White et al v. West Publishing Corporation et al

Filing 71

DECLARATION of James Hough in Opposition re: 53 MOTION for Summary Judgment (Notice of Motion Previously Filed).. Document filed by Reed Elsevier Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Hough, James)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK EDWARD L. WHITE, P.C., Plaintiff, ECF CASE v. WEST PUBLISHING CORPORATION d/b/a “West,” and REED ELSEVIER INC. d/b/a LexisNexis, Civil Action No. 12-CV-1340 (JSR) Defendants. DECLARATION OF JAMES HOUGH IN SUPPORT OF DEFENDANT REED ELSEVIER INC.’S OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT ny-1062594 I, James E. Hough, hereby declare: 1. I am a member of the Bar of the State of New York and am admitted to practice before this Court. I am a partner in the law firm of Morrison & Foerster LLP, counsel for Defendant LexisNexis, a division of Reed Elsevier Inc. (“Lexis”), in this action. I submit this Declaration in support of Defendant Reed Elsevier Inc.’s Opposition to Plaintiff’s Motion for Summary Judgment. I have personal knowledge of the following facts. 2. Attached hereto as Exhibit A is a true and correct copy of relevant excerpts from the transcript of the deposition of Edward L. White in this action, dated August 30, 2012. 3. Attached hereto as Exhibit B is a true and correct copy of the May 20, 2010 Certificate of Registration with the United States Copyright Office for Plaintiff’s Combined Motion For Summary Judgment For Plaintiffs, Beer And Ramsey, And Brief In Support, bearing production numbers P00119-120 and included as Exhibit 5 to the deposition of Mr. White in this action. 4. Attached hereto as Exhibit C is a true and correct copy of the May 21, 2010 Certificate of Registration with the United States Copyright Office for Plaintiff’s Motion In Limine, bearing production numbers P00054-55 and included as Exhibit 6 to the deposition of Mr. White in this action. I declare under the penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed on October 23, 2012. /s/ James E. Hough James E. Hough ny-1062594 1

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