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)

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