Case 4:23-cv-01147-ALM Document 101-1 Filed 03/11/25 Page 1 of 3 PageID #:
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`Exhibit 1
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`Case 4:23-cv-01147-ALM Document 101-1 Filed 03/11/25 Page 2 of 3 PageID #:
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`Civil Action No. 4:23-cv-01147-ALM
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`Jury Trial Demanded
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`R2 Solutions LLC,
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` Plaintiff,
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`v.
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`Databricks, Inc.,
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` Defendant.
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`DECLARATION OF CARDER W. BROOKS IN SUPPORT OF PLAINTIFF’S SUR-
`REPLY IN OPPOSITION TO DATABRICKS’ MOTION TO
`COMPEL R2 TO PRODUCE FINANCIAL DOCUMENTS
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`I, Carder W. Brooks, declare as follows:
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`1.
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`I am a member of the State Bar of Texas and a partner at the law firm of Nelson
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`Bumgardner Conroy PC, counsel for R2 Solutions LLC (“R2” or “Plaintiff”) in this matter. I make
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`this declaration in support of Plaintiff’s Sur-Reply in Opposition to Databricks’ Motion to Compel
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`R2 to Produce Financial Documents. I make this declaration based upon personal knowledge. If
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`called to testify as to any of the matters set forth in this declaration, I could and would testify
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`thereto.
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`2.
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`Attached as Exhibit A is a true and correct copy of an excerpt of the “Opening
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`Expert Report of Dr. Jon Weissman,” which is Databricks’ opening expert report regarding validity
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`that was served on R2 on February 20, 2025.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct.
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`1
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`Case 4:23-cv-01147-ALM Document 101-1 Filed 03/11/25 Page 3 of 3 PageID #:
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`Executed this 4th day of March, 2025.
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`By: /s/ Carder W. Brooks
` Carder W. Brooks
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`2
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