TimesLines, Inc v. Facebook, Inc.

Filing 141

MEMORANDUM by Facebook, Inc. in support of motion in limine 139 to Exclude Evidence, Testimony, and Argument Relating to Facebook, Inc.'s Overall Financial Condition and Net Worth (Attachments: # 1 Declaration of Brendan Hughes, # 2 Exhibit A)(Willsey, Peter)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TIMELINES, INC.
Plaintiff,
v.
FACEBOOK, INC.
Defendant.

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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. 5
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. 5: To Exclude Evidence, Testimony, and Argument
Relating To Facebook, Inc.’s Overall Financial Condition and Net Worth.

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 are true and correct copies of excerpts from the

deposition transcript of Brian Hand, dated September 20, 2012.
3.

Attached hereto as Exhibit B is a true and correct copy of the Expert Report of

David A. Haas, dated September 27, 2012 (Highly Confidential – Outside Counsel Only).

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
Phone: [phone]
Fax: [phone]
Email: [e-mail]

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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. 5 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: [phone]
Fax: [phone]
Email: [e-mail]

1114375 HN

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