2I, Azra M. Hadzimehmedovic, declare as follows:1.
I am an attorney at the law firm of Tensegrity Law Group LLP, counsel of recordfor Skyhook Wireless, Inc. (“Skyhook”) in the above-captioned matter. I am an attorney in goodstanding licensed to practice in the State of California and the District of Columbia and admittedto practice before this Court
pro hac vice
in the above-captioned matter. I submit thisdeclaration in support of Skyhook’s Motion to Compel Google Inc. To Produce Mr. Patrick Brady for a Deposition and To Produce Certain Documents Responsive to Skyhook’s DocumentRequests. I am personally familiar with the facts stated herein, and, if called as a witness, couldtestify competently hereto.2.
An electronic search of Google’s production, using Patrick Brady as a custodianin the patent infringement case, yields 6648 documents. Mr. Brady’s corporate deposition inSkyhook’s state law case of tortious interference took place on November 4-5, 2011, and hisindividual deposition took place on January 31, 2012. Mr. Brady’s documents, naming him as acustodian in the federal patent infringement case, were produced on March 29, 2012.3.
I met and conferred with Google’s counsel Sanjeet Dutta regarding the TracBeamlitigation document request at least twice telephonically and I sent Google’s counsel additionalwritten correspondence on this issue. Skyhook’s request for production of documents Googlehas produced in the
litigation is as follows: All Documents or Things produced or made available for inspection in
TracBeam, L.L.C. v. Google, Inc.
, Case No. 6:13-cv-00093,including without limitation depositions and discovery responses.” Ex. 6 to this Affidavit at 120.In the two telephonic discussions with Mr. Dutta, I explained that Skyhook was particularlyinterested in Google’s depositions and discovery responses from that litigation (as Skyhook’srequest specifically stated in the “including” clause). I explained Skyhook’s belief that the
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