`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`WEATHERFORD INTERNATIONAL, LLC;
`WEATHERFORD/LAMB, INC.;
`WEATHERFORD US, LP; and WEATHERFORD
`ARTIFICIAL LIFT SYSTEMS, LLC
`Petitioners
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`v.
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`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
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`___________________
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`Case IPR2016-01509
`Patent 7,861,774
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`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`MOTION TO EXCLUDE
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Exclusive Licensee Rapid Completions LLC moves to exclude the
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`Case IPR2016-01509
`Patent 7,861,774
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`following exhibits and testimony pursuant to Rule 42.64:
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`Exhibit 1008—Transcript of Daniel Themig – 01/08/2007
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`Objections: (1) Authentication – Federal Rule of Evidence (“FRE”) 901(a); (2)
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`Hearsay – FRE 801(c), 802.
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`Location of prior objections: Paper 26 at 2-3.
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`Locations exhibit is relied upon by RC: Petition at 17-18.
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`Explanation: Weatherford has not offered evidence that the documents are
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`authentic. To the extent Weatherford relies on the declaration of their paralegal
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`Carrie Anderson, they must establish a foundation that would enable her to
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`competently testify about the exhibit’s authenticity. Moreover, Weatherford relies
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`on these documents for the truth of the matters asserted, and thus, they are hearsay.
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`However, Weatherford has not asserted any hearsay exception that renders them
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`admissible.
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`Exhibit 1011—Affidavit of Ken Trahan
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`Objections: (1) Authentication – Federal Rule of Evidence (“FRE”) 901(a); (2)
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`Hearsay – FRE 801(c), 802.
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`Location of prior objections: Paper 26 at 3.
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`Locations exhibit is relied upon by RC: Petition at 18.
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`Case IPR2016-01509
`Patent 7,861,774
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`Explanation: Weatherford has not offered evidence that the documents are
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`authentic. To the extent Weatherford relies on the declaration of their paralegal
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`Carrie Anderson, they must establish a foundation that would enable her to
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`competently testify about the exhibit’s authenticity. Moreover, Weatherford relies
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`on these documents for the truth of the matters asserted, and thus, they are hearsay.
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`However, Weatherford has not asserted any hearsay exception that renders them
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`admissible.
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`Exhibit 1012—Expert Report of Kevin Trahan
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`Objections: (1) Authentication – Federal Rule of Evidence (“FRE”) 901(a); (2)
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`Hearsay – FRE 801(c), 802.
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`Location of prior objections: Paper 26 at 3-4.
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`Locations exhibit is relied upon by RC: Petition at 19 and 55.
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`Explanation: Weatherford has not offered evidence that the documents are
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`authentic. To the extent Weatherford relies on the declaration of their paralegal
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`Carrie Anderson, they must establish a foundation that would enable her to
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`competently testify about the exhibit’s authenticity. Moreover, Weatherford relies
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`on these documents for the truth of the matters asserted, and thus, they are hearsay.
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`However, Weatherford has not asserted any hearsay exception that renders them
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`admissible.
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`Exhibit 1013—First Supplemental Report of Kevin Trahan
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`Objections: (1) Authentication – Federal Rule of Evidence (“FRE”) 901(a); (2)
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`Case IPR2016-01509
`Patent 7,861,774
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`Hearsay – FRE 801(c), 802.
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`Location of prior objections: Paper 26 at 4-5.
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`Locations exhibit is relied upon by RC: Petition at 19.
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`Explanation: Weatherford has not offered evidence that the documents are
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`authentic. To the extent Weatherford relies on the declaration of their paralegal
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`Carrie Anderson, they must establish a foundation that would enable her to
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`competently testify about the exhibit’s authenticity. Moreover, Weatherford relies
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`on these documents for the truth of the matters asserted, and thus, they are hearsay.
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`However, Weatherford has not asserted any hearsay exception that renders them
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`admissible.
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`Exhibit 1014—Supplemental Engineering Report Prepared By Ronald
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`Britton, P.E.
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`Objections: (1) Authentication – Federal Rule of Evidence (“FRE”) 901(a); (2)
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`Hearsay – FRE 801(c), 802.
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`Location of prior objections: Paper 26 at 5.
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`Locations exhibit is relied upon by RC: Petition at 20.
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`Explanation: Weatherford has not offered evidence that the documents are
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`authentic. To the extent Weatherford relies on the declaration of their paralegal
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`Carrie Anderson, they must establish a foundation that would enable her to
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`Patent 7,861,774
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`competently testify about the exhibit’s authenticity. Moreover, Weatherford relies
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`on these documents for the truth of the matters asserted, and thus, they are hearsay.
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`However, Weatherford has not asserted any hearsay exception that renders them
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`admissible.
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`Dated: September 28, 2017
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`Respectfully submitted,
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`Rapid Completions LLC
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`By /Justin T. Nemunaitis/
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`Hamad M. Hamad, Reg. No. 64,641
`Bradley W. Caldwell (pro hac vice)
`Justin T. Nemunaitis (pro hac vice)
`CALDWELL CASSADY CURRY,
`P.C.
`2101 Cedar Springs Road, Suite 1000
`Dallas, Texas 75201
`Telephone: 214.888.4848
`Facsimile: 214.888.4849
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`rapid@caldwellcc.com
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`Dr. Gregory Gonsalves, Re. No.
`43,639
`GONSALVES LAW FIRM
`2216 Beacon Lane
`Falls Church, Virginia 22043
`Telephone: 571.419.7252
`gonsalves@gonsalveslawfirm.com
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`Case IPR2016-01509
`Patent 7,861,774
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`The undersigned hereby certifies that the foregoing document was served
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`via electronic mail, as previously consented to by Petitioner upon the following
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`counsel of record:
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`Jason Shapiro (Lead Counsel)
`Patrick Finnan (Back-up Counsel)
`EDELL,SHAPIRO & FINNAN, LLC
`js@usiplaw.com
`pjf@usiplaw.com
`epatent@usiplaw.com
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`Date: September 28, 2017
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` /Hamad M. Hamad/
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`Hamad M. Hamad, Reg. No. 64,641
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