Zynga Game Network, Inc. v. Williams et al

Filing 10

Declaration of Tara D. Rose in Support of 9 MOTION for Discovery Motion for Leave to Conduct Third Party Discovery; and Memorandum of Points and Authorities filed byZynga Game Network, Inc.. (Attachments: # 1 Exhibit 1-4 of the Declaration of Tara D. Rose)(Related document(s) 9 ) (Caplan, David) (Filed on 5/12/2010)

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Larry W. McFarland (Bar No. 129668)
E-Mail: [e-mail]
Dennis Wilson (Bar No. 155407)
E-Mail: [e-mail]
David K. Caplan (Bar No. 181174)
E-Mail: [e-mail]
Tara D. Rose (Bar No. 256079)
E-Mail: [e-mail]
KEATS McFARLAND & WILSON LLP
9720 Wilshire Boulevard
Penthouse Suite
Beverly Hills, California 90212
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
ZYNGA GAME NETWORK INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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ZYNGA GAME NETWORK INC., a Delaware
Corporation,

CASE NO. CV-10:01022 JF (PVTx)

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Plaintiff,
v.
JASON WILLIAMS, an individual, LUNA
MARTINI, an individual, and JOHN DOES 1-5
D/B/A MW GROUP

DECLARATION OF TARA D. ROSE IN
SUPPORT OF PLAINTIFF ZYNGA GAME
NETWORK INC.’S MOTION FOR LEAVE
TO CONDUCT THIRD PARTY
DISCOVERY

Defendants.

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CASE NO. CV-10:01022 JF (PVTx)
DECLARATION OF TARA D. ROSE IN SUPPORT OF
PLAINTIFF ZYNGA GAME NETWORK INC.’S MOTION
FOR LEAVE TO CONDUCT THIRD PARTY DISCOVERY

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I, Tara D. Rose, declare as follows:
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I am an associate with the law firm of Keats McFarland & Wilson LLP, counsel to

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Plaintiff Zynga Game Network Inc. (“Zynga”) in this case. I am over the age of eighteen, and unless

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otherwise stated herein, I have personal knowledge of the facts stated in this declaration, and if

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

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2.

Attached hereto as Exhibit 1 is a true and correct copy of the Affidavit of Reasonable

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Diligence of Robina Alves following attempted service of the summons and complaint in this action

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on defendant Jason Williams at the address listed in the Whois database information Domain History

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for the domain name MWBLACKMARKET.COM.

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3.

Attached hereto as Exhibit 2 is a true and correct copy of the Affidavit of Reasonable

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Diligence of Arath T. Avila following attempted service of the summons and complaint in this action

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on defendant Luna Martini at the address listed in the Whois database information Domain History

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for the domain name MWFEXPRESS.COM.

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4.

Attached hereto as Exhibit 3 is a true and correct copy of the Whois database

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information Domain History for the domain name MAFIAWARSDIRECT.COM. The Whois

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database information web page for this domain name identifies the registrant as: MW Group, 2325

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Chester Boulevard, Richmond, Indiana 47374. A search for this address on the Internet indicates

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that the given address is the same as that for Indiana University East.

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5.

Attached hereto as Exhibit 4 is a true and correct copy of the webpage that appears at

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the Internet URL http://www.iue.edu/contact.php indicating the address for Indiana University East

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as 2325 Chester Boulevard, Richmond, Indiana 47374.

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

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Executed this 12th day of May, 2010 at Beverly Hills, CA.

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____________/s/____________________
Tara D. Rose
-1-

CASE NO. CV-10:01022 JF (PVTx)
DECLARATION OF TARA D. ROSE IN SUPPORT OF
PLAINTIFF ZYNGA GAME NETWORK INC.’S MOTION
FOR LEAVE TO CONDUCT THIRD PARTY DISCOVERY