PA Advisors, LLC v. Google Inc. et al

Filing 458

RESPONSE in Opposition re #427 Third MOTION in Limine Defendants' Motion in Limine No. 3 filed by PA Advisors, LLC. (Attachments: #1 Affidavit, #2 Exhibit A)(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 deposition transcript of Mr.

Ilya Geller dated August 19, 2008.

Executed this 25th of February, 2010, in Austin, Texas. /s/ Elizabeth A. Wiley Elizabeth A. Wiley