`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`
`
`Plaintiff
`
`Civil Action NO. 5:19-cv-00036-RWS
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`SECOND DECLARATION OF CAMERON W. WESTIN IN SUPPORT OF
`APPLE INC.’S DAUBERT MOTION TO EXCLUDE THE OPINIONS AND
`TESTIMONY OF PLAINTIFF’S DAMAGES EXPERT MS. CARLA MULHERN
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 439-1 Filed 07/24/20 Page 2 of 2 PageID #: 24237
`
`
`I, Cameron W. Westin, declare as follows:
`
`1.
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`I am an attorney at the law firm of O’Melveny & Myers LLP, counsel for
`
`Defendant Apple Inc. (“Apple”) in this matter instituted by Plaintiff Maxell, Ltd. (“Maxell”). I
`
`am a member in good standing of the State Bar of California and have been admitted to practice
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`before this Court. The statements below are based on personal knowledge and/or investigation
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`of the facts stated herein and if called to testify could competently testify to their substance.
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`2.
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`Attached as Exhibit 31 is a true and correct copy of excerpts of the transcript
`
`from the deposition of Ms. Carla Mulhern, taken on June 24, 2020.
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`3.
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`Attached as Exhibit 32 is a true and correct copy of excerpts of Apple’s Tenth
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`Supplemental Objections and Responses to Maxell’s First Set of Interrogatories, served on
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`May 14, 2020.
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` declare under penalty of perjury under the laws of the United States of America that the
`
` I
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`foregoing is true and correct.
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`Executed July 22, 2020, in Newport Beach, California.
`
`
`
`/s/ Cameron W. Westin
` Cameron W. Westin
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`
`
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`
`
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`2
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