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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`IN RE AUTOMOTIVE PARTS
`ANTITRUST LITIGATION
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`Master File No. 12-md-02311
`Honorable Sean F. Cox
`Mag. Judge R. Steven Whalen
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`THIS DOCUMENT RELATES TO:
`ALL END-PAYOR ACTIONS
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`DECLARATION OF JENNA
`FARLEIGH IN SUPPORT OF
`END-PAYOR PLAINTIFFS’
`MOTION TO STRIKE
`FINANCIAL RECOVERY
`SERVICES, LLC’S MOTION
`FOR RECONSIDERATION OF
`THE COURT’S APRIL 28
`OPINION AND ORDER
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`DECLARATION OF JENNA FARLEIGH IN SUPPORT OF END-PAYOR
`PLAINTIFFS’ MOTION TO STRIKE FINANCIAL RECOVERY
`SERVICES, LLC’S MOTION FOR RECONSIERATION OF THE
`COURT’S APRIL 28 OPINION AND ORDER
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`I, Jenna Farleigh, hereby declare the following in accordance with the
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`provisions of 28 U.S.C. § 1746:
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`1.
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`I am a partner at the law firm of Susman Godfrey L.L.P., one of the
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`firms serving as Co-Lead Counsel for the End-Payor Plaintiff Settlement Classes. I
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`submit this declaration in support of End-Payor Plaintiffs’ Motion to Strike Financial
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`1
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`Case 2:12-md-02311-SFC-RSW ECF No. 2138-2, PageID.39328 Filed 05/15/21 Page 2 of 3
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`Recovery Services, LLC’s Motion for Reconsideration of the Court’s April 28
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`Opinion and Order.
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`2.
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`The following facts are based on my personal knowledge and
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`knowledge acquired in my role as an attorney in this litigation. If called upon as a
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`witness, I could and would testify competently to them.
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`3.
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`Attached as Exhibit A is a true and accurate copy of FRS’s opening
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`brief to the Sixth Circuit filed on April 21, 2001.
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`4.
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`Attached as Exhibit B is a true and accurate copy of 3 Newberg on
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`Class Actions § 9:37.
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`5.
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`Attached as Exhibit C is a true and accurate copy of Taylor v. KeyCorp,
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`680 F.3d 609 (6th Cir. 2012).
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`6.
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`Attached as Exhibit D is a true and accurate copy of Griggs v. Provident
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`Consumer Discount Co., 459 U.S. 56 (1982).
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`7.
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`I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that
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`the foregoing is true and correct.
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`Executed this 15th day of May 2021, in Seattle, WA.
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`/s/ Jenna Farleigh
`Jenna Farleigh
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`2
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`Case 2:12-md-02311-SFC-RSW ECF No. 2138-2, PageID.39329 Filed 05/15/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that on May 15, 2021, I electronically filed the foregoing
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`document with the Clerk of the Court using the CM/ECF system which will send
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`notification of such filing to all parties of record.
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`/s/ Jenna G. Farleigh
`Jenna G. Farleigh
`SUSMAN GODFREY L.L.P.
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`3
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