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

Filing 276

DECLARATION of Elizabeth Anne Figueira, Esq. in Opposition re: 167 MOTION for Summary Judgment.. 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 189, # 2 Exhibit 190, # 3 Exhibit 191, # 4 Exhibit 192, # 5 Exhibit 193, # 6 Exhibit 194, # 7 Exhibit 195, # 8 Exhibit 196, # 9 Exhibit 197, # 10 Exhibit 198, # 11 Exhibit 199, # 12 Exhibit 200, # 13 Exhibit 201, # 14 Exhibit 202, # 15 Exhibit 203, # 16 Exhibit 204, # 17 Exhibit 205, # 18 Exhibit 206, # 19 Exhibit 207, # 20 Exhibit 208, # 21 Exhibit 209, # 22 Exhibit 210, # 23 Exhibit 211, # 24 Exhibit 212, # 25 Exhibit 213, # 26 Exhibit 214, # 27 Exhibit 215, # 28 Exhibit 216, # 29 Exhibit 217, # 30 Exhibit 218, # 31 Exhibit 219, # 32 Exhibit 220, # 33 Exhibit 221, # 34 Exhibit 222, # 35 Exhibit 223, # 36 Exhibit 224 Part 1, # 37 Exhibit 224 Part 2, # 38 Exhibit 225, # 39 Exhibit 226, # 40 Exhibit 227 Part 1, # 41 Exhibit 227 Part 2, # 42 Exhibit 227 Part 3, # 43 Exhibit 227 Part 4, # 44 Exhibit 228, # 45 Exhibit 229, # 46 Exhibit 230, # 47 Exhibit 231, # 48 Exhibit 232, # 49 Exhibit 233, # 50 Exhibit 234, # 51 Exhibit 235, # 52 Exhibit 236, # 53 Exhibit 237, # 54 Exhibit 238, # 55 Exhibit 239, # 56 Exhibit 240, # 57 Exhibit 241, # 58 Exhibit 242, # 59 Exhibit 243, # 60 Exhibit 244, # 61 Exhibit 245, # 62 Exhibit 246, # 63 Exhibit 247, # 64 Exhibit 248, # 65 Exhibit 249, # 66 Exhibit 250, # 67 Exhibit 251, # 68 Exhibit 252, # 69 Exhibit 253, # 70 Exhibit 254, # 71 Exhibit 255, # 72 Exhibit 256, # 73 Exhibit 257, # 74 Exhibit 258, # 75 Exhibit 259, # 76 Exhibit 260, # 77 Exhibit 261, # 78 Exhibit 262, # 79 Exhibit 263, # 80 Exhibit 264, # 81 Exhibit 265, # 82 Exhibit 266, # 83 Exhibit 267, # 84 Exhibit 268, # 85 Exhibit 269, # 86 Exhibit 270, # 87 Exhibit 271, # 88 Exhibit 272 Part 1, # 89 Exhibit 272-2, # 90 Exhibit 272 Part 3, # 91 Exhibit 272 Part 4, # 92 Exhibit 272 Part 5, # 93 Exhibit 272 Part 6, # 94 Exhibit 272 Part 7, # 95 Exhibit 272 Part 8, # 96 Exhibit 272 Part 9, # 97 Exhibit 272 Part 10, # 98 Exhibit 272 Part 11, # 99 Exhibit 272 Part 12, # 100 Exhibit 272 Part 13, # 101 Exhibit 272 Part 14, # 102 Exhibit 272 Part 15, # 103 Exhibit 272 Part 16, # 104 Exhibit 272 Part 17, # 105 Exhibit 272 Part 18, # 106 Exhibit 272 Part 19, # 107 Exhibit 273, # 108 Exhibit 274, # 109 Exhibit 275, # 110 Exhibit 276, # 111 Exhibit 277, # 112 Exhibit 278, # 113 Exhibit 279, # 114 Exhibit 280, # 115 Exhibit 281, # 116 Exhibit 282, # 117 Exhibit 283, # 118 Exhibit 284, # 119 Exhibit 285, # 120 Exhibit 286, # 121 Exhibit 287, # 122 Exhibit 288, # 123 Exhibit 289, # 124 Exhibit 290, # 125 Exhibit 291, # 126 Exhibit 292, # 127 Exhibit 293, # 128 Exhibit 294, # 129 Exhibit 295, # 130 Exhibit 296, # 131 Exhibit 297, # 132 Exhibit 298, # 133 Exhibit 299, # 134 Exhibit 300, # 135 Exhibit 301, # 136 Exhibit 302, # 137 Exhibit 303, # 138 Exhibit 304, # 139 Exhibit 305, # 140 Exhibit 306, # 141 Exhibit 307, # 142 Exhibit 308, # 143 Exhibit 309, # 144 Exhibit 310, # 145 Exhibit 311, # 146 Exhibit 312, # 147 Exhibit 313, # 148 Exhibit 314, # 149 Exhibit 315, # 150 Exhibit 316, # 151 Exhibit 317, # 152 Exhibit 318, # 153 Exhibit 319, # 154 Exhibit 320, # 155 Exhibit 321, # 156 Exhibit 322, # 157 Exhibit 323, # 158 Exhibit 324, # 159 Exhibit 325, # 160 Exhibit 326, # 161 Exhibit 327, # 162 Exhibit 328, # 163 Exhibit 329, # 164 Exhibit 330, # 165 Exhibit 331, # 166 Exhibit 332, # 167 Exhibit 333 Part 1, # 168 Exhibit 333 Part 2, # 169 Exhibit 334, # 170 Exhibit 335, # 171 Exhibit 336, # 172 Exhibit 337, # 173 Exhibit 338)(Figueira, Elizabeth)

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11/3/2009 Marx Henry Thb UNITED FOR THE STATES DISTRICT DISTRICT COURT OF Figueir Deci. SOUTHERN NEW YORK 324 THE FOOTBALL LEAGUE ASSOCIATION PREMIER LIMITED with its BOURNE affiliate CO. MURBO CHERRY together MUSIC LANE PUBLISHING MUSIC CAL INC. ENTERTAINMENT LOS PUBLISHING IV COMPANY INC. TUR LLC NEWS ROBERT d/b/a ANGELES SERVICE NATIONAL MUSIC THE PUBLISHERS RODGERS STAGE THREE B. ASSOCIATION HI1MERSTEIN MUSIC MARX US MUSIC ORGANIZATION INC. COMPANY EDWARD 10 MUSIC COMPANY FREDDY BIENSTOCK BIENSTOCK ALLEY d/b/a 11 PUBLISHING MUSIC CORPORATION FEDERATION MUSIC MUSIC COMPANY X-RAY DOG MUSIC DE INC. 12 FRANCAISE FORCE TENNIS GROUP THE MEDIA LLC THE 13 FORCE LTD. LLC on others and SIN-DROME of RECORDS and behalf themselves 14 15 all similarly situated Plaintiffs vs. Case No. 07CV3582 YOUTUBE Defendants. 16 YOUTUBE 17 18 19 INC. LLC and GOOGLE INC. HIGHLY 20 CONFIDENTIAL OF VIDEOTAPED PALO DEPOSITION HENRY MARX ALTO CALIFORNIA 2009 21 TUESDAY JOB NO. NOVEMBER 1941 22 23 24 25 11/3/2009 Marx Henry Henry Marx on the Palo Alto CA side of November the 2009 Channel A. lefthand page Yes. Is Q. that you Is MR. MR. Mr. GALDSTON LIDDIARD what that -- is what him Is his channel Marxs channel MR. GALDSTON Objection. Lacks foundation. 10 THE BY MR. WITNESS dont know. 11 LIDDIARD Is it 12 Q. your testimony create Mr. Marx under 13 oath that A. you That So didnt is YouTube channel 14 correct. have no idea what 15 Q. you Exhibit Number 11 16 is A. 17 That Okay. or The is correct. 18 Q. Its Music not Force its not associated label or Force 19 with you not entities or The 20 its associated with you Music 21 entities A. 22 dont Would channel Yes. know be that it is or if it isnt. created 23 Q. you surprised your someone 24 YouTube A. using email address 25 142 11/3/2009 Marx Henry Henry Marx MR. Palo Alto CA November to the form 2009 of GALDSTON Objection the BY question. MR. LIDDIARD Why would you be Q. surprised have then it A. Because they would done without my knowledge. MR. GALDSTON And it assumes facts not in evidence 10 lacks foundation. BY MR. LIDDIARD On the 11 Q. profile of and then this you was individual recall an thats 12 referred showed said grumpom earlier that you 13 you document which email 14 was A. yours Yes. GrumpoM 15 16 Q. Okay. Is there anyone in your that could have 17 created Youlube MR. channel behalf the form of the 18 GALDSTON Object to 19 question THE that. BY MR. 20 WITNESS somebody dont could know how sure. to answer 21 mean LIDDIARD Have have 22 23 Q. you ever authorized anybody to create 24 YouTube A. account No. 25 143

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