Free Errata - District Court of California - California

Case 3:07-cv-04755-JSW

Document 65

Filed 03/26/2008

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BIRNBERG & ASSOCIATES
703 MARKET STREET SUITE 600 SAN FRANCISCO CA, 94103 TEL (415) 398-1040 FAX (415) 398-2001

BIRNBERG & ASSOCIATES CORY A. BIRNBERG (SBN 105468) JOSEPH SALAMA, ESQ. (SBN 212225) BIRNBERG & ASSOCIATES 703 Market Street, Suite 600 San Francisco, CA 94103 Telephone: (415) 398-1040 Facsimile: (415) 398-2001 Attorneys for Plaintiffs JOHN GIDDING, PIVOTAL, INC.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION JOHN GIDDING, PIVOTAL, INC. ) ) Plaintiffs, ) ) v. ) ) DEREK ANDERSON, et al., ) ) Defendants. ) ) ) ) ) __________________________________ ) Case No. C-7-04755-JW ERRATA TO DECLARATION OF JOHN GIDDINGS IN OPPOSITION TO MOTION TO .A.S. LES CHAMPS RENIERS AND CHRISTOPHE RAPENEAU FOR LACK OF PERSONAL JURISDICTION Date: May 30, 2008 Time: 9:00 a.m. Place: 2, 17th Floor.

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ERRATA DECLARATION OF JOHN GIDDING IN OPPOSITION TO MOTION TO DISMISS FOR .A.S. LES CHAMPS RENIERS AND CHRISTOPHE RAPENEAU LACK OF PERSONAL JURISDICTION Case No. C-7-04755-JW -1-

Case 3:07-cv-04755-JSW

Document 65

Filed 03/26/2008

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Now comes Plaintiffs JOHN GIDDING and PIVOTAL, INC. and make the following errata to the DECLARATION OF JOHN GIDDING IN OPPOSITION TO MOTION TO .A.S. LES CHAMPS RENIERS AND CHRISTOPHE RAPENEAU FOR LACK OF PERSONAL JURISDICTION

Previously paragraph 3 stated:

"3.

Christophe and Jean Francois Rapeneau control companies that control the

diverse Champagne holdings of the Rapeneau and Ducellier families. Many of these companies sell Champagne and the Unites States is a major Champagne market. One, some, or all of these companies solicit sales in the United States. In my twenty five years in the wine trade, Christophe's agents have solicited business from me. Christophe is the administrative brother, Jean-Francois is the sales brother, and they are two sides of the same coin, one side sells the other administers. " However, the Exhibit that shows the many companies and contacts with the United States was inadvertently left off. The exhibit was left out and now will be attached as Exhibit F and this paragraph 3 should read: 3. Christophe and Jean Francois Rapeneau control companies that control the

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BIRNBERG & ASSOCIATES
703 MARKET STREET SUITE 600 SAN FRANCISCO CA, 94103 TEL (415) 398-1040 FAX (415) 398-2001

diverse Champagne holdings of the Rapeneau and Ducellier families. Many of these companies sell Champagne and the Unites States is a major Champagne market. One, some, or all of these companies solicit sales in the United States. In my twenty five years in the wine trade, Christophe's agents have solicited business from me. Christophe is the administrative brother, Jean-Francois is the sales brother, and they are two sides of the same

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ERRATA DECLARATION OF JOHN GIDDING IN OPPOSITION TO MOTION TO DISMISS FOR .A.S. LES CHAMPS RENIERS AND CHRISTOPHE RAPENEAU LACK OF PERSONAL JURISDICTION Case No. C-7-04755-JW -2-

Case 3:07-cv-04755-JSW

Document 65

Filed 03/26/2008

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BIRNBERG & ASSOCIATES
703 MARKET STREET SUITE 600 SAN FRANCISCO CA, 94103 TEL (415) 398-1040 FAX (415) 398-2001

coin, one side sells the other administers. Attached hereto marked Exhibit F and incorporated herein by reference is a true and correct copy of a web page that confirms the many companies and brands showing there is contact with the Untied States by the sale of wine and champagne. (Italic portion shows amendment) I declare under penalty of perjury the foregoing is true and correct under the laws of the United States and pursuant to 28 U.S.C.§ 1746. Executed this 26th day of March 2008 at San Francisco, California.

__s/s John Gidding____________ John Gidding

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ERRATA DECLARATION OF JOHN GIDDING IN OPPOSITION TO MOTION TO DISMISS FOR .A.S. LES CHAMPS RENIERS AND CHRISTOPHE RAPENEAU LACK OF PERSONAL JURISDICTION Case No. C-7-04755-JW -3-