Oracle Corporation et al v. SAP AG et al

Filing 797

Declaration of Tharan Gregory Lanier in Support of 796 Administrative Motion to File Under Seal Defendants' Administrative Motion to Permit Defendants to File Under Seal Plaintiffs' Documents in Support of Defendants' Daubert Motions and Oppositions to Plaintiffs' Motions in Limine< Declaration of Tharan Gregory Lanier ISO Defendants' Administrative Motion to Permit Defendants to File Under Seal Plaintiffs' Documents in Support of Defendants' Daubert Motions and Oppositions to Plaintiffs' Motions in Limine filed bySAP AG, SAP America Inc, Tomorrownow Inc. (Related document(s) 796 ) (Lee, Jacqueline) (Filed on 8/19/2010)

Download PDF
Oracle Corporation et al v. SAP AG et al Doc. 797 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 26 27 28 Robert A. Mittelstaedt (SBN 060359) Jason McDonell (SBN 115084) Elaine Wallace (SBN 197882) JONES DAY 555 California Street, 26th Floor San Francisco, CA 94104 Telephone: (415) 626-3939 Facsimile: (415) 875-5700 ramittelstaedt@jonesday.com jmcdonell@jonesday.com ewallace@jonesday.com Tharan Gregory Lanier (SBN 138784) Jane L. Froyd (SBN 220776) JONES DAY 1755 Embarcadero Road Palo Alto, CA 94303 Telephone: (650) 739-3939 Facsimile: (650) 739-3900 tglanier@jonesday.com jfroyd@jonesday.com Scott W. Cowan (Admitted Pro Hac Vice) Joshua L. Fuchs (Admitted Pro Hac Vice) JONES DAY 717 Texas, Suite 3300 Houston, TX 77002 Telephone: (832) 239-3939 Facsimile: (832) 239-3600 swcowan@jonesday.com jlfuchs@jonesday.com Attorneys for Defendants SAP AG, SAP AMERICA, INC., and TOMORROWNOW, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION ORACLE USA, INC., et al., Plaintiffs, v. SAP AG, et al., Defendants. Case No. 07-CV-1658 PJH (EDL) DECLARATION OF THARAN GREGORY LANIER ISO DEFENDANTS' ADMINISTRATIVE MOTION TO PERMIT DEFENDANTS TO FILE UNDER SEAL PLAINTIFFS' DOCUMENTS IN SUPPORT OF DEFENDANTS' DAUBERT MOTIONS AND OPPOSITIONS TO PLAINTIFFS' MOTIONS IN LIMINE DECLARATION OF THARAN GREGORY LANIER ISO MOTION TO FILE UNDER SEAL Case No. 07-CV-1658 PJH (EDL) SVI-84019v1 Dockets.Justia.com 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 26 27 28 I, THARAN GREGORY LANIER, declare: 1. I am a partner in the law firm of Jones Day, 1755 Embarcadero Road, Palo Alto, CA 94303, and counsel of record for Defendants SAP AG, SAP America, Inc., and TomorrowNow, Inc. (collectively, "Defendants") in the above-captioned matter. I am a member in good standing of the state bar of California and admitted to practice before this Court. I make this declaration based on personal knowledge and, if called upon to do so, could testify competently thereto. 2. Pursuant to Civil Local Rule 79-5 and the stipulated Protective Order entered on June 6, 2007 in this case, I make this Declaration in support of Defendants' Administrative Motion to Permit Defendants to File Under Seal Plaintiffs' Documents in Support of Defendants' Daubert Motions and Oppositions to Plaintiffs' Motions in Limine. 3. Defendants file this motion at the request of Plaintiffs. The requested relief is necessary and narrowly tailored to protect the alleged confidentiality of the material put at issue by Defendants' Motion to Exclude Expert Testimony of Paul K. Meyer and Defendants' Oppositions to Plaintiffs' Motions in Limine until such time as Plaintiffs may submit a declaration in accordance with Civil Local Rule 79-5(d), and the Court makes a final ruling as to confidentiality of the relevant subject matter. Specifically, the following portions of documents filed and lodged with the Court contain information designated by Plaintiffs as "Highly Confidential - Attorneys' Eyes Only" and "Confidential Information" pursuant to the Stipulated Protective Order in this case: Portions of Defendants' Motion to Exclude Expert Testimony of Paul K. Meyer: portions of 4:14-15 and 10:19-12; Portions of Exhibit 1 to the Declaration of Elaine Wallace in Support of Defendants' Motion to Exclude Expert Testimony of Paul K. Meyer ("Wallace Decl."); SVI-84019v1 Portions of Exhibit 3 to the Wallace Decl.; Exhibit 5 to the Wallace Decl.; Exhibit 6 to the Wallace Decl.; Portions of Exhibit 20 to the Wallace Decl.; -1DECLARATION OF THARAN GREGORY LANIER ISO MOTION TO FILE UNDER SEAL Case No. 07-CV-1658 PJH (EDL) 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 26 27 28 Portions of Defendants' Oppositions to Plaintiffs' Motions in Limine: portions of 19:16-17 Portions of Exhibit 13 to the Declaration of Tharan Gregory Lanier in Support of Defendants' Oppositions to Plaintiffs' Motions in Limine ("Lanier Decl."); Portions of Exhibit 21 to the Lanier Decl.; Portions of Exhibit 22 to the Lanier Decl.; Portions of Exhibit 23 to the Lanier Decl; and Exhibit 31 to the Lanier Decl. I declare under penalty of perjury under the laws of the United States and the State of California that the foregoing is true and correct. Executed this 19th day of August, 2010 in Palo Alto, California. /s/ Tharan Gregory Lanier Tharan Gregory Lanier SVI-84019v1 -2- DECLARATION OF JASON MCDONELL ISO MOTION TO FILE UNDER SEAL Case No. 07-CV-1658 PJH (EDL)

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?