`
`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 L. SIMMONS IN SUPPORT OF APPLE INC.’S REPLY IN
`SUPPORT OF ITS MOTION TO EXCLUDE THE TESTIMONY
`OF ROBERT L. STOLL (D.I. 357)
`
`I, Luann L. Simmons, hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm of O’Melveny & Myers LLP, counsel for Apple,
`
`Inc. (“Apple”) in this matter filed by Maxell, Ltd. (“Maxell”). I have personal knowledge of the
`
`facts stated herein and if called to testify could and would competently testify thereto.
`
`2.
`
`Attached as Exhibit 4 is a true and correct copy of excerpts from the deposition
`
`transcript of Robert L. Stoll, taken on June 18, 2020.
`
`3.
`
`Attached as Exhibit 5 is a true and correct copy of from Ask Yale Library entitled
`
`“Q. What does “non-circulating” mean?”, dated April 7, 2020, as retrieved from Yale University
`
`Library’s website: https://ask.library.yale.edu/faq/175310.
`
` declare under the penalty of perjury that the foregoing is true and correct. Executed in
`
` I
`
`San Francisco, California, on this 22nd day of July, 2020.
`
`
`
`
`
`
`/s/ Luann L. Simmons
`Luann L. Simmons
`
`
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