Rupa Marya v. Warner Chappell Music Inc

Filing 27

DECLARATION of Betsy C. Manifold in support of MOTION for Appointment of Counsel Wolf Haldenstein as Interim Lead Class Counsel 26 filed by Plaintiff Rupa Marya. (Attachments: # 1 Exhibit A, # 2 Declaration of Service)(Rickert, Rachele)

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8 FRANCIS M. GREGOREK (144785) BETSY C. MANIFOLD (182450) RACHELE R. RICKERT (190634) MARISA C. LIVESAY (223247) WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP 750 B Street, Suite 2770 San Diego, CA 92101 Tel.: 619/239-4599 Fax: 619/234-4599 9 Attorneys for Plaintiffs 1 2 3 4 5 6 7 10 11 12 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15 WESTERN DIVISION 16 17 18 RUPA MARYA, et al., 19 Plaintiffs, 20 v. 21 22 WARNER/CHAPPELL MUSIC, INC., 23 Defendant. 24 25 26 27 28 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Lead Case No. CV 13-04460-GHK (MRWx) DECLARATION OF BETSY C. MANIFOLD IN SUPPORT OF MOTION FOR APPOINTMENT OF WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP AS INTERIM LEAD CLASS COUNSEL Date: Time: Room: Judge: September 9, 2013 9:30 a.m. 650 Hon. George H. King, Chief Judge 1 I, Betsy C. Manifold, hereby declare as follows: 2 1. I am an attorney duly licensed to practice before all the courts of the 3 State of California and before this court. I am a partner with the law firm Wolf 4 Haldenstein Adler Freeman & Herz LLP (“Wolf Haldenstein”), counsel of record 5 for plaintiffs. I have personal knowledge of the following facts, and if called upon 6 to do so, I could and would competently testify thereto. 7 2. Working with its co-counsel, Randall S. Newman, Wolf Haldenstein 8 has dedicated considerable time and resources and performed exhaustive research to 9 independently investigate the claims asserted in this litigation. I have been 10 personally involved in the work that Wolf Haldenstein has performed to date, and I 11 have worked with several partners and associates of the firm in doing so. 12 3. Wolf Haldenstein filed a highly-detailed complaint against 13 Warner/Chappell after all the pertinent facts were uncovered. Among other things, 14 Wolf Haldenstein met several times with a leading copyright scholar; parsed 15 through scores of original copyright and assignment records; reviewed pleadings 16 from decades-old, previously-filed actions; performed an exacting review of the 17 Copyright Act of 1909 and its legislative history; visited the Library of Congress, 18 the United States Copyright Office, as well as various university libraries to collect 19 research; and reviewed hundreds of books and articles on the subject available in 20 print and online. 21 meticulously researched and persuasively written. 22 4. The original complaint that Wolf Haldenstein filed was Wolf Haldenstein has sought to coordinate the efforts of all plaintiffs’ 23 counsel in the prosecution of this litigation by moving to consolidate and coordinate 24 these actions to reduce duplication of efforts and streamline the prosecution of the 25 actions on behalf of Plaintiffs. 26 counsel in the organization of the litigation, and thus far has obtained the support of 27 Donohue Gallagher Woods, which had independently researched the validity of Wolf Haldenstein has sought to include other 28 -1- 1 Warner/Chappell’s copyright to Happy Birthday to You, to lead the prosecution for 2 Plaintiffs. 3 4 5. Attached hereto as Exhibit A, is a true and correct copy of Wolf Haldenstein’s firm resume. 5 I declare under penalty of perjury under the laws of the United States of 6 America that the foregoing is true and correct. Executed this 5th day of August 7 2013, at San Diego, California. 8 9 BETSY C MANIFOLD 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 WARNER/CHAPPELL:201 16decl 28 -2-

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