`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`HTC CORPORATION and
`HTC AMERICA, INC.,
`
`
`Plaintiffs,
`
`
`v.
`
`INNOVATION SCIENCES, LLC
`
`
`Defendant.
`
`
`
`Civil Action No. 4:20-cv-00180-ALM
`
`
`
`JURY TRIAL DEMANDED
`
`
`DECLARATION OF JAMES D. BERQUIST IN SUPPORT
`OF INNOVATION SCIENCES, LLC’S
`MOTION TO STRIKE OR FOR ALTERNATE RELIEF
`
`
`I, James D. Berquist, declare as follows:
`
`
`
`1.
`
`I am a partner with the law firm of Davidson Berquist Jackson & Gowdey,
`
`LLP and serve as counsel to Innovation Sciences LLC (“Innovation”) in the above-captioned
`
`matter. If called as a witness, I could and would testify competently to each fact stated
`
`herein.
`
`2.
`
`Attached as Exhibit 1 is a true and correct copy of an email string between
`
`counsel for Innovation and the HTC parties.
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of the Entry of Appearance
`
`in this Action filed on April 1, 2020 by Mr. Philip Ou as counsel for both HTC Corp. and HTC
`
`America, Inc.
`
`I declare under penalty of perjury that the foregoing is true and accurate.
`
`
`DATED: May 13, 2020
`
`/s/ James D. Berquist
`James D. Berquist
`
`
`
`
`
`
`1
`
`