Virgin Records America, Inc v. Thomas

Filing 51

DECLARATION of Brian N. Toder in Opposition to 50 Memorandum in Opposition to Motion filed by Jammie Thomas. (Attachments: # 1 Exhibit(s) 1 thru 20)(Toder, Brian) Modified on 9/7/2007 (jc).

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Virgin Records America, Inc v. Thomas Doc. 51 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA VIRGIN RECORDS AMERICA, INC., a California corporation; CAPITOL RECORDS INC., a Delaware corporation; SONY BMG MUSIC ENTERTAINMENT, a Delaware general partnership; ARISTA RECORDS LLC, a Delaware limited liability company; INTERSCOPE RECORDS, a California general partnership; WARNER BROS. RECORDS INC., a Delaware corporation; and UMG RECORDINGS, INC., a Delaware corporation, Plaintiffs, v. Jammie Thomas, Defendant. Case No. 06-cv-1497 (MJD/RLE) DECLARATION OF BRIAN N. TODER Brian N. Toder declares as follows: 1. 2. I am counsel for Defendant, Jammie Thomas, in the above-entitled matter. This Declaration is offered in opposition to Plaintiffs' Motion to Enforce Stipulation re Specific Facts or, in the Alternative, for Leave to File Dispositive Motion as to Such Facts. [Dkt. 41] 3. Attached hereto are true and correct photocopies of the following: Exhibit 1 ­ August 6, 2007 email from Plaintiffs to Defendant's counsel transmitting proposed Stipulation without "Schedule 1." 1 Dockets.Justia.com Exhibit 2 ­ August 9, 2007 email from Plaintiffs to Defendant's counsel. Exhibit 3 ­ August 17, 2007 email from Plaintiffs to Defendant's counsel without attachments. Exhibit 4 ­ August 17, 2007 email from Plaintiffs to Defendant's counsel. Exhibit 5 ­ August 21, 2007 email from Defendant's counsel to Plaintiffs' counsel. Exhibit 6 ­ Schedule 1. Exhibit 7 ­ Certificate of Registration of USCO Serial #SR 85-358. Exhibit 8 - Certificate of Registration of USCO Serial #SR 141-365. Exhibit 9 - Certificate of Registration of USCO Serial #SR 69-529. Exhibit 10 - Certificate of Registration of USCO Serial #SR 43-223. Exhibit 11 - Certificate of Registration of USCO Serial #SR 83-468. Exhibit 12 - Certificate of Registration of USCO Serial #SR 153-061. Exhibit 13 - Certificate of Registration of USCO Serial #SR 90-420. Exhibit 14 - Certificate of Registration of USCO Serial #SR 256-807. Exhibit 15 - Certificate of Registration of USCO Serial #SR 58-024. Exhibit 16 - Certificate of Registration of USCO Serial #SR 209-823. Exhibit 17 - Certificate of Registration of USCO Serial #SR 134-647. Exhibit 18 - Certificate of Registration of USCO Serial #SR 30-088. Exhibit 19 - Certificate of Registration of USCO Serial #SR 174-392. Exhibit 20 - Certificate of Registration of USCO Serial #SR 241-879. 2 I declare under penalty of perjury under the laws of the United States of America, particularly 28 U.S.C. § 1746, that the foregoing is true and correct and that this Declaration was executed on the 6th day of September, 2007 in Minneapolis, Minnesota. Dated: September 6, 2007 s/ Brian N. Toder Brian N. Toder, #17869X Chestnut & Cambronne, P.A. 3700 Campbell Mithun Tower 222 South Ninth Street Minneapolis, MN 55402 (651) 653-0990 Attorneys for Defendant 3

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