Chang et al v. Virgin Mobile USA LLC et al
Filing
60
Appendix in Support filed by Virgin Mobile PTY LTD re 59 Response in Opposition to Plaintiffs Motion for Leave to File Sur-Reply to Defendants Reply to Plaintiffs Opposition to Defendants Motion to Dismiss (Meyerhoff, Lisa)
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Chang et al v. Virgin Mobile USA LLC et al
Doc. 60
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SUSAN CHANG, AS NEXT FRIEND OF ALISON CHANG, A MINOR, AND JUSTIN HO-WEE WONG, PLAINTIFFS, V. VIRGIN MOBILE PTY LTD., DEFENDANT. § § § § § § § § § §
CA No. 3:07-cv-1767
APPENDIX IN SUPPORT OF DEFENDANT VIRGIN MOBILE (AUSTRALIA) PTY LTD.'S OPPOSITION TO PLAINTIFFS' MOTION FOR LEAVE TO FILE SUR-REPLY TO DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO DEFENDANT'S MOTION TO DISMISS Description Declaration of Lisa H. Meyerhoff Excerpts of Flickr.com discussion forum entitled "Virgin Mobile advertising campaign using Flickr photos" by an individual identifying himself/herself as sesh00 and A.C's brother, Damon Chang Defendant Virgin Mobile Pty Limited's First Supplemental Objections and Answers to Plaintiffs' Original (First) Interrogatory Nos. 2, 18, and 19 Excerpts from the deposition of David Cain that was taken on April 23, 2008 Bates APP 1 2 APP 3-8
APP 9-15 APP 16-37
HOUDMS/205628.1
Dockets.Justia.com
Respectfully submitted, BAKER & McKENZIE LLP /s/ Lisa H. Meyerhoff Lisa H. Meyerhoff Texas Bar No. 14000255 Email: Lisa.Meyerhoff@Bakernet.com BAKER & McKENZIE LLP 2300 Trammell Crow Tower 2001 Ross Avenue Dallas, TX 75201 Telephone: 214 978 3000 Facsimile: 214 978 3099 Myall S. Hawkins Texas Bar No. 09250320 Email: Myall.Hawkins@Bakernet.com Todd Y. Brandt Texas Bar No. 24027051 Email: Todd.Brandt@Bakernet.com Tan Pham Texas Bar No. 24046628 Email: Tan.Pham@Bakernet.com BAKER & McKENZIE LLP 711 Louisiana, Suite 3400 Houston, Texas 77002 Telephone: 713 427 5000 Facsimile: 713 427 5099 ATTORNEYS FOR DEFENDANT VIRGIN MOBILE PTY, LTD.
HOUDMS/221178.1
2
CERTIFICATE OF SERVICE I hereby certify that, on the 14th day of August 2008, I electronically filed the foregoing "Appendix in Support of Defendant Virgin Mobile (Australia) Pty Ltd.'s Opposition to Plaintiffs' Motion for Leave to File Sur-Reply to Defendant's Reply to Plaintiffs' Opposition to Defendant's Motion to Dismiss" with the Clerk of Court for the U.S. District Court, Northern District of Texas, using the electronic case filing system of the Court. The electronic case filing system sent a "Notice of Electronic Filing" to the following attorneys of record who have consented in writing to accept this Notice as service of this document by electronic means: Bryant A. Fitts Ryan H. Zehl Fitts Zehl LLP 5065 Westheimer Rd., Suite 700 Houston, Texas 77056 Email: rzehl@fittszehl.com /s/ Lisa H. Meyerhoff
HOUDMS/221178.1
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SUSAN CHANG, AS NEXT FRIEND OF ALISON CHANG, A MINOR, AND JUSTIN HO-WEE WONG, Plaintiffs, V. VIRGIN MOBILE PTY, LTD., Defendant. § § § § § § § § § § §
C.A. No. 3-07-CV-01767-ECF
DECLARATION OF LISA H. MEYERHOFF IN SUPPORT OF DEFENDANT VIRGIN MOBILE PTY, LTD.'S OPPOSITION TO PLAINTIFFS' MOTION FOR LEAVE TO FILE SUR-REPLY TO DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO DEFENDANT'S MOTION TO DISMISS I, Lisa H. Meyerhoff, declare and state as follows: 1. My name is Lisa H. Meyerhoff. I am a partner with the firm of Baker &
McKenzie LLP. Our firm represents Defendant Virgin Mobile Pty, Ltd. in the above-captioned suit. This Declaration is submitted in support of Defendant Virgin Mobile Pty, Ltd.'s Opposition to Plaintiffs' Motion for Leave to File SurReply to Defendant's Reply to Plaintiffs' Opposition to Defendant's Motion to Dismiss. 2. I am over the age of twenty-one (21) and am competent to make this Declaration. I have personal knowledge of the facts stated herein. 3. Attached to Defendant's Appendix is a true and correct copy of excerpts from a Flickr.com discussion blog entry entitled "Virgin Mobile advertising campaign using Flickr photos" by an individual identifying himself/herself as sesh00 and A.C's brother, Damon Chang. APP 3-8.
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