, including the attorneys described below, have worked
a. Hagens Berman
Hagens Berman is uniquely qualified to serve as interim co-lead counsel. The firm not
only litigates complex class actions throughout the country and in this District, but also has been
appointed lead or co-lead counsel in some of the largest drug pricing, consumer fraud, product
liability, securities, and antitrust class actions in history. Indeed, Hagens Berman has led the
fight for more affordable prescription drugs and a more responsible pharmaceutical industry for
over a decade. Hagens Berman has represented consumers, for-profit and not-for-profit health
insurers, consumer organizations, state attorneys general, and drug wholesalers and retailers.
Hagens Berman is also counsel to the Prescription Access Litigation project, a leading drug
pricing organization that fights for access to more affordable prescription drugs through
enforcement of existing federal and state laws. In recent years, Hagens Bermans aggressive
prosecution of pharmaceutical industry misconduct has yielded more than a billion dollars in
Hagens Berman has been consistently recognized for this work. The National Law
Journal named Hagens Berman to its Plaintiffs Hot List in 2006, 2007, and each of the years
2009 to 2014. In 2014, the National Law Journal named also Hagens Berman to its inaugural list
of Americans Elite Trial Lawyersa compilation of the nations leading firms bringing about
significant change and major plaintiffs settlements through complex litigation. The firm is
particularly skilled at managing multi-state and nationwide class actions through a coordinated
approach that implements an efficient and aggressive prosecutorial strategy. Below are a few
-5-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 9 of 23 PageID: 534
-6-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 10 of 23 PageID: 535
-7-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 11 of 23 PageID: 536
Hagens Berman has committed its top attorney, Steve W. Berman, to this proposed class
action. Mr. Berman is the founder and managing partner of Hagens Berman and has served as
lead or co-lead counsel in antitrust, securities, consumer, product liability, and employment class
-8-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 12 of 23 PageID: 537
actions and complex litigation throughout the country. Appointing Mr. Berman in a recent
But it must be said that the track record of Hagens Berman and its
lead partner Steve Berman is even more impressive, having racked
up such accomplishments as a $1.6 billion settlement in the Toyota
Unintended Acceleration Litigation and a substantial number of
really outstanding big-ticket results. It may be worth mentioning
that to this Courts recollection, it has had no first-hand judicial
experience with either of the two finalist firms[,] . . . [b]ut that is
not true of its colleagues in this District of more recent vintage, an
email inquiry to whom brought in return some high praise of
attorney Bermans skills.8
Perhaps most notable is Mr. Bermans role as a Special Assistant Attorney General for
the states of Illinois, Washington, Arizona, Indiana, New York, Alaska, Idaho, Ohio, Oregon,
Nevada, Montana, Vermont, and Rhode Island in the landmark tobacco litigation. That case
resulted in the largest settlement in history, a settlement that occurred while Mr. Berman was
b. Carella Byrne
Carella Byrnes depth of experience in a broad range of practice areas is also well-
recognized. Carella Byrne has an experienced team of attorneys and support staff who are
dedicated to representing individuals, businesses, and public and private pension funds that have
suffered from corporate fraud and wrongdoing. Carella Byrne and its attorneys also have a
proven leadership record in multi-district and class action lawsuits, serving as lead, co-lead,
committee member, and liaison counsel in securities actions, mass-torts, consumer class actions
-9-
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 13 of 23 PageID: 538
counsel in this suit that recovered $1.06 billion for investors, the
second largest securities recovery in the Districts history.
- 10 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 14 of 23 PageID: 539
Carella Byrnes experience prosecuting class cases in the District of New Jersey over the
past decade is unrivaled. For example in In re Merck & Co. Enhance Securities Class Action
No. 07-cv-00397 (D.N.J.), the firm served as court-appointed liaison counsel and recovered $688
million for investors. Indeed, Carella Byrne has been appointed lead counsel in many of the
largest class cases litigated in the District of New Jersey over the past ten years. These include
telecommunications industries where Carella Byrne has served as lead or co-lead counsel.
Like Hagens Berman, Carella Byrne has dedicated its top class action litigator, James
Cecchi, to this matter. With over twenty-five years of experience, Mr. Cecchi has successfully
handled numerous significant cases on behalf of institutional and individual clients throughout
the United States. Furthermore, Mr. Cecchi currently helps lead numerous class actions
involving healthcare industry defendants. Some notable examples include: In re AETNA, Inc.,
Out-of-Network UCR Rates Litigation, MDL No. 2020 (D.N.J.) (appointed settlement counsel
in a case alleging ERISA and RICO claims arising from nationwide underpayment of out-of-
network benefits); In re Invokana (Canagliflozin) Products Liability Litigation, MDL No. 2750
Fosamax (Alendronate Sodium) Product Liability Litigation, MDL No. 2243 (same).
- 11 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 15 of 23 PageID: 540
Additionally, over the course of his career, Mr. Cecchi has collected extensive experience
prosecuting RICO claims beginning with his service as an Assistant United States Attorney in
the State of New Jersey. Just last year, Mr. Cecchi was appointed co-lead counsel in a multi-
Litigation, Civil Action No. 3:16-cv-03087 (D.N.J.). This class action alleges RICO violations
arising from drug-maker Valeants use of a secret network of captive pharmacies to fraudulently
inflate the prices of the drug companys products to the detriment of third-party payers.
On February 2, 2017, proposed interim co-lead counsel filed In re Insulin in the District
of New Jersey.9 This filing was the culmination of nearly a year-long factual investigation. After
a number of periodicals spotlighted the rising insulin prices last spring, our firms began to
research the issue. We soon realized that the industry dynamics at play in Average Wholesale
Pricing and New England Carpenterscases which Hagens Berman ledmight also be driving
the rising cost of insulin. To further investigate this problem, Hagens Berman purchased private
financial analyses of the pharmaceutical industry, consulted economists regarding trends in the
health insurance marketplace, and acquired proprietary drug pricing data. Alongside this
research, Hagens Berman began to consult regularly with insulin patient advocacy groups,
endocrinologists, and other public health activists regarding this issue. These patient allies
introduced the firm to many of the plaintiffs whose stories we shared in our original complaint.
Over the course of the last few months, we have developed strong relationships with these
plaintiffs, regularly speaking over the phone to answer questions and discuss the case.
9
This action was initially filed in the District of Massachusetts. It was voluntary withdrawn from that district
and re-filed in the District of New Jersey because a related investor suit had already been filed in this district.
- 12 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 16 of 23 PageID: 541
Proposed interim co-lead counsel took equal care in drafting the legal claims set forth in
their complaint. After analyzing a broad range of legal claims, they included only the most
viable. Hagens Berman and Carella Byrne believe the interests of the class are best served not
by positing every legal claim imaginable against every possible defendant, but rather by
judiciously presenting only the most cogent. In crafting their legal theory, Hagens Berman drew
on its experience litigating Average Wholesale Price and New England Carpenters. Ultimately,
the two firms decided not to name the Pharmacy Benefit Managers (PBMs) as defendants. If
appointed co-lead counsel, it is our intention to divide the case into two closely coordinated
tracksthe drug manufacturer track and the PBM track. The firm of Keller Rohrback will direct
the PBM track, while Hagens Berman and Carella Byrne direct the manufacturer track. This
division will ultimately serve the interests of the class by allowing for the coordinated and
efficient prosecution of all cases before the Court. Furthermore, this approach has been followed
before. Indeed, Hagens Berman did not name the PBMs in New England Carpenters. This
streamlined approach worked there, and we believe it will work just as well here.
corporations for their violations of RICO and state consumer protection laws. Moreover, Hagens
Berman and Carella Byrne have unparalleled experience in drug pricing class actions. Both
firms have established relationships with the top experts in the pharmaceutical and drug pricing
field, including health care economists and ex-industry representatives. Proposed interim
counsel has also worked with a wide variety of damages experts to ensure that damage models
meet the theory of liability pursued. Finally, the two firms have class certification expertise that
- 13 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 17 of 23 PageID: 542
will be critical to this case: Hagens Berman is one of the few firms in the country to have
4. Hagens Berman and Carella Byrne will devote all resources necessary to this
action.
Hagens Berman and Carella Byrne are ready to commit the substantial resources
necessary to litigate a case of this magnitude. The firms suggest that two points animate this
factor: commitment of firm resources and senior partners to the case and a willingness to take the
case to trial and settle only if consumers obtain real relief. Proposed interim co-lead counsel rate
pharmaceutical, tobacco, consumer goods, and banking interestsdemonstrate that each firm
commits their full power to prosecute claims in the best interests of the plaintiffs and proposed
class. This past work also demonstrates that the firms have the ability to fund substantial costs
accruing over many years of litigation and trial. Proposed interim co-lead counsel are fully
aware that this case will likely require plaintiffs counsel to expend millions of dollars in
expenses and attorney time to oppose the very substantial law firms and corporations arrayed
against them. Hagens Berman and Carella Byrne stand ready to commit these resources to this
action.
Furthermore, both firms have dedicated eminent litigators to this matter. Both Mr.
Berman and Mr. Cecchi will personally dedicate whatever time is necessary to successfully
10
Class action cases that Hagens Berman has tried include: In re Neurontin Marketing & Sales Practices
Litigation, MDL No. 1629 (D. Mass.); Williams v. The Boeing Co., No. 98-cv-761 P (W.D. Wash.); In re Burlington
Northern & Santa Fe Railway Co. Employee Settlement Agreements Litigation (W.D. Wash.); In re Pharmaceutical
Industry Average Wholesale Price (AWP) Litigation, MDL No. 1456, No. 01-12257 (D. Mass.), and Kucera v. The
State of Washington Department of Transportation & Washington State Ferries, No. 99-2-01161-1 (Wash. King
Cty. Super. Ct.).
- 14 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 18 of 23 PageID: 543
manage and prosecute the cause, and both expect to devote a substantial amount of their time to
this matter. Hagens Berman and Carella Byrne also have the roster of talented attorneys and
capable staff necessary to deal with the substantial amount of discovery, motion practice, and
Additionally, proposed interim co-lead counsels nationwide offices will benefit the
putative class. Even though this litigation will proceed in New Jersey, the plaintiffs and
defendants are located across the United States. Hagens Berman and Carella Byrnes amended
complaint set forth claims on behalf of thirty-nine plaintiffs from nineteen different states.11
Since filing this amended complaint, twelve additional plaintiffs have retained Hagens Berman
to represent them in this suit, representing an additional seven states.12 Hagens Berman has a
national practice with offices in San Francisco, Seattle, New York, Boston, Washington, D.C.,
Chicago, Los Angeles, Phoenix, and Colorado Springs. Carella Byrne holds office in Roseland,
New Jersey and litigates cases nationwide. Appointing counsel with a strong presence
Finally, Hagens Berman and Carella Byrne are fully prepared to and capable of
committing the type of resources necessary to take this matter to trial. The attorneys at both
firms are trial lawyers, including former Assistant United States Attorneys, Assistant State
Attorneys General, and local prosecutors. Both firms have the resolve necessary to take complex
class actions to trial, should that be in the best interests of the plaintiffs and putative class.
11
The states are: Arizona, California, Florida, Georgia, Indiana, Iowa, Kansas, Louisiana, Maine,
Massachusetts, Michigan, Mississippi, New Jersey, New York, Ohio, South Carolina, Texas, Utah, and Washington.
12
The additional states are: Kentucky, Minnesota, Nebraska, Nevada, Pennsylvania, Tennessee, and Wisconsin.
- 15 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 19 of 23 PageID: 544
Rule 23(g)(1)(B) encourages the Court to consider any other matter pertinent to
counsels ability to fairly and adequately represent the interest of the class, and we suggest that
a. Hagens Berman and Carella Byrne will ensure any recovery reaches
the class.
First, Hagens Berman and Carella Byrne will ensure that real value is provided to the
class. This is especially true in the event of settlement. For example, in In re Charles Schwab
Corp. Securities Litigation, No. 08-cv-01510 (N.D. Cal.), Hagens Berman negotiated a
settlement for the California class that recovered about 82% of damages with average check
amounts of approximately $1,564, and a settlement for the federal class that recovered
approximately 44% of damages with an average payout to class members of about $881. In
Toyota, vehicle registration data was used to identify and mail checks to class members. Class
members were then provided the opportunity to obtain enhanced recoveries by filing claim forms
Finally, Hagens Berman and Carella Byrne are committed to building strong relationships
to the putative class to ensure that the plaintiffs are heard and best represented. Indeed, these
firms have already begun this process. Proposed interim co-lead counsel has set up a plaintiff
portal, where potential plaintiffs can inquire with the firm about the lawsuit. So far, we have
received over 1,300 inquiries, and we strive to respond to inquiries within a week. Furthermore,
over the last few months, proposed interim co-lead counsel has cultivated close relationships
- 16 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 20 of 23 PageID: 545
with many of the named plaintiffs. For these reason Hagens Berman and Carella Byrne are in
- 17 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 21 of 23 PageID: 546
IV. CONCLUSION
For the foregoing reasons, plaintiffs respectfully request that this Court appoint Hagens
Berman and Carella Byrne as interim co-lead counsel pursuant to Rule 23(g).
Roberta D. Liebenberg
Adam J. Pessin
FINE, KAPLAN AND BLACK, R.P.C.
One South Broad Street, Suite 2300
Philadelphia, PA 19107
Telephone: (215) 567-6565
Facsimile: (215) 568-5872
- 18 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 22 of 23 PageID: 547
rliebenberg@finekaplan.com
apessin@finekaplan.com
Craig L. Briskin
MEHRI & SKALET, P.L.L.C.
1250 Connecticut Avenue NW, Suite 300
Washington, D.C. 20036
Telephone: (202) 822-5100
Facsimile: (202) 822-4997
cbriskin@findjustice.com
Linda P. Nussbaum
Bradley J. Demuth
NUSSBAUM LAW GROUP, P.C.
1211 Avenue of the Americas, 40th Floor
New York, NY 10036-8718
Telephone: (917) 438-9102
lnussbaum@nussbaumpc.com
Michael E. Criden
CRIDEN & LOVE, P.A.
7301 S.W. 57th Court, Suite 515
South Miami, Florida 33143
Telephone: (305) 357-9000
Facsimile: (305) 357-9050
mcriden@Cridenlove.com
Jayne A. Goldstein
Natalie Finkelman Bennett
SHEPHERD FINKELMAN MILLER &
SHAH, LLP
1625 N. Commerce Parkway, Suite 320
Fort Lauderdale, FL 33326
Telephone: (954) 515-0123
Facsimile: (866) 300-7367
jgoldstein@sfmslaw.com
- 19 -
Case 3:17-cv-00699-BRM-LHG Document 49-1 Filed 04/28/17 Page 23 of 23 PageID: 548
CERTIFICATE OF SERVICE
I, James E. Cecchi, certify that, on this date, the foregoing document was served by filing
it on the courts CM/ECF system and additionally via electronic mail to all counsel of record.
- 20 -