Capitol Records, LLC v. Redigi Inc.

Filing 292

REPLY DECLARATION OF GARY ADELMAN IN SUPPORT OF DEFENDANTS' MOTION FOR SUMMARY JUDGMENT. (This document was previously filed under seal in envelope #94 and unsealed on 12/20/2016.)(mro)

Gary P. Adelman, Esq.
MEISTER SEELIG & FEIN LLP
Attorneys for Defendant ReDigi Inc.
Two Grand Central Tower
140 East 45 th Street, 19th Floor
New York, New York 10017
[phone]
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

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CAPITOL RECORDS, LLC,
Civil Action No: 12 CIY 0095
(RJS)

Plaintiff,
- againstREDIGI, INC. ,
Defendant.

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REPLY DECLARATION OF GARY ADELMAN IN SUPPORT OF
DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

GARY ADELMAN, pursuant to 28 U.S.C. § 1746, declares under the penalty of perjury, as
follows:
1.

I am a partner at the law firm of Meister, Seelig & Fein LLP, attorneys for Defendant

Redigi, Inc. ("Defendant"). As such, I am fully familiar with the facts and circumstances herein
based upon my personal handling of the file.
2.

I make this declaration in support of Defendant's reply for its motion for summary

judgment granting Defendant judgment as a matter of law and dismissing all of Plaintiff Capitol
Records LLC's ("Plaintiff') claims on the grounds that the Plaintiff cannot prove the necessary
elements of all of its claims.
3.

A true and correct copy of the documents with the bate stamp numbers CAP 000384-

CAP 385, as received from Plaintiff during discovery are annexed hereto as Exhibit "1."

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4.

The reason for this declaration is solely because the pages attached as Exhibit "1"

have been designated by the Plaintiffs as "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES
ONLY (OUTSIDE COUNSEL ONLY)" and thus Mr. Lawrence Rudolph a/k/a Rogel, who has also
submitted a declaration with this reply, cannot review the Exhibit "1" and cannot declare that it is a
true and correct copy of same.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on August 24, 2012 in New York, New York.

~~ ==--GARY ADELMAN ESQ.

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