Skyhook Wireless, Inc. v. GOOGLE, INC.

Filing 64

Emergency MOTION to Preclude Presentations by Fact Witness at the Technology Tutorial by GOOGLE, INC.. (Attachments: # 1 Declaration, # 2 Correspondence, # 3 Correspondence, # 4 Correspondence, # 5 Correspondence, # 6 Correspondence)(Manning, Susan)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
SKYHOOK WIRELESS, INC.,
Plaintiff,
v.
GOOGLE INC.,
Defendant.

GOOGLE INC.,
Counterclaim-Plaintiff,
v.
SKYHOOK WIRELESS, INC.,
Counterclaim-Defendant.

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CIVIL ACTION
NO. 1:10-cv-11571-RWZ

DECLARATION OF WILLIAM F. ABRAMS
IN SUPPORT OF GOOGLE INC.’S EMERGENCY MOTION TO PRECLUDE
PRESENTATIONS BY FACT WITNESS AT THE TECHNOLOGY TUTORIAL
I, William F. Abrams, declare as follows:
1.

I am over 18 years of age. I have personal knowledge of the facts

stated herein, except those stated on information and belief, and, if called upon, could and
would testify competently to them. I am a partner of the law firm of Bingham McCutchen
LLP, counsel for defendant Google, Inc. I make this declaration in support of Google Inc.’s
Emergency Motion to Disallow Use of a Fact Witness at Tutorial.
2.

On December 14, 2010, I attended the scheduling conference for the

above-captioned matter.
3.

At that scheduling conference, the Court indicated that the tutorials

should take the form of attorney presentations.

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4.

On September 19, 2011, I spoke with Samuel K. Lu, counsel for

Skyhook Wireless, Inc., regarding the technology tutorial. The parties agreed that the tutorial
would be conducted by counsel, and that experts and fact witnesses would not participate.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 14, 2011 in Palo Alto, California.

William F. Abrams

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Certificate of Service
I hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic
Filing (NEF) and paper copies will be sent to those indicated as non-registered
participants, by federal express, on October 14, 2011.
/s/ Julie S. Palmer
Julie S. Palmer

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