`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`
`MAXELL, LTD.,
`
`Plaintiff,
`
`v.
`
`ZTE CORPORATION and
`ZTE USA INC.,
`
`Defendants.
`
`Case No. 5:16-cv-00179-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF MAXELL, LTD.’S
`OPPOSITION TO ZTE (USA) INC.’S MOTION TO EXCLUDE PORTIONS OF
`EXPERT OPINION TESTIMONY
`
`
`
`
`I, Tiffany A. Miller, hereby declare and state as follows:
`
`1.
`
`I am an attorney at Mayer Brown LLP, counsel for Plaintiff Maxell, Ltd.
`
`(“Maxell”) in the above-captioned lawsuits. I submit this declaration in support of Maxell’s
`
`Opposition to ZTE (USA) Inc.’s Motion to Exclude Portions of Expert Opinion Testimony. I
`
`have personal knowledge of the statements herein, and, if called to do so, I could and would
`
`testify competently as to the same.
`
`2.
`
`Attached as Exhibit A are true and accurate excerpts of the Expert Report of Carla
`
`S. Mulhern dated January 12, 2018, including certain Revised Exhibits dated February 20, 2018.
`
`3.
`
`Attached as Exhibit B are true and accurate excerpts of the Videotaped Deposition
`
`of Carla S. Mulhern dated February 21, 2018.
`
`4.
`
`Attached as Exhibit C are true and accurate excerpts of the Videotaped Deposition
`
`of Kenji Nakamura dated December 15, 2017.
`
`
`
`1
`
`
`
`Case 5:16-cv-00179-RWS Document 56-1 Filed 03/22/18 Page 2 of 2 PageID #: 939
`
`5.
`
`Attached as Exhibit D are true and accurate excerpts of the Videotaped
`
`Deposition of Patrick Kennedy dated February 28, 2018.
`
`6.
`
`Attached as Exhibit E are true and accurate excerpts of the Expert Report of Tulin
`
`Erdem dated January 5, 2018.
`
`
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`above is true and correct and that this Declaration was executed on March 19, 2018 in
`
`Washington, D.C.
`
`
`
`Dated: March 19, 2018
`
`
`
`
`
`By:
`
`_______________________
`
`Tiffany A. Miller
`
`
`
`2
`
`
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`
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`
`
`
`
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