The Marshall County Coal Company et al v. Oliver et al

Filing 13

Memorandum in Opposition re 3 MOTION to Remand to State Court filed by Home Box Office, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Fitzsimmons, Robert)

Case 5:17-cv-00099-JPB Document 13-1 Filed 07/21/17 Page 1 of 3 PageID #: 193

Exhibit 1

Case 5:17-cv-00099-JPB Document 13-1 Filed 07/21/17 Page 2 of 3 PageID #: 194

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA
THE MARSHALL COUNTY COAL
COMPANY, THE MARION COUNTY COAL
COMPANY, THE MONONGALIA COUNTY
COAL COMPANY, THE HARRISON
COUNTY COAL COMPANY, THE OHIO
COUNTY COAL COMPANY,
MURRAY ENERGY CORPORATION, and
ROBERT E. MURRAY,

Civil Action No. 17-cv-00099
Judge John P. Bailey

Plaintiffs,
v.
JOHN OLIVER, CHARLES WILSON,
PARTIALLY IMPORTANT PRODUCTIONS,
LLC, HOME BOX OFFICE, INC., TIME
WARNER INC., and DOES 1 through 10,
Defendants.

DECLARATION OF DAVID MARTIN
I, David Martin, declare as follows:
1.

I am over the age of 18, and the following statements are based on my personal

knowledge.
2.

I am the CEO of Avalon Television, Inc. Avalon Television, Inc. is incorporated

under the laws of California. Avalon Television, Inc. has two offices in the United States, in
California and New York. Avalon Television, Inc. is not a citizen of Ohio or West Virginia.
3.

Partially Important Productions, LLC is a limited liability company formed under

the laws of Delaware. Avalon Television, Inc. is the sole member of Partially Important
Productions, LLC.

Case 5:17-cv-00099-JPB Document 13-1 Filed 07/21/17 Page 3 of 3 PageID #: 195

I declare under penalty of perjury that the foregoing is true and correct.

Executed this ^(T th day of July, 2017 at Beverly Hills, California.

avid Martin

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