`
`#:16603
`
`Dustin J. Edwards (pro hac vice
`dedwards@winston.com
`WINSTON & STRAWN LLP
`800 Capitol St., Suite 2400
`Houston, TX 77002-2925
`Telephone: (713) 651-2600
`Facsimile:
`(713) 651-2700
`
`Diana Hughes Leiden (SBN: 267606)
`dhleiden@winston.com
`WINSTON & STRAWN LLP
`333 S. Grand Avenue, 38th Floor
`Los Angeles, CA 90071-1543
`Telephone: (213) 615-1700
`Facsimile:
`(213) 615-1750
`
`
`George C. Lombardi (pro hac vice)
`glombardi@winston.com
`WINSTON & STRAWN LLP
`35 West Wacker Drive
`Chicago, IL 60601-9703
`Telephone: (312) 558-5600
`Facsimile:
`(312) 558-5700
`
`E. Danielle T. Williams (pro hac vice)
`dwilliams@winston.com
`WINSTON & STRAWN LLP
`300 South Tryon Street, 16th Floor
`Charlotte, NC 28202
`Telephone: (704) 350-7700
`Facsimile:
`(704) 350-7800
`
`Michael S. Elkin (pro hac vice)
`melkin@winston.com
`WINSTON & STRAWN LLP
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 294-6700
`Facsimile: (212) 294-4700
`
`Attorneys for Defendants
`BANK OF AMERICA CORPORATION
`and BANK OF AMERICA, N.A.
`
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`UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`Case No. 2:20-cv-07872-GW-PVC
`NANTWORKS, LLC, a Delaware
`limited liability company, and
`
`NANT HOLDINGS IP, LLC, a
`Judge: Hon. George H. Wu
`
`Delaware limited liability company,
`DECLARATION OF E. DANIELLE T.
`
`WILLIAMS IN SUPPORT OF
`Plaintiffs,
`DEFENDANTS’ OPPOSITION TO
`
`MOTION TO STRIKE PORTIONS OF
`vs.
`THE EXPERT REPORT OF DR.
`
`NATHANIEL POLISH
`BANK OF AMERICA
`CORPORATION, a Delaware
`
`corporation, and BANK OF
`Hon. George H. Wu
`AMERICA, N.A., a national banking
`United States District Court Judge
`association,
`Hearing Date: May 2, 2024
`
`Time: 8:30 AM
`Place: Courtroom 9D
`
`
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`
`
`Defendants.
`
`
`
`1
`DECLARATION IN SUPPORT OF APPLICATION TO FILE UNDER SEAL
`CASE NO. 2:20-CV-07872-GW-PVC
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 310-1 Filed 03/28/24 Page 2 of 3 Page ID
`
`#:16604
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`DECLARATION OF E. DANIELLE T. WILLIAMS
`I, E. Danielle T. Williams, hereby declare, under penalty of perjury as follows:
`1.
`I am a partner at Winston & Strawn, LLP, counsel for the Defendants Bank
`of America Corporation and Bank of America, N.A. (“Defendants”) in this matter. I
`am over the age of eighteen years old, and I have personal knowledge of each and every
`fact stated in this declaration. If called to testify, I could testify competently thereto. I
`make this declaration in support of Defendants’ Opposition to Motion to Strike Portions
`of the Expert Report of Dr. Nathaniel Polish.
`2.
`Attached hereto as Exhibit 1 is a copy of a copy of U.S. Pat. No 6,947,571
`B1, Rhoads.
`I declare under penalty of perjury that the foregoing is true and correct.
`Executed on this 28th day of March, 2024 in Winston-Salem, North Carolina.
`
`
`
`
`
`/s/.
`E. Danielle T. Williams
`
`
`
`
`
`2
`DECLARATION IN SUPPORT OF APPLICATION TO FILE UNDER SEAL
`CASE NO. 2:20-CV-07872-GW-PVC
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 310-1 Filed 03/28/24 Page 3 of 3 Page ID
`
`#:16605
`
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`PROOF OF SERVICE
`
`I certify that that on March 28, 2024, I caused a true and correct copy of the
`
`foregoing document titled “Declaration of E. Danielle T. Williams in Support of
`
`Defendants’ Opposition to Motion to Strike Portions of the Expert Report of Dr.
`
`Nathaniel Polish” to be served via email to all counsel of record who have appeared for
`
`Plaintiffs in this matter.
`
`Dated: March 28, 2024
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`By: /s/ E. Danielle T. Williams
`
`E. Danielle T. Williams
`
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`
`3
`DECLARATION IN SUPPORT OF APPLICATION TO FILE UNDER SEAL
`CASE NO. 2:20-CV-07872-GW-PVC
`
`
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