PA Advisors, LLC v. Google Inc. et al

Filing 426

Second MOTION in Limine Defendants' Motion in Limine No. 2 by Google Inc., Yahoo! Inc.. (Attachments: #1 Exhibit White Decl., #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Text of Proposed Order)(Perlson, David)

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PA Advisors, LLC v. Google Inc. et al Doc. 426 Att. 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, L.L.C., Plaintiff, v. GOOGLE INC., et al., Defendants. Civil Action No. 2:07-CV-480 RRR DECLARATION OF JASON WHITE IN SUPPORT OF DEFENDANTS' MOTION IN LIMINE NO. 2: MOTION TO PRECLUDE PLAINTIFF FROM OFFERING ANY EVIDENCE OR TESTIMONY OF A PRIORITY DATE THAT WAS NOT CONTAINED IN PLAINTIFF'S INTERROGATORY RESPONSES 1. I am a partner with the law firm Howrey LLP, and counsel for Yahoo! Inc. I have personal knowledge of the pleadings and files in this matter. I have personal knowledge of the documents submitted with this declaration and, if called upon as a witness, could and would testify competently thereto. 2. Attached, as Exhibit 1, is a true and correct copy of excerpts from Defendants' first set of interrogatories served on November 17, 2008. 3. Attached, as Exhibit 2, is a true and correct copy of excerpts from Plaintiff's response to Defendants' first set of interrogatories served on December 22, 2008. 4. Attached, as Exhibit 3, is a true and correct copy of excerpts from the deposition of Ilya Geller on August 19, 2009. 1 DM_US:23050104_2 Dockets.Justia.com I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed on February 19, 2010 in Austin, Texas. /s/ Jason White Jason White 2 DM_US:23050104_2

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