Leader Technologies Inc. v. Facebook Inc.

Filing 505

DECLARATION of Melissa H. Keyes re 504 MEMORANDUM in Support re 503 MOTION in Limine No. 12, by Facebook Inc.. (Attachments: # 1 Exhibit)(Caponi, Steven) Modified on 6/7/2010 (nms). (nms).

IN THE UNITED STATES COURT
FOR THE DISTRICT OF DELAWARE
LEADER TECHNOLOGIES, INC.,
a Delaware corporation,
Plaintiff and Counterdefendant,
v.
FACEBOOK, INC.,
a Delaware corporation,
Defendant and Counterclaimant.

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) CIVIL ACTION
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) No. 1:08-cv-00862-JJF
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DECLARATION OF MELISSA KEYES IN SUPPORT OF
FACEBOOK INC.’S MOTIONS IN LIMINE NO. 12
I, Melissa H. Keyes, declare:
1.

I am an attorney with Cooley LLP, of counsel in this action for Defendant

Facebook, Inc. (“Facebook”). I make this declaration in support of Facebook’s Motion in Limine
No. 12. I have personal knowledge of the facts contained within this declaration, and if called as
a witness, could testify competently to the matters contained herein.
2.

Attached hereto as Exhibit 1 is a true and correct copy of Leader Technologies,

Inc.’s Responses to Facebook, Inc.’s Fourth Set of Interrogatories (Nos. 12-18), dated October
15, 2009.
3.

Attached hereto as Exhibit 2 is a true and correct copy of Leader Technologies,

Inc.’s Responses to Facebook, Inc.’s Sixth Set of Interrogatories (Nos. 22-35), dated November
20, 2009.
4.

Attached hereto as Exhibit 3 is a true and correct copy of Leader Technologies,

Inc.’s Responses to Facebook, Inc.’s Second Set of Requests for Production of Documents to
1.