In Re Sony PS3 "Other OS" Litigation

Filing 31

Declaration of DEBORAH E. MCCRIMMON in Support of 30 Statement, OF SUPPORT OF ADMINISTRATIVE MOTIONS TO RELATE VENTURA, BAKER, AND DENSMORE CASES filed bySony Computer Entertainment America Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)(Related document(s) 30 ) (McCrimmon, Deborah) (Filed on 5/19/2010)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DLA PIPER LLP (US) S A N FR A N C I S C O LUANNE SACKS, Bar No. 120811 luanne.sacks@dlapiper.com GEORGE J. GIGOUNAS, Bar No. 209334 george.gigounas@dlapiper.com CARTER W. OTT, Bar No. 221660 carter.ott@dlapiper.com DEBORAH E. MCCRIMMON, Bar No. 229769 deborah.mccrimmon@dlapiper.com DLA PIPER LLP (US) 555 Mission Street, Suite 2400 San Francisco, CA 94105 Tel: 415.836.2500 Fax: 415.836.2501 Attorneys for Defendant SONY COMPUTER ENTERTAINMENT AMERICA LLC UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ANTHONY VENTURA, on behalf of himself and all others similarly situated, Plaintiff, v. SONY COMPUTER ENTERTAINMENT AMERICA INC., Defendant. CASE NO. 3:10-CV-01811-RS DECLARATION OF DEBORAH E. MCCRIMMON IN SUPPORT OF DEFENDANT'S STATEMENT OF SUPPORT OF ADMINISTRATIVE MOTIONS TO RELATE VENTURA, BAKER, AND DENSMORE CASES (CIVIL LOCAL RULE 3-12) I, DEBORAH E. MCCRIMMON, hereby declare as follows: 1. I am an attorney admitted to practice law in the State of California and authorized to practice before this Court. I am an associate with the law firm of DLA Piper LLP (US), counsel for Defendant Sony Computer Entertainment America LLC, erroneously sued as Sony Computer Entertainment America Inc., ("SCEA"). As such, I have personal knowledge of the matters contained herein and, if called as a witness, I could and would competently testify to the following. -1WEST\21971355.3 MCCRIMMON DECL. ISO DEFENDANT'S STMT. OF SUPPORT OF ADMIN. MOTIONS CASE NO. 3:10-CV-01811-RS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DLA PIPER LLP (US) S A N FR A N C I S C O 2. This declaration is submitted in support of SCEA's Statement of Support of Administrative Motions to Relate Ventura, Baker, and Densmore Cases. 3. Attached hereto as Exhibit A is a true and correct copy of the Class Action Complaint filed in Ventura, et al. v. Sony Computer Entertainment America Inc., Case No. 3:10cv-01811 ("Ventura") on April 27, 2010 in the Northern District of California. 4. Attached hereto as Exhibit B is a true and correct copy of the Class Action Complaint filed in Densmore, et al. v. Sony Computer Entertainment America Inc., Case No. 3:10-cv-01945 ("Densmore") on May 5, 2010 in the Northern District of California. 5. Attached hereto as Exhibit C is a true and correct copy of the Class Action Complaint filed in Baker, et al. v. Sony Computer Entertainment America LLC, Case No. 3:10-cv01897 ("Baker") on April 30, 2010 in the Northern District of California. 6. Attached hereto as Exhibit D is a true and correct copy of the Class Action Complaint filed in Wright, et al. v. Sony Computer Entertainment America Inc., et al., Case No. 3:10-cv-01975 ("Wright") on May 6, 2010 in the Northern District of California. 7. Attached hereto as Exhibit E is a true and correct copy of the Notice of Related Cases filed by plaintiff Baker in Baker on April 30, 2010. 8. Attached hereto as Exhibit F is a true and correct copy of the Notice of Related Cases filed by plaintiff Wright in Wright on May 6, 2010. 9. Attached hereto as Exhibit G is a true and correct copy of the Administrative Motion to Relate Baker and Ventura filed by plaintiff Baker in Ventura on May 14, 2010. 10. Attached hereto as Exhibit H is a true and correct copy of the Administrative Motion to Consider Whether Cases Should be Related filed by plaintiff Densmore in Ventura on May 17, 2010. 11. Attached hereto as Exhibit I is a true and correct copy of plaintiff Ventura's Notice of Motion and Memorandum of Points and Authorities in support of his Motion for Order: (1) Finding Cases Related; (2) Consolidating Related Cases; (3) Appointing Interim Co-Lead Counsel, and (4) Setting Case Management Dates filed in Ventura on May 17, 2010. -2WEST\21971355.3 MCCRIMMON DECL. ISO DEFENDANT'S STMT. OF SUPPORT OF ADMIN. MOTIONS CASE NO. 3:10-CV-01811-RS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DLA PIPER LLP (US) S A N FR A N C I S C O I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of my knowledge, and that this Declaration is executed on May 19, 2010, at San Francisco, California. /s/ Deborah E. McCrimmon DEBORAH E. MCCRIMMON -3WEST\21971355.3 MCCRIMMON DECL. ISO DEFENDANT'S STMT. OF SUPPORT OF ADMIN. MOTIONS CASE NO. 3:10-CV-01811-RS