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 8 Foundation A-5997 for Defendants Joint Pretrial A-5997 Trial Exhibit Statement Undisputed facts Foundational Support section identifying Jeff Henley as Oracles chairman of the board 0RCL00034267 Oracle identifying Jeff Henley as Oracles organizational chart organizational chart identifying Craig Tate chairman of the board ORCLOO1 group Oracles Nov 2010 Trial July 23 GyP GVP Tr at 78110-14 Larry Ellison testifying that Mr Henley is A-64 Oracle 2008 Depo Tr 1184-5 Rule 30b6 testimony indicating that at stands for group vice president production North Central Applications SVI-108747v1 Oracle chairman of the board Oracle 11 as vice president Ellison Blotner 60564 Oracle document in 2006 listing located Craig Tate at as Oracle 0RCL00747255 Group Vice President FiIedO4/26/12 Documentll4l Case407-cv-01658-PJH McCUTCHEN LLP PICKEYF SBN 72257 DONN GEOFFREY HOWARD SBN BREE HANN SBN 215695 JONES DAY BINGI-IAM 157468 MInELSTAEDT ROBERT 584 JASON McDONELL SBN 115084 ELAINE WALLACE SBN I97R82 555 California San Francisco Telephone CA 94111-4067 415 393-2000 Facsimile 415 Facsimile Three San Embarcadero Center Francisco 393-2286 26th Street CA 415 415 Telephone 626-3939 875-5700 bree.hannbingham.com ewaLlace@jonesday.com FLEXNER LLP BOlES SCHILLER DAVID BOLES Admitted Pro Hac Vice JONES DAY 333 Main ThARAN GREGORY LANLER SBN FROYD SBN 220776 J4E Street NY 10504 TeLephone 914 749-8200 dboies@bstlip.com Facsimile 14 IS Harrison St. SBN 144177 CA 94612 Telephone 510 874-1000 jfroyd@jonesday.com JONES DAY shoItzman@bsfllp.com DORLAN DALEY SBN JENNIFER GLOSS SBN 500 Oracle Paway MIS Redwood City CA 94070 Telephone COWAN SCOTF JOSHUA 129049 717 154227 57 Suite TX Pro Hoc Admitted Pro Hac Vice Vice 3300 77002 832 832 Telephone Facsimile 650.506.4846 Admitted FUCHS Texas Houston 239-3939 239-3600 swcowan@jonesday.com 650.506.7114 dorian.daleyorac1e.com glossoracle.com Jennifer 17 is 739-3939 739-3900 tglarnerjonesday.com 900 Suite Oakland Facsimile 16 HOLTZMAN 94303 650 650 Telephone STEVEN 1999 L3 CA Alto Palo 138784 Road Embarcadero 1755 Armonlc 12 Floor 94104 jmcdonell@jonesday.com geoff.howardbingham.com 11 060359 ramittelstaedtjonesday.com donn.pickettbinghamcom 10 133 of Pagel Attorneys Attorneys Oracle SAP for Plaintiff International AG for SAP America Inc TomorrowNow and Inc Corporation 19 NORTHERN 20 DISTRICT OAKLAND 21 et COURT STATES DISTRICT UNITED ORACLE USA Defendants at OF CALIFORNIA DIVISION Case No 07-C V01658 Pill EDL 22 JOINT PRETRIAL Plaintiffs STATEMENT 23 Date SAP AG 25 Time Defendants 3rd Judge at May 24 2012 230 pm Place IA lIon Floor Courtroom Phyllis Hamilton 26 27 28 SVI- Casc 107234v JOINT PRETRIAL STATEMENT No 07-CV-01658 PJH EDL Case407-cv-01658-PJH FiIedO4/26/12 Documentll4l 99 Charles lOU Safra Catz 01 Safra Catz was the Chief Financial was Phillips Jeff Henley 103 On or about Board the this held has held and 2004 2010 to 2004 since position from 2005 of Oracle Officer Chairman of Oracies is has 133 in from some Lime Oracle of of Oracle and the President is 102 the Co-President of Pagel3 2008 to this position since 2004 information with the with That document 10 was made 11 information 12 regularly 13 as at 15 16 the 17 document at 20 regularly 21 as or near 24 connection 25 PJF 26 business 27 therein 28 kept No true of those made by the SAP matters of fmancial connection EDL PJF business record by forth therein set business that from or in the course kept conducted regularly in 07-C V-U 1658 of an copy of the matters knowledge and Customer Report.xls eta. Case is report of activity July 15 2009 Defendants name -SAP Customer Report file USA Inc et SAP at is of the occurrence by with person activity et July 2009 at Case No true AG SAP-0R00789887 copy of an of the matters knowledge set of those made by and customer produced in connection lipdate.xls 07-CV-01 SAP forth the regularly 658 record by therein or in kept conducted with EDL PJF business matters of financial report That was that from the course business of activity practice On with or with the from SAP USA information made at transmitted et au SAPAG the time by JOINT activity PRETRRL el is at true with and knowledge No copy 07-C V-01 658 of the matters of those made by in of an SAP the Caj No STATEMENT of report 0-30-09.xls Case of the occurrence person business 1587 13 SVI-th7234v customer produced Customer Report Updated SAP-OR0084 or near conducted Defendants Inc bates-stamped was of regularly 2009 name file Oracle Litigation document that in the course November or about the That record by with activity business information EDL 15 of the occurrence person the time conducted 105 financial the transmitted regular 23 time by bates-stamped information 22 the or about Oracle litigation 19 AG SAP at SAP-0R006036 business On with made ci 5SAP 0060361 customer produced practice information IS or near conducted 104 14 Inc bates-stamped transmitted regular USA Oracle the litigation SAP-OR name file Defendants 2009 January set forth matters regularly O7-CV-01655 PJH EOL Organization Chart ORACLE Page Aria of People Search CEO ______ _____ DhocItll I9Od GPO r..d 5540 Totul Law..n LV _________________ ______ .S UL x.ahU1 AsSMt Ofac Pr. DftheCEOatId Totat s. pEssa AsS1 Exosdv of Totat TO$at68602 tha CEO and _____________ O4ce Pr Corndtg _______ Totsi 33235 S4 fl ToS 13505 _______________ Ca Tolal kda Saoq ViCe eSdtt 463 16712 Highly Confidential nfomation Attorneys Eyes Only ORCL00034237 NA Commercial Apps Organization ERP North Central MidSize Co Tn fl us h2Ji Sr MUAi sh Oil Ted IIl RWO1 MIt cI_ Co ________________________________________________________________________________ NC PM.Psa NC WSSbhCnRtuEza NC u0il Slabla L11 l.n Asia Co Its Juu MM ml5iie Jj4eI htzat CIS.JA1 MSS JDEE In ASIA Mr PMrrtd Co Ml ThuZ al Midoa JOlNO SLuwS Proprietary and lii McS ASia lAS Ca ASIA Coins MlaS IAN Mt ASia NO Cinga Lii 1U MM SuSj Sal Cetts MN Co Oncl Silt CII Co NswCI Oil Ocaw Ii A@AL2 PI CoIixitt Mid flflW iAI CIn.S IL CsjlTs Ca C4tigc.d Toni Ci Snc uSii Asi N.tNaqOtlge Nil Co Ca Crfr.ifl Cuani OH J.ffSMn TDI MM IMs Kids Wi Clik.qo Ctd iDj IS IAhiu.$i ________________ MiTi eTwr ftM LIIdSJz Co NaqMIik.e StIjitt CJrlno.L MM Oi.mS Las Ci St MM MS2a Nil icW bM froae Ca 1li Ea CSimjl RsciN4 Mui Co Sz4 Ca IL Othigo SIS. Cued MM Co fl Co tO I4oMI..Th 06/20/2008 Confidential HIGHLY CONFIDENTIAL INFORMATION tdSe ASia Srcdisi MM ias Co sPdSsNott Auetn LMdS DdTM Oracle Uiy MM M6I Co InsLa OiOol SI a.t JaM sum SM Mi Ca o.o in il Nil Ca i1 EflhJOIjS.S dLMO ed.fl.are 5erb MMMSI.Ca Pg Sll CSao MIIn. sd JoJii AsiA .aLa dwOaINl M.CO qr MMMpdS.CCCa4XeI Ciwago Co NC ke%io Rile a.drey WiE 1W MCCI L. A5MISaC Si Mirnellois MdIe RM NC Prod4CedJi 0jo-L MNflhSgeCo.Sr NM N.N5 aalr ce$ aft Ca Jat 8ol SrÆthw AI NC MuraeepotWi MsC Save MaC@ AUORNEYS EVES ONLY MM ClaMS MbmpcS CIoIL RALCLE 12 0RCL00160564 UNITED STATES NORTHERN BEFORE THE ORACLE CORPORATION HONORABLE DISTRICT DISTRICT PHYLLIS FT OF CALIFORNIA HANILTON AL JURY JUDGE TRIAL NO PLAINTIFFS VS SAP COURT 07-01658 PJH VOLURE AG ET AL PAGES DEFENDANTS 754 CALIFORNIA NOVEMBER OAKLAND I4ONDAY __________________________ TRANSCRIPT OF 946 2010 PROCEEDJNG.S APPEARANCES FOR PLAINTIFFS BINGHAM I4UCCUTCHEN LLP THREE EMBARCADERO CENTER SAN CALIFORNIA FRANCISCO 94111-4607 ZACHARY ALINDER HOLLY HOUSE GEOFFREY 14 HOWARD DUNN ATTORNEYS PICKETT BY AT LAW SCHILLER FLEXNER LLP HARRISON SUITE 900 STREET OAKLAND CALIFORNIA 94612 DAVID BOILS STEVEN ATTORNEYS AT HOLTZMAN BOlES 1999 BY APPEARANCES REPORTED BY CONTINUED RAYNEE DIANE RAINEE vr IL ier ClIR CSR MERCADO CRR IL NEXT NERCADO SKILLMAN RMR CRR FCRR LAW PAGE CSR CSR NO NO CCRR 8258 4909 510 4517530 Riiinn 15aa486af-96d5-4O92bO78-2f276d57563o 781 Page IF WOULD YOU SIR THERE YOU A4089 TO BINDER DOCUMENTS REVIEWING ARE YOUR IN TURN TAM YOU THNil YOU AND HENLEY JEFF SEE JOB AT COPIED THERE TIME YOURE BETWEEN EXCHANGE THIS THAT SEE YOU EMAIL AN AND MS CATI AND THATS THAT IDO 10 11 WHAT MR WAS HENLEYS THE IS MARCH OF 2005 WAS 12 TBE THE 13 30 14 AND 16 THATS YOU BOSS HAVE DIRECTORS OF HE WAS YOUR BOSS CORRECT 15 EXTENT BOARD OF OUR CHAIRMAN SHE MS SHE CATZ REPORTING WAS DIRECTLY TO YOU AT THE TIME CORRECT DOES STILL YES YOU SOMEBODY 20 TRUST AND RELY ON ASSUME YES 21 MR LANIER 22 MR BOlES NO 23 TRE COURT ALL YOUR HONOR WE RIGHT 25 RECEIVED _.r 4089 ADMITTED EXHIBIT DEFENDANTS iIsan OF OBJECTION 24 vta MOVE ADMISSION IN A4089 EVIDENCE FC Sa aSUf.96d5-4O92-bO18.Zf276d57563O 94 OF REPORTER CZBTflICATE tE REPORTERS FOR UNITED THE HEREBY CALIFORNIA BY ON MONDAY SHORTHAND 10 DIRECTION INTO 11 COMPLETE 12 THE AND REPORTERS TIME 2010 SAID 15 FROM THE VALIDITY TRANSCRIPT SAID PROCEEDINGS COURT MAY BE OF TI-IC VOID REPORTERS UPON 24 25 AS MERCADO RAYNEE DIANE CSR BOUND BY US OF AND/OR REMOVAL SKILLMAN IXC4L.C14 R1R CSR CR FCRR RPS FCRR TUESDAY NCVEPIBER 2010 OUR FULL IS rILE 22 23 UNDER CERTTFIC1TION DISASSEMBLY tL 21 CERTIFIED FOREGOING THE WERE OF FILING 14 18 AL El TRANSCRIBED THAT OF AG SAP THERAFTEP WERE RECORD AL NOVEMBER TYPEWRITING TRUE THE 13 ET OF DISTRICT PROCEEDINGS FOREGOING THE INC USA US AND THAT CERTIFY NORTHERN COURT OFEICIAL SKILLMAN DIANE AND STATES ORACLE C0701658PJR REPORTED MERADO RAYNEE CCRR AT BLOTNER RICHARD July CONFIDENTIAL HIGHLY UNITED NORTRERN SAN DISTRICT STATES DISTRICT OF FRANCISCO 23 2008 COURT CALIFORNIA DIVISION 000 ORACLE CORPORATION Delaware corporation ORACLE Colorado USA INC and ORACLE corporation INTERNATIONAL CORPORATION California corporation Plaintitfs No vs SAP AG German corporation Delaware INC SAP AMERICA corporation INC DOES O7CVl6SSPJfl TOMORROWNOW corporation inclusive Texas 1SO and Defendants DEPOSITION RICHARD Wednesday CONTAINS REPORTED BY HIGHLY CYNTHIA OF BLOTNER July 23 2008 CONFIDENTIAL PACINI CSR MATERIAL 6ll7 RNR CRR Ol4ll414 Merrill Legal Solutions 800 8699132 fa6333c2.5247.4156-8fef.c02a2d623366 RICHARD BLOTNER 23 July CONFIDENTIAL HIGHLY 2008 118 Page starting appear under the have theres Bouchers name GVP their Mr letters What under does GVP Group vice Are 10 MS 11 12 me president 14 have GVP 15 level 15 vice of level Mr or presidents that level that Overbroad The their you the Im Boucher underneath VPs vice relation to In WALLACE vice names Objection sales So clarify them of earlier WITNESS North American several for senior the MS HOUSE THE stand and president those referred to you people who number of 160553 what level sorry would people names referred to be at below is below that Yeah Let the senior that that under The who the the first senior presidents Yes 18 And Bouchers 20 more along 23 24 25 the geographical MS 22 sorry organization Yes 21 Im it Was forget one that was John organized lines was WALLACE Lets mark this one as Exhibit whereupon Defendants Exhibit was marked for identification Merrill Legal 800 Solutions 8699132 fa6333c2-5247-4l %-Sfet-c02a2d623366 RXCHARD BLOTNER Ju1y HIGHLY CONFIDENTIAL declare the under foregoing 15 true and t$C. of ___________ penalty correct of 23 2008 perjury that Subscribed at California this3 day 2OO8 RIC1PRD BLOTNER 1.0 11 12 13 14 15 .LI fl 18 19 20 21 22 23 24 25 149 Merrill Legal Solutions 800 8699132 Merrill Leg1 Solutions YOUR INSTRUCTIONS FOR IEADING/CORRECTING To assist pages in you directions makIng corrections below back to the This is Please the final read it directly you are in your deposition furnish follow the of the possession original the transcript transcript do NOT make any changes on the transcript any of the questions After completing your review the designated Signature please line arid sign return ERRATA Page please make of necessary please Do NOT change above testimony If you find any errors or changes you wish to the errata sheet beside the page and line numbers on version pages sheet are careftilly insert the corrections If your deposition attach the errata of to them and additional If DEPOSITION the last page of the transcript to the errata sheet your attorney SHEET Line ii Change_____ Reason_________________________________________ Change Reason Page Line Change Reason_______________________________________ Change Reason Change Reason If change Reason Change Reason Change Reason Change Reason___________________________________________ to the above changes certify that the transcript is true and correct made certify that the transcript is true and ________ Subject 7i_ No changes have been /4 signaturØ correct ___ date OF REPORTER CERTIFICATE CYNTHIA Reporter truth whole the That said me by 10 witness 11 computer was and that reduced sworn to tell but the the truth before 13 review 14 If 15 provided to 16 appended completion at person the to down taken was and my direction That the the nothing disinterested thereafter under 12 and deposition therein stated place in in the time and the said cause within-entitled shorthand witness the by me duly was foregoing deposition truth that certify hereby Certified ShorLhand PACIt1It in the testimony of typewriting by supervision of the not hereto of requested transcript any the 19 deposition nor in 20 this and 21 parties cause or any that by during certify either attorney 25 for made reporter 18 22 changes further 17 was deposition that the was the the am any of way interested am not thereto and deponent period not parties related requested are of counsel to the in the to allowed said event any of of the fo DATED CYNT IA PACINI CSR No 6117 or From Mio SchIiren Sent Friley lo Jefl Cc Keith Subject RE FW EW FYI woke pracbve me thaI peffiormt The jrnce.sNnorocI..cvn PM 30.20061024 June NsnJ.y Crolg Tait bbck John Bouchen jim Tesla with sol she has vetella hr el e.llv the is she thai lead Ann do will McFarland Frarico OSO from and wwPang however Kith on To Hwworth the the go oTher is rlty and hat Oracle Their stand lie todd the has apfrtn his in of part things dredio.i stuaon the tiarule Jim pojecl raqon on where status no.. IC does sock 914 thought anything ii 5pm at yesterday na o.e he speot alroy dditl botwewi met wit emctions us wtd agaSt we wtio Ne LInda rtffs convrallon today So ow on is nothh Pne donna and vdatas further OUT aclon plan flegardw Mce Schtimgoa Message Heey Sent Friday une 3t 2006 4Q1 ---Oægbial From Jeff Cc hn ect EW Subject doWt what intend has in time The on big call is problem win but lunch If you purpose her feedback et to is want guys can on our cofletm out hying and bitch will not be vet That posilive will me help in just of the was It call not will arent Franco on overrule rarely try to show loam his shake fair getting to unroaona2.e the given it sure the be hen think Late at otice peraon Franco 9SSLt not really loose tasonabie that we him we if wbats to on rully going we probably guante think we her torpedo welt doomed and lose here Jeff Thanks Highly ConftdeThaI CEO up The it brings at McFarnd Btck fMr chance thax we ct etc Otherwise will stale Im look fonard to the weekly cMl Mike knows the windows form she to she us Kth WInk Tate on the that if lei professionafly Qaig true me flIfl and are hes unless us wth agathst thin2s if call Panco ahfs Unda donna and flanco Fnnco with we dont Franca she and stacked bow see etwe cowersatbn the since seem to rnIPeshhgenOorecom Phore meiaion to IMI she deck The BotcMr FYI transpjjtd checking call PM Ta Cza and Oat you expect sm.tI but vindow to didnt think it an tIwitflo was to could unreasonsble tbe calls not arent for as watt make today dealing to run but with suggest she blew dad is ie eaiI Infonnation extenced alt hne she is trail tc reach ptazrnurg with Mtomeys out to Fraflcos Eyes to be her on directly the athir Franco and be just call have careful been am She trying Was to Monday keep not it ORGLOO74fl51 Only Noznmtlq Case No WflXTctCIflNTA 407-cv-oIosgPsHtDt DDArFtrbaIt Dic Nt A-6411 Ad_______ By___________ Nicole Hcath that dont obviously way that prepared she may you and Donna Ill send want on it the be con need to on the call but we finds out about it her if she info call under be email seperata Regards Craig From Sent Jeff LmllLQ Henley 359 PM June 30 2006 Friday To Craig Tate Cc Keith Block can be the on could have clear the doubt dont slot it John Boucher FW FW Re Subject call been think its thrash through the unreasonable but voicemail Craig Tate at least McFarland Block we thought list initial small team of people should have should have Perhaps been on the call had else something at that one and to but so only time notice before our morning rahlls Linda Keith 10 Calif time at might have that Ann should also call think and Franco The only time she gave us today was noon her time difference today giveil the short Monday morning on the call today but and air between conversation Monday would make donna mike.schflmqen@oracIe.com Phone 1-4 call as to followup with Franco she cant say didnt to try meeting todays shes true reach to form Id suggest try her out If Ill probably just get wrote Jeff We have Please set see Given your un ut call note previous for below Reith to On the exposure to talk co weekly F.ranco Franco on call status and the tone Ronday at 1000am POT earlier today of thi with Ann conversation Thanks Craig Ressage--From Rith Block Sent Friday June 30 2006 ------OriginaL .Block0oraclecom 232 PIJ To Cc Craig Tate Linda McFarland Smith John Boucher mike.sohlimcien@oracle.com .Rc Ft Phone conversation between France and keith Block Subject Id tuck be willing to do this call lets swing away her Craig Tate in the think morning the next approach week should Sean whistler time be are it we wasti wrote Linda Highly Confidential Information Attorneys Eyes Only 0R0L00747252 The back response Keith just could Let me from was 1.5 staous update bnt wrong know office off got be Francos what hr honestly dorit 10th July think call w/ pushed the and her 010 directed France has back them think you Craig --Original Message--From Donna Wnlderzak imailtcDonna Malderzak@Haworth Sent Friday June 30 2006 155 PM To Craig Tate RE Phone conversation Subject between France coin Keith and Block Craig France said Keeping the will he with talk difference time on you in mind from Monday he will be Italy hours ahead what Walderzak Executive kdmin Pasistant One Bawooth Center Donna Holland Direct MI 4923 616.353 1955 Fax 616.3931033 Donna.walderzakSbaworth Originai From Craig corn Message Tate June Friday 30 2006 122 PM Palderzak RE Phone conversation between Subject Scent To Donna France and Keith Block Thank you Craig Origiral Message-From Donna Waldersak Sent Friday June 30 rnaiitoiDonna 2006 128 .Walder-zak@Haworth corn PM To Craig Tate Subject RE Phone conversation Hghiy Confidentia Information Attorneys Eyes Only between France and Faith Block 0RCL00747253 Craig Franco ctua1ly is on vacation but will be to happy forward your mes you Thank Donna Walderzak Executive Admin Donna Haworth One Assistant Center MI 49423 1olland 616.393.1959 Direct Fax 616.393.1033 .walderzak@haworth Donna con ---Crigiual Message From Craig Tate rafltocxaig tate9oracle.com June Sent Friday 30 2006 126 P14 To Donna Subject Ann Harten Naldersak Phone conversation RE between Franco and Keith Slock Donna Thanks for the response My only concern is that laworth Is on very Regards Craig ---Original Message FrOm Donna Walderxak fmeiltcDonna.Waiderzak9Haworth 1216 P11 Sent FrIdsy June 30 2006 To Ann Subject Is That Monday Please Thank Harten Craig.Tete6oracie.com Phone conversation between July and Keith Block Franoc will be leaving shortly after 200 PM today PM EST could be available for call at 600 correct 107 Franco .cos he advise you Walderaak Executive Admin Donna Oe Maworth Assistant Center MI 49423 Holland Direct 616.393.1959 Fax 616.393.1033 Highly Confidentiel Information Attorneys Eyes Only 0RGL00747254 r_na ide we Origina From Sent Message--- Karten t.n.n 1212 June 30 2006 Friday Craig.Tateorace.con To Re Subject Phone conversation Donna tD Craig am copyirl9 around 200 PM us after to Donna speak SST he confirm Waldertak between that Donna may returns PM be Franco Elanchi and Keith Block France Franca is leaving able to provide today for suggested Europe time fo Ann tnn VP Harter Information Inc Global Haworth ire1ess Sent from my BlackBerry Handbeld Original Messag Craic rate From To CC Services Ann Harten mrke.sch11mgenorac1ecor Sent Jun Fri Subject Phone 30 115233 2006 conversation between Franca and Keith Block Ann Keith has time between 330pm EST and 500pm EST today for phone cart Cra Craig It Tate Group Vice President North Centra Applications Oracle 312 LISA Erm Suite 1525 Cincinnati Phone Fax Highly Confidential Information Inc Street OH 45202 5136292229 51365L4463 Attorneys Eyes Only Mobile Email 5137034529 Craiq.Tate8oracie.cout 0RCL00747255

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