Free Declaration - District Court of California - California

Case 3:07-cv-02391-JAH-POR

Document 27

Filed 02/08/2008

Page 1 of 4

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RONALD MARTINETTI, ESQ. State Bar No.106 898 KAZANJIAN & MARTINETTI 520 East Wilson Avenue Glendale, California 91206 Tel. 818-241-1011 FAX 818-241-2193
E-Mail [email protected] --

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Attorneys for Lee's General John Lee

Defendants Toys, Inc.,

and

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UNITED STATES DISTRICT

COURT OF CALIFORNIA

FOR THE SOUTHERN DISTRICT

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CASE. GEORGIA-PACIFIC CONSUMER PRODUCTS LP, a Delaware partnership, . limited

NO.07 CV 2391 (JAR POR)

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Plaintiff, vs.
LEE'S GENERAL TOYS, INC., corporation, JOHN LEE, an DOES 1-10, ,-,

SUPPLEMENTAL DECL. OF RON MARTINETTI I OPPOSING PLAINTIFF'S .EX PARTE APPLICATrON ) FOR EXPEDITED ",;,,~,.).. DISCOVERY -;",..;c I ) and) )

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a Cil~i£ornia individual;

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Defendants.

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Case 3:07-cv-02391-JAH-POR

Document 27

Filed 02/08/2008

Page 2 of 4

SUPPLEMENTAL DECLARATIO~ OF RON MARTINETTI
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OPPOSING PLAINTIFF

GEORGIA-PACIFIC'S
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APPLICATION declare:
Lee's

FOR EXPEDITED DISCOVERY

I,
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Ron Martinet
I represent

ti,

Defendant

General

Toys

and

Defendant

John

4 Lee in
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2.

the

present

matter. 7, 2008 I faxed to Mr. Adam of Welland, counsel
bills of

On February Georgia-Pacific

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for
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thirty-five

pages

invoices,

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Toys

imported

from

China. that

~ese

items 292,800 Court, time

were

contained As these was
my

in

six

container 12 13 the 14
3.

shipments

totaled and the at the have

tissues. 59,5?0 of

client

has

informed in the

Defendant warehouse

tissues
filed--and

remained

this

action removed the
one

Angelite The

outer thirty-five

wrappings

now been that 2003 in
(in

and destroyed. first
container) Angelite .

pages from China

reflect in

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tissues remaining since
2003,

were

shipped were

The

items my client

shipped

in the

2007

five

other in

containers.
California in

trademarked

name Angelite

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slept notice 4. tissue distributors Angelite
connection

of

the

Angelite

name. have of this stopped case will selling and have refill with any even any Angelite
informed

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However, pending in tissue.
with
I

Defendants the outcome that letters

writing These
the

they

not

orders Court

for
in

have
motion

been
for

filed

the

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pending

a preliminary

injunction.

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However,

will
I

continue
its

to
request

cooperate
for

with
expedited

Plaintiff's
discovery as

counsel.
unneces-

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regard

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sary
I

and uniustified. declare
penalty perjury the

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under and the
is

, bf

1\ under

laws

of

the

united true Executed this February 7, 2008 at Glendale, California. and correct.

states

state

of

California

that

the

foregoing

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Page 3 of 4

... P.
.Q

Filed 02/08/2008

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Case 3:07-cv-02391-JAH-POR

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Case 3:07-cv-02391-JAH-POR

Document 27

Filed 02/08/2008

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PROOF OF SERVICE I am employed in Los Angeles the age of eighteen years and not My business address is 520 East 91206. On this date netti Opposing Discovery
by personal

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County, a party wilson

California; I am over to the within action. Glendale, California of Ron Martifor Expedited

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I served Plaintiff's

Supplemental Ex Parte

Declaration Application

delivery

.,'"tt:o"Ccthe"address thereof prepaid, California,

below) enclosed in a in the united addressed to: sealed states

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by placing envelope with postage Post Office mail box a trueCcopy thereon fully at Glendale,

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Stephen Swinton, Esq. Latham & Watkins 12636 High Bluff Drive, San Diego, California Tel. 858-523-5400 . FAX 858-523-5450

1( suite 400 92130-2071

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ZOO: OJ/)O ",N,," .J -"' .J ~~< '" :I "' (J) 0( W O N J/) U . W .J < C Z W .J ~

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and via

FAX to

counsel

for

Georgia-Pacific

Consumer

Prod.

(x)

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(x) BY MAIL I sealed and placed such envelope for collection and mailing to be deposited in the mail on the same day in the ordinary course of business at Glendale, California. I am readily familiar with our law firm's practice of collecting and processing correspondence and documents for mailing. They are deposited with u. S of servica~on..,.t.he,same,day as dated, -7-in the ordinary the course .Postal business. ,

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lawSOf foregoing (x)

(State) the State is true

I declare under penalty of California and the and correct.

of perjury united states

under that

the the

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(Federal are also to be filed via e-mail. of the state of California

The papers that

I declare under penalty the foregoing is true Executed this February

of perjury and correct. 7, 2008 at

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Glendale,

California

91206

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