Free Declaration - District Court of Delaware - Delaware

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Exhibit 4

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MITCHELL S. BERNARD 40 West 20th Street, 11th Floor New York, New York 10011 (212) 727-4469

BORN: EDUCATION:

March 1, 1952; New York City New York University (J.D., 1979): Poses Prize for student practice; Arthur Garfield Hays Civil Liberties Fellowship Princeton University (A.B., cum laude, 1974): Page Prize for "Achievements in Creative Writing"

EMPLOYMENT: Natural Resources Defense Council (1988-1996, 1999-present): Litigation Director; federal litigation in California, Delaware, Maine, and other states enforcing environmental laws, especially Clean Water Act and Resource Conservation and Recovery Act. Association to Benefit Children (1987-present): Special Counsel to nonprofit group providing services and advocacy for homeless and handicapped children; litigated federal cases securing right of homeless infants and children to prompt release from hospitals where they were being warehoused by City of New York; litigated case to win effective medical screening, diagnosis, and treatment for NYC homeless children who suffer from asthma. U.S. Attorney's Office Expert Work (2000-02): Consultant to U.S. Attorney's Office for the Southern District of New York, monitoring implementation and enhancement of Con Edison's environmental compliance program. Court-Appointed Monitor (1995-1998): Appointed by Hon. John S. Martin, Jr. (Southern District of New York) to monitor Con Edison's compliance with conditions of probation imposed after its conviction of federal crimes. The Court required Con Edison to comply with all federal environmental laws relating to its operations, and to implement a compliance program consistent with standards set forth in the federal Sentencing Guidelines. Coalition for the Homeless (1986-1987): Litigated in state and federal courts to create and protect rights for homeless individuals and families. Westway Litigation (1981-1985): Represented environmental and community groups that stopped the proposed Westside Highway Project ("Westway") in New York City. United States Court of Appeals, 2d Circuit (1979-1980): Pro se law clerk under Hon. Walter R. Mansfield; preparation of bench memoranda on substantive motions and direct civil and criminal pro se appeals.

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PUBLICATIONS/OTHER ACTIVITIES: Lyricist for the musical The Chosen, produced in 1988 at the Second Avenue Theatre, New York City; Author of the musical Snapshot, produced in 1980 by the Hudson Guild Theatre, New York City; Co-Author of The Rights of Single People, an American Civil Liberties Union Handbook published in 1985. SUMMARY OF SELECTED LITIGATIONS: Maine People's Alliance v. Holtrachem Manufacturing, 211 F. Supp.2d 237 (D. Me. 2002), 471 F.3d 277 (1st Cir. 2006): Citizen suit brought under Resource Conservation and Recovery Act; District Court ruled, after trial, that defendant's discharges of mercury to Penobscot River may imminently and substantially endanger human health and the environment. The Court ordered a comprehensive study of a large area of Penobscot River and Bay, to be followed by appropriate remediation. NRDC v. California Department of Transportation, CV 93-6073-ER (1994): First citizen action successfully enforcing stormwater runoff provisions of Clean Water Act. After three-week trial, Caltrans enjoined to clean 80,000 catch basins (many of which were filled with lead and other pollutants), train its employees, and devise and implement, under Court supervision, comprehensive stormwater pollution protection program to control polluted runoff from 1100 miles of roadways and 50 maintenance yards near Santa Monica Bay. EPA, NRDC v. County Sanitation Districts of Los Angeles County, CV 92-0061-RG (1994): Clean Water Act enforcement case against LA County Sewer Authority, which serves four million people. In Consent Decree, County agreed to spend $400 million to upgrade its sewage facilities to full secondary treatment under Court-enforceable deadline, pay civil penalties, and undertake other environmentally beneficial programs. NRDC v. Texaco, 800 F. Supp. 1 (D. Del. 1992), 2 F.3d 493 (3d Cir. 1993): Citizen enforcement action against Texaco for unlawful pollutant discharges from its oil refinery in Delaware City, Delaware. After three-week trial, Court entered judgment for plaintiffs. Texaco has thus far paid millions of dollars in civil penalties and is subject to a stringent permanent injunction barring future noncompliance. After a motion to enforce the injunction, the Court required Texaco to undertake an elaborate study to determine the effect of its unlawful pollutant discharges on the ecology of the Delaware River, 20 F. Supp. 2d 700 (D. Del. 1998). Baby Jennifer v. Koch, 86 Civ. 9676 (VLB) (1987): Constitutional challenge to government practice of warehousing homeless infants and children in New York City hospitals. On the eve of trial, the City of New York entered into a Consent Decree prescribing effective mechanisms for removing these children (called "boarder babies") from hospitals as soon as they were medically cleared for discharge. The Decree has resulted in a 90% reduction in the number of

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boarder babies in City hospitals, and a decrease from 34 to four days in their average length of stay beyond medical necessity. In a subsequent case, Baby Angel v. Koch, 89 Civ. 4770 (VLB) (1991), the City agreed to extend the successful Baby Jennifer measures to hospitalized children with special medical needs (including cerebral palsy and HIV infection). Chinese Staff and Workers Association v. City of New York, 68 N.Y. 2d 359 (1986): New York Court of Appeals established that the displacement of lower income residents and local businesses is an environmental impact cognizable under the New York State Environmental Quality Review Act. In so doing, the Court nullified a permit for the first luxury residential development in New York City's Chinatown. Sierra Club v. U.S. Army Corps of Engineers, 614 F. Supp. 1475 (S.D.N.Y.), 772 F. 2d 1043 (2d Cir. 1985): After a seven-week trial, Court invalidated Clean Water Act permit granted for the proposed Westway, a multibillion dollar federal-state highway project that would have filled in more than 200 acres of the Hudson River.

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DIMPLE CHAUDHARY
672 President Street · Apartment 4 · Brooklyn, NY · 11215 · (732) 213-3113 · [email protected] EDUCATION COLUMBIA UNIVERSITY SCHOOL OF LAW, New York, NY J.D., May 2005. Honors: Harlan Fiske Stone Scholar Robert Noxan Toppan Prize in Constitutional Law Alfred A. Forsyth Prize in Environmental Law Human Rights Intern Thomas Scheuer Fellow Activities: Articles Editor ­ Columbia Human Rights Law Review Research Assistant ­ Professor Jack Greenberg Academic Chair ­ South Asian Law Students Association Political Asylum Project with Davis Polk & Wardwell/Center for Public Interest Law LONDON SCHOOL OF ECONOMICS AND POLITICAL SCIENCE, London, England M.Sc. in Urban and Regional Planning Studies, with distinction, December 2002. Focus on infrastructure development and urban economics. Dissertation: Transforming Suburbia: The Formation and Implication of Indian Ethnic Enclaves HARVARD UNIVERSITY, Cambridge, MA B.A. in Social Studies, magna cum laude, June 2001. Focus on political theory and economic development. Honors: Harvard College Scholarship Arthur Liman Public Interest Law Fellowship Weatherhead Center for International Affairs Research Fellow Thesis: Growing from the Grassroots? Participatory Democracy in the Self-Employed Women's Association of Ahmedabad, India EXPERIENCE HON. CAROL BAGLEY AMON, EASTERN DISTRICT OF NEW YORK Law Clerk

Aug. 2007-Aug. 2008

NATURAL RESOURCES DEFENSE COUNCIL, New York, NY Sept. 2005-Jul. 2007 Attorney, Urban Legal Fellow Conducted federal litigation related to resource protection and information access. Performed legal research, drafted briefs, and conducted depositions. Worked with community coalitions on policy projects related to recycling and drinking water protection. FORDHAM UNIVERSITY SCHOOL OF LAW, New York, NY Adjunct Professor of Law Taught semester-long seminar on Environmental Law and Justice. Spring 2007

CLEARY, GOTTLIEB, STEEN & HAMILTON, New York, NY Summer 2004 Summer Associate Performed legal research for international litigation disputes. Assisted with corporate real estate transactions. JUDGE JACK B. WEINSTEIN, EASTERN DISTRICT OF NY Intern Jan.-May 2004

LEGAL RESOURCES CENTRE, Durban, South Africa Legal Intern Summer 2003 Prepared land claim cases involving resettlement rights under post-apartheid restitution legislation. Performed legal research on a proposal to construct an experimental nuclear reactor in South Africa. BAR Admitted in New York (Nov. 2006).

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THOMAS CMAR
EXPERIENCE

206 Skyhill Rd. #10 Alexandria, VA 22314

(202) 289-2405 (work) (617) 285-3034 (cell) [email protected]

NATURAL RESOURCES DEFENSE COUNCIL (NRDC), New York, NY Sept. 2006-Aug. 2007 Washington, DC Aug. 2007-present Litigation Fellow. Staff attorney to New York and DC Litigation Teams, handling wide variety of complex environmental and Freedom of Information Act litigation and acting as lead attorney in some cases. Research, draft, and edit pleadings, motions, memoranda, appellate briefs, and letters to counsel and court. Work with experts and clients to draft declarations and prepare testimony. Participate in conferences, hearings, depositions, and oral arguments. Supervise interns. Investigate potential legal claims against polluters through public records requests and other means. INTERNATIONAL LABOR RIGHTS FUND (ILRF), Washington, DC Mar. 2006-Sept. 2006 Staff Attorney. Researched, drafted, and edited pleadings, motions, memoranda, appellate briefs, and letters to counsel and court in international human rights litigation in federal court under state tort law, international law, and Alien Tort Statute. UNITED STATES MAGISTRATE JUDGE DEBRA FREEMAN, Southern District of New York Law Clerk. Mar. 2005-Mar. 2006 Researched and drafted reports and recommendations, orders, memoranda, and jury charges. Researched legal questions and advised on issues involved. Assisted in preparation for and during conferences, hearings, oral arguments, and trial. Communicated with litigants regarding case management. Supervised and coordinated interns. ENVIRONMENTAL RIGHTS INTERNATIONAL, New York, NY / Conway, MA Associate Counsel. June 2004-Mar. 2005 Represented Republic of Ecuador in litigation to stay arbitration commenced by ChevronTexaco Corporation in dispute over legal responsibility for oil-related damage to Ecuadorian Amazon. Performed all legal research for and drafted all pleadings, dispositive and discovery motions, memoranda, and letters to counsel and the court. Researched and drafted pleadings, motions in limine, and memoranda for tort cases involving environmental remediation and administrative due process in state and federal courts in Massachusetts. Assisted with mediation.

EDUCATION
HARVARD LAW SCHOOL, J.D., June 2004 Honors: cum laude (approx. 3.6 GPA) Irving R. Kaufman Public Service Fellowship, Kirkpatrick & Lockhart Public Interest Fellowship Activities: Harvard Journal on Legislation, Articles Editor (Vol. 41), Student Writing Editor (Vol. 40) Law and Philosophy Society, President U.S. Public Interest Research Group Democracy Program, Legal Analyst John Bonifaz (attorney for Military Families Speak Out), research assistant National Voting Rights Institute, legal intern Civil Rights Project at Harvard University, legal intern United States Attorney, Southern District of Ohio, legal intern UNIVERSITY OF PITTSBURGH, B.A. in Politics and Philosophy, May 2001 Honors: summa cum laude (3.97 GPA), Phi Beta Kappa Chancellor's Scholar, Brackenridge Research Fellowship Activities: Students in Solidarity, founding member Congressman William J. Coyne, legislative intern Pittsburgh Undergraduate Review, editor

PUBLICATIONS

Book Review, 13 CONSTELLATIONS 431 (2006) (reviewing THE CONSTITUTION IN WARTIME: BEYOND ALARMISM AND COMPLACENCY (Mark Tushnet ed., 2005)). Toward a Small Donor Democracy: The Past and Future of Incentive Programs for Small Political Contributions, 32 FORDHAM URB. L.J. 443 (2005). Recent Development, Office of Homeland Security, 39 HARV. J. ON LEGIS. 455 (2002). Admitted in Mass. (Dec. 2004), N.Y. (Jan. 2005), and U.S. District Court, S.D.N.Y. (Dec. 2006).

BAR

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AARON COLANGELO NRDC, 1200 New York Ave, NW, Suite 400 Washington, DC 20005 EXPERIENCE NATURAL RESOURCES DEFENSE COUNCIL, Washington, DC 2001 -- present Conducted environmental impact litigation in federal courts of appeals, district courts, and administrative proceedings. Argued appeals in D.C. Circuit, 2nd Circuit, and 9th Circuit and dispositive motions in several federal district courts (including S.D.N.Y., D.D.C., D.N.J., N.D.Cal., C.D.Cal., and D.Md.). Drafted appellate briefs, complaints, summary judgment motions, motions to intervene, motions to dismiss, discovery motions, petitions for rehearing, and other pleadings. Conducted legal research and prepared memoranda evaluating possible litigation. Coordinated litigation and advocacy efforts with other environmental and public health groups. Authored media statements and conducted interviews with national press on environmental issues. COVINGTON & BURLING, Washington, DC 1999 -- 2001 Represented clients in various stages of state and federal civil litigation. Drafted briefs, complaints, answers, pretrial motions, and legal memoranda. Propounded discovery requests and prepared discovery responses. Conducted and defended depositions. Authored proposed state and local legislation, analyzed state and federal bills, and drafted briefs to legislators regarding pending legislation. Represented disabled clients pro bono in impact litigation to compel a national grocery store chain to comply with ADA requirements. Represented African-American farmer in arbitration regarding discriminatory farm lending practices by USDA. BREAD FOR THE CITY LEGAL SERVICES, Washington, DC September 2000 -- April 2001 Eight month pro bono rotation representing clients in all aspects of trial litigation in District of Columbia courts and in administrative hearings. Tried cases in civil division, family division, landlord and tenant court, and small claims court. Prepared witnesses for evidentiary hearings and trial. LEGAL RESOURCES CENTER, Cape Town, South Africa Summer 1999 Submitted brief to Minister of Health regarding proposed mandatory AIDS notification; prepared lawsuit challenging lack of available public education for profoundly mentally handicapped children. PROFESSOR CHARLES OGLETREE, Harvard Law School Prepared legal research memoranda, drafted speeches, and edited book manuscript. 1998 -- 1999

DISABILITY LAW CENTER, Boston, MA Spring 1999 Represented clients in disability discrimination hearings. Drafted briefs and researched legal issues. TESTIMONY Lead in the District of Columbia and the Provision of Safe Drinking Water, Hearings before the Energy and Commerce Committee, U.S. House of Representatives, Subcommittee on Environment & Hazardous Materials, 108th Cong. (July 22, 2004) "A Public Accommodations Challenge to the Use of Indian Team Names and Mascots in Professional Sports," 112 Harv. L. Rev. 904 (1999). "Critique of Runnebaum v. NationsBank -- Fourth Circuit Holds that Asymptomatic HIV is not a Disability," 111 Harv. L. Rev. 843 (1998). BAR Member of District of Columbia Bar. Admitted to practice before the following courts: D.C. Cir., 2nd Cir., 9th Cir. , D.D.C. HARVARD LAW SCHOOL, J.D. cum laude, June 1999 Activities: Harvard Law Review, editor PENN STATE UNIVERSITY, B.A. in History with Highest Honors, December 1995

PUBLICATIONS

EDUCATION

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Benjamin Longstreth
2454 Ontario Road, NW Washington, D.C. 20009 202.513-6256(w), 202.483.1997(h), [email protected]

EDUCATION Columbia Law School, J.D. May 2002 Articles Editor, Columbia Law Review Kent Scholar (GPA >3.8) 1999­2000, 2000­2001, 2001­2002 Forsyth Prize in environmental law, Beck Prize for best Property examination, Williams College, B.A., cum laude, 1993 Dean's list, Geology major, Environmental Studies Concentration EXPERIENCE Natural Resources Defense Council, Washington, DC 2006-Present Senior Attorney, Litigation Team. Litigate environmental matters before district and appellate courts. United States Department of Justice, Washington, DC 2003- 2006 Honors Program Attorney, Environment and Natural Resources Division. Represent the United States in environmental matters before U.S. district courts. Recipient of Outstanding Performance Rating Award and "on-the-spot" award. Chief Judge John M. Walker, Jr., United States Court of Appeals for the Second Circuit, New Haven, CT 2002-2003 Law Clerk. United States Department of Justice, Washington, DC Summer 2001 Summer Law Intern, Environment and Natural Resources Division. Research and writing on takings and administrative law. New York State Department of Law, New York, NY Summer 2000 Legal Intern, Environmental Protection Bureau. Research and writing of briefs to federal and state appellate courts. Baykeeper, New York, NY 1995-1999 New York City Coordinator. Initiated projects on oyster restoration, toxics reduction, public access and wetlands restoration. Developed policy for harbor dredging, open space and water quality. Responsible for communications. PUBLICATIONS Note, Protecting "The Wastes of the Foreshore": The Federal Navigational Servitude and Its Origins in State Public Trust Doctrine, 102 Colum. L. Rev. 471 (2002).

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NANCY S. MARKS 60 Beverley Road Montclair, New Jersey 07043 H: (973) 744-3642 W: (212) 727-4414 [email protected] LEGAL EXPERIENCE Natural Resources Defense Council, New York, NY Senior Attorney: 1990 - present Senior Project Attorney: 1988 - 1990 Project Attorney: 1986 - 1988 Senior litigator in NRDC's litigation group, representing national and local groups in Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and other environmental litigation in federal district and appellate courts. SELECTED RECENT LITIGATION Ohio Citizen Action v. American Electric Power, 137 F. Supp. 2d 1060 (S.D. Ohio 2001): Lead counsel for citizen groups in Clean Air Act case (consolidated with case brought by EPA and states) challenging practices of nation's largest utility in extending lives of highly polluting coal-fired power plants without complying with New Source Review. Landmark proposed consent decree lodged with Court in October 2007. Maine People's Alliance v. Mallinckrodt Inc., 471 F.3d 277 (1st Cir. 2006), cert. denied, No. 06-1540, 2007 WL 1479993 (U.S. Oct. 1, 2007); MPA v. HoltraChem Mfg. Co., 211 F. Supp. 2d 237 (D. Me. 2002): Developed and co-counseled case against chemical companies under Resource Conservation and Recovery Act (RCRA). Following trial, Court found companies liable for imminent and substantial endangerment resulting from historic mercury discharges into Penobscot River, and appointed science panel to oversee remedy. First Circuit upheld district court in December 2006, and the U.S. Supreme Court denied certiorari in October 2007. Recently developed and settled a similar RCRA case against DuPont in Virginia for mercury contamination of river, 5:05-cv-30013 (W.D.Va.). Arbor Hill Concerned Citizens Neighborhood Association v. Delaney, 95-CV-0968 (N.D.N.Y.): Lead counsel for community group in RCRA "imminent and substantial endangerment" case against New York State for toxic lead legacy from state-run incinerator. Innovative settlement in 1998 created and funded two new community organizations to address environmental justice and public health issues.

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NRDC v. Texaco, 20 F. Supp. 2d 700 (D. Del. 1998): Co-counsel in trial to enforce Clean Water Act injunction; Court ordered Texaco to undertake an elaborate study to determine the effect of its unlawful pollutant discharges on the ecology of the Delaware River. Co-counsel in appeal upholding district court, 182 F.3d 904 (1999). Motion to enforce judgment settled in September 2007. Benjamin N. Cardozo School of Law, New York, NY Adjunct Professor of Law: Spring semester 2004, 2005 Co-taught seminar on Urban Environmental Law with NRDC colleague Office of the Massachusetts Attorney General, Environmental Protection Division, Boston, MA Assistant Attorney General: 1984 - 1986 Lead and co-counsel in litigation enforcing state and federal environmental laws, including air and water pollution, wetlands protection, hazardous waste cleanup, and offshore oil challenges. Natural Resources Defense Council, San Francisco, CA Legal Fellow: 1983 - 1984 Coastal and public lands litigation. Conservation Law Foundation of New England, Boston, MA Legal Intern: 1981 - 1983 (during law school term) Environmental Defense Fund, Berkeley, CA Legal Intern: Summer 1982 EDUCATION Harvard Law School J.D. 1983, cum laude Stanford University M.S. 1979 in Geology Williams College B.A. 1976, magna cum laude, with Highest Honors in Geology. Phi Beta Kappa GUEST LECTURER Columbia Law School, New York University Environmental Law Clinic, Fordham Law School, Rutgers Law School, Pace Law School, City University of New York Law School, Brooklyn Law School, New York University Wagner School, Williams College 2

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GEOLOGY EXPERIENCE National Park Service, Redwood National Park, Orick, CA Geologist: January 1979 - June 1979 Conducted field studies for experimental erosion control and land rehabilitation project on clearcut lands. U.S. Geological Survey, Menlo Park, CA Geologist: Summer 1978 Seismic exploration of Chukchi Sea. Woods Hole Oceanographic Institution, Woods Hole, MA Research Assistant in Geology: Summer 1976 Summer Fellow in Geology: Summer 1975

CURRENT BOARD MEMBERSHIP Vermont Law School Environmental Law Center

BAR MEMBERSHIPS New York State Commonwealth of Massachusetts (inactive) U.S. Court of Appeals for the First, Third, Sixth, and District of Columbia Circuits U.S. District Courts for the Southern District of New York, Northern District of New York, District of Massachusetts, Eastern District of Wisconsin PUBLICATIONS N. Marks, "Citizen Enforcement of the Clean Water Act: From Pittsfield to the North Slope of Alaska," A Journal (Williams College Center for Environmental Studies) 7:2324 (1990). N. Marks, "Citizen Enforcement of Environmental Laws," Environment 29:5, (1987). N. Marks, "Sedimentation on New Ocean Crust: the Mid-Atlantic Ridge at 37' N.," Marine Geology 43:65-82 (1981). C. Summerhayes, G. Sestini, R. Misdorp, and N. Marks, "Nile Delta: Nature and Evolution of Continental Shelf Sediments," Marine Geology 27:43-65 (1978).

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AMELIA EVANGELISTA TOLEDO
509 West 121st St., Apt. 713, New York, NY 10027 Email: [email protected] Phone: 917-676-5937
EXPERIENCE NATURAL RESOURCES DEFENSE COUNCIL, New York, NY 2004-Fall 2006 F.A.O. Schwarz fellow in Litigation Department. Drafted complaints, notice letters, legal research memos, declarations, discovery requests, and briefs for federal litigation involving environmental and public health laws. Participated in court conferences and negotiations. UNITED STATES DISTRICT COURT, Brooklyn, NY 2002-2004 Law clerk to the Honorable Lois Bloom, United States Magistrate Judge, whose docket consists entirely of pro se plaintiffs. Wrote opinions, prepared bench memoranda, evaluated submissions, managed over 300 cases, attended pre-trial and discovery conferences, and reviewed transcripts and records. INTERNATIONAL WOMEN'S HUMAN RIGHTS CLINIC, CUNY Law School 2001-2002 Researched admissibility of expert testimony for Alien Tort Claims Act case. Developed strategy for filing a petition to the Organization of American States on social and economic rights violations in the United States. Edited portions of the judgment for the Women's International War Crimes Tribunal for Japan's Military Sexual Slavery. NATURAL RESOURCES DEFENSE COUNCIL, New York, NY Summer 2001 Researched and wrote memoranda on environmental and occupational health issues. Crafted arguments for summary judgment and amicus briefs. MAIN STREET LEGAL SERVICES, CUNY Law School Spring 2001 Represented CUNY students receiving public assistance at administrative fair hearings. Conducted client interviews; researched federal, state, and municipal regulations, rules, and legislation; and advocated for clients at welfare centers. FAMILY LAW CENTER, New York, NY Fall 2000 Conducted client intake interviews and wrote legal memoranda for a small firm specializing in matrimony law. ASIAN AMERICAN LEGAL DEFENSE AND EDUC. FUND, New York, NY Summer 2000 Conducted client intake interviews and community legal education workshops for low-wage and domestic workers of the South Asian Workers' Rights Project. Helped draft a guidebook on employment, labor, and immigration rights of domestic workers. EDUCATION CITY UNIVERSITY OF NEW YORK SCHOOL OF LAW, J.D. May 2002 Honors: Am. Assoc. of University Women, Selected Professionals Fellowship 2001-2002 NY State Bar Association Minority Fellowship for Environmental Law 2001 Asian American Bar Association of New York Community Internship Award 2000 BROWN UNIVERSITY, B.A. in Biomedical Ethics May 1998

PUBLICATION Rights Begin at Home: Protecting Yourself as a Domestic Worker, by Chaumtoli Huq, Naomi Zauderer, Monika Batra, and Amelia Toledo. Asian American Legal Defense and Education Fund and National Employment Law Project, May 2001. ADMISSIONS New York State Bar (2003), Eastern and Southern Districts of New York (2004) LANGUAGES Intermediate Tagalog and Spanish

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KATHRYN BOUDOURIS
2626 Tunlaw Road, NW #308 Washington, DC 20007 Phone: (734) 417-8601 Email: [email protected] EDUCATION University of Michigan B.A. with Highest Distinction and Honors in English Language and Literature Ann Arbor, MI April 2004

·4.00 GPA ·Phi Beta Kappa ·Virginia Voss Award for excellence in writing ·Substantial science background, including organic chemistry and microbiology National University of Ireland Institute for Study Abroad Galway, Ireland Spring Semester 2003

·Enrolled in English literature and Irish history courses with regular NUI students EMPLOYMENT Litigation Assistant Natural Resources Defense Council Washington, DC September 2006-Present

·Research procedural rules, federal regulations, and factual matters ·Cite-check pleadings and briefs, create tables of authorities, and proofread legal documents ·Work with NRDC members to draft declarations in support of organizational standing ·Prepare documents for filing Project Assistant Decision Quest Washington, DC April ­ September 2006

·Researched news media using LexisNexis and internet resources ·Performed community outreach and conducted stakeholder communications regarding environmental remediation projects Litigation Legal Assistant Spiegel & McDiarmid Washington, DC 2004 ­ 2006

·Researched aspects of energy law, wrote research memoranda, and drafted sections of pleadings ·Cite-checked pleadings and briefs, created tables of authorities, and proofread legal documents ·Managed discovery documents and maintained database of articles, laws, and other resources ·Drafted newsletter articles and policy reports for National Association of Local Government Environmental Professionals ·Researched and drafted report on best practices for international cooperative law and regulation ·Coordinated workshops for initiative on international cooperative law and regulation Office Assistant University of Michigan Department of Dermatology Ann Arbor, MI Summer 2002

·Prepared regulatory correspondence, created PowerPoint presentations of dermatological research data, and entered research data into Excel PUBLICATION Sean Flynn with Kathryn Boudouris, Democratising the Regulation and Governance of Water in the U.S., in RECLAIMING PUBLIC WATER: ACHIEVEMENTS, STRUGGLES AND VISIONS FROM AROUND THE WORLD (Belén Balanyá et al. eds., 2005).