FOX TELEVISION STATIONS, INC., et al v. AEREOKILLER LLC, et al

Filing 52

Emergency MOTION to Modify THE SCOPE OF THE INJUNCTION by FILMON X, LLC, FILMON.COM, INC,, FILMON.TV NETWORKS, INC.,, FILMON.TV, INC. (Attachments: # 1 Request for Judicial Notice, # 2 Declaration of Ryan Baker, # 3 Exhibit to Baker Declaration)(Baker, Ryan)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
_______________________________________
CIVIL ACTION NO. 1:13-cv-00758 (RMC)

FOX TELEVISION STATIONS, INC., et al.,
Plaintiffs/Counter-Defendants,
v.

Civil No. 1:13-cv-00758 (RMC)

FILMON X, LLC, et al.,
Defendants/Counter-Plaintiffs.
_______________________________________

DECLARATION OF RYAN G. BAKER IN SUPPORT OF
EMERGENCY MOTION

I, Ryan G. Baker, declare:
1.

I am an attorney admitted to practice in the State of California, and a partner at

Baker Marquart LLP. I represent the defendants in this action.
2.

I submit this declaration in support of Defendants’ Emergency Motion to Modify

the Scope of the Injunction. I have personal knowledge of the facts set forth herein and, if called
as a witness, I could and would testify competently thereto.
3.

On October 10, 2013, I gave notice pursuant to Local Rule 7(m) to plaintiffs’

counsel that Defendants planned to file this emergency motion to modify the geographic scope of
the injunctive relief .
4.

Also on October 10, 2013, plaintiffs’ counsel informed me that plaintiffs will

oppose Defendants’ motion. Attached as Exhibit 1 is a true and correct copy of the meet and
confer correspondence between myself and counsel for the plaintiffs on the subject of this
emergency motion.
5.

Defendants have brought these motions at the first available opportunity.
1

DECLARATION OF RYAN G. BAKER

I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed on October 10, 2013 at Los Angeles, California.

By

Ryan G. Baker

2

DECLARATION OF RYAN G. BAKER