PA Advisors, LLC v. Google Inc. et al

Filing 433

MOTION in Limine and Daubert Motion to Exclude the Testimony of Mr. Stanley Peters by PA Advisors, LLC. (Attachments: #1 Affidavit, #2 Exhibit A, #3 Exhibit B-1, #4 Exhibit B-2, #5 Exhibit B-3, #6 Exhibit B-4, #7 Exhibit B-5, #8 Exhibit B-6, #9 Exhibit B-7, #10 Exhibit B-8, #11 Exhibit B-9, #12 Exhibit B-10, #13 Exhibit B-11, #14 Exhibit B-12, #15 Exhibit B-13, #16 Exhibit C, #17 Text of Proposed Order)(Wiley, Elizabeth)

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 ELZABETH A. WILEY My name is Elizabeth A. Wiley. I am a member of the State Bar of Texas, with The Wiley Firm PC, and 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 excerpts from the expert report of Mr. Peters,

dated December 30, 2009. 2. Exhibit B is a true and correct copy of the charts attached to or served with the Peters

Expert Report, designated as ACC1 through ACC 13, with each chart designated for purposes of exhibits to this motion as B-1 through B-13. 3. Exhibit C is a true and correct copy of excerpts from the transcript of the deposition of

Mr. Peters, which occurred on February 9, 2010. Executed this 19th of February, 2010, in Austin, Texas. /s/ Elizabeth A. Wiley Elizabeth A. Wiley