Fairey et al v. The Associated Press

Filing 212

DECLARATION of Robyn Crowther in Support re: 210 MOTION in Limine NOTICE OF MOTION IN LIMINE NO. 4 TO EXCLUDE THE OPINION OF THE ASSOCIATED PRESS'S DESIGNATED EXPERT WILLIAM M. LANDES.. Document filed by One 3 Two, Inc.. (Attachments: # 1 Exhibit A to Crowther Declaration PART I, # 2 Exhibit A to Crowther Declaration PART II, # 3 Exhibit A to Crowther Declaration PART III, # 4 Exhibit A to Crowther Declaration PART IV, # 5 Exhibit A to Crowther Declaration Part V, # 6 Exhibit A to Crowther Declaration Part VI, # 7 Errata A to Crowther Declaration Part VII, # 8 Exhibit A to Crowther Declaration Part VIII, # 9 Exhibit A to Crowther Declaration Part IX, # 10 Exhibit B to Crowther Declaration)(Crowther, Robyn)

Fairey et al v. The Associated Press

Doc. 212

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. 4 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. 4 to Exclude the Opinion of the Associated Press's Designated Expert William M. Landes. 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 the Expert Report of

William M. Landes, an expert designated by the Associated Press, which was provided to counsel for One 3 Two on November 2, 2010.

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3.

Attached hereto as Exhibit "B" is a true and correct copy the Supplemental

Expert Report of William M. Landes, an expert designated by the Associated Press, which was provided to counsel for One 3 Two on December 1, 2010.

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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