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UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
| THE TAUBMAN COMPANY |
| LIMITED PARTNERSHIP, |
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| Plaintiff, | |
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| | Civil Action No. 01-72987 |
| v. |
| | District Judge Zatkoff |
| WEBFEATS AND HENRY MISHKOFF, |
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Magistrate Judge Komives |
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| Defendants. | |
AFFADAVIT OF HENRY MISHKOFF
My name is Henry Mishkoff. This affidavit is made to support my motion to reconsider the
denial of my motion to dismiss the copyright claim for lack of personal jurisdiction.
According to a document that I obtained in late May through discovery, plaintiff Taubman did
not receive a written assignment of the copyright for the two graphics that are at issue on the
copyright count until February, 2002. This assignment was made by JPRA and Associates to Taubman. A
copy of that assignment is attached to this affidavit.
In response to the order compelling further discovery responses, Taubman revealed that JPRA
is an architectural firm, that its name is JPRA Architects, and that it is located in Michigan.
It was not until Taubman provided these additional discovery responses that I learned that
JPRA is located in Michigan. At the time I copied the graphics, and throughout the time that the
graphics appeared on my web site, I had no idea where JPRA was located.
I hereby certify under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing
is true and correct. Executed on October 17, 2002.
Henry Mishkoff
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