Doe 1 et al v. Ciolli et al

Filing 86

AFFIDAVIT of Benjamin Berkowitz. Signed By Benjamin Berkowitz filed by Doe 1, Doe 2. (Attachments: # 1 Affidavit)(Berkowitz, Benjamin) Modified on 11/26/2008 to correct text (Grady, B.). (Additional attachment(s) added on 12/1/2008: # 2 Certificate of Service) (Grady, B.).

UNITED STATES DISTRICT COURT DISTRICT OF CONNCTICUT
DOE I, and DOE II, Plaintiffs,
v.
November 25,2008

Case No. 3:07CV00909 (CFD)

Matthew C. Ryan, a.k.a. ":D"; and individuals using the following pseudonyms: pauliewalnuts; neoprag; STANORDtroll; lkjhgf; yalelaw; Spany; ylsdooder; HI; David Car; Cheese Eating Surender Monkey; A horse walks into a bar; The Ayatollah ofRock-nRollah; DRACULA; Sleazy Z; Ar Gold; Ugly Women; playboytroll; Dean_Harold _ Koh; krOnz; reminderdood; r(êygold; who is; Joel Schellhammer; Prof. Brian Leiter; hitlerhitlerhitler; lonelyvirgin; Patrick Zeke ':patrck8765(êhotmai1.com~; Patrck Bateman
.:batemanls08(êhotmai1.com~; (DOE I) got a
157 LSAT; azn, azn, azn; Dirty

Nigger; leaf; t14

guer; kibitzer; yalels2009; AK47,

Defendants.

DECLARTION OF BENJAMIN BERKOWITZ
I, Benjamin Berkowitz, declare as follows:
1. I am duly licensed to practice law in the State of California and am an associate
with the law firm of

Keker & Van Nest, LLP, counsel for plaintiffs DOE I andDOE II in the

above-captioned proceeding. I am admitted pro hac vice to appear before this Cour in this
action. I have knowledge of

the facts set forth herein, and if called to testify as a witness thereto,

could do so competently under oath.
2. On July 24, 2008, Plaintiffs deposed Matthew Ryan in accordance with this
Cour's order permitting them to engage in expedited discovery to uncover the identities of

the

defendants in this case.
3.

Attached hereto as Exhibit A is a true and correct copy of excerpts from the

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transcript ofthe deposition of defendant Matthew Ryan, dated July 24, 2008. Exhibit A has
been redacted to replace plaintiffs name with DOE I and co-plaintiffs name with DOE II, in
accordance with this Cour's June 18, 2007 Order granting Plaintiffs' motion to proceed
anonymously.

I declare under penalty of perjur that the foregoing is true and correct. I executed this
Declaration this 25 day of

November, 2008 in San Francisco, CA.
Isl Ben;amin Berkowitz

BENJAMIN BERKOWITZ

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