Free Statement - District Court of Arizona - Arizona

Case 2:O4—cv—OO408-SI\/II\/I Document 57-6 FiIed10/07/2005 Page10f3

. 1 talked to hundreds of people each day of the art show and the information that Plaintiffs
if 2 are seeking is not clear. Subject to and not waiving that objection, Thunderbird Artists
· 3 was responsible for putting on the Carefree Art Show and the owners of Thunderbird
4 Artists are Judy and Roger Combs.
5
6
Non-Uniform Interrogatory 16
7 V · In defense counsel's July 19,2004 correspondence to Plaintiffs' counsel, Attomey
8 Laura Zeman wrote: "Defendants do not deny they had access to your clients' photograph
9 entitled 'Mother Mountain Lion with Baby in Mouth. ", That being the case, please state
10 precisely what "access" the defendants had concerning the photograph entitled "Mother
1; Mountain Lion with Baby in Mouth."
ig { 13 Response to Non-Uniform Interrogatogy 16
E: 14 Kent Dyer gave Jason Napier a miniprint of the photograph at the Carefree Art
2 J 15 Show in early 2001 and this miniprint was in the possession of Defendants until about
C;) i 16 November 2002, when Defendants cleaned and discarded many items in their possession
6 17 in preparationfor moving their residence.
1 8 A
19 ·
Non-Uniform Interrogatogy 17
20 In connection with the immediately preceding interrogatory, please state precisely .
21 how many times Defendants (list separately for each defendant) had contact with Kent
22 Dyer.
23 ‘
24 Danielle Napier: _
25 `
_ Jason Napier: _
26
27 I ‘
28
as28i'5liO4—cv—OO4O8-SI\AI\A Document 57-61 - Filed 10/O7/2005 Page 2 of 3

A 1 Response to Non-Uniform Interrogatory 17
if 2 Danielle Napier talked with Jason Napier and Kent Dyer about Jason Napier using
3 Mr. Dyer’s photograph as a reference to create a bronze sculpture at the 1998 Carefree Art
4 Show, the 1999 Carefree Art Show, the 2000 Carefree Art Show, and the 2001 Carefree
5 Art Show.
I 6 Jason Napier talked with Danielle Napier and Kent Dyer about Jason Napier using
7 Mr. Dyer’s photograph as a reference to create a bronze sculpture at the 1998 Carefree Art
8 Show, the 1999 Carefree Art Show, the 2000 Carefree Art Show, and the 2001 Carefree
9 Art Show. I »
10 ‘
1 1 - .
12 Non-Uniform Interrogatogy 18 ‘
ig ' 13 Please state precisely how Defendants came into possession of the photograph
rl E 14 known as "Mother Mountain Lion with Baby in Mouth."
2 [ 15 Response to Non-Uniform Interrogatogy 18
(2;* 16 Kent Dyer gave Jason Napier a miniprint of the photograph at the Carefree Art
6 17 Show in early 2001.
18
19 _ I
20 Non-Uniform Interrogatogy 19
21 Did Defendants use or hire "Reflections Fine Art Gallery" in Oregon to create any
22 of the "Precious Cargo" sculptures?
23 Response to Non-Uniform Interrogatory 19
24 Defendants did not use or hire Reflections Fine Arts or any other artists or entity to
25 create Jason Napier’s "Precious Cargo" sculptures. The sculpture was originally formed
26‘ in clay by Mr. Napier and a foundry was employed to mold and cast the original clay
27 sculpture created by Mr. Napier. The molding and casting of Mr. Napier’s originally
2 8 created sculpture by the foundry did not entail the creation or addition of any original
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Case 2:04-cv-00408-SMM

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