IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

SIGNODE INDUSTRIAL GROUP LLC, 

 Plaintiff, 

 v. 

SAMUEL, SON & CO., LTD. and SAMUEL, SON 

& CO. (USA) INC. d/b/a SAMUEL PACKAGING 

SYSTEMS GROUP and SAMUEL STRAPPING 

SYSTEMS, 

 Defendants. 

Civil Action No. 2:24-cv-00080-JRG 

DECLARATION OF GABRIELLA SALEK IN SUPPORT OF DEFENDANTS SAMUEL, 

SON & CO., LTD.’S AND SAMUEL, SON & CO. (USA) INC.’S MOTION TO 

TRANSFER TO THE NORTHERN DISTRICT OF ILLINOIS PURSUANT TO 28 U.S.C. 

§ 1404(a) 

 

 

Case 2:24-cv-00080-JRG Document 52-1 Filed 09/18/24 Page 1 of 3 PageID #: 962
1 

I, Gabriella Salek, declare as follows: 

1. I am an associate at the law firm of Foley & Lardner LLP and counsel of record for 

Samuel, Son & Co., Ltd. and Samuel, Son & Co. (USA) Inc. (“Samuel”) in the above-captioned 

case. I am submitting this declaration in support of Samuel’s Reply in Support of its Motion to 

Transfer to the Northern District of Illinois Pursuant to 28 U.S.C. § 1404(a). 

2. Attached as Exhibit 1 is a true and correct copy of Signode Industrial Group LLC’s 

(“Signode”) Document Subpoena to DiMonte Group, Inc. (“DiMonte”), emailed to counsel for 

Samuel on September 6, 2024, seeking documents relating to product features (see, e.g., topic #1). 

And 173 documents DiMonte documents have already been produced in this case. 

3. Attached as Exhibits 2 and 3 are true and correct copies from the Hilton website 

and Google Maps, showing that a four-night stay for a single king bed nonsmoking room during 

the second full week of December 2024 at the Hampton Inn located approximately 0.7 miles from 

the N.D. Ill. courthouse costs $93 per night, and showing that the Hampton Inn located 4.2 miles 

from the Eastern District of Texas courthouse costs $110 per night. Trial is currently scheduled to 

begin the second full week of December 2025, but hotel rates are not yet available for that period, 

so the same week of December 2024 was used as representative. These exhibits show that a 

comparable room for the Hampton Inn in Chicago costs (including taxes) approximately 12% less 

than the Hampton Inn in Marshall, and is over three miles closer to the N.D. Ill. federal courthouse. 

4. Attached as Exhibits 4, 5, and 6 are true and correct copies of Google Maps, 

showing that travel on a non-stop flight from Zurich, Switzerland to Chicago’s airport takes less 

than 10 hours, with an additional 43 minutes of drive time to the N.D. Ill. courthouse. Travel from 

Zurich, Switzerland to Dallas’ airport takes approximately 13 hours, with an additional drive time 

of over 2.5 hours to the Eastern District of Texas courthouse. Travel from Zurich, Switzerland to 

Case 2:24-cv-00080-JRG Document 52-1 Filed 09/18/24 Page 2 of 3 PageID #: 963
2 

the Shreveport, LA airport takes approximately 15 hours, with an additional drive time of 38 

minutes to the Eastern District of Texas courthouse. 

5. Attached as Exhibit 7 is a true and correct copy of a screenshot of a report from 

Docket Navigator for the Northern District of Illinois, showing that for the pre-pandemic period 

between 2015-2020, the average time-to-trial for patent cases was 37 months. Attached as Exhibits 

8 and 9 are true and correct copies of the first General Order for the N.D. Ill. Court’s continuance 

of civil jury trials dated March 12, 2020, stating that all civil jury trials scheduled to begin before 

April 3, 2020 were continued, and the final – tenth amended General Order for the N.D. Ill. Court’s 

suspension of civil jury trials dated February 12, 2021, stating that all civil jury trials would 

continue to be suspended until April 5, 2021. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on: September 18, 2024 

 /s/ Gabriella M. Salek 

 Gabriella M. Salek 

Case 2:24-cv-00080-JRG Document 52-1 Filed 09/18/24 Page 3 of 3 PageID #: 964