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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
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`Civil Action
`File No. 1:16-cv-02690-AT
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`SIPCO, LLC, and IP CO, LLC
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`(d/b/a INTUS IQ),
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`Plaintiffs,
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`v.
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`EMERSON ELECTRIC CO., EMERSON
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`PROCESS MANAGEMENT LLLP,
`FISHER-ROSEMOUNT SYSTEMS, INC., )
`ROSEMOUNT INC., BP p.l.c., BP
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`AMERICA, INC., and BP AMERICA
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`PRODUCTION COMPANY,
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`Defendants.
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`DECLARATION OF PAUL J. CRONIN, ESQ.
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`I, Paul J. Cronin, Esq., state as follows:
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`1.
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`I am a competent adult over 18 years of age without any criminal
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`convictions. I submit this declaration in support of Plaintiffs’ Sur-Reply in Support
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`of their Opposition to Defendant BP p.l.c.’s Motion to Dismiss for Failure to State
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`a Claim and Misjoinder.
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`Case 1:16-cv-02690-AT Document 127-2 Filed 08/09/16 Page 2 of 5
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`2.
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`The facts in this declaration are true and correct to the best of my
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`knowledge, information, and belief, and I am competent to testify to them if called
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`upon to do so.
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`3.
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`I am a partner at the law firm Nutter McClennen & Fish, LLP in
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`Boston, Massachusetts, which represents Plaintiffs’ SIPCO, LLC and IP CO, LLC
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`(together “Plaintiffs”) in the above-captioned matter.
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`4.
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`The First Amended Complaint was served on the U.S. BP entities
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`shortly after it was filed.
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`5.
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`Emerson’s attorneys appeared on behalf of the U.S. BP entities.
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`Plaintiffs inquired whether BP p.l.c. would accept service of the First Amended
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`Complaint. BP and Emerson’s counsel indicated that they did not represent BP
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`p.l.c. and thus could not accept service on behalf of BP p.l.c. But BP and
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`Emerson’s counsel indicated that BP p.l.c. wanted to explore the possibility of
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`allowing BP p.l.c. to exit the case without the need for service of the First
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`Amended Complaint.
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`6.
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`Plaintiffs inquired about the substance of BP p.l.c.’s proposal. When
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`BP p.l.c. finally provided a proposal, Plaintiffs determined that it was
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`unacceptable.
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`Case 1:16-cv-02690-AT Document 127-2 Filed 08/09/16 Page 3 of 5
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`7.
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`Plaintiffs paid more than $2,000 to serve BP p.l.c. through the Hague
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`Convention.
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`8.
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`Attached hereto as Exhibit A is a true and correct copy of an email I
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`sent to opposing counsel on March 4, 2016.
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`Signed under the penalties of perjury this 9th day of August, 2016.
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`/s/ Paul J. Cronin
`Paul J. Cronin, Esq.
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`Case 1:16-cv-02690-AT Document 127-2 Filed 08/09/16 Page 4 of 5
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`CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
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`The undersigned hereby certifies that this filing was prepared using one of
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`the font and point selections approved by this Court in Local Rule 5.1C.
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`Specifically, Times New Roman font was used in 14 point.
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`J. Christopher Fox, II
`J. Christopher Fox, II
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`Case 1:16-cv-02690-AT Document 127-2 Filed 08/09/16 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`This is to certify that I have this day served all counsel of record with a
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`copy of the within and foregoing DECLARATION OF PAUL J. CRONIN, ESQ.
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`using the Court’s ECF filing system which will automatically send a copy to
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`all counsel of record registered to receive service thereby, and also by U.S. Mail,
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`postage prepaid, upon the following:
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`3231480
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`Donald L. Jackson
`James D. Berquist
`J. Scott Davidson
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive, Suite 500
`McLean, Virginia 22102
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`William V. Custer
`Damon J. Whitaker
`Bryan Cave, LLP
`One Atlantic Center, Fourteenth Floor
`1201 W. Peachtree St., N.W.
`Atlanta, Georgia 30309
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`J. Christopher Fox, II
`J. Christopher Fox, II
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`5
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