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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
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`
`
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`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.,
`
`Petitioner,
`
`v.
`
`TELEFLEX LIFE SCIENCES LIMITED,
`
`Patent Owner.
`
`
`
`
`
`
`
`Case IPR2020-01341
`U.S. Patent No. 8,142,413
`
` Case IPR2020-01343
`U.S. Patent No. RE 46,116
`
`
`
`
`
`
`PETITIONER’S MOTION TO EXCLUDE EXHIBIT 2024
`AND PORTIONS OF EXHIBIT 1799
`
`
`
`
`
`TABLE OF CONTENTS
`
`
`I.
`II.
`
`INTRODUCTION ............................................................................................ 1
`TELEFLEX HAS NOT AUTHENTICATED EXHIBIT 2024 AND
`CANNOT RELY ON IT FOR THE TRUTH OF ITS CONTENTS. .............. 3
`A.
`Exhibit 2024 is unreliable on its face. ................................................... 4
`B.
`Peterson cannot authenticate Exhibit 2024. .......................................... 6
`1.
`Peterson lacks personal knowledge of Exhibit 2024. ................. 7
`2.
`Peterson lacks knowledge of VSI’s record-keeping
`procedures. .................................................................................. 8
`No other witness can authenticate Exhibit 2024. .................................. 8
`C.
`III. PORTIONS OF ERB’S DEPOSITION TESTIMONY ARE BEYOND
`THE SCOPE, UNTIMELY, AND PREJUDICIAL. ...................................... 10
`A. On redirect, over Medtronic’s objection, Erb provided new
`testimony regarding the timing of prototype testing. .......................... 11
`Erb’s testimony on re-cross should likewise be excluded. ................. 13
`B.
`IV. CONCLUSION .............................................................................................. 15
`
`
`
`
`
`
`
`
`i
`
`
`
`TABLE OF AUTHORITIES
`
` Page(s)
`
`Cases
`Ingenico Inc. v. Iogene, LLC,
`IPR2019-00929, Paper 53 (PTAB Sept. 21, 2020) ......................................... 6
`Linear Technology Corp. v. Micrel, Inc.,
`275 F.3d 1040 (Fed. Cir. 2001) .............................................................. 6, 7, 9
`Netflix, Inc. v. DivX, LLC,
`IPR2020-00511, Paper 20 (PTAB Aug. 13, 2021) ........................................11
`Riverbed Tech., Inc. v. Realtime Data LLC,
`IPR2016-00978, Paper 67 (PTAB Oct. 30, 2017) ........................................... 3
`Schroeder v. Smith’s Food & Drug Centers, Inc.,
`No. 2:12-CV-02024-APG, 2014 WL 548149 (D. Nev. Feb. 11, 2014) ........10
`Standard Innovation Corp. v. Lelo, Inc.,
`IPR2014-00148, Paper 41 (PTAB Apr. 23, 2015) ......................................5, 6
`Statutes
`37 C.F.R. § 42.64(a) .......................................................................................... 10, 12
`Rules
`Fed. R. Evid. 403 .....................................................................................................10
`Fed. R. Evid. 901 ....................................................................................................... 3
`
`
`
`
`
`ii
`
`
`
`
`
`I.
`
`INTRODUCTION
`Teleflex uses unreliable, untimely evidence to bolster its prior invention
`
`arguments. The Board should exclude the improper evidence.
`
`To try to antedate Medtronic’s primary prior art reference, Itou, Teleflex relies
`
`on a “Product Requirements: Guideliner Catheter System” document (Ex-2024).
`
`Medtronic objected to Exhibit 2024 under Federal Rules of Evidence 802 and 901.
`
`See IPR2020-01341, Paper 29; IPR2020-01343, Paper 24. Teleflex relies on Exhibit
`
`2024 for the truth of its contents, and it tries to authenticate the document using Dean
`
`Peterson, a former-VSI, now-Teleflex Research and Development Engineer. But
`
`Exhibit 2024 lacks critical indicia of reliability on its face, and Teleflex’s attempt to
`
`authenticate the document using Peterson’s conclusory declaration fails.
`
`Indeed, none of Teleflex’s witnesses appear to have personal knowledge of
`
`Exhibit 2024. Gregg Sutton, Deborah Schmalz, and Howard Root all mention
`
`Exhibit 2024 in their declarations and depositions. See Ex-1762, 116:11 et seq.;
`
`Ex-1757, 79:20 et seq.; Ex-1766, 56:9 et seq. But none provides information
`
`necessary to verify that the document is what Teleflex says.1
`
`
`1 In related IPR proceedings, the Board determined that Teleflex had satisfied its
`
`authenticity obligations, but it discounted the document and recognized that it is
`
`not entirely reliable on its face:
`
`
`
`1
`
`
`
`Teleflex’s reduction-to-practice case balances on unfounded assumptions
`
`about Exhibit 2024 and a presumption of its reliability. Based on those assumptions,
`
`Teleflex witnesses offer only additional assumptions regarding VSI’s prototype
`
`efforts. Thus, Exhibit 2024 is entitled to no—rather than little—weight. Because
`
`Teleflex cannot prove that Exhibit 2024 is what it claims—a document created on
`
`August 24, 2005, and addressing RX prototypes as of that date—its witnesses’
`
`assumptions regarding the document are unreliable and, thus, irrelevant. The Board
`
`should exclude Exhibit 2024.
`
`Further, in a late attempt to strengthen its reduction-to-practice case,
`
`Teleflex’s star non-inventor witness, Steve Erb, expanded his testimony during his
`
`deposition. The Board should exclude those portions of Erb’s deposition, identified
`
`
`Although
`this document sets
`
`forth several user
`
`requirements for the device, it does not identify the
`
`product specifications and test methods correlating to
`
`those requirements. Ex. 2024, 24. The revision history of
`
`the document also indicates it is “pre-release,” thereby
`
`suggesting that it may not have been finalized at the time.
`
`IPR2020-00126, Final Written Decision at 45.
`
`
`
`2
`
`
`
`here, because they prejudice Medtronic’s ability to respond to Teleflex’s CRTP
`
`arguments.
`
`II. TELEFLEX HAS NOT AUTHENTICATED EXHIBIT 2024 AND
`CANNOT RELY ON IT FOR THE TRUTH OF ITS CONTENTS.
`Under Federal Rule of Evidence 901, Teleflex “must produce evidence
`
`sufficient to support a finding that [Exhibit 2024] is what the proponent [Teleflex]
`
`claims it is.” Fed. R. Evid. 901; Riverbed Tech., Inc. v. Realtime Data LLC,
`
`IPR2016-00978, Paper 67 at 41 (PTAB Oct. 30, 2017) (“The burden is on Patent
`
`Owner to produce evidence sufficient to support a finding that [the exhibit] is what
`
`the Patent Owner claims it is.”). Teleflex cannot prove that Exhibit 2024 is what it
`
`claims it is: a document that VSI created as of a particular date—August 24, 2005—
`
`that “signaled the transition to the formal Quality process for bringing [the
`
`GuideLiner RX] to market.” IPR2020-01341, Paper 23 (POR) at 34; IPR2020-
`
`01343, Paper 21 (POR) at 26. Teleflex contends that “such a document would not
`
`be drafted until prototypes had been made and tested to show that they would work
`
`for their intended purpose.” IPR2020-01341, Paper 23 (POR) at 35; IPR2020-01343,
`
`Paper 21 (POR) at 26. If Teleflex cannot (i) date the document, or (ii) show that the
`
`document addressed RX Product Requirements as of August 24, 2005, the document
`
`is not what Teleflex claims and, thus, is unauthenticated, irrelevant, and
`
`inadmissible.
`
`
`
`3
`
`
`
`A. Exhibit 2024 is unreliable on its face.
`Exhibit 2024 lacks critical indicia of reliability. First, the document does not
`
`provide a reliable date. The “8/24/05” on the face of the document is an unexplained
`
`“effective” date:
`
`
`
`
`
`Ex-2024, 1, 4. The date—“8/24/05”—is neither a date created nor a date last
`
`modified. It provides no information about when the author prepared or revised the
`
`document. The document’s metadata includes no “Date Created” or “Date Last
`
`Modified.” Ex-1855. Teleflex cannot rely on the date on the face of the document
`
`“as proof of date[] of creation, modification, or publication”—the date is
`
`inadmissible hearsay if Teleflex “has not established that the dates [on the face of
`
`the document] are automatically generated.” See Standard Innovation Corp. v. Lelo,
`
`
`
`4
`
`
`
`Inc., IPR2014-00148, Paper 41 at 18 (PTAB Apr. 23, 2015). Thus, Teleflex cannot
`
`rely on “8/24/05” to date the document.
`
`Further, the document’s metadata suggests that the author created the
`
`document to address only GuideLiner OTW (prior art), not GuideLiner RX
`
`(purported invention). The document’s file name is “PS1068 rev 01 Product User
`
`Requirements for GuideLiner OTW Support Catheter.” Ex-1855 (emphasis added).
`
`No evidence—no witness, no document—provides information regarding when, or
`
`how, the author added GuideLiner RX to the document. Indeed, VSI tracked
`
`versions of the document only in hard copy. See Ex-1766, 53:22-54:5. Based on the
`
`evidence of record, there is no way to know when a version of the document referring
`
`to the GuideLiner RX was created.
`
`Second, the document is an incomplete draft. See Ex-1762, 117:14-118:3. The
`
`document is missing most of its substance (no product specifications, no test
`
`methods), is marked “Rev. 01,” and includes a note that the document is “Pre-
`
`release.” Ex-2024.
`
`Third, the document does not identify its author. The document only identifies
`
`“J. Kauphusman” as “Reviewer” and “J. Kujawa” for “Documentation,” Ex-2024,
`
`1, neither of whom authored the document. Nor could either Teleflex witnesses who
`
`relied on the document —Root and Schmalz—identify the author. Ex-1762, 116:21-
`
`117:2; Ex-1766, 56:17-25 (“He was clearly the person that reviewed and approved
`
`
`
`5
`
`
`
`this document, but I cannot say for certain that he was the one that actually wrote
`
`it.”).
`
`The document—which is an incomplete draft—provides no reliable date,
`
`substance, or author. The August 24, 2005, date on the face of the document is
`
`neither reliable nor meaningful on the current record. Exhibit 2024 is, on its face,
`
`unreliable.
`
`Peterson cannot authenticate Exhibit 2024.
`B.
`Even if Exhibit 2024 did not facially present reliability and hearsay issues,
`
`Teleflex still must authenticate it to rely on it. Teleflex relies on Peterson’s
`
`declaration, but he cannot authenticate the document. Peterson does not speak to the
`
`creation of the document, and his testimony regarding VSI’s document maintenance
`
`practices is directly contradicted by other record evidence.
`
`Though authentication is not a significant hurdle, failure to authenticate
`
`warrants exclusion. Linear Technology Corp. v. Micrel, Inc., 275 F.3d 1040, 1055-
`
`56 (Fed. Cir. 2001); see also Standard Innovation Corp., IPR2014-00148, Paper 41
`
`at 10-23 (excluding documents on hearsay and authentication grounds where no
`
`witness in the proceeding had personal knowledge of the documents); Ingenico Inc.
`
`v. Iogene, LLC, IPR2019-00929, Paper 53 at 97-98 (PTAB Sept. 21, 2020) (patent
`
`owner did not meet authentication burden in absence of any testimony about the
`
`document).
`
`
`
`6
`
`
`
`Peterson lacks personal knowledge of Exhibit 2024.
`1.
`The sum total of Peterson’s testimony purportedly authenticating Exhibit
`
`2024 is as follows:
`
`
`
`Ex-2252 ¶ 18. Peterson does not purport to have personal knowledge of the
`
`document, testifying only that it “was made by VSI personnel with knowledge of the
`
`issues contained therein on or near the date of the document.” Id. There is no record
`
`evidence that Peterson has personal knowledge of the document, especially
`
`considering he joined VSI only one month before the purported creation date.
`
`Ex-1856, 1.
`
`Peterson offers only conclusory statements about Exhibit 2024 and the
`
`systems used to prepare and maintain it. He cannot and does not speak to the
`
`document’s authorship, date of creation, method of creation, or maintenance.
`
`Peterson’s testimony is conclusory, and for that reason, it cannot authenticate
`
`Exhibit 2024. See Linear Technology Corp., 275 F.3d at 1055-56 (exhibit excluded
`
`
`
`7
`
`
`
`where authenticating witness had only knowledge of a file type generally, and not
`
`specific knowledge of the challenged documents).
`
`2.
`
`Peterson lacks knowledge of VSI’s record-keeping
`procedures.
`The conclusory testimony that Peterson does provide is inconsistent with
`
`other evidence of record. Peterson testifies that the document was maintained “on
`
`[VSI’s] network.” Ex-2252 ¶ 18. But Schmalz’s testimony contradicts Peterson’s.
`
`See Ex-2039 ¶ 8; Ex-1766, 53:22-54:5 (testifying that the “doc control system” at
`
`VSI was not electronic and that “[w]e maintained hard copies of all documents”). If
`
`anything, Peterson leaves Exhibit 2024 less reliable than when he found it.
`
`C. No other witness can authenticate Exhibit 2024.
`Exhibit 2024 is not self-authenticating, and Teleflex offers no witness to
`
`authenticate it. A witness authenticates a document by having personal knowledge
`
`of its creation and maintenance, by providing information showing what the
`
`document is, and by confirming that the document is reliable. Fed. R. Evid. 901.
`
`None of Teleflex’s witnesses can do this.
`
`Sutton lacks personal knowledge. Sutton’s declaration states that a product
`
`requirements document, in general, is “one of the first documents that is part of the
`
`design history process” and that VSI did not create product requirements documents
`
`“unless or until we had gone through feasibility and prototyping of a device and were
`
`ready to move forward with commercialization efforts.” Ex-2119 ¶ 44. That is it. He
`
`
`
`8
`
`
`
`does not discuss the particular product requirements document that Teleflex filed.
`
`Sutton does not even swear that Exhibit 2024 is a “true and correct” copy of a
`
`product requirements document. But Sutton should have been able to say more about
`
`the document. In August 2005, Sutton was VSI’s Vice President of Research and
`
`Development. Id. ¶ 2.
`
`Schmalz lacks personal knowledge. Schmalz’s testimony is limited to
`
`product requirements documents in general, too. She has no personal knowledge of
`
`Exhibit 2024. Ex-2039 ¶ 6 (describing “[s]uch a document” rather than this
`
`particular document). She describes information found on the face of the document.
`
`Id. ¶ 7. Like Sutton, she cannot confirm that the document is “true and correct.” Id.
`
`¶ 6. She admits that she lacks first-hand knowledge of the document’s creation. Id.
`
`¶¶ 6-8; Ex-1766, 44:24-45:17 (testifying that someone in VSI’s R&D department
`
`authored the document and that no one on Schmalz’s team authored the document);
`
`56:17-25 (testifying that she did not know if the “J. Kauphusman listed at the top of
`
`this document” authored the document); 48:2-7 (testifying that she did not know if
`
`engineers revised product requirements documents). Schmalz’s second-hand
`
`knowledge and testimony related to a category of documents rather than a particular
`
`document is insufficient to authenticate Exhibit 2024. See, e.g., Linear Technology
`
`Corp., 275 F.3d at 1055-56 (knowledge of a file type generally, without knowledge
`
`of specific documents, not sufficient); Schroeder v. Smith’s Food & Drug Centers,
`
`
`
`9
`
`
`
`Inc., No. 2:12-CV-02024-APG, 2014 WL 548149, at *2 (D. Nev. Feb. 11, 2014)
`
`(excluding videos and photographs under Rule 901 where authenticating witness
`
`only “received” them and otherwise had no personal knowledge of them).
`
`Root lacks personal knowledge. Root has no personal knowledge of the
`
`creation or maintenance of Exhibit 2024, either. Like Sutton and Schmalz, Root
`
`discusses only product requirements documents in general—he offers no specifics
`
`about Exhibit 2024. Ex-2118 ¶ 57.
`
`Authentication requires personal knowledge about the particular document in
`
`question, yet Teleflex’s witnesses offer only conclusory statements regarding a
`
`category of documents.
`
`III. PORTIONS OF ERB’S DEPOSITION TESTIMONY ARE BEYOND
`THE SCOPE, UNTIMELY, AND PREJUDICIAL.
`In his latest deposition, Erb testified beyond the scope of his declaration,
`
`providing new, untimely evidence and, thus, prejudicing Medtronic—the Board
`
`should exclude this testimony. Under 37 C.F.R. § 42.64(a), a party may “challenge
`
`the admissibility of deposition evidence.” PTAB Consolidated Trial Practice Guide
`
`at 78 (Nov. 2019). To allow a witness to expand the scope of his direct
`
`testimony—to exceed the scope of his declaration—during deposition creates new,
`
`untimely evidence and, thus, and prejudices the opposing party. See Fed. R. Evid.
`
`403. The Board may consider whether it is “in the interests of justice to maintain
`
`
`
`10
`
`
`
`[this evidence] in the case file.” Netflix, Inc. v. DivX, LLC, IPR2020-00511, Paper
`
`20 at 55 (PTAB Aug. 13, 2021).
`
`During his July 22, 2021 deposition, Erb added new evidence to the record
`
`to support Teleflex’s reduction-to-practice arguments during redirect and then
`
`changed and expanded his testimony when challenged on re-cross. Medtronic asks
`
`the Board to exclude (1) Erb’s testimony regarding the timing of prototype testing;
`
`and (2) Erb’s admittedly new testimony revising and expanding the scope of his
`
`testimony related to particular prototype testing.
`
`A. On redirect, over Medtronic’s objection, Erb provided new
`testimony regarding the timing of prototype testing.
`On redirect, Teleflex asked Erb “when” VSI assembled and tested
`
`prototypes purportedly relevant to reduction to practice:
`
`Q. And when was the test done on the prototype made
`with components 2114 and 2092?
`
`Ms. Tremblay: Objection, scope.
`
`
`
`
`A. Well yeah, that would have been immediately after
`assembly. So as soon as the parts were assembled,
`they were very quickly tested.
`
`
`
`
`Q. Okay. Okay. So for the prototype that you said was
`made and tested from component parts made out of
`the drawings shown in 2113 and 2089, . . . when
`would that have been tested?
`
`. . .
`
`
`
`
`Ms. Tremblay: Objection, scope.
`
`
`
`11
`
`
`
`
`A. Yeah, that would have been immediately
`afterwards, after assembly. As soon as the parts
`were received, we were always eager to receive
`parts, so as soon as we got them, within days we
`would have assembled them and then the testing
`would have followed quickly after that.
`
`
`Ex-1799, 37:2-7, 37:20-38:6. Until this point, Erb had not discussed these
`
`components and prototypes in detail, nor had he offered testimony regarding when
`
`VSI assembled them. See, e.g., IPR2020-01341, Reply (Paper 48) at 11. Thus,
`
`Medtronic lodged a scope objection. See 37 C.F.R. § 42.64(a).
`
`Teleflex elicited new evidence to bolster its reduction-to-practice arguments.
`
`Erb provided new, untimely testimony regarding when VSI tested prototypes,
`
`beyond the scope of his declaration. Teleflex has previously adjusted Erb’s
`
`declaration—between the first set of IPR proceedings and these proceedings—to
`
`tighten gaps in its case in response to Medtronic’s arguments. Compare IPR2020-
`
`00126, Ex-2122 ¶¶11-12 with IPR2020-01341, Ex-2122 ¶¶12-13. Erb’s deposition
`
`provided another (albeit improper) “opportunity” to fill-in additional holes and to
`
`attempt to rehabilitate and strengthen the only witness available to corroborate
`
`inventor testimony. See Reply at 10-11. Erb’s late testimony prejudiced
`
`Medtronic’s ability to defend against Teleflex’s moving-target CRTP evidence.
`
`Teleflex knew—when Erb signed his latest declaration (Ex-2122) and during his
`
`July 22, 2021 deposition—that when VSI tested prototypes is integral to whether
`
`
`
`12
`
`
`
`and when VSI reduced to practice. Therefore, if he had that knowledge, it should
`
`have been included in the Erb declaration. But it was not. Instead, Teleflex asked
`
`questions targeting—and eliciting—testimony beyond the scope of Erb’s
`
`declaration.
`
`By waiting until Erb’s July 22, 2021 deposition to develop new testimony,
`
`Teleflex deprived Medtronic of the opportunity to meaningfully prepare and test
`
`that testimony. Erb’s testimony on timing was new, untimely, beyond the scope,
`
`and prejudicial under Rule 403; the interests of justice support excluding those
`
`portions of his deposition testimony.
`
` Erb’s testimony on re-cross should likewise be excluded.
`B.
`On re-cross, Medtronic tried to confirm Erb’s limited knowledge related to
`
`prototype testing and reduction to practice. Instead, Erb took the opportunity to
`
`change and expand his declaration testimony:
`
`Q.
`
`True that in paragraph 12 of your declaration you
`state that you were not personally involved in tests
`of the GuideLiner prototypes involving the
`delivery of stents and balloons in a benchtop heart
`model?
`
`A. Yes. . . . I wasn’t personally involved, but I did
`observe. So I – I never did deliver a balloon or
`stent that I recall, but that was common procedure.
`
`
`Q.
`
`So let me follow up on that for just one moment,
`Mr. Erb. So . . . are you changing your testimony
`to that you observed these tests, even though in
`
`
`
`13
`
`
`
`your declaration you state that you were only
`aware of them happening?
`
`
`A. Yes. Yes, as time goes on here I would say I
`remember more and more, I’m seeing – you know,
`the more I get into this, yes, I do recall seeing a
`balloon delivered. It was kind of new and novel to
`me at the time, so, yes, I’m just – I would say I’m
`adding to my testimony.
`
`
`Q.
`
`But at the time that you wrote this declaration, you
`did not state that you had personally observed any
`testing involving balloons or stents; true?
`
`
`A. Yes.
`
`Q. And now, only after having discussed it a bit, have
`you added that testimony to your declaration; true?
`
`
`A. Well since my – yeah, since my first declaration,
`yeah. So no, it’s just my – you know, as I get
`deeper into this, you know, my memory is – is
`being jogged that I do remember.
`
`
`Ex-1799, 39:17-40:20.2
`
`Again, on re-cross, Erb provided new, untimely evidence beyond the scope
`
`of his declaration. Further, this testimony directly contradicted Erb’s and
`
`Teleflex’s previous positions. See IPR2020-01341, Reply (Paper 48) at 14-15, n.7.
`
`This testimony about prototype testing should have been addressed in Erb’s latest
`
`
`2 Erb gave this testimony on re-cross and therefore Medtronic did not and could not
`
`object.
`
`
`
`14
`
`
`
`declaration. Medtronic had no ability to prepare to meaningfully cross-examine
`
`Erb. Accordingly, this second portion of testimony should also be excluded as out
`
`of scope and prejudicial under Rule 403.
`
`IV. CONCLUSION
`Teleflex relies on Exhibit 2024 and the date on the face of the document to
`
`make sweeping statements about prototyping and testing work at VSI in 2005.
`
`Teleflex must prove that Exhibit 2024 is what it claims. But Teleflex cannot
`
`authenticate the unreliable document. No witness has personal knowledge of the
`
`document. Further, Teleflex improperly attempts to bolster its corroboration case in
`
`support of reduction to practice using late, prejudicial testimony from Erb.
`
`Medtronic requests that the Board exclude Exhibit 2024 and the above-identified
`
`portions of Exhibit 1799.
`
`
`
`Dated: October 29, 2021
`
`
`
`
`
`
`
`
`
`15
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/Cyrus A. Morton/
`Cyrus A. Morton
`Reg. No. 44,954
`Robins Kaplan LLP
`2800 LaSalle Plaza
`800 LaSalle Avenue
`Minneapolis, MN 55402
`Attorney for Petitioner
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e)(4), the undersigned certifies that on October
`
`29, 2021, a copy of PETITIONER’S MOTION TO EXCLUDE EXHIBIT 2024
`
`AND PORTIONS OF EXHIBIT 1799 was served by electronic mail on Patent
`
`Owner’s counsel as indicated in Patent Owner’s Mandatory Notices:
`
`J. Derek Vandenburgh, Reg. No. 32,179
`dvandenburgh@carlsoncaspers.com
`
`Dennis C. Bremer, Reg. No. 40,528
`dbremer@carlsoncaspers.com
`
`Joseph W. Winkels
`jwinkels@carlsoncaspers.com
`
`Peter M. Kohlhepp
`pkohlhepp@carlsoncaspers.com
`
`Alexander S. Rinn
`arinn@carlsoncaspers.com
`
`Megan E. Christner, Reg. No. 78,979
`mchristner@carlsoncaspers.com
`
`Shelleaha L. Jonas
`sjonas@carlsoncaspers.com
`
`Tara C. Norgard
`tnorgard@carlsoncaspers.com
`
`
`Dated: October 29, 2021
`
`Respectfully submitted,
`
`
`
`/Cyrus A. Morton/
`Cyrus A. Morton
`Registration No. 44,954
`Attorney for Petitioner
`
`
`
`
`
`
`
`16
`
`
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