Perfect 10 Inc v. Google Inc et al

Filing 552

DECLARATION of MELANIE POBLETE (SUPPLEMENTAL DECLARATION) IN OPPOSITION TO GOOGLE'S SUPPLEMENTAL MEMORANDUM IN SUPPORT OF ITS MOTION TO COMPEL PERFECT 10 TO AFFIX DOCUMENT CONTROL NUMBERS TO ITS DOCUMENT PRODUCTION (DOCKET NO. 543); re MOTION to Compel Perfect 10, Inc. to Produce Documents, Comply with the Protective Order, and Affix Document Control Numbers to its Document Productions #407 This document is to be linked to Docket Number 543; filed by Plaintiff Perfect 10 Inc. (Mausner, Jeffrey)

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Jeffrey N. Mausner (State Bar No. 122385) Law Offices of Jeffrey N. Mausner Warner Center Towers 21800 Oxnard Street, Suite 910 Woodland Hills, California 91367-3640 Email: [e-mail] Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Perfect 10, Inc. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PERFECT 10, INC., a California corporation, Plaintiff, v. Case No. CV 04-9484 AHM (SHx) Consolidated with Case No. CV 05-4753 AHM (SHx) DISCOVERY MATTER

SUPPLEMENTAL DECLARATION GOOGLE, INC., a corporation; and OF MELANIE POBLETE IN OPPOSITION TO GOOGLE'S DOES 1 through 100, inclusive, SUPPLEMENTAL MEMORANDUM IN SUPPORT OF ITS MOTION TO Defendant. ______________________________ COMPEL PERFECT 10 TO AFFIX DOCUMENT CONTROL NUMBERS TO ITS DOCUMENT PRODUCTION AND CONSOLIDATED CASE. (DOCKET NO. 543) Before Judge Stephen J. Hillman Date: None Set (taken under submission) Time: None Set Place: Courtroom 14, Courtroom of the Honorable A. Howard Matz Discovery Cut-Off Date: None Set Pretrial Conference Date: None Set Trial Date: None Set

Supplemental Declaration of Melanie Poblete in Opposition to Google's Supplemental Memo Re Mtn to Compel P10 to Affix Document Control Numbers to Document Production

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I, Melanie Poblete, declare as follows: 1. I am employed by Perfect 10, Inc. and the Law Offices of Jeffrey N. Mausner. This declaration is meant to supplement the declaration which I submitted earlier today, to include evidence that was not available to me at the time I wrote the prior declaration (Docket No. 550). Unless otherwise stated, I have direct and personal knowledge of the facts set forth herein and, if called as a witness, could and would competently testify thereto. 2. Attached as Exhibit B is a true and correct copy of a PDF file that was contained on Exhibit 1 to the Second Supplemental Kassabian Declaration. .Exhibit 1 allegedly contains the results of Google's Bate Stamping of a small portion of Perfect 10's production, which was selected by Google. The Bates number on this document is so small that it is not readable. Furthermore, the original file, a .jpg, has been converted to a PDF, so that Perfect 10's evidence has been altered in the process. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed this 2nd day of October, 2009, in Los Angeles County, California. ___________________________ Melanie Poblete

Supplemental Declaration of Melanie Poblete in Opposition to Google's Supplemental Memo Re Mtn to Compel P10 to Affix Document Control Numbers to Document Production

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Exhibit B

P10000110