Oracle Corporation et al v. SAP AG et al

Filing 354

Declaration of Chad Russell in Support of 348 MOTION for Leave to File Amended Complaint CORRECTION OF DOCKET # 350 . filed byOracle EMEA Limited, Oracle International Corporation, Oracle USA Inc.. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C, # 4 Exhibit Exhibit D, # 5 Exhibit Exhibit E, # 6 Exhibit Exhibit F, # 7 Exhibit Exhibit G, # 8 Exhibit Exhibit H, # 9 Exhibit Exhibit I, # 10 Exhibit Exhibit J, # 11 Exhibit Exhibit K, # 12 Exhibit Exhibit L, # 13 Exhibit Exhibit M, # 14 Exhibit Exhibit N, # 15 Exhibit Exhibit O, # 16 Exhibit Exhibit P, # 17 Exhibit Exhibit Q, # 18 Exhibit Exhibit R, # 19 Exhibit Exhibit S, # 20 Exhibit Exhibit T)(Related document(s) 348 ) (Russell, Chad) (Filed on 7/17/2009)

Oracle Corporation et al v. SAP AG et al

Doc. 354 Att. 16

Case4:07-cv-01658-PJH Document354-17

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Exhibit Q

Dockets.Justia.com

Case4:07-cv-01658-PJH Document354-17

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Lester, George Final 4/23/2009 12:00:00 PM

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ORACLE CORPORATION, a Delaware corporation, ORACLE ) USA, INC., a Colorado corporation, and ORACLE California corporation, ) Plaintffs, ) vs. ) SAP AG, a German corporation, ) SAP AMERICA, INC., a Delaware ) corporation, TOMORROWNOW, INC., a Texas corporation, and ) DOES 1-50, inclusive, ) Defendants. ) _______________________________) ) ) ) NO. 07-CV-1658 (PJH) ) ) ) ) )

INTERNATIONAL CORPORATION, a )

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY VIDEOTAPED DEPOSITION OF GEORGE LESTER (Taken by Plaintiff) Charlotte, North Carolina Thursday, April 23rd, 2009

Reported in Stenotype by Lisa A. Wheeler, RPR, CRR Transcript produced by computer-aided transcription
Oracle_SAP None Page 1

Case4:07-cv-01658-PJH Document354-17

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Lester, George Final 4/23/2009 12:00:00 PM

19 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 Q. A. Q. When was that approximately? I'm not exactly sure. How did your responsibilities change

when you were promoted? A. My responsibilities were to manage the

technical support engineers and manage the engineers building environments. Q. By environments, what -- what does that

include? A. That would be just PeopleSoft

environments. Q. And can you be more specific about what

the environment is, what it includes? A. It would be a support environment. A

demo installation of -- of PeopleSoft is what was installed to the best of my recollection. Q. And -- and you're speaking of the -- the

PeopleSoft applications? A. That is correct. The client's -- the

client's environment. Q. You say the client's environment. You

mean the -- the software that the client provided to TomorrowNow? A. Q. That is correct. And did those environments also have a

20 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 database component? A. Q. Correct. Was your team also responsible for

building out the database component for those environments? A. Q. That is correct. And where did the database layer come

from that was used to build those environments? A. Where did the database layer software --

actually, I do not know. I believe that was installed by -- that was -- either existed before I got there or that was -- actually, yeah. I think the software for the database layer was in place when I arrived in 2004 so I don't know. Q. Was it the same -- same combination of

database software that you described that you worked with earlier at PeopleSoft, Oracle and -- and -- and SQL? MR. COWAN: Objection, form. BY MR. HOWARD: Q. What -- what different databases were --

were in existence when you arrived at TomorrowNow? A. it. Q. What versions of Oracle were used in SQL Server, Oracle. I believe those are

Oracle_SAP

None

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