`
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`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`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
`
`
`
`
`
`Defendant.
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`
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`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF MAXELL, LTD.’S
`OPPOSITION TO APPLE INC.’S MOTION TO STAY PENDING PROCEEDINGS AT
`THE PATENT OFFICE OR, IN THE ALTERNATIVE TO CONTINUE TRIAL DUE TO
`THE COVID-19 PANDEMIC
`
`
`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 Opposition to
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`Apple Inc.’s Motion to Stay Pending Proceedings at the Patent Office or, in the Alternative to
`
`Continue Trial Due to the COVID-19 Pandemic. I have personal knowledge of the statements
`
`herein, and, if called to do so, I could and would testify competently as to the same.
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`2.
`
`Attached as Exhibit A
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`is a
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`true and correct copy of a printout of
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`http://www.cafc.uscourts.gov/sites/default/files/the-court/statistics/06_Med_Disp_Time_
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`MERITS_table.pdf, accessed on March 1, 2021.
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`3.
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`Attached as Exhibit B is a true and correct copy of the Order issued at Docket No.
`
`205 on November 23, 2020 in Ramot at Tel Aviv Univ. Ltd. v. Cisco Sys., Inc., No. 2:19-cv-00225-
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`JRG (E.D. Tex.).
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`
`
`1
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`
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`Case 5:19-cv-00036-RWS Document 636-1 Filed 03/01/21 Page 2 of 2 PageID #: 32252
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`
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`4.
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`Attached as Exhibit C is a true and correct copy of the article “COVID-19
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`hospitalizations trending downward in Bowie County,” dated February 5, 2021, available at
`
`https://www.ktbs.com/news/texarkana/covid-19-hospitalizations-trending-downward-in-bowie-
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`county/article_3976a7f8-67fb-11eb-86dc-6704d9e3f772.html (last accessed March 1, 2021).
`
`5.
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`The below excerpts are true and correct copy excerpts of the webpage
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`https://www.nytimes.com/interactive/2021/us/bowie-texas-covid-cases.html as of March 1, 2021:
`
`
`
` 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 1, 2021 in Washington,
`
`D.C.
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`
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`Dated: March 1, 2021
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`
`
`
`
`By:
`
`_______________________
`
`
`
`
`
`Tiffany A. Miller
`
`2
`
`
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