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

Filing 107

Supplemental Declaration of Gill Sperlein in Support of Plaintiff's Motion for Summary Judgment 78 filed by IO Group, Inc. (Attachments: # 1 Exhibit Papa Deposition Excerpts# 2 Exhibit Dunning Deposition Excerpts# 3 Errata Shapiro Deposition Excerpts# 4 Exhibit Styn Deposition Excerpts# 5 Exhibit Bilger Deposition Excerpts)(Related document(s) 78 ) (Sperlein, Dennis) (Filed on 9/5/2007) Text modified on 9/5/2007 to conform to document caption post by cousnel (bw, COURT STAFF).

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

Doc. 107

Case 5:06-cv-03926-HRL

Document 107

Filed 09/05/2007

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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) SUPPLEMENTAL DECLARATION OF GILL SPERLEIN IN SUPPORT OF PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT ON LIABILITY

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. matter. Io Group previously submitted excerpted pages from various depositions in this

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Dockets.Justia.com

Case 5:06-cv-03926-HRL

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3.

At the Summary Judgment Motion hearing on September 4, 2007, the Court

informed Io Group, Inc. that some deposition pages references in Io's papers were not included in earlier submissions and instructed Io to file this supplemental Declaration with the missing pages. 4. 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 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. 5. Attached hereto as Exhibit B is a true and correct copy of the relevant excerpted

pages of the deposition transcript of Defendant Veoh Network's Chief Scientific Officer, Dr. Ted Dunning ("Dunning"). The excerpted deposition pages accurately reflect the questions asked and the answers given during the Dunning deposition which I took on March 16, 2007, in San Diego, California. Dr. Dunning's deposition was reported by Rita Burgess, RPR, CSR No. 8374. 6. Attached hereto as Exhibit C is a true and correct copy of the relevant excerpted

pages of the deposition transcript of Defendant Veoh Network's Chief Executive Officer, Dmitry Shapiro ("Shapiro") who testified on behalf of Veoh Networks under F.R.C.P. 30(b)(6). The excerpted deposition pages accurately reflect the questions asked and the answers given during the Shapiro deposition which I took on May 21, in San Diego, California. Mr. Shapiro's deposition was reported by Nicole R. Harnish, RPR, CSR No. 13101. 7. Attached hereto as Exhibit D 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

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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. 8. Attached hereto as Exhibit E is a true and correct copy of the relevant excerpted

pages of the deposition transcript of Mr. Arthur Bilger ("Bilger"), who testified on behalf of Shelter Capital Partners, LLC, under F.R.C.P. 30(b)(6). The excerpted deposition pages accurately reflect the questions asked and the answers given during the Bilger deposition which I took on June 5, 2007, in El Segundo, California. Mr. Bilger's deposition was reported by Chia Mei Jui, RPR, CSR No. 3287.

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

Dated: September 5, 2007

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

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