Free Declaration - District Court of Delaware - Delaware

Case 1:07-cv-00067-MPT Document 15 Filed O3/15/2007 Page 1 of 3
TN TI-IE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OP DELAWARE

Plaintiff, g
v. i C. A. No. 1:O7—cv-067·»w=#=
) iury Trial Demancicd
GPNE CORP., )
Defendant. g

DECLARATION OF AN DREW T. BLOCK IN OPPOSITION TO MOTEON
TO DISMISS, STAY OR TRANSFER
I, Andrew T. Block. hereby declare and state as follows:
t., Unless otherwise stated, 1 have personal knowledge of the facts stated
herein and if called to testify, I could and would be able to testify to the statements made
herein.
2. I am Vice President and Chief Counsel, IP, of Time Warner Cable Inc.
("`i`WC"). I have personal knowledge ofthe corporate structure and operations of`TWC.
I have been an attorney with TWC since September 200t.
3. TWC is a Delaware corporation having its corporate headquarters at 290
Harbor Drive, Stamford, Connecticut. TWC also has signiticant corporate operations in
Charlotte, North Carolina; Herndon, Virginia; and Westminster, Colorado. TWC has a
corporate marketing function located in Stamford, and its corporate finance litnction is
located in both Stamford and Charlotte. TWC has approximately 45,000 of its own
empioyees, Substantially all of the personnel and ciocttments relating to each of those
corporate functions are located in the respective locations where the function is located.
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Case 1:07-cv-00067-MPT Document 15 Filed O3/15/2007 Page 2 of 3
4. TWC is a separate and distinct corporate entity from Time Warner inc.
("TWI“) and is not a whollyowned subsidiary of TWI. TWC and TWI are separately
traded companies on the New York Stock Exchange. TWI is a shareholder in TWC.
5. None of the senior executive officers of TWC responsible for the
management of'1`WC’s business operation are officers or directors of TWI. None of the
directors of TWC are directors of TWI.
I declare under penalty of perjury that to the best of my knowledge, ini`or1nation
and belief, the foregoing statements are true and correct.
Executed this gfimday of March 2007 in Stamford, Connecticut.
% Angew T. Block
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Case 1:07-cv-00067-MPT Document 15 Filed O3/15/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on March 15, 2007, I eiectronically tiled the foregoing document
with the Clerk of Court using CM/EC? which will send notification of such tiling(s) and Hand
Delivered to the following:
Richard K. Herrmann, Esquire
Morris James, LLP
500 Delaware Avenue, suite 1500
Wilmington, DE 19801-1494
I hereby certify that on March 15, 2007, E have sent by Federal Express, the foregoing
document to the following non—registered participants:
Edward W. Goldstein
Corby R. Vowell
Goldstein, Faucett & Prebeg, LLP
1177 West Loop South, Suite 400 _
Houston, Texas 77027 _ g i g
J eson weedie (#4927)
[email protected]
arr 1-2 224520-l