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Mitchell Silberberg & Knupp LLP Case 2:11-cv-10294-MMM-JCG Document 117 Filed 11/13/12 Page 42 of <strong>45</strong> Page ID #:2034 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 intelligent, capable, open minded, curious and passionate woman takes a leadership position in understanding and accepting an alien intelligence. 129. The Grace Augustine character combines these two themes that form a pattern in my work: the good scientist, meant as a role model, and the strong intelligent woman, also a positive role model. 130. My real-life inspirations for Grace’s character included researchers like ethnobotanist Wade Davis. I read his early book, Serpent and the Rainbow, in the mid-1980s, as part of my general interest in anthropology and indigenous cultures. In college I took a class in Cultural Anthropology and became fascinated with indigenous cultures. During college I also read the best-selling books of Carlos Castenada, who worked with Yaqui shaman Don Juan to understand the spiritual properties of consciousness-altering plants. 131. In Wind Warriors, there is a scientist character named Dr. Ian MacTerry, who is described as an “archeologist.” However, he functions in the story more as an ethnobotanist, studying an indigenous tribe and a (fictional) psychotropic drug they are using called yupumo. He believes that the visions induced by the drug contain real information that will lead him to the object of his quest. Just as Grace Augustine ultimately dies in the process of experiencing a vision, in which she contacts the alien mind of a plant-based being called Eywa, MacTerry risks death, and indeed almost dies, to experience a vision created by plants which reveal themselves to be of alien, intelligent origin. 132. The themes of scientists in general, specifically a scientist studying alien plants in a rainforest setting, and even more specifically a female scientist who runs a science research program created by a mining company on an alien planet and who operates a genetically engineered alien via a mental and technological link, all precede my first contact with Mr. Morawski, as 42 DECLARATION OF JAMES CAMERON
Mitchell Silberberg & Knupp LLP Case 2:11-cv-10294-MMM-JCG Document 117 Filed 11/13/12 Page 43 of <strong>45</strong> Page ID #:2035 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 demonstrated by my prior works. And these prior works can be traced to influences which are in the public domain and widely recognizable. 133. As shown above, there is a direct through-line between my interests, activities, and creative output in the 1970s and 1980s, right through to the resultant concepts that appear in the treatment for Avatar, written in 1995. I required and received no input whatsoever from Mr. Morawski in order to form these concepts. Development of Avatar 134. In 1996, I sent copies of my scriptment for Avatar to Twentieth Century Fox Film Corporation (“Fox”), and Lightstorm initiated negotiations with Fox for initial funding for design and technology development in order to make Avatar. From about 1995 to 1997, I met with others at Lightstorm and members of Digital Domain to brainstorm about the technology needed to make Avatar, known also as “Project 880.” However, I elected not to go forward with the project at that time because I believed that the technology needed to make Avatar was not sufficiently developed. 135. In 2005, I decided to re-explore whether the technology had sufficiently developed to make Avatar. In December 2005, Lightstorm signed an agreement with Fox assigning Fox rights in Avatar, including the scriptment I had written in 1995. 136. Beginning in or about late 2005, and continuing through approximately April 2006, I wrote the first draft of the script for Avatar. In or about January 2006, I was forwarded a letter that appeared to be from Mr. Morawski, in which he apologized for interrupting my “writing session” and asked for a meeting with me before I “start[ed] shooting [my] upcoming feature.” Exhibit 27 is a true and correct copy of that letter. To the best of my knowledge, when I received this letter I had not spoken with Mr. Morawski since 1991. 43 DECLARATION OF JAMES CAMERON
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45-page sworn declaration - Business Insider

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