Rockstar Consortium US LP et al v. Google Inc

Filing 173

REPLY to Response to Motion re 126 MOTION to Compel filed by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Declaration of Jonathan Solomon, # 2 Declaration of John Lahad, # 3 Exhibit 1 to Declaration of John Lahad)(Nelson, Justin)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES
LLC,

Civil Action No. 2:13-cv-893

Plaintiffs,
v.

JURY TRIAL DEMANDED

GOOGLE INC.,
Defendant.

DECLARATION OF JOHN LAHAD

1. My name is John Lahad. I

am an attomey for Plaintifß in this case and a member in

good standing of the Texas State Bar.

2.

I attended the in-person meet and confer on July 10,2014.

3.

Before the meet and confer, my colleague Amanda Bonn sent Google's counsel an email

discussing Google's failure to produce documents from custodians. Attached as Exhibit

email exchange that Ms. Bonn and

I

I

is an

had with Google's counsel both before and after the in-

person meet and confer.

4. At the meet and confer itself, we specifically

discussed Google's disagreement that

documents from its senior leadership would be responsive and not cumulative.

I declare under penalty of perjury that the foregoing is true and correct. Executed
26,2014 in Houston, Texas.

Lahad

September