`
`September 22, 201-4 _
`
`Mr. Bryan J. Mechell, Esq.
`Mr. Richard M. Martinez, Esq.
`ROBINS, KAPLAN, MILLER & CIRESI
`2800 lAsALLE Plaza
`800 LaSalle Avenue
`
`Minneapolis, MN 55402
`
`Mr. John D. Vandenberg, Esq.
`Ms. Kristen P. Lantz Reichenbach, PhD, Esq.
`KARQUIST SPARKMAN
`One World Trade Center
`121 SW Salmon Street
`
`Portland, OR 97204
`
`IN RE: American Express, et al v. Metasearch Systems
`Case CBM2014—00001
`
`Patent 8,326,924
`
`Deposition of Dr. Jaime Carbonell — Exhibit 1041
`
`Dear Counsel:
`
`It came to the attention of Paradigm Reporting & Captioning that the exhibit index
`prepared in the above-referenced deposition by Paradigm Court Reporter Dana
`Anderson-LinneIl contains an error on page 4 at Line 23. Specifically, it purports to
`indicate that the document entitled “Travel Related Items” was marked for identification
`
`as Exhibit #1041 in the Carbonell deposition, when, in fact, it was not ultimately marked
`as such; it was simply referenced as such on page 118.
`
`Attached please find an Affidavit by Ms. Anderson-Linnell testifying to the same.
`
`If further questions remain, feel free to contact me directly.
`
`Thank you
`
`:EflsimanRPR CMRS
`
`Plesident
`
`Attachment
`
`1400 Rand Tower 0 527 Marquette Avenue South 0 Minneapolis, MN 55402—1331
`
`AMERICAN EXPRESS V. METASEARCH
`CBM2014-00001 EXHIBIT 2041 - 1
`
`
`
`.41 FFIDA 3”] T 0F D..~l/‘v".<l S. ANDERSON-LINNELL
`
`I, Dana S. Anderson—Linnefl, certify and state that I reported the deposition of Dr.
`Jaime Carbonell on August 28th, 2014;
`
`That thereafter, I created a verbatim transcript of the same;
`
`That as part of that verbatim transcript, I created my standard Exhibit Index,
`which attempts to create an efficiency for counsel by listing the pages upon which
`documents are marked for identification and/or referenced throughout the deposition;
`
`That there were no new exhibits marked in the deposition of Dr. Jaime Carbonell,
`only previously marked exhibits which were referred to in the deposition;
`
`That in creating my standard Exhibit Index, I therefore referenced, on Page 4 of
`said transcript, all exhibits previously marked for identification but referenced during the
`deposition of Dr. Jaime Carbonell;
`
`That on Page 4, Line 23 of the transcript, I erroneously referred to a document
`entitled “Travel-Related Item” as “Exhibit 1041” in the Exhibit Index, but, in fact, that
`document was never marked as such during the deposition of Dr. Jaime Carbonell;
`
`That said notation in the Exhibit Index came from the reference on page 118 of
`“Exhibit 1041;” however, that document was never marked into evidence by me on
`August 28th, 2014, as the Exhibit Index would appear to indicate.
`
`FURTHER AFFIANT SAITH NOT.
`
`I hereby swear that the above representations are true and correct, to the best of
`my knowledge, belief and information.
`
`OVZZ—lfi/
`
`éfiflnfiy ”MW
`
`
`
`Date
`
`Dana S. Anderson—Linnell, Court Reporter
`
`STATE OF MINNESOTA
`COUNTY OF RAMSEY
`
`I, the undersigned Notary Public, do hereby affirm that Dana Anderson—Linnell
`personally appeared before me on the 22nd day of September, 2014, and signed the above
`Affidavit as a free and voluntary act.
`)
`.
`vf/
`.
`MW“ (mat/m
`Notary Public
`
`
`
`AMERICAN EXPRESS V. METASEARCH
`CBM2014-00001 EXHIBIT 2041 - 2
`
`
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