TimesLines, Inc v. Facebook, Inc.
Filing
120
MEMORANDUM by Facebook, Inc. in support of motion in limine 119 to Exclude Dr. Eli Seggev's Survey and Related Expert Report and Testimony (Attachments: # 1 Declaration of Brendan Hughes, # 2 Exhibit A, # 3 Exhibit B)(Willsey, Peter)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TIMELINES, INC.
Plaintiff,
v.
FACEBOOK, INC.
Defendant.
)
)
)
)
)
)
)
)
)
Civil Action No.: 11 CV 6867
HONORABLE JOHN W. DARRAH
DECLARATION OF BRENDAN J. HUGHES IN SUPPORT OF
DEFENDANT FACEBOOK, INC.’S MOTION IN LIMINE NO. 1
I, Brendan J. Hughes, declare:
1.
I am an associate with the law firm Cooley LLP, counsel for Defendant Facebook,
Inc. (“Facebook”) in connection with the above-titled action. I submit this declaration in support
of Facebook’s Motion in Limine No. 1: To Exclude Dr. Eli Seggev’s Survey and Related Expert
Report and Testimony (“Motion”). I make this declaration upon personal knowledge and, if
called and sworn as a witness, I could and would testify as to the matters set forth herein.
2.
Attached hereto as Exhibit A is a true and correct copy of the Expert Report of
Dr. Seggev, dated September 28, 2012.
3.
Attached hereto as Exhibit B are true and correct copies of excerpts from the
deposition transcript of Dr. Seggev, dated December 6, 2012.
I declare under penalty of perjury that the foregoing statements are true and correct.
Executed in Washington, D.C. this 8th day of April, 2013.
/s/ Brendan J. Hughes
Brendan J. Hughes (pro hac vice)
COOLEY LLP
1299 Pennsylvania Avenue, NW, Suite 700
Washington, DC 20004-2400
T: (202) 842-7800; F: (202) 842-7899
Email: bhughes@cooley.com
CERTIFICATE OF SERVICE
The undersigned, an attorney, hereby certifies that he served the foregoing
DECLARATION OF BRENDAN J. HUGHES IN SUPPORT OF DEFENDANT
FACEBOOK, INC.’S MOTION IN LIMINE NO. 1 by means of the Court’s CM/ECF System,
which causes a true and correct copy of the same to be served electronically on all CM/ECF
registered counsel of record, on April 8, 2013.
Dated: April 8, 2013
/s/ Brendan J. Hughes
Brendan J. Hughes (pro hac vice)
COOLEY LLP
1299 Pennsylvania Ave., NW, Suite 700
Washington, DC 20004-2400
Phone: (202) 842-7800
Fax: (202) 842-7899
Email: bhughes@cooley.com
1084305 HN
2
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?