Oracle Corporation et al v. SAP AG et al

Filing 455

DECLARATION of Joshua L. Fuchs Declaration of Joshua L. Fuchs in Support of Defendants' Opposition to Plaintiffs' Motion to Amend Complaint - Correction of Docket # 382 filed bySAP AG, SAP America Inc, Tomorrownow Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B-1, # 3 Exhibit B-2, # 4 Exhibit B-3, # 5 Exhibit B-4, # 6 Exhibit B-5, # 7 Exhibit B-6, # 8 Exhibit B-7, # 9 Exhibit C-1, # 10 Exhibit C-2, # 11 Exhibit D, # 12 Exhibit E, # 13 Exhibit F, # 14 Exhibit G, # 15 Exhibit H, # 16 Exhibit I, # 17 Exhibit J, # 18 Exhibit K-1, # 19 Exhibit K-2, # 20 Exhibit L-1, # 21 Exhibit L-2, # 22 Exhibit L-3, # 23 Exhibit L-4, # 24 Exhibit L-5, # 25 Exhibit L-6, # 26 Exhibit L-7, # 27 Exhibit M, # 28 Exhibit N)(Lanier, Tharan) (Filed on 8/31/2009)

Oracle Corporation et al v. SAP AG et al

Doc. 455 Att. 2

Case4:07-cv-01658-PJH Document455-3

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EXHIBIT B-2

Dockets.Justia.com

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JOHN M. BAUGH February 7, 2008 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 150
IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION Case No. 07-CV-01658 (MJJ) ORACLE CORPORATION, a Delaware corporation, ORACLE USA, INC., a Colorado corporation, and ORACLE INTERNATIONAL CORPORATION, \a California corporation, Plaintiffs, v. SAP AG, a German corporation, SAP AMERICA, INC., a Delaware corporation, TOMORROWNOW, INC., a Texas corporation, and DOES 1-50, inclusive, Defendants. ______________________________________________________ VIDEOTAPE RULE 30(b)(6) DEPOSITION OF: JOHN M. BAUGH - February 7, 2008 - Volume II TomorrowNow, Inc. (Highly Confidential - Attorneys' Eyes Only) ______________________________________________________ PURSUANT TO NOTICE, the Videotape Rule 30(b)(6)deposition of JOHN M. BAUGH was continued on behalf of the Plaintiffs at 1700 Lincoln Street, Suite 4100, Denver, Colorado 80203, on February 7, 2008, at 8:40 a.m., before Sandra L. Bray, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public within Colorado.

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JOHN M. BAUGH February 7, 2008 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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09:34:47

25

A.

When we first compiled this document, I

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JOHN M. BAUGH February 7, 2008 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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09:34:56 09:35:12 09:35:14 09:35:19 09:35:24 09:35:27 1 2 3 4 5 6

had thought that all of our environments were in SAS Environment Portal and dotProject, but it was only in performing research over the last few days in preparation for this deposition that we found, looking at BakTrak, that there was some additional environments that were not in this document.

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JOHN M. BAUGH February 7, 2008 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 318
REPORTER'S CERTIFICATE STATE OF COLORADO CITY AND COUNTY OF DENVER ) ) ) ss.

I, SANDRA L. BRAY, Registered Diplomate Reporter, Certified Realtime Reporter, and Notary Public, State of Colorado, do hereby certify that previous to the commencement of the examination, the said JOHN M. BAUGH was duly sworn by me to testify to the truth in relations to the matters in controversy between the parties hereto; that the said deposition was taken in machine shorthand by me at the time and place aforesaid and was thereafter reduced to typewritten form; that the foregoing is a true transcript of the questions asked, testimony given, and proceedings had. I further certify that I am not employed by, related to, nor of counsel for any of the parties herein nor otherwise interested in the outcome of this litigation.

IN WITNESS WHEREOF, I have affixed my signature this 12th of February, 2008.

My commission expires January 16, 2012.

__X__ _____ _____

Reading and Signing was requested. Reading and Signing was waived. Reading and Signing is not required.

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