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)

Exhibit A

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF ILLINOIS

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EASTERN DIVISION

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TIMELINES, INC.,

)
)

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Plaintiff,

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)

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vs.

) No. 11-CV-06867
)

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FACEBOOK, INC.,

)
) Judge John W. Darrah

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Defendant.

)

___________________________)
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HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY

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VIDEOTAPED DEPOSITION OF BRIAN HAND

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Chicago, Illinois

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Thursday, September 20, 2012

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Reported by:

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PAULA CAMPBELL, CSR, RDR, CRR, CCP

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JOB NO. 53018
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HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

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any knowledge of that as we sit here, or his

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knowledge would be work product.

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Aside from the report we are going to

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give --

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A.

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I don't know.
MR. ALBRITTON:

-- I'm free to let Mr. Hand

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testify to what he knows personally.

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A.

I don't know.

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Q.

So is it correct to say you are relying on

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an expert witness to come up with a purported

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damages --

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A.

Yes.

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Q.

-- figure?

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And broadly speaking, has the company done

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anything to mitigate its damages resulting from

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Facebook's use of the term timeline?

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MR. ALBRITTON:

Object to the extent it

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calls for a legal conclusion, but to any --

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whatever you know about personally.

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A.

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I don't have anything to add that we

haven't discussed already today.
MR. WILLSEY:

Okay.

Let's go off the

record for just a second.
VIDEOGRAPHER:

It is 5:06 P.M.

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We are off