Lawsuit Against Former LAT Employees

Two former employees of the Los Angeles Times Operations Department contacted me regarding a notice of a lawsuit they received in the mail, I assume from Tribune creditors, requesting they return a certain amount of cash they received when they tendered their Tribune stock after the company was purchased by Sam Zell. Can’t seem to locate much information via the Internet regarding this lawsuit, and will share the eleven files I have as long as the names of the defendants are not used. Stay tuned as additional information is revealed.



AO 398 (Rev. 01/09) Notice of a lawsuit and Request to Waive Service of a Summons

UNITED STATES DISTRICT COURT
for the
Southern District of New York

Deutsche Bank Trust Company Americas et al
Plaintiff

v. First Republic Bank et al
Civil Action No. 1:'1 1-cv-09572-WHp
Defendant

NOTICE OF A LAWSUIT AND REQUEST TO WAVE SERVICE OF A SUMMONS

To: (Name removed)
(Name of the defendant or if the defendant is a corporation partnership, or association-or an officer or agent authorized to receive service)

Why are you getting this?
A lawsuit has been filed against you, or the entity you represent, in this court under the number shown above. A copy of the complaint is attached.

This is not a summons, or an official notice from the court. It is a request that, to avoid expenses, you waive formal service of a summons by signing and returning the enclosed waiver. to avoid these expenses, you must return the signed waiver within 30 days (give at least 30 days, or at least 60 days if the defendnnt is outside any judicial district of the United States) from the date shown below, which is the date this notice was sent. Two copies of the waiver form are enclosed, along with a stamped, self-addressed envelope or other prepaid means for returning one copy. you may keep the other copy. '

What happens next?
- If you return the signed waiver, I will file it with the court. The action will then proceed as if you had been served on the date the waiver is filed, but no summons_will be served on you and you will have 60 days from the date this notice is sent (see the date below) to answer the complaint (or 90 days if this notite is sent to you outside any judicial district of the United States).

- If you do not return the signed waiver within the time indicated, I will arrange to have the summons and complaint served on you. And I will ask the court to require you, or the entity you represent, to pay the expenses of making service.

Please read the enclosed statement about the duty to avoid unnecessary expenses.

I certify that this request is being sent to you on the date below.
Date: March 9, 2012


Printed name: Christine Doniak

Akin Gump Strauss Hauer & Feld LLP
One Bryant Park
New York, NY 10036


E-mail address: cdoniak@akingump.com
(212) 872-1000