IO Group, Inc. v. Veoh Networks, Inc.

Filing 101

Declaration of Gill Sperlein in Support of Reply to Defendant's Opposition to Plaintiff's Motion for Summary Judgment 99 filed by IO Group, Inc. (Attachments: # 1 Exhibit Papa Exhibit Pages# 2 Exhibit Styn Exhibit Pages# 3 Exhibit Veoh v. UMG Complaint)(Related document(s) 99 ) (Sperlein, Dennis) (Filed on 8/21/2007) Text modified on 8/22/2007 to conform to document caption post by counsel (bw, COURT STAFF).

IO Group, Inc. v. Veoh Networks, Inc.

Doc. 101

Case 5:06-cv-03926-HRL

Document 101

Filed 08/21/2007

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GILL SPERLEIN (172887) THE LAW FIRM OF GILL SPERLEIN 584 Castro Street, Suite 849 San Francisco, California 94114 Telephone: [phone] X32 Facsimile: [phone] [e-mail] Attorney for Plaintiff IO GROUP, INC.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION IO GROUP, INC., a California corporation, Plaintiff, vs. VEOH NETWORKS, Inc., a California Corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) C-06-03926 (HRL) DECLARATION OF GILL SPERLEIN IN SUPPORT REPLY TO DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT DATE: September 4, 2007 TIME: 10:00 a.m. COURTROOM: 2

I, GILL SPERLEIN, declare: 1. I am an attorney at law licensed to practice in the State of California and attorney of

record for Plaintiff Io Group, Inc. 2. Attached hereto as Exhibit A is a true and correct copy of the relevant excerpted

pages of the deposition transcript of Defendant Veoh Network's Director of Product Development, Joseph Papa, who testified on behalf of Defendant Veoh Networks, Inc. under F.R.C.P. 30(b)(6). The excerpted deposition pages accurately reflect the questions asked and the answers given
-1SPERLEIN DECLARATION IN SUPPORT OF REPLY C-06-3926 (HRL)

Dockets.Justia.com

Case 5:06-cv-03926-HRL

Document 101

Filed 08/21/2007

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during depositions which I took on May 21 and 22, 2007, in San Diego, California. Defendant's deposition was reported by Nicole R. Harnish, RPR, CSR No. 13101. 3. Attached hereto as Exhibit B is a true and correct copy of the relevant excerpted

pages of the deposition transcript of Mr. John Styn ("Styn") a paid consultant of Defendant Veoh Network. The excerpted deposition pages accurately reflect the questions asked and the answers given during the Styn deposition which I took on May 31, in San Diego, California. Mr. Styn's deposition was reported by Regina L. Garrison, RPR, CSR No. 12921. 4. These pages supplement excerpted pages filed with Plaintiff's Motion for Summary

Judgment, and Plaintiff's Opposition to Defendant's Motion for Summary Judgment. 5. Attached here to as Exhibit C is a true and complete copy of the Complaint for

declaratory relief filed on August 9, 2007 by Defendant in the Southern District of California against UMG Recordings, Inc. et al. I downloaded this complaint directly from the Southern District's e-filing system.

Pursuant to the laws of the United States, I declare under penalty of perjury the foregoing is true and correct.

Dated: August 21, 2007

/s/ Gill Sperlein ____________________ GILL SPERLEIN, Attorney for Plaintiff

-2SPERLEIN DECLARATION IN SUPPORT OF REPLY C-06-3926 (HRL)