The Football Association Premier League Limited et al v. Youtube, Inc. et al

Filing 166

DECLARATION of Elizabeth Anne Figueira in supoport of Class Plaintiffs' Statement of Uncontroverted Material Facts in support of Their Motion For Partial Summary Judgment in Support re: 158 MOTION for Partial Summary Judgment dismissing with prejudice Defendants' First Defense asserted in Defendants' Answer to the Second Amended Class Action Complaint... Document filed by The Music Force LLC, Cal IV Entertainment, LLC, Cherry Lane Music Publishing Company, Inc., The Football Association Premier League Limited, Robert Tur, National Music Publishers' Association, The Rodgers & Hammerstein Organization, Edward B. Marks Music Company, Freddy Bienstock Music Company, Alley Music Corporation, X-Ray Dog Music, Inc., Federation Francaise De Tennis, The Scottish Premier League Limited, The Music Force Media Group LLC, Sin-Drome Records, Ltd., Murbo Music Publishing, Inc., Bourne Co.. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5, # 6 Exhibit Exhibit 6, # 7 Exhibit Exhibit 7, # 8 Exhibit Exhibit 8, # 9 Exhibit Exhibit 9, # 10 Exhibit Exhibit 10, # 11 Exhibit Exhibit 11, # 12 Exhibit Exhibit 12, # 13 Exhibit Exhibit 13, # 14 Exhibit Exhibit 14, # 15 Exhibit Exhibit 15, # 16 Exhibit Exhibit 16, # 17 Exhibit Exhibit 17, # 18 Exhibit Exhibit 18, # 19 Exhibit Exhibit 19, # 20 Exhibit Exhibit 20, # 21 Exhibit Exhibit 21, # 22 Exhibit Exhibit 22, # 23 Exhibit Exhibit 23, # 24 Exhibit Exhibit 24, # 25 Exhibit Exhibit 25, # 26 Exhibit Exhibit 26, # 27 Exhibit Exhibit 27, # 28 Exhibit Exhibit 28, # 29 Exhibit Exhibit 29, # 30 Exhibit Exhibit 30, # 31 Exhibit Exhibit 31, # 32 Exhibit Exhibit 32, # 33 Exhibit Exhibit 33, # 34 Exhibit Exhibit 34, # 35 Exhibit Exhibit 35, # 36 Exhibit Exhibit 36, # 37 Exhibit Exhibit 37, # 38 Exhibit Exhibit 38, # 39 Exhibit Exhibit 39, # 40 Exhibit Exhibit 40, # 41 Exhibit Exhibit 41, # 42 Exhibit Exhibit 42, # 43 Exhibit Exhibit 43, # 44 Exhibit Exhibit 44, # 45 Exhibit Exhibit 45, # 46 Exhibit Exhibit 46, # 47 Exhibit Exhibit 47, # 48 Exhibit Exhibit 48, # 49 Exhibit Exhibit 49, # 50 Exhibit Exhibit 50, # 51 Exhibit Exhibit 51, # 52 Exhibit Exhibit 52, # 53 Exhibit Exhibit 53, # 54 Exhibit Exhibit 54, # 55 Exhibit Exhibit 55, # 56 Exhibit Exhibit 56, # 57 Exhibit Exhibit 57, # 58 Exhibit Exhibit 58, # 59 Exhibit Exhibit 59, # 60 Exhibit Exhibit 60, # 61 Exhibit Exhibit 61, # 62 Exhibit Exhibit 62, # 63 Exhibit Exhibit 63, # 64 Exhibit Exhibit 64, # 65 Exhibit Exhibit 65, # 66 Exhibit Exhibit 66, # 67 Exhibit Exhibit 67, # 68 Exhibit Exhibit 68, # 69 Exhibit Exhibit 69, # 70 Exhibit Exhibit 70, # 71 Exhibit Exhibit 71, # 72 Exhibit Exhibit 72, # 73 Exhibit Exhibit 73, # 74 Exhibit Exhibit 74, # 75 Exhibit Exhibit 75, # 76 Exhibit Exhibit 76, # 77 Exhibit Exhibit 77, # 78 Exhibit Exhibit 78, # 79 Exhibit Exhibit 79, # 80 Exhibit Exhibit 80, # 81 Exhibit Exhibit 81, # 82 Exhibit Exhibit 82, # 83 Exhibit Exhibit 83, # 84 Exhibit Exhibit 84, # 85 Exhibit Exhibit 85, # 86 Exhibit Exhibit 86, # 87 Exhibit Exhibit 87, # 88 Exhibit Exhibit 88, # 89 Exhibit Exhibit 89, # 90 Exhibit Exhibit 90, # 91 Exhibit Exhibit 91, # 92 Exhibit Exhibit 92, # 93 Exhibit Exhibit 93, # 94 Exhibit Exhibit 94, # 95 Exhibit Exhibit 95, # 96 Exhibit Exhibit 96, # 97 Exhibit Exhibit 97, # 98 Exhibit Exhibit 97 part 2, # 99 Exhibit Exhibit 98, # 100 Exhibit Exhibit 99, # 101 Exhibit Exhibit 100, # 102 Exhibit Exhibit 101, # 103 Exhibit Exhibit 102, # 104 Exhibit Exhibit 103, # 105 Exhibit Exhibit 104, # 106 Exhibit Exhibit 105, # 107 Exhibit Exhibit 106, # 108 Exhibit Exhibit 107, # 109 Exhibit Exhibit 108, # 110 Exhibit Exhibit 109, # 111 Exhibit Exhibit 110, # 112 Exhibit Exhibit 111, # 113 Exhibit Exhibit 112, # 114 Exhibit Exhibit 113, # 115 Exhibit Exhibit 114, # 116 Exhibit Exhibit 115, # 117 Exhibit Exhibit 116, # 118 Exhibit Exhibit 117, # 119 Exhibit Exhibit 118, # 120 Exhibit Exhibit 119, # 121 Exhibit Exhibit 120, # 122 Exhibit Exhibit 121, # 123 Exhibit Exhibit 122, # 124 Exhibit Exhibit 123, # 125 Exhibit Exhibit 124, # 126 Exhibit Exhibit 125, # 127 Exhibit Exhibit 126, # 128 Exhibit Exhibit 127, # 129 Exhibit Exhibit 128, # 130 Exhibit Exhibit 129, # 131 Exhibit Exhibit 130, # 132 Exhibit Exhibit 131, # 133 Exhibit Exhibit 132, # 134 Exhibit Exhibit 133, # 135 Exhibit Exhibit 134, # 136 Exhibit Exhibit 135, # 137 Exhibit Exhibit 136, # 138 Exhibit Exhibit 137, # 139 Exhibit Exhibit 138, # 140 Exhibit Exhibit 139, # 141 Exhibit Exhibit 140, # 142 Exhibit Exhibit 141, # 143 Exhibit Exhibit 142, # 144 Exhibit Exhibit 143, # 145 Exhibit Exhibit 144, # 146 Exhibit Exhibit 145, # 147 Exhibit Exhibit 146, # 148 Exhibit Exhibit 147, # 149 Exhibit Exhibit 148, # 150 Exhibit Exhibit 149, # 151 Exhibit Exhibit 150, # 152 Exhibit Exhibit 151, # 153 Exhibit Exhibit 152, # 154 Exhibit Exhibit 153, # 155 Exhibit Exhibit 154, # 156 Exhibit Exhibit 154 Part 2, # 157 Exhibit Exhibit 154 Part 3, # 158 Exhibit Exhibit 154 Part 4, # 159 Exhibit Exhibit 155, # 160 Exhibit Exhibit156, # 161 Exhibit Exhibit 157, # 162 Exhibit Exhibit 158, # 163 Exhibit Exhibit 159, # 164 Exhibit Exhibit 160, # 165 Exhibit Exhibit 161, # 166 Exhibit Exhibit 162, # 167 Exhibit Exhibit 163, # 168 Exhibit Exhibit 164, # 169 Exhibit Exhibit 165, # 170 Exhibit Exhibit 166, # 171 Exhibit Exhibit 167, # 172 Exhibit Exhibit 168, # 173 Exhibit Exhibit 169, # 174 Exhibit Exhibit 170, # 175 Exhibit Exhibit 171, # 176 Exhibit Exhibit 172, # 177 Exhibit Exhibit 173, # 178 Exhibit Exhibit 174, # 179 Exhibit Exhibit 175, # 180 Exhibit Exhibit 176, # 181 Exhibit Exhibit 177, # 182 Exhibit Exhibit 178, # 183 Exhibit Exhibit 179, # 184 Exhibit Exhibit 180, # 185 Exhibit Exhibit 181, # 186 Exhibit Exhibit 182, # 187 Exhibit Exhibits 183 - 187, # 188 Exhibit Exhibit 188)(Figueira, Elizabeth)

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UNITED FOR THE STATES DISTRICT DISTRICT OF COURT SOUTHERN NEW YORK VIACOM INTERNATIONAL INC. COMEDY COUNTRY MUSIC PARTNERS TELEVISION INC. PARAMOUNT PICTURES and BLACK CORPORATION ENTERTAINMENT TELEVISION FigueirdDecI.Tab 17 LLC Plaintiffs vs. NO. 07CV2203 YOUTUBE INC. YOUTUBE and GOOGLE INC. LLC Defendants. THE FOOTBALL ASSOCIATION PREMIER et all LEAGUE BOURNE LIMITED CO. behalf of themselves and on others al. similarly situated Plaintiffs vs. NO. 07CV3582 YOUTUBE GOOGLE INC. INC. YOUTUBE LLC and Defendants. VIDEOTAPED SAN DEPOSITION OF MARYROSE DUNTON CALIFORNIA FRANCISCO AUGUST FRIDAY 22 2008 BY CSR JOB ANDREA LICENSE NO. M. NO. IGNACIO 9830 HOWARD CSR RPR CLR 15500 28 DUNiON 17-0002 iO 37 31741 .Pie.ase. kay. She. third irno reads Aco1nmp1ishrne.nts tO summ.arize your overa11 pe.rtcirma.oce and most 10 46 significant sccnmp1isb.meuds this year. 103750 13 37 Tio31 you 2337 ..t.esp3.ndcd. Ft nbc bra 2300 thrtugh iabt 53 oiarme of manageo egnrne core pLodunt .10 .375J 03 dvelupItePt br318nizdtidh .0h1oh tottishod .of foo.qh17 315 tOrSO. produot ma.nager.s. engineers editors. stat.emsnt erperienoed .10 t31 14 designe.rs and contecrt 10 10 .3OO8 Is that. c.or.re.oL of your duties fl 133812 10 .35ot3. frail 7001 throu.Ob the .firdt 31iart.ei Of 0.7 12 31 FrOm .5.1346 tO 2307 did manate .0 pCodu.o.t 13 10 .36.331 dVe1opIteOt Or31dnizdtidh .13hioh Oottls46d .of prddudt 14 tO 38..23 .manage.rs englnes..re. designers do and oonlent editr3rs.. 731 .10 .31..i8. Otay. 5hat the nonte.nt sditora dot 1.6 10 43 MR. tPAoiot The guestiori is vague. 10 33 47 THE 0123058 Can you be more specific 13 10 -38 48 39 10 36 40 .ME.. DESANGT18 .Q .Weli. yOu mOna 446 0.000800 10 tO38..5I editoreI Creot. .8t 21 .10 .31 55. 13 onrtain pcint Sn time .1 mmnage.d peopia 33 10 3659 we referred bo as o.oritenh e.ditars. 2.3 1.03902 10 13 3tf 03a31. .1346. to .abkipO Chat tIe pp1e rsterr31d 24 nere 308.0 duticE of the ptOp.Ie who you to .ot 350 .31j duntent editIOraf 805 Third Avenue DAVID FELDMAN WORLD WllE New York New York 10022 INC. 212705-8585 DUNTcIN 17-0003 Thhy were 40E32iS. the .ccmnojnjty.. f.Spw1itib1h far interattihq with tQ Th ey.were or.ne.ra.lly the 7jR .taw th .4 l039.21 C.cnfljn Fity. They were wa.uId. a..s.o.. .ie ..naldl.E. chocsing 3739 10391.33. videos. that. ke featured. on dhe d1euIuke oem HeMtptgt. .10 .3 3..3..3 3. 0.kay It tine. says it a.I ii01idEs g. t0 .en.ni.neera in the list tf efroloyeet that yea t3naded. En .40 2.55. lid ycu betw.een 20.0 engineers at louffuhe 10 1042 o3 and the .flwst quwrte.r cf 20.072 11 70 0107 10 73 .5 nj tay not. hith engineerd did. yOu mahO5Oi 1.3 .14 40 12 .A ThafigOcl th.O e.ndindert 2hc Bert j-f .the bore 14 10 .4.o 05IodUCt team And 40 many were tall you. there 10 10 42 22 A. cannot 17 70124 511 It it cha.nge cve.r ti.rn eHO 15 10 40 .20 /5 .. ten rOd .th.OOged. 0.tti that.. 15 .10 40.3.2 3. Wa ljeilhruh abe at thern lEO. 10 .4.03 No. 2.l 1.0 .35. Wan. Matt OiZonbne of theml 22 10 42 37 YeaS. 2.3 7114.0 E7 Brad H.eiibrun wa.a an engineer aS YouHPube 2.4 10 40 43 25 i04341 .A H.Ailhfuri 55 System .adthiniatrater at 805 Third Avenue DAVID FELDMAN WORLD W11OF New York New York 10022 INC. 212705-8585

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