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Case 1:19-cv-00484-PP Filed 05/09/19 Page 1 of 3 Document 32

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IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF WISCONSIN


GREEN BAY DIVISION

ANDREW L. COLBORN,

Plaintiff,

vs. Civil No.: 19-CV-484-PP

NETFLIX, INC.; CHROME MEDIA LLC,


F/K/A SYNTHESIS FILMS LLC; LAURA
RICCIARDI; AND MOIRA DEMOS,

Defendants.

DECLARATION OF JAMES A. FRIEDMAN


IN SUPPORT OF MOTION TO DISMISS

I, James A. Friedman, declare as follows:

1. I am one of the attorneys for the defendants in the above-captioned action. I have

personal knowledge of the matters set forth herein.

2. In the fall of 2006, plaintiff Andrew L. Colborn ran for Sheriff of Manitowoc

County. In response to a public records request, the Manitowoc County Clerk provided copies of

public records concerning the November 7, 2006 election. I have appended to this Declaration

as Exhibit 1 a true and correct copy of a sample ballot from that election, provided by the

Manitowoc County Clerk, showing plaintiff Andrew L. Colborn as the Republican candidate for

Sheriff in Manitowoc County. I have appended to this Declaration as Exhibit 2 a true and correct

copy of the vote Tally Sheet from Manitowoc County for the November 7, 2006 election,

provided by the Manitowoc County Clerk, showing plaintiff Andrew L. Colborn as the

Republican candidate for Sheriff of Manitowoc County and as having received more than 12,000

votes.

Case 1:19-cv-00484-PP Filed 05/09/19 Page 1 of 3 Document 32


3. In the spring of 2003, plaintiff Andrew L. Colborn ran for Town Constable for the

Town of Kossuth. In response to a public records request, the Town Clerk for the Town of

Kossuth provided public records concerning the April 1, 2003 election. I have appended to this

Declaration as Exhibit 3 a true and correct copy of plaintiff Andrew L. Colborn’s Nomination

Papers for the Town Constable for the Town of Kossuth for the April 1, 2003 election, provided

by the Town of Kossuth Town Clerk.

4. I have appended to this Declaration as Exhibit 4 a true and correct copy of the

transcript from February 20, 2007, in the jury trial of the case captioned State of Wisconsin

v. Steven A. Avery, Manitowoc County Circuit Court, Case No. 05-CF-381, including the

testimony of plaintiff Andrew L. Colborn.

5. I have appended to this Declaration as Exhibit 5 a true and correct copy of the

transcript from February 12, 2007, in the jury trial of the case captioned State of Wisconsin

v. Steven A. Avery, Manitowoc County Circuit Court, Case No. 05-CF-381.

6. I have appended to this Declaration as Exhibit 6 a true and correct copy of the

Decision and Order on State’s Motion to Exclude Blood Vial Evidence dated January 30, 2007,

in the case captioned State of Wisconsin v. Steven A. Avery, Manitowoc County Circuit Court,

Case No. 05-CF-381.

I declare under penalty of perjury that the foregoing is true and correct.

Case 1:19-cv-00484-PP Filed 05/09/19 Page 2 of 3 Document 32


Executed this 9th day of May, 2019.

GODFREY & KAHN, S.C.

/s James A. Friedman
James A. Friedman, SBN 1020756
One East Main Street
Suite 500
Madison, WI 53703-3300
T: (608) 284-2617
F. (608) 257-0609
jfriedman@gklaw.com
20587940.1

Case 1:19-cv-00484-PP Filed 05/09/19 Page 3 of 3 Document 32

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