Free Declaration - District Court of Delaware - Delaware

Case 1 :08-cv-00127-GIVIS Document 18 Filed 06/05/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OP DELAWARE
CRS, LLC )
I
Plaintiff, )
)
v. ) C.A. No. 08-l2'/—GI\/IS
I
TURNER BROADCASTING SYSTEM, )
INC. 1 )
' I
Defendant. )
DECLARATION OF STEPHEN PYBURN IN SUPPORT OF DEFENDANT
TURNER BROADCASTING SYSTEM, INC.’S MOTION TO
TRANSFER TO THE WESTERN DISTRICT OF WASHINGTON .
I, Stephen Pyburn, the undersigned, declare:
l. I am a Controller III for Turner Entertainment Networks, Inc. and provide
services to TGN, Inc. I am over the age of 18 and competent to testify to the matters
contained in this Declaration. I have knowledge ofthe matters stated herein, and will
testify to the same if called upon to do so. I declare as follows:
2. TGN, Inc. operates the video gaming website known as "Game"l`ap."
TGN, Inc. is a whol1y—owned subsidiary of TBS, Inc. TGN, Inc. exists as a separate and
DECLARATION OF STEPHEN PYBURN IN SUPPORT OF TBS’S MOTION TO
TRANSFER CASE — I
C.A. No. 08-127-GMS

Case 1:08-cv-00127—Gl\/IS Document 18 Filed 06/05/2008 Page 2 of 2
distinct corporate entity from TBS, Inc., with TGN, Inc. maintaining separate tinancial
records for the business activities conducted by TGN, Inc.
3. Revenues generated by the Ga1neT ap website are attributed directly to
TGN, inc. Costs incurred by the Ga1neTap website are paid by or allocated to TGN, Inc.
TGN, Inc. has its own employees, who work on developing and operating the Ga1neTap
website, and their salaries are paid for by TGN, Inc. To the extent that employees of
TBS, Inc. or other TBS, Inc. subsidiaries, including myself, provide services to TGN,
Inc., those costs are allocated to TGN, Inc. as well.
4. I swear under penalty of perjury, under the laws of the United States, that
the foregoing statements are true and accurate to the best of my knowledge.
Executed this Sth day of June, 2008 at Atlanta, Georgia.
·z· ’/`?V"""""
Stephen yburn
DECLARATION OF STEPHEN PYBURN TN SUPPORT OF "l`BS’S MOTION TO
TRANSFER CASE — 2
C.A. No. 08-l27—Gl\/{S

Case 1:08-cv-00127-GMS

Document 18

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Case 1:08-cv-00127-GMS

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