Free Reply - District Court of California - California

Case 3:07-cv-02430-IEG-POR

Document 8-2

Filed 02/01/2008

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1 MARIA C. ROBERTS, State Bar No. 137907 [email protected] 2 RONALD R. GIUSSO, State Bar No. 184483 [email protected] 3 SHEA STOKES ROBERTS & WAGNER, ALC 510 MARKET STREET, THIRD FLOOR 4 SAN DIEGO, CALIFORNIA 92101-7025 TELEPHONE: (619) 232-4261 5 FACSIMILE: (619) 232-4840 6 Attorneys for Specially Appearing Defendants HARRAH'S ENTERTAINMENT, INC., HARRAH'S OPERATING COMPANY, INC. and HARRAH'S RINCON RESORT & CASINO, 7 INC. 8 9 10 11 MARISELA AYON, an individual, JOSE R. AYON, an individual, 12 Plaintiffs, 13 vs. 14 HARRAH'S ENTERTAINMENT, INC., a 15 Delaware corporation; HARRAH'S OPERATING COMPANY, INC., a Delaware 16 corporation; HARRAH'S RINCON RESORT & CASINO, INC., a corporation qualified to 17 do business in California; and DOES 1 to 25, inclusive, 18 Defendant. 19 20 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / /
S0079627

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

CASE NO. 07-CV-2430 IEG POR Action Date: Judge: Mag. Judge: July 9, 2007 Hon. Irma E. Gonzalez Hon. Louisa S. Porter

DECLARATION OF RONALD R. GIUSSO IN SUPPORT OF SPECIALLY APPEARING DEFENDANTS' REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO DISMISS ACCOMPANYING DOCUMENTS: REPLY MEMORANDUM OF POINTS AND AUTHORITIES Date: February 11, 2008 Time: 10:30 a.m. Courtroom: 1

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CASE NO. 07-CV-2430 IEG POR

Case 3:07-cv-02430-IEG-POR

Document 8-2

Filed 02/01/2008

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I, Ronald R. Giusso, declare as follows:

1.

I am an attorney duly admitted to practice before this Court. I am an attorney with

4 Shea Stokes Roberts & Wagner, ALC, attorneys of record for Specially Appearing Defendants 5 Harrah's Entertainment, Inc., Harrah's Operating Company, Inc., and Harrah's Rincon Resort & 6 Casino, Inc. If called as a witness, I could and would competently testify to all facts within my 7 personal knowledge except where stated upon information and belief. 8 9 2. This declaration is submitted in support of Specially Appearing Defendants' Reply

10 Memorandum of Points and Authorities in Support of Motion to Dismiss. 11 12 3. On January 8, 2008, Specially Appearing Defendants filed a Motion to Dismiss the

13 AYONS' complaint. The AYONS' Opposition to the Motion to Dismiss was due on January 28, 14 2008. As of February 1, 2008, the AYONS still had not filed their Opposition to Specially 15 Appearing Defendants' Motion to Dismiss. 16 17 4. I have attempted to contact Plaintiffs' counsel numerous times, both telephonically

18 and in writing to discuss this case, and the AYONS' counsel has never returned my calls or 19 responded to my letters. 20 21 I declare under penalty of perjury that the foregoing is true and correct, and that this

22 declaration was executed by me on February 1, 2008 at San Diego, California. 23 24 25 26 27 28
S0079627

/s/ Ronald R. Giusso Ronald R. Giusso

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CASE NO. 07-CV-2430 IEG POR