`
`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
`
`FILED UNDER SEAL
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S OPPOSED MOTION FOR EXTENSION OF TIME TO
`SUPPLEMENT INFRINGEMENT CONTENTIONS PURSUANT TO P.R. 3-1(g)
`
`
`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
`
`Opposed Motion for Extension of Time to Supplement Infringement Contentions Pursuant to
`
`P.R. 3-1(g). 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 a letter sent from Marc
`
`Pensabene to Jamie Beaber on February 26, 2020.
`
`3.
`
`Attached as Exhibit B is a true a correct copy of an email sent from Vincent Zhou
`
`to Saqib Siddiqui on February 20, 2020.
`
`4.
`
`Attached as Exhibit C is a true a correct copy of an email sent from Marc
`
`Pensabene to Saqib Siddiqui on February 18, 2020.
`
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 212-1 Filed 03/06/20 Page 2 of 2 PageID #: 8843
`
`5.
`
`Attached as Exhibit D is a true a correct excerpt of a letter sent from Jamie Beaber
`
`to Tony Beasley and Vincent Zhou on October 11, 2019.
`
`6.
`
`Attached as Exhibit E is a true a correct excerpt of a letter sent from Jamie Beaber
`
`to Tony Beasley on November 14, 2019.
`
`7.
`
`Attached as Exhibit F is a true a correct copy of an email sent from Marc
`
`Pensabene to Tiffany Miller on March 2, 2020.
`
`
`
`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 3, 2020 in
`
`Washington, D.C.
`
`
`
`Dated: March 3, 2020
`
`
`
`
`
`By:
`
`_______________________
`
`
`
`
`
`
`
`
`
`
`Tiffany A. Miller
`
`2
`
`
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