Oracle Corporation et al v. SAP AG et al

Filing 860

Declaration of Chad Russell in Support of 859 Memorandum in Opposition, to Defendants' Motion to Partially Exclude Testimony of Kevin Mandia and Daniel Levy filed byOracle 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, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V)(Related document(s) 859 ) (Russell, Chad) (Filed on 9/9/2010)

Oracle Corporation et al v. SAP AG et al

Doc. 860 Att. 11

EXHIBIT K
Dockets.Justia.com

EDWARD SCREVEN November 30, 2009 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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A. It was called the Tools Group. Q. Tools Group. And how long were you in the Tools Group for? A. I was in the Tools Group until probably close to -- probably close to 1990. Q. And then you were in the Advanced Product Group, correct? A. Right, yeah. Q. And how long were you in that group? A. I think that was probably about 18 months or two years. Q. And then you were -- you talked about being part of the technical staff to Larry Ellison. About how long were you in that position? A. It's -- small number of years. It's hard for me to remember. I mean, eventually I became Chief Corporate Architect. So somewhere -Q. So that job just kind of transferred in to your job as Chief Corporate Architect? A. Right. There was a short period of time where another one of Oracle's very early employees created the job of Chief Corporate Architects reporting to Larry. And I reported to him for a short amount of time. And then he decided to retire and I became Chief Corporate Architect.

ambiguous. MR. WILKES Q. You can answer. A. Well, I think it was significant. I mean, to help provide guidance the way the products are fitting together and the way the products should consume existing Oracle technologies; the way that they should be integrated with other important Oracle applications for our customers. Q. Is it fair to say that those responsibilities all were -- generally relate to the integration of the PeopleSoft products into the overall Oracle family of products? A. Part of it is related to integration of the -of the PeopleSoft applications and to the overall family. Part of it is the way we should exploit existing Oracle technologies to make the PeopleSoft applications better. Part of it is just, you know, the way applications should be built in general. Q. So let me ask you the same questions about JD Edwards. Have you ever worked on developing any of the JD Edwards products directly? A. The answer is the same. So, no, I've never directly written any JD Edwards program, right, but I've been in discussions and many times about the way JD Edwards programs should or could take advantage of

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Q. At any time during those job responsibilities that you have talked about, did you ever work on developing PeopleSoft products directly? MR. HOWARD: Objection; vague and ambiguous. THE WITNESS: Could you define what you mean by "work on developing"? MR. WILKES Q. Sure. Did you develop any of the PeopleSoft product lines? A. I never wrote PeopleSoft code, but I participated in many technical discussions about, you know, the way PeopleSoft products are built; the way they should be built; the way that we should -- the way that we should offer the same functionality in the future; the way those products should use Oracle technologies; the way they should integrate with other Oracle operations. Q. But you've never actually written any PeopleSoft code? A. No, I have never written any PeopleSoft programs. Q. And when you were talking about kind of this high-level understanding of work that you have done on the PeopleSoft product lines, what would you say your level of involvement was in those types of decisions? MR. HOWARD: Objection; overbroad, vague and

existing Oracle technologies; the way that they could be integrated with other Oracle applications, you know; the way that we should -- we should modify the applications going forward to provide a better experience for customers. Q. And the same questions for Siebel. Have you ever been involved on developing any of the Siebel products? A. And the answer would be the same. So, no, I've never directly written any -- any Siebel program, although many times have been involved with and led discussions about how Siebel can or should be taking advantage of existing Oracle technologies. How it could or should be integrated with other Oracle applications, and, you know, how we can take advantage of what's in Siebel to have a better experience for the end customer. Q. Prior to joining Oracle in 1986, where did -can you give me a brief description of where you worked since college? A. I was in college before 1986. Q. Okay. So you joined Oracle right after you left college? A. That's right. That's right. Q. And so you never worked for PeopleSoft directly prior to the Oracle's acquisition of

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