throbber

`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Case 3:17-cv-05659-WHA Document 440-1 Filed 04/18/19 Page 1 of 2
`
`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Alan Heinrich (SBN 212782)
`aheinrich@irell.com
`Joshua Glucoft (SBN 301249)
`jglucoft@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca Carson (SBN 254105)
`rcarson@irell.com
`Ingrid M. H. Petersen (SBN) 313927)
`ipetersen@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`FINJAN, INC., a Delaware Corporation,
`)
`Case No. 3:17-cv-05659-WHA
`
`)
`
`DECLARATION OF JOSHUA GLUCOFT
`Plaintiff,
`)
`IN SUPPORT OF DEFENDANT JUNIPER
`
`)
`NETWORKS, INC.’S REPLY
`vs.
`
`)
`REGARDING JUNIPER’S
`
`)
`MOTION FOR SANCTIONS
`JUNIPER NETWORKS, INC., a Delaware
`)
`Corporation,
`)
`
`
`)
`Date:
`
`May 2, 2019
`)
`Time:
`8:00 a.m.
`)
`Courtroom: Courtroom 12, 19th Floor
`Hon. William Alsup
`)
`Before:
`)
`)
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`DECLARATION OF JOSHUA GLUCOFT ISO
`JUNIPER’S REPLY REGARDING
`JUNIPER’S MOTION FOR SANCTIONS
`Case No. 3:17-cv-05659-WHA
`
`

`

`Case 3:17-cv-05659-WHA Document 440-1 Filed 04/18/19 Page 2 of 2
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`DECLARATION OF JOSHUA GLUCOFT
`I, Joshua Glucoft, declare as follows:
`1.
`I am a member in good standing of the State Bar of California and an associate at
`Irell & Manella LLP, counsel of record in this action for Defendant Juniper Networks, Inc.
`(“Juniper”). The statements in this declaration reflect my current knowledge, and I could and
`would testify competently thereto if called upon to do so. I make this declaration in support of
`Juniper’s Reply Regarding Juniper’s Motion for Sanctions.
`2.
`Attached hereto as Exhibit A is a true and correct copy of the document bearing
`Bates JNPR-FNJN_29035_00962471 through _00962499, which Juniper produced on July 12,
`2018.
`
`3.
`Attached hereto as Exhibit B is a true and correct copy of the document bearing
`Bates JNPR-FNJN_29040_01280968 through _01280978, which Juniper produced on November
`6, 2018.
`4.
`Attached hereto as Exhibit C is a true and correct copy of the document bearing
`Bates JNPR-FNJN_29040_01462115 thorough _01462143, which Juniper produced on November
`6, 2018.
`5.
`Attached hereto is Trial Exhibit 91, which was admitted into evidence during trial
`on December 11, 2018.
`6.
`Attached hereto is Trial Exhibit 345, which was admitted into evidence during trial
`on December 12, 2018.
`7.
`Attached hereto is Trial Exhibit 1760, which was admitted into evidence during
`trial on December 12, 2018.
`//
`
`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct to the best of my knowledge. Executed this 18th day of April, 2019
`at Los Angeles, California.
`
`
`By: /s/ Joshua Glucoft
`Joshua Glucoft (SBN 301249)
`
`
`
`
`
`
`- 1 -
`
`DECLARATION OF JOSHUA GLUCOFT ISO
`JUNIPER’S REPLY REGARDING
`JUNIPER’S MOTION FOR SANCTIONS
`Case No. 3:17-cv-05659-WHA
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket