CNG Financial Corporation v. Google Inc

Filing 74

RESPONSE in Opposition re 69 MOTION to Exclude Testimony of Plaintiff's Expert Michael Mazis filed by Plaintiff CNG Financial Corporation, Counter Defendant CNG Financial Corporation. (Attachments: # 1 Affidavit /Declaration of Hunter in support of CNG Opposition to Motion# 2 Exhibit Exhibit A to Attachment# 3 Exhibit Exhibit B to Attachment to Opposition# 4 Exhibit Exhibit C to Attachment to Opposition# 5 Exhibit Exhibit D to Attachment to Opposition# 6 Exhibit Exhibit D - Part B to Attachment to Opposition# 7 Exhibit Exhibit E to Attachment to Opposition to Motion to Exclude) (Hunter, Barry)

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CNG Financial Corporation v. Google Inc L Doc. 74 Att. 1 '. Case 1:06-cv-00040-SSB-TSB Document 74-2 Filed 07/20/2007 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION CNG FINANCIAL CORPORATION Case No. 1 :06-cv-040 Plaintiff/CounterclaimDefendant, vs. Chief Judge Sandra S. Beckwith Magistrate Timothy S. Black DECLARTION OF BARY D. GOOGLE INe. HUNTER IN SUPPORT OF PLAINTIFF. CNG FINANCIAL Defendant/Counterclaim- : CORPORATION'S OPPOSITION TO Plaintiff. GOOGLE'S MOTION TO EXCLUDE TESTIMONY OF PLAINTIFF'S EXPERT MICHAEL MAZIS I, Barry D. Hunter, declare as follows: 1. I am a member of Frost Brown Todd LLC, counsel of record for Plaintiff, CNG Financial Corporation ("CNG") in the above-captioned action. I am the lead trial counsel in this case for CNG Financial Corporation. 2. Exhibit A to this Declaration is a true and correct copy of cited excerpts from the deposition transcript of Dr. !tamar Simonson taken on March 2, 2007. 3. Exhibit B to this Declaration is a true and correct copy of the cited excerpts from the deposition transcript of Dr. Michael Mazis taken on February 1, 2007. 4. Exhibit C to this Declaration is a tre and correct copy of the April 18, 2007 Order by the United States District Court for the Northern District of California, San Jose Division, in Googlf:, Inc. v. American Blind & Wallpaper Factory, Inc., Case No. C 03-5340, granting in part and denying in par Google's Motion for Sumary Judgment. 5. Exhibit D to this Declaration is a true and correct copy of the Surey Report of Dr. Jacob Jacoby, filed by Google in the Geico litigation. Dockets.Justia.com Case 1:06-cv-00040-SSB-TSB Document 74-2 Filed 07/20/2007 Page 2 of 2 6. Exhibit E to this Declaration is a true and correct copy of the Expert Report of Dr. !tamar Simonson, filed by Google in the Geico litigation. I declare under penalty of peijury that the foregoing is true and correct. Executed this 20th day of July, 2007 in Lexington, Kentucky. Isl Barry D. Hunter BARY D. HUTER LEXLibrary 0102393,0533475 339928vl 2

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