PA Advisors, LLC v. Google Inc. et al

Filing 418

MOTION in Limine and Daubert Motion to Exclude Testimony of Gerald Mossinghoff by PA Advisors, LLC. (Attachments: #1 Affidavit, #2 Exhibit A, #3 Exhibit B, #4 Text of Proposed Order)(Hoffman, Adam)

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PA Advisors, LLC v. Google Inc. et al Doc. 418 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-RRR JURY TRIAL DEMANDED DECLARATION OF ADAM HOFFMAN IN SUPPORT OF PA ADVISORS LLC'S MOTION IN LIMINE AND DAUBERT MOTION TO EXCLUDE TESTIMONY OF GERALD J. MOSSINGHOFF My name is Adam Hoffman. I am a member of the State Bar of California, with the firm of Russ August & Kabat, PC, and am admitted to the Eastern District of Texas. I am one of the counsel of record for nXn Tech, LLC (f/k/a PA Advisors, LLC) ("nXn") in the above-referenced action. The facts recited below are with my personal knowledge in my capacity as counsel for nXn and based on my access to documents produced in this litigation as maintained in client files regarding this litigation. These facts are true and correct and if called upon testify I would truthfully testify regarding these facts. 1. Exhibit A is a true and correct copy of the December 31, 2009 Expert Report of The Honorable Gerald J. Mossinghoff. 2. Exhibit B is a true and correct copy of excerpts from the certified transcript of the Feb. 12, 2010, Deposition of Gerald J. Mossinghoff. I declare under penalty of perjury that the statements in this declaration are true and correct. Executed this 19th of February, 2010, in Los Angeles, California. /s/ Adam Hoffman Adam Hoffman CERTIFICATE OF SERVICE I hereby certify that the counsel of record who are deemed to have consented to electronic service are being served today with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. \s\ Adam Hoffman Adam Hoffman 2

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