The Authors Guild, Inc. et al v. Hathitrust et al

Filing 52

DECLARATION of Joseph Petersen in Support re: 37 MOTION for Judgment on the Pleadings.. Document filed by Hathitrust. (Attachments: # 1 Exhibit A - Objections and Responses to Requests for Admission, # 2 Exhibit B - Objections and Responses to Request for Production, # 3 Exhibit C - Objections and Responses to Requests for Admissions, # 4 Exhibit D - Objections and Responses of Plaintiff SFF, # 5 Exhibit E - Objections and Responses of Plaintiff NFFO, # 6 Exhibit F - Objections and Responses of Plaintiff Authors Licensing and Collecting)(Petersen, Joseph)

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KILPATRICK TOWNSEND & STOCKTON LLP Joseph Petersen (JP 9071) 31 West 52nd Street, 14th Floor New York, NY 10019 Telephone: (212) 775-8700 Facsimile: (212) 775-8800 Email: jpetersen@kilpatricktownsend.com Joseph M. Beck (admitted pro hac vice) W. Andrew Pequignot (admitted pro hac vice) Allison Scott Roach (admitted pro hac vice) 1100 Peachtree Street, Suite 2800 Atlanta, Georgia 30309-4530 Telephone: (404) 815-6500 Facsimile: (404) 815-6555 Email: jbeck@kilpatricktownsend.com Attorneys for Defendants UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE AUTHORS GUILD, INC., ET AL., Plaintiffs, Case No. 11 Civ. 6351 (HB) v. HATHITRUST, ET AL., Defendants. DECLARATION OF JOSEPH PETERSEN IN FURTHER SUPPORT OF DEFENDANTS’ MOTION FOR JUDGMENT ON THE PLEADINGS I, Joseph Petersen, make the following declaration: 1. I am a member of the Bar of this Court and a partner at the law firm of Kilpatrick Townsend & Stockton LLP, attorneys for the Defendants in the above-captioned action (“Defendants”). I make this Declaration, based on my own personal knowledge, in further support of Defendants’ Motion for Judgment on the Pleadings. 2. Attached as Exhibit A is a true and correct copy of Plaintiff The Authors Guild, Inc.’s Responses and Objections to Defendants’ First Set of Requests For Admission. 3. Attached as Exhibit B is a true and correct copy of Plaintiff The Authors Guild, Inc.’s Responses and Objections to Defendants’ First Set of Interrogatories and Requests for the Production of Documents. 4. Attached as Exhibit C is a true and correct copy of Plaintiff Union des Ecrivaines et des Ecrivains Quebecois’ Responses and Objections to Defendants’ First Set of Requests For Admission. 5. Attached as Exhibit D is a true and correct copy of Plaintiff Sveriges Forfattarforbund’s Responses and Objections to Defendants’ First Set of Requests For Admission. 6. Attached as Exhibit E is a true and correct copy of Plaintiff Norsk Faglitteraer Forfatter-og Oversetterforening’s Responses and Objections to Defendants’ First Set of Requests For Admission. 7. Attached as Exhibit F is a true and correct copy of Plaintiff Authors’ Licensing and Collecting Society’s Responses and Objections to Defendants’ First Set of Requests For Admission. I declare under penalty of perjury of the laws of the United States that the foregoing is true and correct. Dated: February 17, 2012 /s/ Joseph Petersen Joseph Petersen