`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`Plaintiff,
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S SURREPLY IN OPPOSITION TO APPLE INC.’S MOTION TO
`STAY PENDING DECISION ON ITS MOTION TO TRANSFER VENUE PURSUANT
`TO 28 U.S.C. § 1404(a)
`
`
`
`
`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 lawsuit. I submit this declaration in support of Maxell’s
`
`Surreply in Opposition to Apple Inc.’s Motion to Stay Pending Decision on its Motion to Tranfer
`
`Venue Pursuant to 28 U.S.C. § 1404(a). 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 is a true a correct copy of an excerpt from Maxell, Ltd.’s
`
`Objections and Responses to Apple Inc.’s First Set of Interrogatories (Nos. 1-16), served on July
`
`29, 2019.
`
`
`
`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 November 6, 2019 in
`
`Washington, D.C.
`
`
`
`1
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`
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`Case 5:19-cv-00036-RWS Document 120-1 Filed 11/08/19 Page 2 of 2 PageID #: 5304
`
`
`Dated: November 6, 2019
`
`
`
`
`
`By:
`
`_______________________
`
`
`
`Tiffany A. Miller
`
`
`
`2
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