Oracle Corporation et al v. SAP AG et al

Filing 783

Declaration of Holly A. House in Support of 781 MOTION No. 1: To Exclude Testimony of Defendants' Expert Stephen Clarke filed byOracle EMEA Limited, Oracle International Corporation, Oracle USA Inc., Siebel Systems, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R)(Related document(s) 781 ) (House, Holly) (Filed on 8/19/2010)

Oracle Corporation et al v. SAP AG et al

Doc. 783 Att. 17

EXHIBIT Q
Dockets.Justia.com

Ramos, Keren S.
From: Sent: To: Cc: Subject: Attachments: MacDonald, Lucia Friday, April 09, 2010 7:18 AM 'Jason McDonell'; Elaine Wallace House, Holly; Donnelly, Amy; Jindal, Nitin; Lee, Lisa FW: Standard Register: Supplemental Statement of Rick Ball [Untitled].pdf

[Untitled].pdf (171 KB)

Counsel, Oracle objects to the Supplemental Statement of Rick Ball. The Ball Statement was not obtained during discovery, which ended 4 months ago, and it was obtained after Defendants' expert report due date. Statements obtained after an expert due date "do not provide a basis for supplementation since there was nothing to prevent [Defendants] from obtaining them before . . . [the] initial report." December 7, 2010 Email from Elaine Wallace to Nitin Jindal. Ms. Wallace's email confirms that both parties expected the production of customer statements to stop after the later of the end of discovery or the service of initial expert reports. Oracle further objects to any and all present and future efforts by Defendants to obtain additional customer statements and/or declarations. Please confirm whether you intend to seek additional customer statements or declarations at this late stage in the litigation. Oracle's prejudice from such ongoing gathering of evidence will justify preclusion of any such material. Regards, Lucia -----Original Message----From: Braig, Kevin [mailto:[e-mail]] Sent: Tuesday, April 06, 2010 11:07 AM To: Jason McDonell; MacDonald, Lucia; Donnelly, Amy Subject: Standard Register: Supplemental Statement of Rick Ball All: As requested by counsel for SAP, please find attached to this e-mail a supplmental statement executed by Standard Register's Rick Ball. As always, if you have any questions relating to this matter or wish to discuss it further, please do not hesitate to contact me. Kevin P. Braig Dinsmore & Shohl, LLP 937-449-6456 NOTICE: This electronic mail transmission from the law firm of Dinsmore & Shohl may constitute an attorney-client communication that is privileged at law. It is not intended for transmission to, or receipt by, any unauthorized persons. If you have received this electronic mail transmission in error, please delete it from your system without copying it, and notify the sender by reply e-mail, so that our address record can be corrected.

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