`Cas 8:19-cv-01151—JLS-DFM Document30-2 Filed 10/21/19 Page10f2 Page |D#:301
`
`Matthew G. Berkowitz (SBN 310426)
`matthew.berkowitz@shearman.com
`Yue (Joy) Wang (SBN 300594)
`joy.wang@shearman.corn
`SHEARMAN & STERLING LLP
`1460 El Camino Real, 2nd Floor
`Menlo Park, CA 94025
`Telephone: 650.838.3600
`Fax: 650.838.3699
`
`L. Kieran Kieckhefer (SBN 251978)
`kieran.kieckhefer@shearman.corn
`SHEARMAN & STERLING LLP
`535 Mission Street, 25th Floor
`San Francisco, CA 94105
`Telephone: 415.616.1100
`Fax: 415.616.1199
`
`Attorneys for Defendant NetSuite Inc.
`
`UNITED STATES DISTRICT COURT
`
`CENTRAL DISTRICT OF CALIFORNIA
`
`SOUTHERN DIVISION
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`UNILOC 2017 LLC,
`Plaintiff,
`
`V.
`
`NETSUITE INC.,
`
`
`
`Defendant.
`
`Case No. 18-CV-01151-JLS-DFM
`DECLARATION OF MATTHEW G.
`BERKOWITZ IN SUPPORT OF
`NETSUITE’S MOTION TO STAY
`DISCOVERY PENDING LIMITED
`
`MARKMAN PROCEEDING
`Judge:
`Hon. Josephine L. Staton
`Date:
`January 10, 2020
`Time:
`10:30 AM
`Location:
`Ronald Reagan Federal
`Building, Courtroom 10A
`
`
`
`BERKOWITZ DECL. ISO NETSUITE’ s
`Mor. TO STAY DISCOVERY
`
`CASE No. 18-cv-01151-JLS-DFM
`
`
`
`Case 8:19-cv-01151-JLS-DFM Document 30-2 Filed 10/21/19 Page 2 of 2 Page ID #:302
`Cas 8:19-cv-01151-JLS-DFM Document30-2 Filed 10/21/19 Page20f2 Page |D#:302
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`1, Matthew G. Berkowitz, declare as follows:
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`1.
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`I am a partner at the law firm of Shearman & Sterling LLP and lead
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`counsel for Defendant NetSuite Inc. (“NetSuite”).
`
`I am a member in good standing
`
`of the Bar of the State of California.
`
`I make this declaration based on personal
`
`knowledge and, if called as a witness, I could and would testify competently to the
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`matters set forth herein.
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of the docket
`
`sheet from the case captioned, Technology Innovations Associates LLC v. Google,
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`Inc., No. 13-0355—LPS, D.I. 33 (D. Del. Jun. 9, 2014). Docket Entry 33 reflects an
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`Order from Judge Stark dated June 9, 2014, staying discovery.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of Uniloc 2017’s
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`Request to Defendant for Production of Documents and Electronically Stored
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`Information dated August 8, 2019.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of Uniloc 2017’s
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`Second Request to Defendant for Production of Documents and Electronically Stored
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`Information dated October 4, 2019.
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`5.
`
`On October 1 1, 2019, I conferred with Mr. James Foster, counsel for
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`Plaintiff Uniloc 2017 LLC (“Uniloc”), pursuant to Federal Rule of Civil Procedure
`
`26(f) regarding NetSuite’s proposed motion to stay discovery. Mr. Foster indicated
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`that Uniloc would oppose and not consent to NetSuite’s requested relief.
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`6.
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`NetSuite has not yet served discovery on Uniloc.
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`I declare under penalty of perjury under the laws of the United States that the
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`foregoing is true and correct.
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`Executed this 21st day of October in Menlo Park, Ca ifornia.
`4
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`Matthew G. Berkowitz
`
`
`
`BERKOWITZ DECL. ISO NETSUITE’ s
`MOT. TO STAY DISCOVERY
`
`I
`
`CASE No. 8:19-cv-01151-JLS-DFM
`
`
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