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Gov.uscourts.flmd.274150.49.1

Gov.uscourts.flmd.274150.49.1

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Gov.uscourts.flmd.274150.49.1
Gov.uscourts.flmd.274150.49.1

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Categories:Business/Law
Published by: J Doe on Apr 12, 2013
Copyright:Attribution Non-commercial

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07/10/2013

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 Exhibit "A"Declaration of Brett Gibbs - 4/11/2013
Case 8:12-cv-01685-MSS-MAP Document 49-1 Filed 04/11/13 Page 1 of 3 PageID 416
 
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DECLARATION
OF
BRETT L.
GIBryS
I, Rrett
L.
Gibbs,
declare and
state
as
tollows:
l.
I
am
an
attorney
at
law
duly
licensed
topracticebefore
all ol'the
courts
in the
State
of
California.
I
havepersonal
knowledge
of
the facts
sei
fkrrth
below.
and
I
could
and
would
competently testifoto
thern
if
called
upon
todo
so.
2.
I
was
previously
"Of
Clounsel"
to
Prenda
Law
ancl
r,viis
ilttorttev
of
record
lbr
Prenda
Law
clients
in
connection
withcopyrightlitigal.ici:
in
California.
3.
At
some
point
in
time in
2012,
I
was
asked
by John
Steele andPaul
Hansmeier,
who
I
have
previously
referenced
as
"senior
tnettiliers"'
*1'Prettda
La.v;
in
a
declarationsubmittedin
a
California
DistrictCourt.r
to
h-re
a
rcsource
ttl
anslverquestions
and
provide
guidance
in
connectiort
with
certain
copyrigitt
cast's
Iiled
by
attorneys
hired
by
Prenda
Law
in
Florida,
including
Sunlttst
[ticiure':;.
Ll'{'t'.
Tttittt
I{guyen,
Case
No.
8:12
-cv-
01685
MSS-MAP
(the
"sunlust
Action").
lf
questions
from
the
Florida
counsel
arose
about
issues
that
I
was
not ianr!iiar
r,t'ittt
cit'requirecidecisions
by
Prenda
Law's
clients,
I
would
raise
them
r'itli
'lolrn
'Stec'le
and
Paul
Hansmeier
and
receive
instructions
from
John
Steele
and Paul
Iianstneierthat
I
would
then
pass
ontothe
Florida
counsel.
4.
For
example,the decision
to
file
the
Sunlusl
Action
was
rnade
bv
Messrs.
Steele
andFlansmeier,the settlementparameters
were
g,iven
ttl
ntc
hv
Messrs.
Steele
andHansmeier,and
it
wasMessrs.
Steele
anciiiansnte-ie-'r
who
gave
me
instructions
concerning
how
to
advisethe
F
lorida
counsel
in
the
Sunius[
Aciion'
Moreover,
I
believe
that
it
was
Mr.
Steele
thatwas
responsible
lar
locatiirg
the
various
Florida
counsel
to
handle
the
litigatiorrin
Floriclaon
beirali'ci
PrencJa
Lal'r.
5.
I
haveno
recollection
oftaiking
to
Paul
Duffy
cottcet'niug,
the
Sunlusl.
Action
prior
to
the Court's
November
8,2012
Order
requiring
"a
princ-iiral
of'Prenda'
DKT'.58
in Ingentrity,
13,
LLCv..lohn[)oe,
Case
No.:
.2:]2
'
c't'
0,9JJ-?
ODIV-
L{i'.
Case 8:12-cv-01685-MSS-MAP Document 49-1 Filed 04/11/13 Page 2 of 3 PageID 417

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