R2 Solutions LLC v. Databricks, Inc. , 4:23-cv-01147, No. 100-1 (E.D.Tex. Mar. 4, 2025)

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R2 Solutions LLC v. Databricks, Inc. , 4:23-cv-01147, No. 100-1 (E.D.Tex. Mar. 4, 2025)

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Case 4:23-cv-01147-ALM Document 100-1 Filed 03/04/25 Page 1 of 3 PageID #:
`6568
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`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`R2 SOLUTIONS LLC,
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`Plaintiff,
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`
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`v.
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`DATABRICKS, INC.,
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`
`Defendant.
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`
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`Civil Action No. 4:23-cv-01147-ALM
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`JURY TRIAL DEMANDED
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`
`
`
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`DECLARATION OF JESSICA M. KAEMPF IN SUPPORT OF
`DATABRICKS, INC.’S REPLY IN SUPPORT OF ITS MOTION TO COMPEL
`PLAINTIFF R2 SOLUTIONS, LLC TO PRODUCE FINANCIAL DOCUMENTS
`
`
`
`

`Case 4:23-cv-01147-ALM Document 100-1 Filed 03/04/25 Page 2 of 3 PageID #:
`6569
`
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`I, Jessica M. Kaempf, declare as follows:
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`1.
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`I am an attorney admitted to this Court, and I am a partner of the law firm of
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`Fenwick and West LLP, counsel of record for Defendant Databricks, Inc. (“Databricks”) in this
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`action. I make this declaration in support of Databricks’ Reply in Support of its Motion to Compel
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`Plaintiff R2 Solutions, LLC to Produce Financial Documents.
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`2.
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`Attached hereto as Exhibit 1 is an excerpt of a true and correct copy of the transcript
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`from the February 6, 2025 deposition of Mr. Craig Yudell.
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`I declare under penalty of perjury under the laws of the United States of America that, to
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`the best of my belief, the foregoing is true and correct, and that this Declaration was executed on
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`February 25, 2025.
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`/s/ Jessica M. Kaempf
`Jessica M. Kaempf
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`1
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`

`Case 4:23-cv-01147-ALM Document 100-1 Filed 03/04/25 Page 3 of 3 PageID #:
`6570
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`CERTIFICATE OF AUTHORIZATION TO SEAL
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`Pursuant to Local Rule CV-5(a)(7)(B), I am authorized to file the foregoing document
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`under seal pursuant to the Protective Order (Dkt. 61) because this document references Designated
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`Material.
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`
`
`
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`/s/ Jessica M. Kaempf
`Jessica M. Kaempf
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`
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who are deemed to have consented to electronic
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`service are being served with a copy of this document via electronic mail per Local Rule CV-5 on
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`February 25, 2025. Additionally, I hereby certify that all counsel of record who have consented
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`to electronic service are being served with a copy of these documents via electronic mail per Local
`
`Rule CV-5.
`
`
`
`
`
`/s/ Jessica M. Kaempf
`Jessica M. Kaempf
`
`2
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`
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`

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