A0 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection ofPremises in a Civil Action
`
`UNITED STATES DISTRICT COURT
`for the
`Southern District of Texas
`
`Civil Action No.
`
`4209-CV-01827
`
`(If the action is pending in another district, state where:
`)
`
`)
`)
`)
`
`))
`
`)
`
`WesternGeco L.L.C.
`Plaintifl
`V.
`ION Geophysical Corporation
`
`Defendant
`
`SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
`OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
`
`To: Petroleum Geo—Services, Inc.
`15150 Memorial Dr., Houston, TX 77079
`
`dProduc!z'0n.' YOU ARE COMM ANDED to produce at the time, date, and place set forth below the following
`documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
`material: See Schedule A.
`
`P1306: Smyser Kaplan & Veselka, L.L.P.
`700 Louisiana, Suite 2300
`Houston’ TX 77002
`
`Date and Time:
`
`,
`02/08/2010 9.00 am
`
`CI Inspection afPremises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
`other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
`may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
`
`Place:
`
`Date and Time:
`
`The provisions of Fed. R. Civ. P. 45(0), relating to your protection as a person subject to a subpoena, and Rule
`45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are
`attached.
`
`Date:
`
`Q][22[2_Q]Q
`
`CLERK OF COURT
`
`OR
`
`Signature ofClerk or Deputy Clerk
`
`Attorney ’: signature
`
`WesternGeco L.L.C.
`The name, address, e-mail, and telephone number of the attorney representing (name cfparty)
`, who issues or requests this subpoena, are:
`Ameet A. Modi, KIRKLAND & ELLIS LLP. 601 Lexington Avenue, New York, NY 10022
`(212) 446-4800
`
`amodi kirkland.com
`
`WESTERNGECO Exhibit 2009, pg. 1
`PGS V WESTERNGECO
`
`IPR2014-01475
`
`WESTERNGECO Exhibit 2009, pg. 1
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`A0 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection ofPremises in a Civil Action (Page 2)
`Civil Action No. 4:O9—cv-01827
`
`PROOF OF SERVICE
`(This section should not befiled with the court unless required by Fed. R. Civ. P. 45.}
`
`This subpoena for (name ofindividual and title, zfany)
`was received by me on (date)
`
`Petroleum Geo-Services, lnc_
`
`Kl served the subpoena by delivering a copy to the named person as follows:
`15150 Memorial Dr., Houston, TX 77079
`
`Petroleum Geo-Services, Inc.
`
`on (date)
`
`; or
`
`Cl I returned the subpoena unexecuted because:
`
`Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, 1 have also
`tendered to the witness fees for one day’s attendance, and the mileage allowed by law, in the amount of
`$
`
`My fees are $
`
`for travel and $
`
`for services, for a total of 39
`
`0'00
`
`I declare under penalty of perjury that this information is true.
`
`Date :
`
`Additional information regarding attempted service, etc:
`
`Server ‘s signature
`
`Printed name and title
`
`Server is address
`
`WESTERNGECO Exhibit 2009, pg. 2
`PGS V WESTERNGECO
`
`|PR2014-01475
`
`WESTERNGECO Exhibit 2009, pg. 2
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`A0 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection ofPremises in a Civil Action(Page 3)
`
`Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07)
`(c) Protecting a Person Subject to a Subpoena.
`(d) Duties in Responding to a Subpoena.
`(1) Avoiding Undue Burden or Expense; Sanctions. A party or
`(1) Producing Documents or Electranicalgr Stored Information.
`attomey responsible for issuing and serving a subpoena must take
`These procedures apply to producing documents or electronically
`stored infonnation:
`reasonable steps to avoid imposing undue burden or expense on a
`(A) Documents. A person responding to a subpoena to produce
`person subject to the subpoena. The issuing court must enforce this
`duty and impose an appropriate sanction — which may include lost
`documents must produce them as they are kept in the ordinary
`earnings and reasonable attorney‘s fees — on a party or attorney
`course of business or must organize and label them to correspond to
`who fails to comply.
`the categories in the demand.
`(2) Command to Produce Materials or Permit Inspection.
`(B) Farmfor Producing Electronically Stored Information Not
`(A) Appearance Not Required. A person commanded to produce
`Specified. If a subpoena does not specify a form for producing
`documents, electronically stored information, or tangible things, or
`electronically stored information, the person responding must
`to permit the inspection of premises, need not appear in person at the
`produce it in a fonn or forms in which it is ordinarily maintained or
`in a reasonably usable form or forms.
`place of production or inspection unless also commanded to appear
`for a deposition, hearing, or trial.
`(C) Electronically Stored Information Produced in Only One
`Farm. The person responding need not produce the same
`(B) Objections. A person commanded to produce documents or
`tangible things or to permit inspection may serve on the party or
`electronically stored information in more than one fonn.
`attorney designated in the subpoena a written objection to
`(D) Inaccessible Electronically Stored Information. The person
`inspecting, copying, testing or sampling any or all of the materials or
`responding need not provide discovery of electronically stored
`information from sources that the person identifies as not reasonably
`to inspectingrthe premises — or to producing electronically stored
`information in the form or forms requested. The objection must be
`accessible because of undue burden or cost. On motion to compel
`served before the earlier of the time specified for compliance or 14
`discovery or for a protective order, the person responding must show
`that the information is not reasonably accessible because of undue
`days afler the subpoena is served. If an objection is made, the
`following rules apply:
`burden or cost. If that showing is made, the court may nonetheless
`order discovery from such sources if the requesting party shows
`(i) At any time, on notice to the commanded person, the serving
`party may move the issuing court for an order compelling production
`good cause, considering the limitations of Rule 26(b)(2)(C). The
`court may specify conditions for the discovery.
`or inspection.
`(ii) These acts may be required only as directed in the order, and
`(2) Claiming Privilege or Protection.
`the order must protect a person who is neither a party nor a party’s
`(A) Information Withheld. A person withholding subpoenaed
`information under a claim that it is privileged or subject to
`officer from significant expense resulting from compliance.
`(3) Quashing or Modxjjiing a Subpoena.
`protection as trial-preparation material must:
`(A) When Required. On timely motion, the issuing court must
`(i) expressly make the claim; and
`quash or modify a subpoena that:
`(ii) describe the nature of the withheld documents,
`communications, or tangible things in a manner that, without
`(i) fails to allow a reasonable time to comply;
`(ii) requires a person who is neither a party nor a party‘s officer
`revealing information itself privileged or protected, will enable the
`parties to assess the claim.
`to travel more than 100 miles from where that person resides, is
`(B) Information Produced If information produced in response to a
`employed, or regularly transacts business in person — except that,
`subject to Rule 45(c)(3)(B)(iii), the person may be commanded to
`subpoena is subject to a claim of privilege or of protection as trial-
`attend a trial by traveling from any such place within the state where
`preparation material, the person making the claim may notify any
`the trial is held;
`party that received the information of the claim and the basis for it.
`Afier being notified, a party must promptly retum, sequester, or
`(iii) requires disclosure of privileged or other protected matter, if
`destroy the specified information and any copies it has; must not use
`no exception or waiver applies; or
`or disclose the information until the claim is resolved; must take
`(iv) subjects a person to undue burden.
`reasonable steps to retrieve the infonnation if the party disclosed it
`(B) When Permitted To protect a person subject to or affected by
`before being notified; and may promptly present the infonnation to
`a subpoena, the issuing court may, on motion, quash or modify the
`the court under seal for a determination of the claim. The person
`subpoena if it requires:
`who produced the information must preserve the information until
`(i) disclosing a trade secret or other confidential research,
`the claim is resolved.
`development, or commercial information;
`(ii) disclosing an unretained expert's opinion or information that
`does not describe specific occurrences in dispute and results from
`the expert’s study that was not requested by a party; or
`(iii) a person who is neither a party nor a party’s officer to incur
`substantial expense to travel more than 100 miles to attend trial.
`(C) Specifizing Conditions as an Alternative. In the circumstances
`described in Rule 45(c)(3)(B), the court may, instead of quashing or
`modifying a subpoena, order appearance or production under
`specified conditions ifthe serving party:
`(i) shows a substantial need for the testimony or material that
`cannot be otherwise met without undue hardship; and
`(ii) ensures that the subpoenaed person will be reasonably
`compensated.
`
`(e) Contempt. The issuing court may hold in contempt a person
`who, having been served, fails without adequate excuse to obey the
`subpoena. A nonparty’s failure to obey must be excused if the
`subpoena purports to require the nonparty to attend or produce at a
`place outside the limits of Rule 45(c)(3)(A)(ii).
`
`WESTERNGECO Exhibit 2009, pg. 3
`PGS V WESTERNGECO
`
`|PR2014-01475
`
`WESTERNGECO Exhibit 2009, pg. 3
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`SCHEDULE A
`
`DEFINITIONS AND INSTRUCTIONS
`
`As used herein, "PGS" means Petroleum Geo-Services, Inc. and all its predecessors
`1.
`(merged, acquired, or otherwise), successors, subsidiaries, parents, sisters, partnerships and
`affiliates thereof (including, but not limited to, Petroleum Geo-Services ASA, Petroleum Geo-
`Services (U.S.), Inc., PGS Onshore do Brasil, PGS Onshore Inc., PGS Mexicana, PGS Onshore
`Peru, PGS de Venezuela, PGS Geophysical AS, PGS Technology (Sweden) AB, PGS Reservoir
`Ltd., PGS - Kazakhstan LLP, PGS CIS LLP, PGS Data Processing Middle East, PGS Angola
`Ltd., PGS Exploration (UK) Ltd., PGS Exploration (Nigeria) Ltd., Petroleum Geo-Services Asia
`Pacific Pte. Ltd., PGS Australia Pty. Ltd., PGS Japan K.K., Petroleum Geo-Services Exploration,
`PGS Data Processing & Technology Sdn. Bhd., and PT. Petroprima Geo Servis Nusantara), and
`all directors, officers, agents, employees, attorneys and other persons acting on their behalf.
`
`As used herein, "ION" means ION Geophysical Corporation and all its predecessors
`2.
`(merged, acquired, or otherwise), successors, subsidiaries, parents, sisters, partnerships and
`affiliates thereof, and all directors, officers, agents, employees, attorneys and other persons
`acting on their behalf.
`
`As used herein, "Bird" means any device with one or more control surfaces, used for
`3.
`positioning of seismic streamers, e.g., for depth and/or lateral positioning, including but not
`limited to DigiFIN and DigiBIRD.
`
`As used herein, "Streamer Control Device(s)" means any technology, apparatus, system,
`4.
`component, software, or method that is capable of taking any part in vertical and/or horizontal
`control, steering, positioning and/or monitoring of any towed seismic streamer and/or Bird.
`
`As used herein, "Asserted WestemGeco Claims" means all patent claims asserted at any
`5.
`time by WestemGeco against ION in Civil Action No. 4:09-CV-01827, including without
`limitation:
`
`A.
`
`B
`
`C.
`
`D
`
`E.
`
`United States Patent No. 6,691,038 claims 1-7, 10-11, 13-17, 20-32, 35-36, 38-42,
`and 45-50;
`
`United States Patent No. 6,932,017 claims 1-9, and 16;
`
`United States Patent No. 7,080,607 claims 1-9, and 15;
`
`United States Patent No. 7,162,967 claims 1, 4-10 and 15; and
`
`United States Patent No. 7,293,520 claims 1-3, 6-20, and 23-34.
`
`As used herein, "1ON Accused Product" means any product or method made, used,
`6.
`offered for sale, imported, licensed, distributed, or otherwise disposed of by or for ION, that
`WestemGeco accuses at any time during the course of Civil Action No. 4:09-CV-01827 of
`infringing any of the Asserted WestemGeco Claims directly (either literally or under the doctrine
`of equivalents) or indirectly (either by inducement or contributory infringement) including
`
`WESTERNGECO Exhibit 2009, pg. 4
`PGS V WESTERNGECO
`
`IPR2014-01475
`
`WESTERNGECO Exhibit 2009, pg. 4
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`without limitation: products and services including, in-whole or in part, ORCA, the lateral
`controller, DigiFIN and/or DigiBlRD.
`
`As used herein "communication" means an transmission of information b one or more
`7.
`3
`y
`y
`ersons and/or between two or more ersons b an means includin tele hone conversations,
`p
`.
`.
`.
`P
`.
`.
`letters, telegrams, teletypes, telexes, telecopies, electronic mail, other computer linkups, written
`memoranda, and face-to-face conversations.
`
`As used herein, "and" and "or" shall be construed conjunctively and disjunctively so as to
`8.
`acquire the broadest meaning possible.
`
`As used herein, "any" and "all" shall each be construed to mean "each and every," so as
`9.
`to acquire the broadest possible meaning.
`
`As used herein, "include" and "including" shall be construed to mean "without
`10.
`limitation," so as to acquire the broadest meaning possible.
`
`The singular and masculine form of a noun or pronoun shall embrace, and shall be read
`11.
`and applied as, the plural or the feminine or neuter, as the particular context makes appropriate
`and to give the noun or pronoun the broadest meaning possible.
`
`As used herein, "document" has the same broad meaning as in Rule 34 of the Federal
`12.
`Rules of Civil Procedure. The term "document" also encompasses tangible things.
`
`As used herein, "person“ means any natural person or any business, legal or
`13.
`governmental entity or association.
`
`As used herein, "relating to" means, without limitation, identifying, describing,
`14.
`discussing, concerning, assessing, stating, reflecting, constituting, containing, embodying,
`tending to support or refute, or referring directly or indirectly to, in any Way, the particular
`subject matter identified.
`
`As used herein, the terms "Complaint," Answer," "Affirmative Defense,"
`15.
`"Counterclaim," and "Reply" shall mean the pleadings as originally filed or as amended or
`supplemented throughout the progression of the case.
`
`The document requests herein shall be deemed to include any and all relevant documents
`16.
`within the possession, custody or control of PGS, including documents located in the personal
`files of any and all past and present directors, officers, agents, representatives, employees,
`attorneys and accountants of PGS.
`
`Documents from any single file should be produced in the same order as they were found
`17.
`in such file, including any labels, files, folders and/or containers in which such documents are
`located in or associated with. If copies of documents are produced in lieu of the originals, such
`copies should be legible and bound or stapled, or with similar breaks and groupings if produced
`electronically, in the same manner as the originals.
`
`WESTERNGECO Exhibit 2009, pg. 5
`PGS V WESTERNGECO
`
`IPR2014-01475
`
`WESTERNGECO Exhibit 2009, pg. 5
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`Discovery in this action is subject to the Court's August 28, 2009 Protective Order, a
`18.
`copy of which is attached hereto. PGS may designate documents and things produced pursuant
`to this subpoena confidential in accordance with the Protective Order.
`
`WESTERNGECO Exhibit 2009, pg. 6
`PGS V WESTERNGECO
`
`IPR2014-01475
`
`WESTERNGECO Exhibit 2009, pg. 6
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`DOCUMENTS TO BE PRODUCED
`
`. Documents sufficient to show the quantity and type of all Streamer Control Devices
`(including the manufacturer, trade name, model, number, part number, catalog number, and
`each other designation known to PGS) made, used, licensed, distributed, supplied, purchased,
`sold, or offered for sale by PGS, including but not limited to any ION Accused Product, on a
`monthly basis since February 25, 2003 (in electronic form to the extent such electronic files
`exist), whether made, used, licensed, distributed, supplied, purchased, sold, or offered for
`sale separately or as part of any other product or service.
`
`. All documents related to PGS's purchase, use, operation, and/or offer for sale of any ION
`Accused Product, including but not limited to DigiBIRD, DigiFIN, and ORCA, and systems
`or services incorporating or including any or all of these products.
`
`. All communications between PGS and ION relating to DigiBIRD, DigiFlN, ORCA or any
`other Streamer Control Device or Bird.
`
`. All documents related to bids, tenders, requests for proposals, or offers for sale PGS has
`received, transmitted, solicited or responded to which include or relate to Streamer Control
`Devices, including but not limited to any ION Accused Product.
`
`. All documents relating to the benefits, advantages, value, or importance of Streamer Control
`Devices, both in general and as relating to any specific Streamer Control Device.
`
`. All documents relating to the benefits, disadvantages, value, or importance of purchasing or
`not purchasing any products or services from ION, including but not limited to Streamer
`Control Devices.
`
`. All documents, including but not limited to studies and tests conducted by PGS, regarding
`the benefits and deficiencies of any Streamer Control Device, including but not limited to
`any ION product.
`
`. All documents relating to the benefits, advantages, value, or importance of any ION
`products, including but not limited to Streamer Control Devices, used, licensed, purchased,
`sold, or offered for sale by PGS.
`
`. All documents related to PGS's past, present, or future market share for seismic surveys,
`including but not limited to those including or involving Streamer Control Devices.
`
`. All documents sufficient to identify all PGS competitors with respect to seismic surveys,
`including but not limited to those involving Streamer Control Devices.
`
`WESTERNGECO Exhibit 2009, pg. 7
`PGS V WESTERNGECO
`
`|PR2014-01475
`
`WESTERNGECO Exhibit 2009, pg. 7
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`o
`
`COURT
`
`COUNTY OF
`WESTERNGECO L.L.C.
`
`UNITED STATES DISTRICT COURT
`FOR THE
`SOUTHERN DISTRICT OF TEXAS
`
`e 1888 JuUUII BL~G,INC.•
`PuBLISHER. NYC 100 1 3
`
`CIVIL ACTION
`Jl1il.B.No. 4: 09-CV-01827
`
`ION GEOPHYSICAL CORPORATION
`
`against
`
`Pia in tiff(s)
`
`AFFIDAVIT OF
`SERVICE OF SUBPOENA
`TO PRODUCE DOCUMENTS,
`INFORMATION, OR. OBJECTS OR TO
`Dejendalll(sJ
`PERMIT INSPECTION OF PREMISES
`---'""'T....E....U.....S , , - - - - - - - - - - - - - - - - - - - - - - - IN A CIVIL ACTION
`STATE OF IIM¥Ut<. COUNTY OF HARRIS
`55:
`The undersigned. being duly sworn. deposes and says; deponent is not a
`pany herein. is over 18 years of age and resides:a1{ IN THE STATE OF TEXAS
`That on
`1/22/10
`at 1:'57P. M.. at1'51'50 MEMORIAL DR., HOUSTON, TX 77079
`deponent served the within subpoena on
`PETROLEUM GEO-SERVICES,
`INC.
`witness therein named,
`SEE ABOVE STATED DOCUMENTS
`by delivering a true copy to said witness personally; deponent knew the person so served to be the witness described in said
`ItlOIVlDUAl
`t. 0
`subpoena.
`MARISA ROWLAND
`corporation. by delivering thereat a true copy (0
`a
`DOMESTIC
`COIlf'OlIAnOll
`liD'
`personally. deponent knew said corporation so served to be ihe corporation witness and knew said individual to be
`MANAGING AGENT
`thereof.
`a person of suitable age
`IlIITAIlUGEI'fllSOIl by delivering thereat a true copy to
`3. 0
`and discretion. Said premises is witness'-actual place of business-dwelling place-usual place of abode-within the state.
`AFFIXING TO DOOR. ETC. by affixing a true copy to the door of said premises. which is witness'-actual place of business-dwelling place-usual place
`4 0
`of abode-within the state. Deponent was unable. with due diligence to find witness or a person of suitable age and discretion
`thereat. having called there
`
`f.
`
`Within 20 days of such delivery or affixing. deponent enclosed a copy of ~ame in a postpaid envelope properly addressed to wibless
`at witness' last known residence. at
`and deposited
`said envelope in an official depository under the exclusive care and custody of the U.S. Postal Service within New York State.
`
`Within 20 days of such delivery or affixing, deponent enclosed a copy of same in a first class postpaid envelope properly
`addressed to witness at witness' actual place of business, at
`in an official depository under the exclusive care and custody of the U.S. Postai Service within New York State. The envelope bore
`the legend "Personal and Confidential" and did not indicate on the outside thereof. by return address or otherwise. that the
`communication was from an attorney or concerned an action against the witness.
`o Under 5'
`o Black Hair
`0 White Hair o 14-20 Yrs.
`p.( 5'0·'-5'3"
`o 21-35 Yrs.
`f,( Brown Hair
`0 Balding
`o 5'4"-5'8" ~ 131-160 Lbs.
`o Blonde Hair
`0 Mustache ~ 36-50 Yrs.
`o 5·9"-6'0"
`o Gray Hair
`0 Beard
`51-65 Yrs.
`DOver 65 Yrs. o Over 6'
`o Red Hair
`0 Glasses
`
`0 Under 100 Lbs.
`0 l00-'l30 Lbs.
`
`161-200 Lbs.
`0 Over 200 Lbs.
`
`Male ~ White Skin
`JC Female o Black Skin
`r; Yellow Skin
`Brown Skin
`o Red Skin
`Other identifying features:
`
`u0
`
`IUll.lllG TO
`IlESIDEI!Cf
`USE W1TJ13 Oil 4
`SA. 0
`
`IIAlI.IIIG TO
`IUSIIESS
`USE WITM 3 Oil 4
`
`saD
`
`OEWlWTION
`USEWlTH
`1.2.011 3
`IX)
`
`At the time of said service. deponent paid (tendered) in advance $
`
`the authorized traveling expenses and one day's witness fee.
`
`WESTERNGECO Exhibit 2009, pg. 8
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`AO 88B (Rev. 06109) Subpoena to Produce Documents. Information, or Objects or to Pennit Inspection ofPremises in a Civil Action
`
`UNITED STATES DISTRICT COURT
`for the
`
`Southern District ofTexas
`
`Civil Action No.
`
`4:09-cv-01827
`
`(If the action is pending in another district, state where:
`
`))))))
`
`WestemGeco L.L.C.
`Plaintif!
`v.
`ION Geophysical Corporation
`
`Defendant
`
`SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
`OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
`
`To: Petroleum Geo-Services, Inc.
`15150 Memorial Dr., Houston, TX 77079
`rIProduction: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
`documents, electronically stored information, or objects, and pennittheir inspection, copying, testing, or sampling ofthe
`material: See Schedule A.
`
`Place: Smyser Kaplan &Veselka, L.L.P.
`700 Louisiana, Suite 2300
`Houston, TX 77002
`
`Date and Time:
`
`02108/2010 9:00 am
`
`CJ Inspection ofPremises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
`other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
`may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it
`
`l_p_Ia_c_e_:
`
`I_D_a_te_an_d_T_im_e_:
`
`---'
`
`The provisions ofFed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
`45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences ofnot doing so, are
`attached;
`
`Date:
`
`0112212010
`
`CLERK OF COURT
`
`OR
`
`Signature ofClerk or Deputy Clerk
`
`Attomey's signature
`
`WestemGeco L.L.C.
`The name, address, e-mail, and telephone number ofthe attorney representing (name ofparty)
`_______________ _ _ _ _ _ _ ____ , who issues or requests this subpoena, are:
`Ameet A. Modi, KIRKLAND &ELLIS LLP, 601 Lexington Avenue, New York, NY 10022
`(212) 446-4800
`.
`amodi@kirkland.com
`
`1
`
`WESTERNGECO Exhibit 2009, pg. 9
`PGS v WESTERNGECO
`IPR2014-01475
`
`

`
`AO 88B (Rev. 06109) Subpoena to Produce Documents,lnfonnation, or Objects or to Permit Inspection ofPremises in a Civil Action (page 2)
`
`Civil Action No. 4:09-cv-01827
`
`PROOF OF SERVICE
`(This section should not befiled with the court unless required by Fed. R. Civ. P. 45.)
`
`This subpoena for (name ofindividual and title, ifany)
`\ - ~d, \. LO
`was received by me on (dale)
`rII served the subpoena by delivering a copy to the named person as follows:
`.
`bu
`
`Petroleum Geo-Services. Inc.
`------------'------------
`
`Petroleum Geo-Services, Inc.
`
`o I returned the subpoena unexecuted because:
`
`I
`
`Unless the subpoena was issued on behalfof the United States, or one ofits officers or agents, I have also
`tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
`
`$
`
`My fees are $
`
`- - - - - - -
`
`for travel and $
`
`- - - - - -
`
`for services, for a total of $
`
`0.00
`
`I declare under penalty of perjury that this information is true.
`
`Date:
`
`Additional information regarding attempted service, etc:
`
`y~~euJ2
`(-F. m 1IV\0lVl~0{ I1(OLOL-14 iJO
`
`------..
`
`WESTERNGECO Exhibit 2009, pg. 10
`PGS v WESTERNGECO
`IPR2014-01475