The Authors Guild, Inc. et al v. Hathitrust et al

Filing 52

DECLARATION of Joseph Petersen in Support re: 37 MOTION for Judgment on the Pleadings.. Document filed by Hathitrust. (Attachments: # 1 Exhibit A - Objections and Responses to Requests for Admission, # 2 Exhibit B - Objections and Responses to Request for Production, # 3 Exhibit C - Objections and Responses to Requests for Admissions, # 4 Exhibit D - Objections and Responses of Plaintiff SFF, # 5 Exhibit E - Objections and Responses of Plaintiff NFFO, # 6 Exhibit F - Objections and Responses of Plaintiff Authors Licensing and Collecting)(Petersen, Joseph)

KILPATRICK TOWNSEND & STOCKTON LLP
Joseph Petersen (JP 9071)
31 West 52nd Street, 14th Floor
New York, NY 10019
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Joseph M. Beck (admitted pro hac vice)
W. Andrew Pequignot (admitted pro hac vice)
Allison Scott Roach (admitted pro hac vice)
1100 Peachtree Street, Suite 2800
Atlanta, Georgia 30309-4530
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendants

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE AUTHORS GUILD, INC., ET AL.,
Plaintiffs,

Case No. 11 Civ. 6351 (HB)

v.
HATHITRUST, ET AL.,
Defendants.

DECLARATION OF JOSEPH PETERSEN IN FURTHER SUPPORT OF
DEFENDANTS’ MOTION FOR JUDGMENT ON THE PLEADINGS

I, Joseph Petersen, make the following declaration:
1.

I am a member of the Bar of this Court and a partner at the law firm of Kilpatrick

Townsend & Stockton LLP, attorneys for the Defendants in the above-captioned action
(“Defendants”). I make this Declaration, based on my own personal knowledge, in further
support of Defendants’ Motion for Judgment on the Pleadings.
2.

Attached as Exhibit A is a true and correct copy of Plaintiff The Authors Guild,

Inc.’s Responses and Objections to Defendants’ First Set of Requests For Admission.
3.

Attached as Exhibit B is a true and correct copy of Plaintiff The Authors Guild,

Inc.’s Responses and Objections to Defendants’ First Set of Interrogatories and Requests for the
Production of Documents.
4.

Attached as Exhibit C is a true and correct copy of Plaintiff Union des Ecrivaines

et des Ecrivains Quebecois’ Responses and Objections to Defendants’ First Set of Requests For
Admission.
5.

Attached as Exhibit D is a true and correct copy of Plaintiff Sveriges

Forfattarforbund’s Responses and Objections to Defendants’ First Set of Requests For
Admission.
6.

Attached as Exhibit E is a true and correct copy of Plaintiff Norsk Faglitteraer

Forfatter-og Oversetterforening’s Responses and Objections to Defendants’ First Set of Requests
For Admission.
7.

Attached as Exhibit F is a true and correct copy of Plaintiff Authors’ Licensing

and Collecting Society’s Responses and Objections to Defendants’ First Set of Requests For
Admission.

I declare under penalty of perjury of the laws of the United States that the foregoing is
true and correct.
Dated: February 17, 2012

/s/ Joseph Petersen
Joseph Petersen