Louis Vuitton Malletier, S.A. v. Akanoc Solutions, Inc. et al

Filing 177

Declaration of Christopher Lai in Support of 175 MOTION for Leave to File DEFENDANTS' MOTION FOR ADMINISTRATIVE RELIEF FOR LEAVE TO FILE MOTIONS IN LIMINE #13, #14 AND #15 filed byAkanoc Solutions, Inc., Steven Chen, Managed Solutions Group, Inc.. (Attachments: # 1 Exhibit 1595 to Lai Declaration)(Related document(s) 175 ) (Lowe, James) (Filed on 7/6/2009)

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GAUNTLETT & ASSOCIATES David A. Gauntlett (SBN 96399) James A. Lowe (SBN 214383) Brian S. Edwards (SBN 166258) Christopher Lai (SBN 249425) 18400 Von Karman, Suite 300 Irvine, California 92612 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] Attorneys for Defendants Akanoc Solutions, Inc., Managed Solutions Group, Inc. and Steve Chen

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

LOUIS VUITTON MALLETIER, S.A., Plaintiff, vs. AKANOC SOLUTIONS, INC., et al., Defendants.

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Case No.: C 07-3952 JW (HRL) DECLARATION OF JAMES A. LOWE IN SUPPORT OF DEFENDANTS' MOTION FOR ADMINISTRATIVE RELIEF FOR LEAVE TO FILE MOTIONS IN LIMINE #13, #14 AND #15

165449.1-10562-002-7/2/2009

DECL. OFJAMES A. LOWE IN SUPPORT OF DEFENDANTS' MOTION FOR ADMINISTRATIVE RELIEF FOR LEAVE TO FILE MOTIONS IN LIMINE #13, #14, AND #15 ­ C 07-3952 JW (HRL)

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I, JAMES A. LOWE, declare: 1. I am an attorney duly licensed to practice law before this Court and am a partner in

the law firm of Gauntlett & Associates, counsel of record for defendants Managed Solutions Group, Inc., Akanoc Solutions, Inc. and Steve Chen ("Defendants"). 2. I have personal knowledge of the facts stated in this Declaration and could testify

competently to them if called upon as a witness. 3. This declaration is submitted in support of Defendants' Motion for Administrative

Relief for Leave to File its Motions in Limine #13, #14 and #15. 4. On June 27, 2009, I personally took the deposition of Michael Wilson, Vuitton's

expert witness. 5. At his deposition, Mr. Wilson indicated, for the first time, that he intended to provide

further testimony, at an unspecified later date, about actions that he planned to take with regard to his attempts to "rebuild" Internet domains.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed at Irvine, California on July 2, 2009.

s/ James A. Lowe James A. Lowe

165449.1-10562-002-7/2/2009

DECL. OF JAMES A. LOWE IN SUPPORT OF DEFENDANTS' MOTION FOR ADMINISTRATIVE RELIEF FOR LEAVE TO FILE MOTIONS IN LIMINE #13, #14, AND #15 ­ C 07-3952 JW (HRL)