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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FRANCIS M. GREGOREK (144785)
[e-mail]
BETSY C. MANIFOLD (182450)
[e-mail]
RACHELE R. RICKERT (190634)
[e-mail]
MARISA C. LIVESAY (223247)
[e-mail]
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ LLP
750 B Street, Suite 2770
San Diego, CA 92101
Tel.: [phone]
Fax: [phone]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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RUPA MARYA, et al.,

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Plaintiffs,

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INC.,
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Defendant.
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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

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I, Betsy C. Manifold, hereby declare as follows:

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1.

I am an attorney duly licensed to practice before all the courts of the

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State of California and before this court. I am a partner with the law firm Wolf

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Haldenstein Adler Freeman & Herz LLP (“Wolf Haldenstein”), counsel of record

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for plaintiffs. I have personal knowledge of the following facts, and if called upon

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to do so, I could and would competently testify thereto.

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2.

Working with its co-counsel, Randall S. Newman, Wolf Haldenstein

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has dedicated considerable time and resources and performed exhaustive research to

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independently investigate the claims asserted in this litigation.

I have been

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personally involved in the work that Wolf Haldenstein has performed to date, and I

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have worked with several partners and associates of the firm in doing so.

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3.

Wolf

Haldenstein

filed

a

highly-detailed

complaint

against

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Warner/Chappell after all the pertinent facts were uncovered. Among other things,

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Wolf Haldenstein met several times with a leading copyright scholar; parsed

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through scores of original copyright and assignment records; reviewed pleadings

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from decades-old, previously-filed actions; performed an exacting review of the

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Copyright Act of 1909 and its legislative history; visited the Library of Congress,

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the United States Copyright Office, as well as various university libraries to collect

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research; and reviewed hundreds of books and articles on the subject available in

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print and online.

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meticulously researched and persuasively written.

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4.

The original complaint that Wolf Haldenstein filed was

Wolf Haldenstein has sought to coordinate the efforts of all plaintiffs’

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counsel in the prosecution of this litigation by moving to consolidate and coordinate

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these actions to reduce duplication of efforts and streamline the prosecution of the

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actions on behalf of Plaintiffs.

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counsel in the organization of the litigation, and thus far has obtained the support of

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Donohue Gallagher Woods, which had independently researched the validity of

Wolf Haldenstein has sought to include other

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Warner/Chappell’s copyright to Happy Birthday to You, to lead the prosecution for

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Plaintiffs.

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5.

Attached hereto as Exhibit A, is a true and correct copy of Wolf

Haldenstein’s firm resume.

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I declare under penalty of perjury under the laws of the United States of

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America that the foregoing is true and correct. Executed this 5th day of August

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2013, at San Diego, California.

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BETSY C MANIFOLD

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WARNER/CHAPPELL:201 16decl

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