Google, Inc. et al v. Microsoft Corporation

Filing 23

Declaration of Michael J. Bettinger in Support of 22 MOTION to Dismiss Transfer or Stay filed byMicrosoft Corporation. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7)(Related document(s)22) (Davidson, Rachel) (Filed on 9/9/2005)

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Google, Inc. et al v. Microsoft Corporation Doc. 23 Case 5:05-cv-03095-RMW Document 23 Filed 09/09/2005 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 MICHAEL J. BETTINGER (State Bar No. 122196) RACHEL R. DAVIDSON (State Bar No. 215517) PRESTON GATES & ELLIS LLP 55 Second Street, Suite 1700 San Francisco, California 94105-3493 Telephone: (415) 882-8200 Facsimile: (415) 882-8220 KARL J. QUACKENBUSH (Admitted Pro Hac Vice) JEFFREY C. JOHNSON (Admitted Pro Hac Vice) PRESTON GATES & ELLIS LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104-1158 Telephone: (206) 623-7580 Facsimile: (206) 623-7022 Attorneys for Defendant MICROSOFT CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION GOOGLE, INC. and KAI-FU LEE, Plaintiffs, v. MICROSOFT CORPORATION, Defendant. Date: Time: Place: Hon. October 14, 2005 9:00 a.m. Courtroom 6 Ronald M. Whyte Case No. C 05-03095 RMW DECLARATION OF MICHAEL J. BETTINGER IN SUPPORT OF MICROSOFT'S MOTION TO DISMISS, TRANSFER OR STAY I, MICHAEL J. BETTINGER, declare as follows: 1. I am an attorney licensed to practice in the State of California and before this Court, and am a partner in the law firm of Preston Gates & Ellis, LLP, attorneys of record for defendant Microsoft Corporation in the above-entitled action. I have personal knowledge of the DECLARATION OF MICHAEL J. BETTINGER IN SUPPORT OF MICROSOFT'S MOTION TO DISMISS, TRANSFER OR STAY (Case No.: C 05-03095 RMW) 1 PRINTED ON RECYCLED PAPER Dockets.Justia.com Case 5:05-cv-03095-RMW Document 23 Filed 09/09/2005 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 facts stated herein and, if called as a witness, would testify as follows. 2. Attached hereto as Exhibit 1 is a true and correct copy of the Employment Agreement between Microsoft Corporation and Kai-Fu Lee, dated August 8, 2000. 3. Attached hereto as Exhibit 2 is a true and correct copy of the complaint filed by Microsoft Corporation against Kai-Fu Lee and Google, Inc. in the Superior Court of the State of Washington In and For the County of King, on July 19, 2005. 4. Attached hereto as Exhibit 3 is a true and correct copy of the Temporary Restraining Order, dated July 28, 2005, signed by King County Superior Court Judge Steven Gonzales. 5. Attached hereto as Exhibit 4 is a true and correct copy of the Order Expediting Trial Date, dated July 29, 2005, signed by King County Superior Court Judge Steven Gonzales. 6. Attached hereto as Exhibit 5 is a true and correct copy of the Order Appointing Discovery Master, dated July 29, 2005, signed by King County Superior Court Judge Steven Gonzales. 7. Attached hereto as Exhibit 6 is a true and correct copy of the Order Granting Motion to Intervene and Granting, In Part, Motion to Unseal Documents, dated August 2, 2005, signed by King County Superior Court Judge Steven Gonzales. 8. Attached hereto as Exhibit 7 is a true and correct copy of a Google, Inc. press release, dated July 19, 2005, announcing that Kai-Fu Lee will lead Google's new Research and Development Center in China. The press release quotes Dr. Lee as stating "I look forward to returning to China to begin this exciting endeavor." DECLARATION OF MICHAEL J. BETTINGER IN SUPPORT OF MICROSOFT'S MOTION TO DISMISS, TRANSFER OR STAY (Case No.: C 05-03095 RMW) 2 PRINTED ON RECYCLED PAPER Case 5:05-cv-03095-RMW Document 23 Filed 09/09/2005 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 I declare under penalty of perjury that the foregoing is true and correct. Executed this 9th day of September, 2005 at San Francisco, California. ________/s/____________________ Michael J. Bettinger DECLARATION OF MICHAEL J. BETTINGER IN SUPPORT OF MICROSOFT'S MOTION TO DISMISS, TRANSFER OR STAY (Case No.: C 05-03095 RMW) 3 PRINTED ON RECYCLED PAPER

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