Declaration of Karen Ahmed

FILED
12 JUN 29 AM 11:21
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THE HONORABLE CAROL SCHAPIRA
KING3:30
COUNTY
MOTION NOTED FOR ORAL ARGUMENT ON JULY 10, 2012 AT
P.M.
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SUPERIOR COURT CLERK
E-FILED
CASE NUMBER: 12-2-21829-3 SEA
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
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GEOFF TATE and SUSAN TATE, a married
couple,
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Plaintiffs,
Case No. 12-2-21829-3 SEA
DECLARATION OF KAREN AHMED
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v.
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EDDIE JACKSON and TERESA GOLDENJACKSON, a married couple; SCOTT
ROCKENFIELD and MISTY
ROCKENFIELD, a married couple;
MICHAEL WILTON and KERRffi LYNN
WILTON, a married couple; TRI-RYCHE,
CORPORATION, a Washington corporation;
QUEENSRYCHE MERCHANDISING, INC.,
a Washington corporation; and MELODISC
LTD., a Washington corporation,
Defendants.
I, Karen Ahmed, declare as follows:
1.
I worked at Rhino Entertainment as a vice-president of artists and repertoire
from 2000 through October, 2006. During that time, I had occasion to work with the band
Queensryche before and after the release of Operation: Mindcrime II.
2.
My experience working with the band was almost solely with Geoff Tate and
Susan Tate. Geoff Tate, almost solely, engaged in the business, development and promotional
activities I was involved with at Rhino. I had very little contact with other members of the
Veris Law Group PLLC
DECLARATION OF KAREN AHMED
1809 Seventh Avenue, Suite 1400
Seattle, Washington 98101
TEL 206.829.9590 FAX 206.829.9245
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band regarding business affairs, project development or production.
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member of the band from which we would receive responses, questions, thoughts, and ideas
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and approvals.
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and idea and the creative process. I cannot remember any time that the other members
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undertook such efforts.
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3.
Geoff was the only
Geoff would come to the offices and assist in the development of concepts
I was the executive producer of a DVD Queensryche filmed at the Moore
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Theater in Seattle in 2006.
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Mindcrime and Operation: Mindcrime II. Geoff was involved in every aspect of the film, from
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development through production, and assisted and directed the film and production crew to
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develop the best end product possible. The other band members were uninvolved during pre-
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production, filming and recording.
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The DVD featured the band's performance of Operation:
I declare under penalty of perjury of the laws of the State of Washington this ^t/ day
of June that the foregoing is true and correct.
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Karen Ahmed
4849-5402-0112, v. 1
is"
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Veris Law Group PLLC
DECLARATION OF KAREN AHMED
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1809 Seventh Avenue Suite 140
Seattle, Washington
>
98101
°
TEL 206.829.9590 FAX 206.829.9245