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`BROADSIGN INTERNATIONAL, LLC,
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`Plaintiff,
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`Civil Action No.: 1:16-cv-04586 (LTS)
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`JURY TRIAL REQUESTED
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`T-REX PROPERTY AB,
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`Defendant.
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`DECLARATION OF ALFRED R. FABRICANT IN SUPPORT
`OF PLAINTIFF’S MOTION FOR LEAVE TO AMEND
`THE COMPLAINT PURSUANT TO FED. R. CIV. P. RULE 15
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`I, Alfred R. Fabricant, being duly sworn, hereby declare as follows:
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`1.
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`I am a member of Brown Rudnick, LLP, counsel of record for Plaintiff BroadSign
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`International, LLC (“BroadSign”). I am a member of the Bar of the State of New York and have
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`been admitted to practice in the United States District Court for the Southern District of New
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`York. I make this declaration in support of Plaintiff BroadSign’s motion for leave to further
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`amend the complaint. The statements in this declaration are based upon my review of
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`information obtained from public records.
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`2.
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`Attached hereto as Exhibit 1 is a proposed Second Amended Complaint and
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`Exhibit A to the Second Amended Complaint in compliance with the Court’s Order. Dkt 40 at
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`10.
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`Case 1:16-cv-04586-LTS-HBP Document 44 Filed 02/01/18 Page 2 of 2
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`3.
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`Attached hereto as Exhibit 2 is a blacklined version of the proposed Second
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`Amended Complaint in compliance with the Court’s Order. Dkt 40 at 10.
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`4.
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`I declare under penalty of perjury that the foregoing is true and correct to the best
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`of my knowledge. Executed on January 31, 2018.
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` /s/ Alfred R. Fabricant
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` Alfred R. Fabricant (AF8255)
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`2
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