Page 82 - RICHERT VS. SORKIN THEFT OF THE AMERICAN PRESIDENT AND THE WEST WING

Locnl8I9, Teamsters,169 F.3d182,784 (2'd Cir.1999) Plaintiffs aPpear to argue, without legal citation, that the rule only applies to the authorized acts of union agents. Even if that were tru€, the Guild agrees that Burmester's actions in administering the credit arbitration for Tle American President were authodzed and within the scope of her employment. Plaintiffs have not alleged othcrwise.
CONCLUSION
For the foregoing reasons, the Amended Crmplairl should be disnissed with prejudice
as against the WGA defeldants. Dated: Pasadena, California
October 9, 2002
Resp€ctfuly submitted,
Fmnklin K. Moss (FM 9161) Gillian Costello (GC 015l) SPIVAK, LIPTON, WATANABE,
SPryAK & MOSS LLP 1700 Broadway
New York, New York 10019 Qr2) 76s-21ffi
ROTHNER, SECALL & GREENSTONE
Anthony R. Segall (ARS 9819) ROTTINER, SEGALL &
510 So. Marengo Ave. Pasadena, CA 91101
(626) 796-7 sss
Attomeys for Defendants Writ€rs Guild of Ame rica, west, Inc. and Sally Burmester
10