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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO—SERVICES INC.
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`Petitioner
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`V.
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`WESTERNGECO LLC
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`Patent Owner
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`Case No. IPR2014-00688
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`Patent No. 7,080,607
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`DECLARATION OF CHRISTOPHER A. SUAREZ IN SUPPORT OF
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`MOTION FOR ADMISSION PRO HAC VICE
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`Mail Stop “PA TENT BOARD”
`Patent Trial and Appeal Board
`US. Patent and Trademark Office
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`PO. Box 1450
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`Alexandria, VA 22313-1450
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`
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`I, Christopher A. Suarez, declare as follows:
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`1.
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`I am a member in good standing of the Bar of the State of Illinois and
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`the Bar of the District of Columbia, and am admitted to practice in the Court of
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`Appeals for the Federal Circuit and the Court of Appeals for the Seventh Circuit.
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`2.
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`On March 18, 2014, I took and passed the USPTO Examination for
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`Registration to Practice in Patent Cases, as confirmed by the March 20, 2014 letter
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`from the USPTO’s Office of Enrollment and Discipline attached to this affidavit as
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`Exhibit A.
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`I submitted the required certificate of good standing to verify my status
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`as an attorney, along with the required oath and declaration, to the USPTO to
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`advance the process of receiving a USPTO Attorney Registration Number soon
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`thereafter.
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`3.
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`My admission to practice before the USPTO is awaiting final
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`approval. To confirm this, my name appeared in the USPTO’s Oflicial Gazette on
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`April 22, 2014—the day before the Petition was filed in this proceeding. This
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`notice makes clear that I am “seeking .
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`.
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`. registration to practice before the United
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`States Patent and Trademark Office.” See Exhibit B. Individuals have until May 9,
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`2014 to provide comments regarding my character to the Office of Enrollment and
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`Discipline. To the best of my knowledge, no comments have been filed to this date
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`that would adversely affect my eligibility to practice before the USPTO, and I have
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`no reason to expect that any such comments would be filed. Assuming that no
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`such comments are filed, I expect to receive a registration number soon after the
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`May 9, 2014 date.
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`4.
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`From September 2012 to September 2013, I served as a law clerk to
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`Judge Timothy B. Dyk of the United States Court of Appeals for the Federal
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`Circuit, and thereby increased my familiarity with the patent laws and doctrines
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`promulgated from that court.
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`5.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`6.
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`I have never filed an application for admission to practice before any
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`court or administrative body that has been denied.
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`7.
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`I have never been issued sanctions or contempt citations from any
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`court or administrative body.
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`8.
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`I have read and will comply with the both the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in part 42 of
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`37 C.F.R.
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`9.
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`I attest that I will be subject to, and comply with, the USPTO Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`10.
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`I have never applied to appear pro hac vice in other proceedings
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`before the Board prior to the date of this declaration. The four matters (2013IPR—
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`
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`00078, 2013IPR-00087, 2013IPR-00088, and 2013IPR-00089) to which this
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`declaration applies are the only matters for which I have ever sought pro hac vice
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`admission before the Board.
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`11.
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`I have familiarity with the subject matter at issue in this proceeding. I
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`have been intimately involved in the details of this case for more than four months,
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`can attest that I have read background materials pertaining to the relevant
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`technology, and have worked extensively with the pertinent experts in this matter
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`in developing the invalidity theories presented in the Petition. These experts have
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`explained concepts relating to marine seismic surveying and control systems to me
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`at length and on many occasions. Additionally, I have a Bachelor’s Degree in
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`Electrical Engineering and Computer Science from the Massachusetts Institute of
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`Technology, and my background knowledge in this area is relevant to
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`computerized control system technology implicated by the patent at issue in this
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`proceeding.
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`12.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements are made with the knowledge
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`that willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States Code.
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`
`
`
`
`rez
`Christopher A. S
`Williams & Connolly LLP
`725 Twelfth St. NW
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`Washington, DC 20005
`Phone: 202—434-5279
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`Facsimile: 202-434-5029
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`E-mail: csuarez@wc.com
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`Date: April 28, 2014
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`
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`SwornJ50 and subscribed before me
`this 4 day of April, 2014.
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`
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`Notary Public
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`
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`Exhibit A
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`OFFICE OF ENROLLMENT AND DISCIPLINE
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`March 20, 2014
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`Christopher Alan Suarez
`Williams & Connolly LLP
`70 I Street SE #721
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`Washington, DC 20003
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`OED ID # 94807
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`NOTICE OF RESULTS OF March 18, 2014 EXAMINATION
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`I am pleased to inform you that you have attained a passing grade on the examination for registration to
`practice before the United States Patent and Trademark Office (“Office”) completed on March 18, 2014.
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`You may not hold yourself out as a registered patent attorney or patent agent until the Office of
`Enrollment and Discipline (“OED”) has given your application final approval. Your name will be
`published in the Official Gazette and information tending to affect your eligibility on moral and ethical
`grounds will be. solicited. If information.1s received affecting your eligibility on moral or ethical grounds,
`you will be given an opportunity to respond.-
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`Please complete the enclosed Data Sheet and oath. The Data Sheet is used in maintaining the register of
`patent attorneys and agents. The completed original Data Sheet, oath and a $100.00 registration fee
`required by 37 CFR § 1.21(a)(2) should be submitted to: Mail Stop OED, Director, United States
`Patent and Trademark Office, P. O. Box 1450, Alexandria, Virginia 22313-1450. Please leave the
`Registration Number block blank.
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`is necessary to have and disclose to OED a postal address for your office.
`it
`To be registered,
`See 37 CFR § 11.11(a). Therefore, it is necessary for you to provide a postal business address in the Data
`Sheet (correspondence business address).
`This address will be published on the USPTO website
`following registration. If you provide OED with only your home address, it will be treated as the postal
`address of your office, and it will be published in accordance with § 11.11(a).
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`The name printed on your certificate of registration will be your legal first name, the first initial of your
`middle name and your last name, as it appears above, unless you make a separate request to OED, which
`must be attached to your Data Sheet. You will be registered as a patent agent unless you file, with your
`Data Sheet, a certificate of good standing, issued within the past six months, from the highest court of a
`state indicating you are an attorney. Certificates from state bars are n_ot acceptable.
`If the certificate of
`good standing is timely filed with your oath and fee, your initial certificate of registration will reflect
`registration as a patent attorney.
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`If you are an attorney and your certificate of good standing is received after receipt of your Data Sheet,
`the certificate. may be used to change your registration status from patent agent to patent attorney at a later
`date, and a separate certificate of registration will be issued to reflect registration as a patent attorney.
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`
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`registration processing fee required by 37 CFR §l.21(a)(2) to change your status from patent agent to
`patent attorney.
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`If you have previously filed a certificate of good standing, you must nonetheless send a new certificate of
`good standing in response to this notice to be registered as a patent attorney. A completed Data Sheet,
`oath and registration fee must be received within two (2) years of the date of this letter, or you will be
`required to retake the registration examination. 37 CFR § 11.8(c).
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`Once OED has given your application final approval, your certificate of registration will be forwarded to
`you at your postal business address given with your Data Sheet. See 37 CFR § 11.11. The date of
`registration that appears on your certificate will be the date of your registration. Your registration number
`will be indicated on your certificate.
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`If you wish to receive acknowledgement of the receipt of any communication, please include a self-
`addressed, stamped post card to be used for such purpose. The card should identify each type of paper
`filed. OED will stamp the receipt date on the card and place it in the outgoing mail. However, the card is
`not verification that all of those items you identified were present.
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`William R. Covey
`Deputy General Counsel for Enrollment and Discipline and
`Director of the Office of Enrollment and Discipline
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`
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`Exhibit B
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`
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`W Top ofN otices April 22,
`US PATENT AND TRADEMARK
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`Print This Notice 1401 0G 302
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`
`OFFICE
`
`
`lRegistration to Practice
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`Registration to Practice
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`The following list contains the names of persons seeking for registration
`to practice before the United States Patent and Trademark Office. Final
`approval for registration is subject to establishing to the satisfaction of
`the Director of the Office of Enrollment and Discipline that the person
`seeking registration is of good moral character and repute. 37 CFR § 11.7
`Accordingly, any information tending to affect the eligibility of any of
`the following persons on moral ethical or other grounds should be furnished
`to the Director of Enrollment and Discipline on or before May 9, 2014 at
`the following address: Mail Stop OED United States Patent and Trademark
`Office P.O. Box 1450 Alexandria VA 22314
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`Aubry, Anne-Raphaellev, Oblon Spivak McClelland Maier & Neustadt LLP, 1940
`Duke Street, Alexandria, VA 22314
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`Bellum, Stephen Clifford, J.A. Lindeman & Co., 3190 Fairview Park Drive,
`Suite 480, Falls Church, VA 22042
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`Brown, Levi Scott, Bechtel Marine Propulsion Corporation, 19 Champagne
`Road, Eighty Four, PA 15330
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`Chong, Jason Yonghoon, 532 Alosio Drive, River Vale, NJ 07675
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`Chun, Changkun, 3147 S. Westminster Way, Bloomington,
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`IN 47401
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`James Eugene, Brooks Cameron & Huebsch, PLLC, 3266 Oak View Drive,
`Woodbury, MN 55129
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`Dilk, Robert Justin, 577 E. Baseline Road Apt. 3038, Tempe, AZ 85283
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`Hathorn, Philip Bradford, 340 Oak Arbor Court, Johns Creek, GA 30005
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`Kalish, Yury, Department of Energy, 1000 Independence Avenue,
`Washington, DC 20585
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`SW,
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`Keros, Peter Evan, 2148 Bel Aire, West Bloomfield, MI 48323
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`Kwak, Na Mi, Novick Kim & Lee PLLC, 1604 Spring Hill Road, Suite 320,
`Vienna, VA 22182
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`Lauritzen, Wendy Renee, 3106 S. Fox Street, Arlington, VA 22202
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`Leege, David Dean, Fitzpatrick, Cella, Harper & Scinto, 975 F Street NW
`Suite 400, Washington, DC 20004
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`Logsdon, Charles Alan, 5406 Glendale Street, Duluth, MN 55804
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`Mederos, Diana Frances, P.O. Box 141614, Gainesville, FL 32614
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`Miller, Timothy Bryce, Whitham, Curtis, Christofferson & Cook, P.C., 11491
`Sunset Hills Road, Suite 340, Reston, VA 20190
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`Morris—Easley, Brittany Noel Delaney, 533 W. 22nd Street, Houston, TX 77008
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`Mouta—Bellum, Carla Alexandra S. P. M. D., Finnegan LLP, 901 New York
`Avenue N.W., Washington, DC 20001
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`Netikosol, Joe Saratool 1230 13th Street NW #503, Washington, DC 20005
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`Patel, Sheetal Subhashbhai, Finnegan, Henderson, Farabow, Garrett
`Dunner, LLP, 901 New York Avenue, NW, Washington, DC 20001
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`&
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`
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`OFFICE
`April 22, 2014
`US PA
`TAND
`E
`1401 0G 303
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`Pennebaker, Sara Lynne, 5600 Castle Drive, Oakland, CA 94611
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`Poulos, John Peter, 210 Bridle Path Circle, Oak Brook,
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`IL 60523
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`Schmidt, Jeffrey Wayne, UNeMed Corporation, 986099 Nebraska Medical Center,
`Omaha, NE 68198—6099
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`Stevenson, Tarley Gwendolyn, Bickel
`Dallas, TX 75201
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`& Brewer, 1717 Main Street, Suite 4800,
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`Suarez, Christopher Alan, Williams & Connolly LLP, 725 Twelfth Street,
`N.W., Washington, DC 20005
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`Valley, Cory Michael, 6803 Lumsden Street, McLean, VA 22101
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`March 25, 2014
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`WILLIAM R. COVEY
`Deputy General Counsel for Enrollment and Discipline and
`Director of the Office of Enrollment and Discipline
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`