PA Advisors, LLC v. Google Inc. et al

Filing 460

RESPONSE in Opposition re #420 MOTION in Limine (Defendant Yahoo! Inc.'s Motions in Limine) MOTION in Limine (Defendant Yahoo! Inc.'s Motions in Limine) filed by PA Advisors, LLC. (Attachments: #1 Affidavit, #2 Exhibit A-1, #3 Exhibit A-2, #4 Exhibit A-3)(Anderson, Patrick)

PA Advisors, LLC v. Google Inc. et al

Doc. 460 Att. 1

ANDERSON DECLARATION

Dockets.Justia.com

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC v. GOOGLE INC., et al. NO. 2:07-cv-480-RRR JURY

DECLARATION OF PATRICK R. ANDERSON IN SUPPORT OF nXn TECH, LLC'S RESPONSE TO YAHOO! INC.'S MOTION IN LIMINE NO. FOUR My name is Patrick R. Anderson. I am a member of the State Bar of Michigan, with Patrick R. Anderson PLLC, and one of the counsel of record for nXn Tech, LLC (f/k/a PA Advisors, LLC) ("nXn") in the above-referenced action. I am one of the counsel of record in the above referenced action. The facts recited below are within 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 to testify I would truthfully testify regarding these facts. 1. Exhibit A is a true and correct copy of documents produced by nXn

between PA0001419 and PA0001583. 2. Exhibit B is a true and correct copy of the transcript of Ilya Geller's

testimony taken on August 19, 2009. 3. Exhibit C is a true and correct copy of documents produced under

subpoena to Ilya Geller between GELLER033540 and GELLER033543.

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4.

Exhibit D is a true and correct copy of the transcript of Ilya Geller's

testimony taken on December 16, 2009. 5. Exhibit E is a true and correct copy of IMX, Inc. v. Lendingtree, LLC, Civ.

No. 03-1067-SLR, 2005 U.S. Dist. LEXIS 33179 (D. Del. December 14, 2005). I declare under penalty of perjury that the statements in this declaration are true and correct. Executed this 25th day of February, 2010, in Dallas, Texas.

/s/ Patrick. R. Anderson Patrick R. Anderson

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