Free Declaration in Support - District Court of California - California

Case 3:07-cv-02748-MHP

Document 86

Filed 02/04/2008

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HARVEY SISKIND LLP IAN K. BOYD (State Bar No. 191434) [email protected] SETH I. APPEL (State Bar No. 233421) [email protected] RAFFI V. ZEROUNIAN (State Bar No. 236388) [email protected] Four Embarcadero Center, 39th Floor San Francisco, California 94111 Telephone: (415) 354-0100 Facsimile: (415) 391-7124 Attorneys for Plaintiff and Counterdefendant Mark Lillge d/b/a Creative Marketing Concepts IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS, Plaintiff, v. ANDREW VERITY and CHRISTINA CHANG, Date: March 10, 2008 Time: 2:00 p.m. Court: Hon. Marilyn Hall Patel Case No. C 07-02748 MHP DECLARATION OF SETH I. APPEL IN SUPPORT OF APPLICATION FOR ORDER TO SHOW CAUSE WHY DEFENDANTS SHOULD NOT BE ADJUDGED IN CONTEMPT AND SANCTIONED

Defendants.

ANDREW VERITY and CHRISTINA CHANG, Counterclaimants, v. MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS, and DOES 1-10, Counterdefendants.
APPEL DECLARATION IN SUPPORT OF APPLICATION FOR ORDER TO SHOW CAUSE RE CONTEMPT Case No. C 07-02748 MHP

Case 3:07-cv-02748-MHP

Document 86

Filed 02/04/2008

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I, Seth I. Appel, declare as follows: 1. I am an attorney at the law firm of Harvey Siskind LLP, counsel of record for Plaintiff

and Counterdefendant Mark Lillge d/b/a Creative Marketing Concepts ("CMC"). I have personal knowledge of the matters stated herein, and, if called as a witness, I could and would testify competently thereto. 2. Attached hereto as Exhibit A are excerpts from a true and correct copy of the

transcript of the hearing on CMC's application for a Temporary Restraining Order, held on May 31, 2007. 3. Attached hereto as Exhibit B are excerpts from a true and correct copy of the transcript

of the hearing on CMC's Motion for Preliminary Injunction, held on August 27, 2007. 4. Attached hereto as Exhibit C is a true and correct copy of the Court's Order granting

CMC's Motion for Preliminary Injunction, issued on October 1, 2007. 5. Attached hereto as Exhibit D is a true and correct copy of the Court's Order

Confirming Scope of Temporary Restraining Order and Preliminary Injunction, issued on November 9, 2007. 6. Attached hereto as Exhibit E is a true and correct copy of email communications from

Defendant Christina Chang to a customer of Plaintiff. Defendants produced this document during discovery in this proceeding in response to a document request. 7. Attached hereto as Exhibit F is a true and correct copy of email communications from

Defendant Christina Chang to another customer of Plaintiff. Defendants ultimately produced this document during discovery in this proceeding in response to a document request. /// /// /// // // ///
-1APPEL DECLARATION IN SUPPORT OF APPLICATION FOR ORDER TO SHOW CAUSE RE CONTEMPT

Case No. C 07-02748 MHP

Case 3:07-cv-02748-MHP

Document 86

Filed 02/04/2008

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