Oracle Corporation et al v. SAP AG et al

Filing 853

Declaration of Elaine Wallace in Support of 851 Memorandum in Opposition, Declaration of Elaine Wallace In Support Of Defendants' Opposition To Plaintiffs' Motion No. 1 To Exclude Expert Testimony Of Stephen K. Clarke 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)(Related document(s) 851 ) (McDonell, Jason) (Filed on 9/9/2010)

Oracle Corporation et al v. SAP AG et al

Doc. 853 Att. 20

EXHIBIT 20

Dockets.Justia.com

RICHARD ALLISON November 12, 2009 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 1
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

ORACLE CORPORATION, a Delaware corporation, ORACLE USA, INC., a Colorado corporation, and ORACLE INTERNATIONAL CORPORATION, a California corporation, Plaintiffs, 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) ) ) ) ) ) ) ) ) )

VIDEOTAPED DEPOSITION OF RICHARD ALLISON _________________________________ THURSDAY, NOVEMBER 12, 2009

HIGHLY

CONFIDENTIAL - ATTORNEYS' EYES ONLY

REPORTED BY:

HOLLY THUMAN, CSR No. 6834, RMR, CRR (1-424330)

Merrill Legal Solutions [phone]

f63d89ba-52fe-4889-9b62-b7983812014e

RICHARD ALLISON November 12, 2009 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 215

TEXT REMOVED - NOT RELEVANT TO MOTION

15:27:08 15:27:09 15:27:13 15:27:15 15:27:19 15:27:20 15:27:23 15:27:24 15:27:27

17 18 19 20 21 22 23 24 25

Q.

Is it your understanding that TomorrowNow

had a copy of the Oracle database software? MR. HIXSON: Objection. Exceeds the scope,

lacks personal knowledge, calls for speculation. THE WITNESS: I don't have personal

knowledge that they had a copy of the database. MR. McDONELL: Q. So is it fair to say you

don't know, if they had it, how they got it either? MR. HIXSON: Same objections.

Merrill Legal Solutions [phone]

f63d89ba-52fe-4889-9b62-b7983812014e

RICHARD ALLISON November 12, 2009 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 216
15:27:28 1

THE WITNESS:

I personally do not.

TEXT REMOVED - NOT RELEVANT TO MOTION

Merrill Legal Solutions [phone]

f63d89ba-52fe-4889-9b62-b7983812014e