Connectu, Inc. v. Facebook, Inc. et al

Filing 127

DECLARATION re #126 Reply to Response to Motion, by Thefacebook LLC, Facebook, Inc., Mark Zuckerberg. (Attachments: #1 Exhibit 6)(Chatterjee, I.)

Connectu, Inc. v. Facebook, Inc. et al

Doc. 127

Case 1:07-cv-10593-DPW

Document 127

Filed 10/05/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS CONNECTU, INC., CAMERON WINKLEVOSS, TYLER WINKLEVOSS, AND DIVYA NARENDRA, Plaint iff, v. FACEBOOK, INC., MARK ZUCKERBERG, EDUARDO SAVERIN, DUSTIN MOSKOVITZ, ANDREW MCCOLLUM, and FACEBOOK, LLC, Defendants.

Civil Action No. 1:07-CV-10593-DPW

DECLARATION OF MONTE COOPER IN SUPPORT OF DEFENDANTS MARK ZUCKERBERG, FACEBOOK, INC., AND THEFACEBOOK LLC'S REPLY IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS' CLAIMS FOR BREACH OF CONTRACT, BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING, AND PROMISSORY ESTOPPEL

Reply Declaration of Monte Cooper ISO Defendants' Motion for Summary Judgment
OHS West:260315445.1

Dockets.Justia.com

Case 1:07-cv-10593-DPW

Document 127

Filed 10/05/2007

Page 2 of 2

I, Monte Cooper, declare as follows: 1. I am Of Counsel at the law firm of Orrick, Herrington & Sutcliffe, counsel for

Defendants Facebook, Inc., Mark Zuckerberg, Dustin Moskovitz, Andrew McCollum, and TheFacebook, LLC in this action. I make this declaration in support of Defendants Mark Zuckerberg, Facebook, Inc., and Thefacebook LLC's reply in support of their Motion for Summary Judgment on Plaintiffs' Claims for Breach of Contract, Breach of the Covenant of Good Faith and Fair Dealing, and Promissory Estoppel. 2. Attached hereto as Exhibit 6 is a true and correct copy of excerpts from the

August 9, 2005, Deposition of ConnectU pursuant to Fed.R.Civ.P. 30(b)(6) taken in ConnectU v. Zuckerberg et al., case no. 1:04-cv-11923. I declare under penalty of perjury that the foregoing is true and correct. Executed this 5th day of October 2007, at Menlo Park, California. /s/ Monte M.F. Cooper /s/ Monte M.F. Cooper

CERTIFICATE OF SERVICE I hereby certify that this document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on October 5, 2007. Dated: October 5, 2007. Respect fully submitted, /s/ I. Neel Chatterjee /s/ I. Neel Chatterjee

-1Reply Declaration of Monte Cooper ISO Defendants' Motion for Summary Judgment
OHS West:260315445.1