Legal Class Certification Declaration

LEGAL CLASS CERTIFICATION DECLARATION

Court:    Case No.:

Plaintiff:    v.    Defendant:

I, Proposed Class Representative: , declare under penalty of perjury under the laws of the State of that the following is true and correct based upon my personal knowledge, review of relevant documents, and discussions with counsel.

RECITALS

WHEREAS, I bring this declaration in support of a motion for class certification seeking to represent the proposed class described as: ;

WHEREAS, the claims asserted on behalf of the proposed class arise from the following operative facts and alleged wrongdoing: ;

WHEREAS, I possess personal knowledge of the facts set forth herein and have reviewed documents, communications and records relevant to class issues and will supplement this declaration as necessary;

NOW THEREFORE, I state and declare as follows:

1. DEFINITIONS

For purposes of this declaration, the following definitions apply: "Class" means the group identified in the proposed_class_description field; "Relevant Time Period" means ; "Documents" means records, communications, contracts, invoices, and electronic data in my possession, custody or control that relate to the claims and issues in this action.

2. DECLARANT BACKGROUND

I am the individual identified above and have direct, personal knowledge of the facts set forth in this declaration. I acquired the information described herein through my dealings and transactions with the Defendant during the Relevant Time Period and through review of Documents provided to me or obtained by counsel.

3. FACTUAL BASIS FOR CERTIFICATION

The factual predicates supporting certification include, but are not limited to, the following:

(a) Numerosity: The proposed class is sufficiently numerous that joinder of all members is impracticable. Based on my review of sales and transaction records, I estimate the class consists of approximately members and class membership can be determined from objective criteria contained in Defendant's records or transaction histories.

(b) Commonality: The claims of class members present common questions of law and fact, including whether the Defendant (i) and (ii) . These common issues predominate over any individualized inquiries.

(c) Typicality: My claims arise from the same course of conduct and are typical of the claims of the proposed class because .

(d) Adequacy: I am willing and able to fairly and adequately protect the interests of the class. I have selected competent counsel, and I will cooperate fully with class counsel in the prosecution of this action, including producing Documents, responding to written discovery, and providing deposition testimony if requested.

4. DOCUMENTS AND EVIDENCE

I have reviewed and will make available to counsel and opposing parties the Documents in my possession identified above and any other Documents responsive to reasonable discovery requests. I further certify that the Documents I have provided to counsel are true and accurate copies of the original Documents to the best of my knowledge.

5. COOPERATION, TESTIMONY AND AVAILABILITY

I agree to cooperate with class counsel and to reasonably make myself available for deposition and trial testimony. I understand that my obligations may include responding to interrogatories, producing Documents and attending court proceedings. I confirm that I am willing to serve as a class representative and to prosecute this action on behalf of the proposed class.

I consent and agree to act as the proposed class representative and to perform the duties described above.

6. CERTIFICATION AND PENALTIES

I declare under penalty of perjury under the laws of the State of that the foregoing is true and correct. I acknowledge that knowingly making a false declaration may subject me to penalties for perjury and other sanctions under applicable law.

7. MISCELLANEOUS PROVISIONS

Governing Law: This declaration shall be interpreted in accordance with the laws of the State of without regard to conflict of law principles.

Entire Agreement: This declaration constitutes the complete and exclusive statement of the declarant's certification representations and supersedes any prior oral or written statements by the declarant on the matters addressed herein.

Severability: If any provision of this declaration is held invalid or unenforceable, the remainder of this declaration shall continue in full force and effect.

Amendments; Waiver: Any amendment or waiver of any provision of this declaration must be in writing and signed by the declarant and counsel. No waiver by any party of any breach or default shall be deemed a waiver of any preceding or subsequent breach or default.

NOTICES

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