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`Exhibit A
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`Case 6:21-cv-00569-ADA Document 95-1 Filed 10/12/22 Page 2 of 3
`Case 6:21-cv-00569-ADA Document 95-1 Filed 10/12/22 Page 2 of 3
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACODIVISION
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`TOUCHSTREAM TECHNOLOGIES, INC.,
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`§
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`Plaintiff,
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`V.
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`Civil Case No. 6:21-cv-569-ADA
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`GOOGLE LLC,
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`JURY TRIAL DEMANDED
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`: §
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`Defendant.
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`DECLARATION OF JANOS LEVAI
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`I, Janos Levai, a fact witness in the above-captioned action have been informed of and
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`understandthat:
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`1. Touchstream Technologies,Inc. (“Touchstream”) and Google LLC (“Google”) may take
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`my deposition pursuant to Federal Rules of Civil Procedure.
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`2. During the deposition, I may be assisted by my own counsel.
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`3.
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`I, a Romanian citizen who currently lives and works in Switzerland, will voluntarily
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`appear at the Swiss offices of Quinn Emanuel at Dufourstrasse 29, 8008 Zurich,
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`Switzerland or, if required, at another location in the canton of Zurich, Switzerland, for
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`the purpose ofthis deposition.
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`4.
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`Iam not obligated to appear and participate in the deposition and cannotbe subjected to
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`any coercive measures.
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`5. By being deposed in the canton of Zurich, Switzerland, I have been apprised that I have
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`rights under Swiss law.
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`Case 6:21-cv-00569-ADA Document 95-1 Filed 10/12/22 Page 3 of 3
`Case 6:21-cv-00569-ADA Document 95-1 Filed 10/12/22 Page 3 of 3
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`6. Atany time during examination, I may invoke anyright or duty to refuse testimony under
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`Swiss Law.
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`I understand that my rights to refuse testimony are set out in particular in
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`Articles 165-166 of the Swiss Code of Civil Procedure.
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`7. At any time during examination, I may also invoke anyright or duty to refuse testimony
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`under U.S. Law.
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`In particular, I understand that I am entitled to refuse to answer any
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`question pertaining to/or which may invoke attorney-client privilege and/or attorney
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`work-product.
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`8. The Swiss Commissioner in this matter, Olivier Buff, with address at Quinn Emanuel
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`Urquhart Sullivan (Schweiz) GmbH, Dufourstrasse 29, 8008 Zurich, Switzerland, will
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`serve as my agent of service (“Domizilhalter”) in Switzerland in this matter. Thus, any
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`correspondence from the US or Swiss authorities may validly be delivered to Olivier
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`Buff, and he will then forward to me.
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`In view of the above, I hereby consent to having my deposition taken in the above-captioned
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`matter by oral examination in the English language under oath, recorded by video and stenography,
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`at a date to be determined.
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`I confirm that I am cooperating of my own accord.
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`patep:
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`/0.(0.2022.
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`:aa
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`JANOS LEVAI
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