Weather Underground, Incorporated v. Navigation Catalyst Systems, Incorporated et al

Filing 122

MOTION for Summary Judgment by Navigation Catalyst Systems, Incorporated. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit F) (Delgado, William)

Weather Underground, Incorporated v. Navigation Catalyst Systems, Incorporated et al

Doc. 122 Att. 2

Exhibit A

Dockets.Justia.com

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN THE WEATHER UNDERGROUND, INC., a Michigan corporation, Plaintiff, vs. NAVIGATION CATALYST SYSTEMS, INC., a Delaware corporation; BASIC FUSION, INC., a Delaware corporation; CONNEXUS CORP., a Delaware corporation; and FIRSTLOOK, INC., a Delaware corporation, Defendants. ______________________________________________________________________ Enrico Schaefer (P43506) Brian A. Hall (P70865) TRAVERSE LEGAL, PLC 810 Cottageview Drive, Unit G-20 Traverse City, MI 49686 231-932-0411 [e-mail] [e-mail] Lead Attorneys for Plaintiff William A. Delgado WILLENKEN WILSON LOH & LIEB LLP 707 Wilshire Boulevard, Suite 3850 Los Angeles, CA 90017 [phone] [e-mail] Lead Counsel for Defendants Case No. 2:09-CV-10756 Hon. Marianne O. Battani

Nicholas J. Stasevich (P41896) Benjamin K. Steffans (P69712) Anthony P. Patti (P43729) BUTZEL LONG, P.C. HOOPER HATHAWAY, PC 150 West Jefferson, Suite 100 126 South Main Street Detroit, MI 48226 Ann Arbor, MI 48104 [phone] 734-662-4426 [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff Local Counsel for Defendants ______________________________________________________________________ DECLARATION OF WILLIAM A. DELGADO

I, William A. Delgado, declare as follows: 1. I am over the age of eighteen and am lead counsel for Navigation Catalyst

Systems, Inc. ("NCS"), defendant in this matter. I have personal knowledge of the facts stated herein except where stated on information and belief, and, as to those matters, I believe them to be true. 2. Attached as Exhibit B are true and correct copies of relevant excerpts from the

deposition transcript of Jeffrey Masters, taken August 3, 2010. I took the deposition of Mr. Masters. 3. Attached as Exhibit C are true and correct copies of relevant excerpts from the

deposition transcript of Alan Steremberg, taken July 28, 2010. I took the deposition of Mr. Steremberg . 4. Attached as Exhibit D are true and correct copies of relevant, non-confidential

excerpts from the deposition transcript of Christopher Schwerzler, taken A pril 29, 2010. I took the deposition of Mr. Schwerzler. // //

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5.

Attached as Exhibit E are true and correct copies of relevant , confidential excerpts

from the deposition transcript of Christopher Schwerzler, taken April 29, 2010. I took the deposition of Mr. Schwerzler. Pursuant to the Protective Order in this matter, this exhibit will be filed separately, under seal. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on this 26th day of October 2010 at Los Angeles, California.

/s/William A. Delgado. William A. Delgado

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