Fairey et al v. The Associated Press

Filing 203

DECLARATION of ROBYN C. CROWTHER in Support re: 201 MOTION in Limine NOTICE OF MOTION IN LIMINE NO. 1 TO EXCLUDE ALL EVIDENCE AND TESTIMONY CONCERNING INDIRECT PROFITS.. Document filed by One 3 Two, Inc.. (Attachments: # 1 Exhibit A to Crowther Declaration, # 2 Exhibit B to Crowther Declaration)(Crowther, Robyn)

Fairey et al v. The Associated Press

Doc. 203

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SHEPARD FAIREY AND OBEY GIANT ART, INC., Plaintiffs, v. THE ASSOCIATED PRESS, Defendant and Counterclaim Plaintiff, v. SHEPARD FAIREY, OBEY GIANT ART, INC., OBEY GIANT LLC, STUDIO NUMBER ONE, INC., and ONE 3 TWO, INC. (d/b/a OBEY CLOTHING), Counterclaim Defendants. DECLARATION OF ROBYN C. CROWTHER IN SUPPORT OF COUNTERCLAIM DEFENDANT ONE 3 TWO, INC.'S MOTION IN LIMINE NO. 1 I, Robyn C. Crowther declare and state: 1. I am a shareholder in the law firm of Caldwell Leslie & Proctor, PC. I am an ECF Case No. 09-01123 (AKH)

attorney admitted to practice in the state of California and have been admitted pro hac vice to practice before this Court. I am one of the counsel of record for Counterclaim Defendant One 3 Two, Inc. d/b/a Obey Clothing ("One 3 Two") in this action and make this Declaration in support of One 3 Two's Motion in Limine No. 1 to Exclude All Evidence and Testimony Concerning Indirect Profits. I have personal knowledge of the facts stated herein, and could and would testify competently thereto if called as a witness in this matter. 2. Attached hereto as Exhibit "A" is a true and correct copy of the Preliminary

Report of Kathleen M. Kedrowski, an expert designated by the Associated Press, which was provided to counsel for One 3 Two on October 1, 2010.

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3.

Attached hereto as Exhibit "B" are true and correct copies of excerpts from the

deposition of Associated Press's designated expert, Kathleen M. Kedrowski, which was taken in this action on December 14 and 15, 2010, in New York, New York.

I declare under penalty of perjury and the laws of the United States that the foregoing is true and correct to the best of my knowledge and that this Declaration was executed on February 25, 2011, at Los Angeles, California. /s/ Robyn C. Crowther ROBYN C. CROWTHER

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