Cas@|2:12-cv-08333-ODW-JC Document 55 Filed 02/20/13 Page 1lof2 Page ID #:1018

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3 IN THE UNITED STATES DISTRICT COURT

4 CENTRAL DISTRICT OF CALIFORNIA

5

6 |] INGENUITY 13 LLC, Case No. 2:12-cv-8333-ODW(JCx)

7 Plaintiff,

g |iv. DECLARATION OF CAMILLE D. 5 KERR

JOHN DOE,

Defendant.

12 |{1, Camille D. Kerr, hereby declare as follows:

13 1. I am a paralegal with Locke Lord LLP, a law firm serving as outside counsel 14 || for SBC Internet Services, LLC d/b/a AT&T Internet Services (“AT&T”) in connection with 15 || numerous subpoenas issued by attorneys with Prenda Law, Inc. in various state and federal 16 || courts across the nation. I regularly assist Bart Huffman in such matters.

17 2 On November 1, 2012, I received an e-mail message from Angela Van Den 18 ||Hemel, whom I believe to be a paralegal with Prenda Law Inc., wherein Ms. Van Den 19 || Hemel requested an update with respect to a subpoena to AT&T issued in AF Holdings LLC 20 || v. John Doe, No. 12-cv-05725 (C.D. Cal.) (the “Subpoena to AT&T” issued in the “5725 21 || Lawsuit”). Ms. Van Den Hemel’s e-mail message to me attached a copy of the 22 || corresponding subpoena package, consisting of a cover letter, the July 11, 2012 Order 23 || Granting Plaintiffs Ex Parte Application for Leave to Take Expedited Discovery, and the 24 || Subpoena to AT&T with proof of service. A true and correct copy of Ms. Van Den Hemel’s

25 || e-mail message to me (including its attachments) is attached hereto as Exhibit 1.

Cas@|2:12-cv-08333-ODW-JC Document 55 Filed 02/20/13 Page 2of2 Page ID #:1019

] S On November 6, 2012, Angela Van Den Hemel sent another e-mail message

2 |} to me asking about the 5725 Lawsuit and the Subpoena to AT&T. A true and correct copy

3 || of that e-mail message is attached hereto as Exhibit 2.

4 4. On November 8, 2012, I was copied on an e-mail message from Bart

5 || Huffman to Ms. Van Den Hemel concerning the 5725 Lawsuit, in which Mr. Huffman stated, “Upon review of the court files, it appears that any early discovery orders in this case

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7 || (and a number of other AF Holdings cases) were vacated. Please let us know if you have 8 || information to the contrary.” (Huffman Decl., § 9 and Ex. 4.) I have not thereafter received 9

any information or communication from Prenda Law, Inc. concerning the Subpoena to

10 || AT&T or the 5725 Lawsuit.

11 oy I declare under penalty of perjury that the above is true and correct.

12 || Dated: February 19, 2013

15 Camille D. Kerr

AUS:0054225/00001:496404 v3