DECLARATION OF ANDREW R. WILSON I, ANDREW H. WILSON, declare an follows: 1.My name is Andr
DECLARATION OF ANDREW R. WILSON
I, ANDREW H. WILSON, declare an follows:
1.My name is Andrew H. Wilson, and I am an attorney at law
licensed to practice before the Courts of the State of California and
before this Court. I am an principal at the law firm of Wilson, Ryan &
Campilongo, 115 Sansome Street, Suite 400, San Francisco, California
94104 ("WRC"). As one of the attorneys responsible for the
representation of Plaintiff RELIGIOUS TECHNOLOGY, INC. and BRIDGE
PUBLICATIONS, INC., I have personal knowledge of the facts set forth
below, except as to those matters set forth on information nd belief,
and as to those matters I am informed and believe them o be true. If
called as a witness, I can competently testify to c matters set forth
2.On Friday, March 3, 1995, I had a telephone call with
Richard Horning, counsel for Defendant Thomas Klemesrud in which we
discussed the steps which Mr. Klemesrud had taken after being informed
of the violation of the temporary restraining order issued n this action
by reason of Erlich's posting of the copyright materials.
3.Mr. Horning told me that Mr. Klemesrud had deleted
theses materials from Klemesrud's computer. I confirmed with Mr.
Horning at what this meant was that the posting had been stored in the
file server used by Klemesrud to operate his bulletin board service and
that Klemesrud had then deleted it.
4.I declare under the penalty of perjury pursuant to the
awe of the State of California that the foregoing in true and correct
and that this Declaration was executed on March 6, 1995.
/s/ Andrew M. WILSON
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