R2 Solutions LLC v. Databricks, Inc. , 4:23-cv-01147, No. 91-1 (E.D.Tex. Feb. 20, 2025)

All Courts

Search for cases ...

Cheat Sheet
Query Builder
Jurisdiction Selector
Suggestions

Basic Search

Selected Courts

Recently Selected Courts

Clear Coverage information Done

All of these words

Any of these words

Exactly this phrase or word

None of these words

This word

Case filed between and

Most recent docket entry filed between and

With deadlines about

Has at least

Party’s Name

Firm

Attorney

Role

Publicly traded

Filter by

Search result types Dockets Documents

Opinions Motions Pleadings Exhibits

Signup
Login
More...
- Signup
- Login
- Features
- Enhance
- Pricing
- News
- About

Exhibits:

R2 Solutions LLC v. Databricks, Inc. , 4:23-cv-01147, No. 91-1 (E.D.Tex. Feb. 20, 2025)

<< Back to Docket Download

<< View Full Docket

Exhibits:

Cite Download

Case 4:23-cv-01147-ALM Document 91-1 Filed 02/20/25 Page 1 of 3 PageID #:
`6468
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Exhibit 1
`
`
`
`
`
`

`Case 4:23-cv-01147-ALM Document 91-1 Filed 02/20/25 Page 2 of 3 PageID #:
`6469
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`
`
`
`
`
`
`
`
`
`
`Civil Action No. 4:23-cv-01147-ALM
`
`Jury Trial Demanded
`
`
`
`R2 Solutions LLC,
`
` Plaintiff,
`
`v.
`
`
`Databricks, Inc.,
`
` Defendant.
`
`
`
`
`
`
`DECLARATION OF CARDER W. BROOKS IN SUPPORT OF
`PLAINTIFF’S MOTION TO COMPEL SUPPLEMENTARY RESPONSE TO
`INTERROGATORY NO. 33 FROM DEFENDANT DATABRICKS, INC.
`
`
`I, Carder W. Brooks, declare as follows:
`
`1.
`
`I am a member of the State Bar of Texas and a partner at the law firm of Nelson
`
`Bumgardner Conroy PC, counsel for R2 Solutions LLC (“R2” or “Plaintiff”) in this matter. I make
`
`this declaration in support of Plaintiff’s Motion to Compel Supplementary Response to
`
`Interrogatory No. 33 (“Motion”) from Databricks, Inc. (“Databricks” or “Defendant”). I make this
`
`declaration based upon personal knowledge. If called to testify as to any of the matters set forth in
`
`this declaration, I could and would completely testify to facts stated herein.
`
`2.
`
`Attached as Exhibit A is a true and correct copy of R2’s Fourth Set of Interrogatories
`
`to Databricks (Nos. 21-35) served on December 20, 2025.
`
`3.
`
`Attached as Exhibit B is a true and correct of an excerpt of Databricks’ Objections
`
`and Responses to R2’s Fourth Set of Interrogatories (Nos. 21-35) served on January 24, 2025.
`
`4.
`
`Attached as Exhibit C is a true and correct copy of excerpts from the rough
`
`transcript of the deposition of John Winkenbach that took place on February 12, 2025.
`
`
`
`1
`
`

`Case 4:23-cv-01147-ALM Document 91-1 Filed 02/20/25 Page 3 of 3 PageID #:
`6470
`
`5.
`
`Attached as Exhibit D is a true and correct copy of email correspondence between
`
`counsel for R2 and counsel for Databricks that took place between February 12, 2025 and February
`
`13, 2025.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct.
`
`Executed this 13th day of February, 2025.
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: /s/ Carder W. Brooks
`Carder W. Brooks
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2
`
`

This document is available on Docket Alarm but you must sign up to view it.

Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

Up-to-date information for this case.
Email alerts whenever there is an update.
Full text search for other cases.
Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.

Access Government Site

We are redirecting you
to a mobile optimized page.

Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket

STEP 2 of 2

Choose your membership type

Flat-Fee

Unlimited document access
Unlimited case alerts
Unlimited docket tracking
Unlimited search
Search/filter by motion
For-pay state court docs

$99/mo.

Excludes PACER and Gov’t fees

Pay-As-You-Go Monthly

$4/document
$3/ docket update
$3/day new case alerts
$2/day for docket tracking
$1/search in Fed Courts
For-pay state court docs

$39.99/mo.

Add-ons include Federal Analytics, Easy Analytics, and the Analytics Workbench.

Add your payment information

Need help? Lets schedule a quick demo.

What is PACER?

PACER is a government system to access US court records.

Why do I need it?

Docket Alarm uses PACER to access Federal Court documents. Under the flat-rate plan, we pass these fees on to your account without markup.

What will I be charged?

If we already have the document in our database, you will not be charged anything. However, if we do not, then we must retrieve it from the court and incur their access fee.

PACER charges $0.10 per page with a 30 page (or $3.00) cap for all documents, except transcripts which have no cap. For example, a five page document is $0.50 and a 50 page document is $3.00. Accessing docket sheets also incurs a fee if we do not already have the full docket sheet (again, max of $3.00). These fees are only incurred for Federal Courts and Bankruptcies.

Do other courts have fees?

Certain state courts, mostly in California, charge for access to some documents. When accessing for-pay state courts, you will always be given an option to accept or decline the payment.

Basic Free Access

We’re committed to keeping the law open. We provide free searches and document/docket views a week for documents already in our system. You have pages left for free viewing.

Note: free views don't apply to documents purchased from government systems, e.g., PACER.

Welcome

Docket Alarm has relationships with many large firms such as yours.

See if your firm has an account

Supplemental Search

Search for PTAB Motions

PTAB Analytics

TTAB Analytics

Basic Search

Filters

Party Search

Advanced

Selected Courts

Recently Selected Courts

Find PTAB Decisions

PTAB Analytics

Special PTAB Alerts

Orange Book

Directly Search Federal Courts

Search Trademark ...

This document is available on Docket Alarm but you must sign up to view it.

Accessing this document will incur an additional charge of $.

Still Working On It

A few More Minutes ... Still Working

This document could not be displayed.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

One Moment Please

Your document is on its way!

Sealed Document

We are redirecting youto a mobile optimized page.

Document Unreadable or Corrupt

We are unable to display this document.

STEP 2 of 2

Choose your membership type

Flat-Fee

Pay-As-You-Go Monthly

Add your payment information

Login or Join

Enter your corporate Email

Thousands of your peers are saving time and gaining a competitive advantage with Docket Alarm.

Join Docket Alarm to perform smarter legal research.

Download this document and millions of others instantly with a Docket Alarm membership.

Join Docket Alarm and start performing smarter legal research.

Start tracking this docket instantly with a Docket Alarm membership.

Join thousands of your peers and start performing smarter legal research.

STEP 1 of 2

Millions of Documents | 15 Seconds to Signup

Hi !

Welcome to Docket Alarm

Welcome to Docket Alarm!

Explore Litigation Insights andManage Your Cases

Reset Password

What is PACER?

Why do I need it?

What will I be charged?

Do other courts have fees?

Basic Free Access

Welcome

Thank you

Check Firm Account

We are redirecting you
to a mobile optimized page.

Explore Litigation Insights and
Manage Your Cases