Oracle Corporation et al v. SAP AG et al

Filing 1201

Declaration of Tharan Gregory Lanier in Support of 1182 Statement Declaration of Tharan Gregory Lanier iso Joint Statement Regarding Exhibit Objections filed bySAP AG, SAP America Inc, Tomorrownow Inc. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59)(Related document(s) 1182 ) (Froyd, Jane) (Filed on 8/2/2012)

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EXHIBIT 12 Foundation for A-6205-1 Defendants 0RCL00034305 Oracle Senior Trial Exhibit Oracle Director A-6205-1 organizational Support Sales Foundational Support chart identifying Richard Rick Cummins as an Mid-Market Cummins Sept 16 2008 Depo Tr at 102-11 143-23 1425-1511 276-23 4911-13 Rule 30b6 testimony by Cummins identifying Cummins as Oracles senior director of support renewals/sales discussing the support Feb 23 2010 Oracle Cummins as Richard SVI-108747v1 in North America describing sales/renewals Expert Report Senior Director his responsibilities and team and reporting structure of Paul Meyer redacted Support Renewals for excerpt identifying North America Chart Organization ORACL. Page Aria People of Search set ..- Directs Total 367 an VP Suppod RiewS Dlrocts TotaL taDthaa Dror Suppod Sas SdJes 211 thhIt.aLinter Qacto. 5Mpport 8pIM4- rotar TstZg SSss ToTaL2 Dy11nS $LQimcQLwoj Coordlna Suoqi mocd QCWliQfl Sublicene Pru4ecI Sr btSCa Total 19 Sntnic TotaLs St tot43 .._ hghIy ConfjdentaI Information Attornev Eyes Ord 0RCL00034305 RICHARD CUMMINS September 16 2008 ATTORNEYS EYES ONLY HIGHLY CONFIDENTIAL INFORMATION Page UNITED STATES DISTRICT DISTRICT NORTHERN SAN OF FRANCISCO COURT CALIFORNIA DIVISION --OOoDelaware CORPORATION Corporation ORACLE USA INC and Colorado Corporation ORACLE INTERNATIONAL CORPORATION ORACLE California Corporation Plaintiffs No Vs SAP AG SAP AIVIERICA German EDL 07-CV-01658-PJH Corporation INC Delaware CORPORATION TOMORROWNOW and Texas Corporation 150 Inclusive INC DOES Defendants ________________/ 30b RULE VIDEOTAPED ORACLE RICHARD CONFIDENTIAL Reported By Job 412495 CUMMINS 16 September Volume HIGHLY ARLEN Merrill Legal 800 2008 255 Pages ATTORNEYS INFORMATION WENDY OF CORPORATION Designee Tuesday DEPOSITION CSR 4355 CRR EYES ONLY RNR Solutions 8699132 e6a0856a-Oee4-4b35.albf-ca2oaf8a26bc RICHARD HIGHLY September 16 2008 INFORMATION ATTORNEYS EYES CUMMINS CONFIDENTIAL ONLY 10 Page Understood Where do Oracle 0913 What North Corporation is Im have long Edwards which acquired by Oracle ii industry for ten MR McDONELL 12 was renewals support So years that for by Ive the in Oracle have we Exhibit 42 with was was in the job since this 3D which Peoplesoft been With Can position 2005 since acquired Defendants 13 2005 marked marked for identification 14 MR 16 marked 17 Im MCDONELL 42 showing you whats been record as Exhibit 18 19 MS HOUSE TUE Can you WITNESS identify that for the Yes 20 21 22 in this morning MR So with When 25 is is various Its that my document brought notes document you prepared Yes 24 what This McDONELL 23 0914 of you had Oracle 10 0914 director America Within 0914 job your senior How 0913 work you Yesterday Merrill did you Legal 800 prepare it Solutions 8699132 eaOO5sa.O..4-4b35-afbf.caflafaa2sbc RICHARD HIGHLY September 16 2008 INFORMATION ATTORNEYS EYES CIJMMINS CONFIDENTIAL ONLY Page those of offerings of business side support When 0918 the really developed 14 existing came to you separate did it have Oracle kind renewals team Did support any group merge into Yes And what it or it replace We 0919 10 At what 11 Well you started 14 At Oracle the team the highest level about this you renewal JD Edwards teani said that -- Then right Right 16 17 of moved you Oracle to upon the acquisition Peoplesoft 18 Right 19 And 20 Oracles at that time your group merged into similar group 21 Yes 22 was 23 0919 of talking support at 15 0919 it Uhhuh 13 0919 into level Im the happened the head was your What merged Who 12 happened there head of that support renewals team 24 MS HOUSE 25 MR McDONELL Merrill Legal 800 At that At time that time Solutions 8699132 oBaOBsea-o.e44b35Ibf.ca2oafssflasc HIGHLY RICHARD CUMMINS 16 2008 September CONFIDENTIAL INFORMATION ATTORNEYS EYES ONLY Page At Chris that into reported reported in 0919 to And worked time Chris Madsen Juan well Juergen Jones and who Rottler Juergen has for 15 that structure reporting changed then since No You still report Chris to Madsen Ido 0920 Has tO since you Since 13 support the renewals time 14 At JD your job were part of changed At JD Edwards forming the Peoplesoft Edwards 16 in that 19 function until MS HOUSE 18 Im sorry WITNESS 21 MR MoDONELL 23 24 25 remained you vague You can answer THE 22 Rave today Objection 20 O92t you at group i5 0921 of No 12 nature Oracle joined 11 0920 basic the certifications Im certification But Merrill or rigt or if Do special sure there that is essentially you have any for training there is kind your one you of job special thats specific training Legal 800 Yeah dont to have that it Solutions 8699132 eeaOeS$a4..4.4b35albf.ca2Qaffiaflbc RICHARD HIGHLY September 16 2008 INFORMATION ATTORNEYS EYES CUMMINS CONFIDENTIAL ONLY Page MR hasnt McDONELL changed terms ci in youve been since your Oracle at base My responsibilities mistdken Am 0935 renewals about 10 11 Ensuring in my for space And how 13 that Theres 14 15 go looking do director renew we of our customers whole but process of the process are do want you or what are me you for Give me the general outline 17 The outline is general 18 contacted 19 time frame 20 that we 21 their contract 22 contracts 23 those 25 that that do 16 24 support renewals you details the through base your America support 12 Changed base are your senior as North for havent lets talk about What responsibilities ag36 job responsibilities responsibilities Then Okay 0936 said your you that 0935 0936 thought 27 regarding We their renewal then work purchase get or and that if questions with customers for the order before please the upcoming customer the are ensure to start date there are any questions about the services we of on answer questions Do deal you directly with customers in your job Merrill Legal 800 Solutions 8699132 eGaOSSSa-O.e4-4b35.1 bfca2OafB2Obc RICHARD HIGHLY September 16 2008 INFORMATION ATTORNEYS EYES CIJIvIMINS CONFIDENTIAL ONLY 49 Page and managers North then America Hes delivery So of support support renewals support Mr Rottler for their business offices our Redwood and here headquarters Jones California in City 10 Yes 11 And whats Mr 12 Hes vice 13 support Madsens job of president North America renewals 11 And 15 In Mr Madsen Ido 16 17 this lB 19 have Peoplesoft you the other individuals Exhibit 43 which of page which and At 22 of 23 24 some this JD this individuals 25 these of responsibility for 21 to report terms of 0RCL00087625 20 1007 all Mr At 1006 for job located physically 1006 support are Where 1005 as of renewals support EVP of the well as side whats Mr Rottlers And 1005 business the all responsibility For Merrill Legal if renewals for Lindsey but no is the any legacy Peoplesoft and longer part other other individuals for support 800 chart the number products Kathy organizational Bates individuals support Edwards point is listed on here have JO Edwards renewals Solutions 8699132 eSatBGSa.0004.4b35..1 bt.ca2oafB82Bbc C4INS RICRARD Septeer 16 2008 CONFIDENTIAL MR break for McDONELL the day Im Counsel See you then Thank week next to you going sir VIDEOGRAPHER 1701 videotape number Cummins Going four off marks This in the the the end of deposiLion record the of time Richard is 502 -oOoWhereupon 502 the adjourned at p.m --eDo-- iO declare 12 13 the 14 /VeJi- 15 was deposition foregoing under is and true _____ .C1ifornia penalty perjury Subscribed correct this of IS day that at of 2008 19 Signature of Witness 20 21 22 23 24 25 253 Merrill Legal 800 Solutions 8699132 Errata Sheet Deposition Page Rick of Line 41 1-22 Cummins September 16 2008 Change Reason Change Juans manager to responsibility Juan is is responsible service Clarification delivery for service delivery managers Change 14 No havent havent 124 talked to talked hundreds to customers to No Clarification of customers about TomorrowNow 174 Change 23 less welcome to 176 Change Hutton 207 Change 219 to to the above Correction Murquia Correction renew Correction to or doesnt Change 14 Correction Hunt to new Correction Oracle to Change 245 A72687826 McGee Change were 22 232 Subject more Change 151 IP to IT changes 1er that to does or doesnt Correction Correction the transcript is true and correct CERTIFICATE WFNDY certify that hereby foregoing deposition the whole by and therein said 11 computer me witness 13 review 14 under requested 15 deponent 16 period of the stated before to tell but the are reduced in the to further either 19 deposition nor in 20 this that 21 parties and any thereto DATED of any way of the by deposition was not made the reporter the by during the hereto that of the am not parties interested am not related Cgk of counsel to the said of in the event to any of nc 2008 23 24 WENDY time typewriting the changes certify or the supervision any to at in testimony was appended attorney for 25 the truth down person the completion requested allowed taken that transcript 18 22 and direction and and provided cause sworn nothtng thereafter my If 17 the duly disinterested was That 12 and in said deposition was shorthand 10 me by witness the cause That place was truth within-entitled Certified Shorthand ARLEN Reporter truth REPORTER OF ARLdN CSR No 4355 the or ORACLE USA INC SAP CASE SUPPLEMENTAL AG No Ft AL Ft AL 07-CV-01658 EXPERT REPORT IM FINANCW FEBRuARY OP PAUL FORENSICS 23 MEYER LLC 2010 IALJ MEYER Rick Cunimins Senior Director America Page SuijecI Highly Prolectiw CozfidnitiilI Order Lnftrmition AtWrneIJ5 Eyn Ony of Th1 Support Renewals or North

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