Free Motion to Dismiss - District Court of California - California

Case 3:07-cv-02226-DMS-AJB

Document 5-4

Filed 11/30/2007

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1 MARIA C. ROBERTS, State Bar No. 137907 RONALD R. GIUSSO, State Bar No. 184483 2 SHEA STOKES, A LAW CORPORATION 510 MARKET STREET, THIRD FLOOR 3 SAN DIEGO, CALIFORNIA 92101-7025 TELEPHONE: (619) 232-4261 4 FACSIMILE: (619) 232-4840 5 Attorneys for Specially Appearing Defendant HARRAH'S ENTERTAINMENT, INC. 6 7 8 9 10 11 JAMES M. KINDER, 12 13 vs. 14 HARRAH'S ENTERTAINMENT, INC. and DOES 1 through 100, inclusive, 15 Defendants. 16 17 18 19 20 21 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / /
S0078282.DOC

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

CASE NO. 07 CV 2226 H (RBB) Judge: Mag. Judge: Hon. Marilyn L. Huff Hon. Ruben B. Brooks

Plaintiff,

DECLARATION OF MICHAEL E. KOSTRINSKY IN SUPPORT OF SPECIALLY APPEARING DEFENDANT'S MOTION TO DISMISS ACCOMPANYING DOCUMENTS: NOTICE OF MOTION AND MOTION; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF MARIA C. ROBERTS; NOTICE OF LODGMENT OF EXHIBITS; [PROPOSED] ORDER Date: Time: Courtroom: January 7, 2008 10:30 a.m. 13

DECLARATION OF MICHAEL E. KOSTRINSKY

Case 3:07-cv-02226-DMS-AJB

Document 5-4

Filed 11/30/2007

Page 2 of 2

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I, Michael E. Kostrinsky, declare:

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I am the Chief Litigation Officer for Harrah's Operating Company, Inc. As such, I

4 have personal knowledge of Harrah's Operating Company, Inc., its holdings and those of its 5 affiliates and Harrah's Entertainment, Inc. I make this declaration based on that knowledge. 6 7 2. Specially Appearing Defendant Harrah's Entertainment, Inc. is a Delaware

8 corporation headquartered in Las Vegas, Nevada. It does not have offices in California; does not 9 own property in California; does not have employees in California; and, does not conduct business 10 in California. 11 12 3. Specially Appearing Defendant Harrah's Entertainment, Inc. does not make

13 telemarketing or other telephone calls to individuals in California using an automatic telephone 14 dialing system, artificial or prerecorded voice, or otherwise. It also does not have employees who 15 do this. 16 17 I declare under penalty of perjury under the laws of the United States of America that the

18 foregoing is true and correct. Executed this 28th day of November 2007, at Las Vegas, Nevada. 19 20 21 22 23 24 25 26 27 28
S0078282.DOC

/s/Michael E. Kostrinsky Michael E. Kostrinsky

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DECLARATION OF MICHAEL E. KOSTRINSKY