Free Affidavit - District Court of California - California

r _ Case 3:07-cv-02771-JSW Document 4 Filed 05/25/2007 Page 1 of 2
s ,4.
l I. Andrew Coombs (SBN 123881) Aj);
[email protected] ’ *?"»·i}’2; "
2 Alexandra E. Ciganer (SBN 241880) . 7 `J °° 3_
alexcz@[email protected] wi _/,8 ·i L4 F; ,_ ` ' Q1,
3 I. Andrew Coombs, A P.C. U ‘° .%?1’:;’ i . .
450 N. rama Blvd. suite 600 I i _f
4 Glendale, California 91203-2349 " ’
Telephone: (818) 291-6444 " '
5 Facsimile: (818) 291 -6446 ‘
6 Michael W.O. Holihan, Esq. l
Michael W.O. Holihan, FA. `
7 1101 N. Lake Destiny Drive, # 350
Maitland, Florida 32751
8 Telephone: (407) 660-8575
Facsimile: (407) 550-0510 _ ' “
9 E filing
Attomeys for Plaintiffs Disney
19 Enterprises, Inc., Sanrio, Inc., DC Comics, I1-]
Hanna-Barbera Productions, Inc. and ·
1 Warner Bros. Entertainment Inc. rl-FI
12 U
` I W
l3 UNITED STATES DISTRICT COURT _<
14 Noari-{BRN DIST cr or CALIFORNIA 'I'I
15 0 7 2 7 7 1 $7
Disney Enterprises, Inc., Sanrio, Inc., DC ) Case No. V
16 Comics, Hanna—Barbera Productions, Inc. and )
17 Wamer Bros. Entertainment Inc., ) DECLARATION RE JOINDER
)
18 Plaintiffs, ) Local Rule 19-2
)
19 v. g
Bouncin Bins, Inc., Tom Mahaney and Does 1- )
20 10, inclusive, )
)
2* Defendants. )
)
22
23 DECLARATION OF ,[. ANDREW COOMBS
24 I, I . ANDREW COOMBS, declare as follows:
25 1. I am an attorney at law, duly admitted to practice before the Courts of the State of
26 California and the United States District Court for the Northern District of California. I am an
attorney for Plaintiffs Disney Enterprises, Inc., Sanrio, Inc., DC Comics, Hanna-Barbera
2
7 Productions, Inc. and Warner Bros. Entertainment Inc., (collectively "Plaintiffs"), in an action styled
28
Disney, etal. v. Bouncin Bins : Declaration re Joinder - 1 -

_ . Case 3:07-cv-02771-JSW Document 4 Filed 05/25/2007 Page 2 of 2
I Disney Entegrises. Inc., et al. v. Bouncin Bins, et al. I submit this Declaration supportingjoinder of
2 the copyright, trademark and related claims in one action, as provided by Local Rule 19-2 of the
3 United States District Court for the Central District of California, formerly Local Rule 3.7.2.2
4 (hereinafter Rule l9—2). Except as otherwise expressly stated to the contrary, I have personal
5 knowledge of the following facts and, if called as a witness I could and would competently testify
thereto.
6 2. The interests of justice will be advanced through joinder of Plaintiffs’ claims for
7 copyright infringement for the following reasons:
8 a. First, I am informed and believe that the Defendants’ mode of conducting
9 business requires the Plaintiffs to act in concert. lt is far more likely that the Plaintiffs will
10 succeed in coordinating these enforcement efforts where relief is sought in one action, in one
U proceeding, before one Court. Even were separate actions "related," which is not certain, it
would still remain possible that proceedings would not necessarily proceed on the same
12 schedule.
I3 b. Second, the interests of justice are sewed because the Plaintiffs seek to
*4 vindicate similar rights. While different intellectual properties are involved, my experience
i5 with similar cases suggests that the most vigorously contested issues will involve Defendants
16 conduct, intent and ability to compensate Plaintiffs for their acts. These issues will be the
U same with respect to each Plaintiff. Accordingly, not only are the interests of justice
advanced through joinder, the risk of prejudice is reduced and judicial economies are
18 advanced.
ig c. Accordingly, joinder of the Plaintiffs’ claims herein will avoid a multiplicity
20 of actions involving substantially the same issues, the same preliminary procedures and the
21 same final relief.
22 I declare under penalty of perjury under the laws of the United States of America that the
23 foregoing is true and correct.
Executed this day of May, ZOQZ, at Glendale, Califorrga.
24 __ . ....
25 A `\ "””
26 J. ANDREW COOMBS
27
28
nisncmr ai. V. Batman Bins ; Declaration rc Joiuder - 2 -

Case 3:07-cv-02771-JSW

Document 4

Filed 05/25/2007

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Case 3:07-cv-02771-JSW

Document 4

Filed 05/25/2007

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