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

Filing 274

DECLARATION of Elizabeth Anne Figueira, Esq. 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., Stage Three Music (US), Inc., Bourne Co.. (Attachments: # 1 Exhibit 15, # 2 Exhibit 16, # 3 Exhibit 21, # 4 Exhibit 22, # 5 Exhibit 24, # 6 Exhibit 41, # 7 Exhibit 54, # 8 Exhibit 55, # 9 Exhibit 56, # 10 Exhibit 57, # 11 Exhibit 58, # 12 Exhibit 72, # 13 Exhibit 78 Part 1, # 14 Exhibit 78 Part 2, # 15 Exhibit 82, # 16 Exhibit 129, # 17 Exhibit 131, # 18 Exhibit 132, # 19 Exhibit 162, # 20 Exhibit 179)(Figueira, Elizabeth)

1/8/2010

Kacholia

Varun

OUTSIDE HIGHLY CONFIDENTIAL COUNSELS EYES ONLY
--

UNITED
FOR THE

STATES

DISTRICT DISTRICT
EYES

COURT OF

SOUTHERN ATTORNEYS

N$W

YORK

ONLY

VIACOM

INTERNATIONAL COUNTRY

INC.

COMEDY
Figueird Den. Tab 57

PARTNERS
TELEVISION PICTURES

MUSIC
PARA1vIOUNT

INC.

CORPORATION

and

BLACK

ENTERTAINMENT

TELEVISION

LLC

Plaintiffs
vs. Case No

l07CV02103

YOUTUBE
and

INC.

YOUTUBE

LLC

000GLE

INC.
Defendants.

__________________
THE
10

FOOTBALL

ASSOCIATION BOURNE

PREMIER
et all
al.

LEAGUE
on

LIMITED
of

CO.
and

behalf

themselves

11

others

similarly situated Plaintiffs

12

vs.

Case

No.

07CV03582

YOUTUBE
13

INC. INC.

YOUTUBE

LLC

and

GOOGLE

Defendants.
14 15 16 17 18 19

________________________________________

Deposition
Palo

of

VARUN

KACHOLIA

Alto

California
2010

Friday January

20 21
22 23 24

JOB

NO.

18544

25

1/8/2010

Kacholia

Varun

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RUBIN

165