Vargas et al v. Pfizer Inc. et al

Filing 146

DECLARATION of Julie A. Ahrens in Support re: 141 MOTION for Attorney Fees and Costs.. Document filed by Brian Transeau. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit H part 2# 10 Exhibit I# 11 Exhibit J# 12 Exhibit K# 13 Exhibit L# 14 Exhibit M# 15 Exhibit N# 16 Exhibit O# 17 Exhibit P# 18 Exhibit Q# 19 Exhibit R# 20 Exhibit S# 21 Exhibit T# 22 Exhibit U# 23 Exhibit V# 24 Exhibit W# 25 Exhibit X# 26 Exhibit Y# 27 Exhibit Z# 28 Exhibit Z part 2# 29 Exhibit AA# 30 Exhibit BB# 31 Exhibit CC# 32 Exhibit DD# 33 Exhibit EE# 34 Exhibit FF)(Falzone, Anthony)

Vargas et al v. Pfizer Inc. et al

Doc. 146 Att. 3

EXHIBIT C

Dockets.Justia.com

Case 1:04-cv-09772-WHP

Document 87-5

Filed 09/26/2006

Page 2 of 2

DECLARATION OF DR. RICHARD BOULANGER 1. My name is Dr. Richard Boulanger and I have been hired as an expert witness in the Vargas v. Pfizer lawsuit on behalf of Brian Transeau. 2. I have provided an expert report in this litigation where I express my opinion that Aparthenonia is not a copy of Bust Dat Groove and is, in fact, substantially different. 3. Additionally, I have provided a rebuttal report after reviewing the reports from Plaintiffs' experts as well as their depositions, which took place in August 2006. My rebuttal report also is based upon analysis of the Bust Dat Groove track from the Funky Drummer Volume II album that was provided by Plaintiffs in August 2006. 4. Based upon the work I did in my expert reports, it is clear that Bust Dat Groove is a 1 bar loop and the 1 bar loop is repeated several times. Each 1 bar loop is identical. I explain my analysis further in my rebuttal report. I declare under penalty of perjury that the above statement is true and correct to the best of my recollection as signed by me on 22nd day of September, 2006.

___________________________ Dr. Richard Boulanger