Yellowone Investments v. Verizon Communications, Inc et al

Filing 12

REPLY to Response to Motion re 8 MOTION to Dismiss VERIZON COMMUNICATION INC. filed by Verizon Communications, Inc. (Attachments: # 1 Exhibit A)(Durst, Timothy)

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Yellowone Investments v. Verizon Communications, Inc et al Doc. 12 Att. 1 Case 2:06-cv-00475-TJW Document 12 Filed 03/08/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION YELLOWONE INVESTMENTS, Plaintiff, vs. VERIZON COMMUNICATIONS, INC., and IDEARC INFORMATION SERVICES, INC. Defendants. 8 6 9 8 0 Civil Action No.: 2-06-CV-475 (TJW) JURY DEMANDED 8 SUPPLEMENTAL DECLARATION OF JANE A. SCHAPKER IN SUPPORT OF VERIZON COMMUNICATIONS INC.'S MOTION TO DISMISS I, Jane A. Schapker , declare as follows: 1. I am currently employed by Verizon Corporate Services Group Inc. My title with Verizon Communications Inc. is Executive Director of Corporate Governance and Assistant Corporate Secretary. My responsibilities include overseeing the corporate governance for certain subsidiaries of Verizon Communications Inc. I make this declaration of my personal knowledge and, if called as a witness, could and would testify competently to these statements. 2. Bill Kula is not an employee of Verizon Communications Inc. Kula is employed by Verizon Corporate Services Group Inc., which is a separate legal entity from Verizon Communications Inc. 3. As I said in my Declaration in Support at paragraph 10, Verizon Communications Inc. has no employees in Texas. I have re-confirmed that fact. The premises at 919 Hidden Ridge, Irving, Texas, 75038, is leased by Verizon Corporate Services Group, Inc, and Verizon Communications Inc. has never had any employees located there. Dockets.Justia.com Case 2:06-cv-00475-TJW Document 12 Filed 03/08/2007 Page 2 of 2 4. The term "Verizon Communications," as it appears on the whois.com website pages submitted by the plaintiff in this case, could refer to any one of a number of operating companies in which Verizon Communications Inc. holds stock, and that use as part of their names the trademark "Verizon." The entity designated on the website pages as "Verizon Communications," with its address at 919 Hidden Ridge, Lrving, Texas, 75038, is not Verizon Communications Inc. 5. The term "Verizon Communications," as it appears in the press release submitted by the plaintiff in this case, does not refer to Verizon Communications Inc. but is intended to encompass the totality of the different operating companies that market and sell products under the "Verizon" trademark, which is not owned by Verizon Communications Inc. 6. The "Verizon Experience Store" referenced in the press release submitted by the plaintiff is leased, jointly and severally, by Dallas MTA, L.P. and San Antonio MTA, L.P., d/b/a Verizon Wireless. I declare under the penalty of perjury that the foregoing is true and correct. Dated: March 8, 2007

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