Vanginderen v. Cornell University et al

Filing 33

DECLARATION of Timothy Stanley in Support re 32 MOTION to Strike 25 Amended Complaint pursuant to Section 425.16 of the California Code of Civil Procedure and 31 MOTION to Strike 25 Amended Complaint pursuant to Section 425.16 of the California Code of Civil Procedure by Defendants Cornell University, Bert Deixler. (Attachments: # 1 Exhibit A)(Davidson, Clifford) Modified on 7/1/2008 - clarify text (vet).

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Vanginderen v. Cornell University et al Doc. 33 1 Bert H. Deixler, SBN 70614 3 PROSKAUER ROSE LLP 5 Facsimile: 7 8 9 10 11 12 14 15 17 18 20 21 22 23 24 25 26 27 28 8085/21177-001 Current/11447537v 2 Clifford S. Davidson, SBN 246119 4 Los Angeles, CA 90067-3206 Telephone: (310) 557-2900 (310) 557-2193 e-mail: bdeixler@proskauer.com e-mail: cdavidson@proskauer.com 2049 Century Park East, 32nd Floor 6 Attorneys for Defendant, CORNELL UNIVERSITY Lary Alan Rappaport, SBN 87614 e-mail: lrappaport@proskauer.com Clifford S. Davidson, SBN 246119 e-mail: cdavidson@proskauer.com PROSKAUER ROSE LLP 2049 Century Park East, 32nd Floor Los Angeles, CA 90067-3206 Telephone: (310) 557-2900 Facsimile: (310) 557-2193 Attorneys for Defendant, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 13 BERT DEIXLER 16 KEVIN VANGINDEREN, Plaintiff, v. 19 CORNELL UNIVERSITY, BERT DEIXLER, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08-CV-736 BTM(JMA) Hon. Barry T. Moskowitz DECLARATION OF TIMOTHY STANLEY IN SUPPORT OF CORNELL'S AND BERT DEIXLER'S SPECIAL MOTIONS TO STRIKE PLAINTIFF'S FIRST AMENDED COMPLAINT PURSUANT TO SECTION 425.16 OF THE CALIFORNIA CODE OF CIVIL PROCEDURE [Per chambers, no oral argument unless requested by the Court] [Special Motions to Strike and Davidson Declaration filed concurrently] Hearing Date: August 22, 2008 Time: 11:00 a.m. Place: Courtroom 15 Action Filed: April 8, 2008 Dockets.Justia.com 1 2 3 1. DECLARATION OF TIMOTHY STANLEY I, Timothy Stanley, declare: I am CEO and co-founder of Justia.com. I submit this Declaration in 4 support of defendant Cornell University's Special Motion to Strike Plaintiff's First 5 Amended Complaint Pursuant to Section 425.16 of the California Code of Civil 6 Procedure and defendant Bert Deixler's Special Motion to Strike Plaintiff's First 7 Amended Complaint Pursuant to Section 425.16 of the California Code of Civil 8 Procedure. I make this declaration of my own personal knowledge except where 9 otherwise stated, and if called as a witness, I could and would testify competently as 10 set forth below. 11 2. Justia.com is a website that focuses on making legal information, 12 resources and services easy to find on the Internet. The company provides Internet 13 users with free case law, codes, regulations, legal articles and legal blog databases, 14 as well as community resources. Justia works with educational, public interest and 15 other socially focused organizations to bring legal and consumer information to the 16 online community. 17 3. As part of Justia.com's aforementioned mission, Justia.com features 18 certain filings in federal court cases. One such district is the Southern District of 19 California. We tend to focus on filings related to electronic information and 20 intellectual property. We find new cases to feature based on keeping track of filings 21 on PACER. Justia.com commenced its coverage of Vanginderen v. Cornell 22 University, 07-cv-2045-BTM-JMA (the "2007 Action") based on these criteria. 23 4. Consistent with our focus on cases involving electronic information and 24 intellectual property, we decided to feature the docket of the 2007 Action. It was 25 our view that the case had important implications for the future of publicly-available 26 works and the extent to which libraries will be willing to circulate information 27 freely. 28 8085/21177-001 Current/11447537v 1 08cv736 BTM(JMA)

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