PA Advisors, LLC v. Google Inc. et al

Filing 298

RESPONSE to Motion re #295 MOTION for Protective Order Modification filed by PA Advisors, LLC. (Attachments: #1 Affidavit of Andrew D. Weiss, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H)(Weiss, Andrew)

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PA Advisors, LLC v. Google Inc. et al Doc. 298 Att. 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC, Plaintiff, v. GOOGLE, INC., et al., Defendants. Civil Action No. 2:07-cv-480-DF JURY TRIAL DEMANDED DECLARATION OF ANDREW D. WEISS IN SUPPORT OF nXn TECH, LLC'S RESPONSE TO YAHOO!, INC.'S MOTION TO MODIFY PROTECTIVE ORDER I, Andrew D. Weiss, declare and state as follows: 1. I am a member of the State Bar of California and an associate at the firm of Russ, August & Kabat, counsel of record for Plaintiff nXn Tech, LLC in the abovecaptioned action. I have personal knowledge of the facts set forth herein, and if called upon to testify, could and would testify competently thereto. 2. The letters attached in support of nXn's Response to Yahoo's Motion to Modify the Protective Order are true and correct copies of correspondence maintained in files regarding this matter: a. Exhibit A is a true and correct copy of a March 11, 2009 letter from John Edmonds, former counsel for nXn, to Jason White, counsel for Yahoo. b. Exhibit B is a true and correct copy of a July 17, 2009 letter from Ari Rafilson, former counsel for nXn, to Mr. White. 2995-010 091106 Weiss Decl ISO Resp.doc 1 Dockets.Justia.com c. Exhibit C is a true and correct copy of a July 28, 2009 letter from Ari Rafilson to Mr. White. d. Exhibit D is a true and correct copy of an August 10, 2009 letter from Ari Rafilson to Mr. White. e. Exhibit E is a true and correct copy of an August 19, 2009 letter from Ari Rafilson to Mr. White. f. Exhibit F is a true and correct copy of an August 25, 2009 letter from Ari Rafilson to Mr. White. g. Exhibit G is a true and correct copy of a September 22, 2009 letter from Ari Rafilson to Mr. White. h. Exhibit H is a true and correct copy of a September 24, 2009 letter from Ari Rafilson to Mr. White. I declare under penalty of perjury pursuant to the laws of the United States that the foregoing is true and correct. Executed this 6th day of November, 2009 at Los Angeles, California By: /s/ Andrew D. Weiss Andrew D. Weiss 2995-010 091106 Weiss Decl ISO Resp.doc 2

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