Oracle Corporation et al v. SAP AG et al

Filing 931

Declaration of Elaine Wallace in Support of 930 Motion to Exclude Expert Testimony of Paul K. Meyer [Filed Pursuant to D.I. 915 ] filed by SAP 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)(Related document(s) 915 ) (Froyd, Jane) (Filed on 10/4/2010) Modified on 10/5/2010 (vlk, COURT STAFF).

Oracle Corporation et al v. SAP AG et al

Doc. 931 Att. 16

EXHIBIT 16

Dockets.Justia.com

THOMAS ZIEMEN September 30, 2008 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. ) CASE NO. 07-CV-01658 (MJJ) ) SAP AG, A GERMAN CORPORATION, ) SAP AMERICA, INC., A DELAWARE ) CORPORATION, TOMORROWNOW, ) INC., A TEXAS CORPORATION, AND) DOES 1-50, INCLUSIVE, ) Defendants. )

*************************************************** "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY" ORAL VIDEOTAPED DEPOSITION OF THOMAS ZIEMEN September 30, 2008 - Volume 1 *************************************************** ORAL VIDEOTAPED DEPOSITION OF THOMAS ZIEMEN, produced as a witness at the instance of the Plaintiffs and duly sworn, was taken in the above-styled and numbered cause on Tuesday, September 30, 2008 - Volume 1, from 8:45 a.m. to 6:24 p.m., before JAMES M. PLAIR, Certified Shorthand Reporter in and for the State of Texas, reported by computerized stenotype machine at the offices of JONES DAY, 717 Texas, Suite 3300, Houston, Texas 77002-2712, pursuant to the Federal Rules of Civil Procedure and the provisions stated on the record or attached hereto. Job No. 1603-88906

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THOMAS ZIEMEN September 30, 2008 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 86
TEXT REMOVED - NOT RELEVANT TO MOTION

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Q.

Okay.

We already covered that, but was the

assumption when you made those projections that the provider of the service would be TomorrowNow? MR. COWAN: A. Q. Objection. Form.

In the presentation we left that open. (MS. HOUSE) But I'm asking you now your At that point in time on December 23rd when

assumption.

you made that PeopleSoft attack plan, was it your assumption that the entity that would be providing the service that was being discussed in the PeopleSoft attack plan, that entity would be TomorrowNow? MR. COWAN: A. Objection. Form.

But I wasn't asked to -- to make any Here we just were asked to put together a

assumptions.

plan assuming that there will be a -- a maintenance provider for that.

TEXT REMOVED - NOT RELEVANT TO MOTION

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