Shloss v. Sweeney et al

Filing 38

Declaration of Robert Spoo in Support of 32 Memorandum in Opposition, filed byCarol Loeb Shloss. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5)(Related document(s) 32 ) (Falzone, Anthony) (Filed on 12/15/2006)

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Shloss v. Sweeney et al Doc. 38 Case 5:06-cv-03718-JW Document 38 Filed 12/15/2006 Page 1 of 3 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 Lawrence Lessig Anthony T. Falzone (SBN 190845) David S. Olson (SBN 231675) STANFORD LAW SCHOOL CENTER FOR INTERNET AND SOCIETY 559 Nathan Abbott Way Stanford, California 94305-8610 Telephone: (650) 724-0517 Facsimile: (650) 723-4426 E-mail: falzone@stanford.edu Mark A. Lemley (SBN 155830) Matthew M. Werdegar (SBN 200470) KEKER & VAN NEST LLP 710 Sansome Street San Francisco, California 94111 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 E-mail: mwerdegar@kvn.com Bernard A. Burk (SBN 118083) Robert Spoo (pro hac vice) HOWARD RICE NEMEROVSKI CANADY FALK & RABKIN, a Professional Corporation Three Embarcadero Center, 7th Floor San Francisco, California 94111-4024 Telephone: (415) 434-1600 Facsimile: (415) 217-5910 E-mail: bburk@howardrice.com Attorneys for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION CAROL LOEB SHLOSS, Plaintiff, v. SEAN SWEENEY, in his capacity as trustee of the Estate of James Joyce, and THE ESTATE OF JAMES JOYCE Defendants. No. C 06 3718 JW HRL DECLARATION OF ROBERT SPOO IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION TO DISMISS DECLARATION OF ROBERT SPOO -1Dockets.Justia.com Case 5:06-cv-03718-JW Document 38 Filed 12/15/2006 Page 2 of 3 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 I, ROBERT SPOO, declare as follows: 1. I am an attorney with the law firm of Howard, Rice, Nemerovski, Canady, Falk & Rabkin, PC, Three Embarcadero Center, San Francisco, California. I serve as co-counsel to Plaintiff Carol Loeb Shloss ("Shloss") in this matter and have been admitted to practice before this Court pro hac vice. I make this declaration in support of Shloss's Opposition to the Defendants' Motion to Dismiss. I have personal, firsthand knowledge of the following facts, and if called as a witness, I could and would testify to them. 2. In February 2000, I received a letter from Robert (Bob) Joyce, a great-nephew of the author James Joyce and then Chief Executive of the James Joyce Centre in Dublin, Ireland--a registered charity that promotes awareness of James Joyce and his writings. Mr. Joyce's letter had been forwarded to me in New York, New York--where I was practicing as an attorney--by the English Department of the University of Tulsa, in Tulsa, Oklahoma, where I had formerly been employed as a faculty member. 3. The letter from Mr. Joyce, which is dated February 4, 2000, discusses the 1998 lawsuit filed by the James Joyce Estate in the Irish High Court against the Irish Distillers Group PLC and The Irish Times Ltd. (Case No. 1998 6968P) concerning those entities' sponsorship of a celebratory Bloomsday webcast reading from James Joyce's Ulysses. ("Bloomsday" is celebrated every year throughout the world on June 16--the day on which the fictional adventures of Ulysses and its hero, Leopold Bloom, take place.). Mr. Joyce's letter, a true and correct copy of which is attached hereto as Exhibit 1, contained certain newspaper clippings, including: (a) January 16, 2000. (b) Peter Carty, "Bloomsday," London Independent, January 12, 2000. True and "Bloomsday Blues as writs fly over Ulysses on Internet," London Independent, correct copies of these two clippings are attached hereto as Exhibits 2 and 3, respectively. 4. Attached hereto as Exhibit 3 is a true and correct copy of the June 19, 2006 New Yorker 26 article entitled Injustice Collector. 27 28 DECLARATION OF ROBERT SPOO -1- Case 5:06-cv-03718-JW Document 38 Filed 12/15/2006 Page 3 of 3

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