Vargas et al v. Pfizer Inc. et al

Filing 87

DECLARATION of Christopher Keegan in Support re: 85 SECOND MOTION for Summary Judgment.. Document filed by Brian Transeau. (Attachments: # 1 Exhibit Ex B# 2 Exhibit Ex C# 3 Exhibit Ex D# 4 Exhibit Ex E# 5 Exhibit Ex F# 6 Exhibit Ex G# 7 Exhibit Ex H# 8 Exhibit Ex I# 9 Exhibit Ex J part 1# 10 Exhibit Ex J part 2# 11 Exhibit Ex K# 12 Exhibit Ex L# 13 Exhibit Ex M# 14 Exhibit Ex N part 1# 15 Exhibit Ex N part 2# 16 Exhibit Ex O# 17 Exhibit Ex P# 18 Exhibit Ex Q# 19 Exhibit Ex R# 20 Exhibit Ex S# 21 Exhibit Ex T# 22 Exhibit Ex U# 23 Exhibit Ex V)(Ahrens, Julie)

Vargas et al v. Pfizer Inc. et al

Doc. 87 Att. 21

EXHIBIT T

Dockets.Justia.com

pECL"{S.ATION MICH,+EL DIMATTIS. OF
1. My nameis Michael DiMaUia,I currentlyresideat 10825RoseAve ApL 103,Los Angeles, are i CA and I am a Composer Editor (Music and Audio). The following statements made personalknowledge. basedon my ovtm 6'8T" sinceFeb.of 2001. 2. I haveknown Brian Transeau \ with BT, I am familiar with someof the allegationsof the Vargas v. 3. From my discussions Mr. Pfizer lawsuit and someof the allegations Vargasand othersare making againstBT. 4. I worked for BT at his studiofrom Feb of 2001 until April of 2006. Binary Acousticswas establishedin 2004 (from Feb 2004 on I was officially considereda Binary Acoustics employee). 5. I am familiar with how BT made someof the tracks for his Breakz from the Nu Skool for album. I wasresponsible portionsof the editing of Breakzfrom the Nu Skool.

6. I worked in BT's studio while BT continuedto program tracks for Breakz from the Nu Skool. At that time BT's studio did not havea turntableor vinyl records. In fact, BT did not havea tumtablein his studiountil yearslater whenhe beganto work asa DJ. and softwarein the creationand productionof beatsfor Breakz from 7. BT usedhis computers one the Nu Skool from scratch,including Aparthenonia of the "dirt breaks." 8. Prior to this lawsuit, I had oever heard of Ralph Vargas, Bland Ricky Roberts,or JBR Records. Likewise, I had never heard of the albums Funky Drummer Vol. 1, Funky DrummerVol. 2 or the track Bust Dat Groove. 9. I am familiar with the Reasonsoftwarepackageand know that it has many different sound libraries availablewith a large inventory of drum soundsthat can be usedto createvirtually any kind of drum rhythm and sound. I also know that you can use any custommadesounds BT with Reasonto createbeatsand loops. When using Reasono took great pride in making presetsand programmingthem using Reason(as he is always on his own sounds,kits, and the cutting edgeand makesevery effort to be original andunique). is I declareunderpenalty of perjury that the abovestatement true and correctto the best by as of my recollection signed me on22nddayof September,2006.

MichaelDiMattia