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Case 5:19-cv-00036-RWS Document 114-1 Filed 11/01/19 Page 1 of 1 PageID #: 5091
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`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`
`
`Plaintiff,
`
`
`
`
`
`vs.
`
`APPLE INC.,
`
`
`
`Defendant.
`
`
`
`
`
`
` Civil Action No. 5:19-cv-00036-RWS
`
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF LUANN SIMMONS IN SUPPORT OF DEFENDANT
`APPLE INC.’S REPLY IN FURTHER SUPPORT OF ITS OPPOSED MOTION TO
`STAY PENDING DECISION ON ITS MOTION TO TRANSFER VENUE PURSUANT
`TO 28 U.S.C. § 1404(A)
`
`I, Luann L. Simmons, hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm of O’Melveny & Myers LLP, counsel for Defendant
`
`Apple, Inc. (“Apple”) in this matter filed by Plaintiff Maxell, Ltd. (“Maxell”). I have personal
`
`knowledge of the facts stated herein and if called to testify could and would competently testify
`
`thereto.
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`2.
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`Attached as Exhibit A is an excerpt of a true and correct copy of “Maxell, Ltd.’s
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`First Supplemental Objections and Responses to Apple Inc.’s First Set of Interrogatories (NOS.
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`1–16)” served on October 9, 2019.
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`I declare under the penalty of perjury that the foregoing is true and correct.
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`Executed in San Francisco, California, on this 30th day of October, 2019.
`
`
`
`/s/ Luann L. Simmons
`Luann L. Simmons
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`1
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`

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