Oracle America, Inc. v. Google Inc.

Filing 509

DECLARATION of RUCHIKA AGRAWAL in Opposition to 496 MOTION in Limine No. 5, 494 MOTION in Limine No. 3, 492 MOTION in Limine No. 1, 493 MOTION in Limine NO. 2, 495 MOTION in Limine No. 4 filed byGoogle Inc.. (Attachments: # 1 Exhibit 1-1, # 2 Exhibit 1-2, # 3 Exhibit 1-3, # 4 Exhibit 1-4, # 5 Exhibit 1-5, # 6 Exhibit 1-6, # 7 Exhibit 1-7, # 8 Exhibit 1-8, # 9 Exhibit 1-9, # 10 Exhibit 1-10, # 11 Exhibit 1-11, # 12 Exhibit 1-12, # 13 Exhibit 2-1, # 14 Exhibit 2-2, # 15 Exhibit 2-3, # 16 Exhibit 2-4, # 17 Exhibit 2-5, # 18 Exhibit 2-6, # 19 Exhibit 2-7, # 20 Exhibit 2-8, # 21 Exhibit 2-9, # 22 Exhibit 2-10, # 23 Exhibit 2-11, # 24 Exhibit 2-12, # 25 Exhibit 2-13, # 26 Exhibit 2-14, # 27 Exhibit 2-15, # 28 Exhibit 2-16, # 29 Exhibit 2-17, # 30 Exhibit 3-1, # 31 Exhibit 3-2, # 32 Exhibit 3-3, # 33 Exhibit 3-4, # 34 Exhibit 3-5, # 35 Exhibit 3-6, # 36 Exhibit 3-7, # 37 Exhibit 3-8, # 38 Exhibit 3-9, # 39 Exhibit 3-10, # 40 Exhibit 3-11, # 41 Exhibit 4-1, # 42 Exhibit 4-2, # 43 Exhibit 4-3, # 44 Exhibit 5-1, # 45 Exhibit 5-2, # 46 Exhibit 5-3, # 47 Supplement 5-4)(Related document(s) 496 , 494 , 492 , 493 , 495 ) (Kamber, Matthias) (Filed on 10/7/2011)

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EXHIBIT 2-12 Highly Confidential - Attorneys' Eyes Only UNITED STATES DISTRICT COURT 1 2 NORTHERN DISTRICT OF CALIFORNIA 3 SAN FRANCISCO DIVISION 4 5 ------------------------- 6 ORACLE AMERICA, INC., 7 Plaintiff, ) ) 8 vs. ) No. CV 10-03561 WHA 9 GOOGLE, INC., ) VOLUME I 10 11 Defendant. ) ------------------------- 12 13 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 14 15 Videotaped Deposition of NOEL POORE, 16 taken at 42 Chauncy Street, Boston, 17 Massachusetts, commencing at 2:05 p.m., 18 Wednesday, September 7, 2011, before 19 Jill Shepherd, RPR, MA-CSR No. 148608, 20 NH-CSR No. 128, CA-CSR No. 13275, CLR, 21 and Notary Public. 22 23 24 25 PAGES 1 - 95 Page 1 Veritext National Deposition & Litigation Services 866 299-5127 EXHIBIT 2-12 Highly Confidential - Attorneys' Eyes Only discussed my report with Mr. Vandette. 2 Q. 3 14:36:07 Did you discuss your report with Erez 14:36:11 Landau? 1 14:36:17 4 MS. AGRAWAL: Objection. Form. 14:36:18 5 A. No. 14:36:19 6 Q. Did you discuss your report with Seeon 14:36:19 Birger? 14:36:22 7 8 MS. AGRAWAL: Objection. Form. 14:36:22 9 A. No. 14:36:23 10 Q. Anyone else you discussed your report with 14:36:24 11 other than Professor Mitchell and 14:36:30 12 Mr. Kessler? 14:36:32 13 14 MS. AGRAWAL: 16 Q. 17 18 14:36:33 I don't recall discussing it with anyone 14:36:33 14:36:39 Did you discuss it with some attorneys; is 14:36:39 that correct? 15 Form. else, no. A. 14:36:43 MS. AGRAWAL: Objection. And I caution -- I 14:36:43 19 instruct the witness -- caution the witness 14:36:44 20 not to reveal attorney-client privileged 14:36:46 21 communications; but to the extent you can 14:36:48 22 answer the question with a yes or no, you 14:36:50 23 can answer. 14:36:52 24 25 A. Yes, I have. I have discussed the report with attorneys, yes. 14:36:53 14:36:56 Page 24 Veritext National Deposition & Litigation Services 866 299-5127 EXHIBIT 2-12

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