`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Plaintiff,
`
`
`
`v.
`
`
`Case No. 6:21-cv-00898-ADA
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`
`
`Defendants.
`
`
`ALMONDNET, INC.,
`
`
`
`
`
`AMAZON.COM, INC.; AMAZON.COM
`SERVICES LLC; and AMAZON WEB
`SERVICES, INC.,
`
`
`
`
`DECLARTION OF ADAM S. HOFFMAN IN SUPPORT OF REPLY TO PLAINTIFF’S
`MOTION TO EXCLUDE CERTAIN OPINIONS OF W. CHRISTOPHER BAKEWELL
`AND TO STRIKE PORTIONS OF HIS EXPERT REPORT
`
`
`
`Case 6:21-cv-00898-ADA Document 188 Filed 09/15/23 Page 2 of 3
`
`I, Adam S. Hoffman, declare and state as follows:
`
`1.
`
`I am a member of the State Bar of California, an attorney at the firm of Russ
`
`August & Kabat, and counsel of record for Plaintiff AlmondNet, Inc. in the above-captioned
`
`action. I submit this declaration in support of Plaintiff’s Reply in Support of its Motion to
`
`Exclude Certain Opinions of W. Christopher Bakewell and to Strike Portions of His Expert
`
`Report. I have personal knowledge of the facts set forth herein, and if called upon to testify,
`
`could and would testify competently thereto.
`
`2.
`
`Attached as Exhibit A is a true and correct copy of excerpts from U.S. Well
`
`Services, Inc. v. Hallliburton Co., Case No. 6:21-cv-367-ADA, Final Jury Instructions, dated
`
`August 24, 2023.
`
`3.
`
`Attached as Exhibit B is a true and correct of excerpts from Hafeman v. LG
`
`Electronics Inc., 6:21-cv-00696-ADA-DTG, Final Jury Instructions, dated April 28, 2023.
`
`4.
`
`Attached as Exhibit C is a true and correct of excerpts from Textron Innovations
`
`Inc. v. SZ DJI Tech. Co., Civil Action No. 6:21-cv-00740-ADA, Final Jury Instructions, April
`
`21, 2023.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed on September 15, 2023, at Los Angeles, California.
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Adam S. Hoffman
`Adam S. Hoffman
`
`i
`
`
`
`
`
`
`
`
`Case 6:21-cv-00898-ADA Document 188 Filed 09/15/23 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that all counsel of record who are deemed to have consented to electronic
`
`service are being served with a true and correct copy of this document on September 15, 2023, via
`
`the Court’s CM/ECF system per Local Rule CV 5(a)(3).
`
`/s/ ADAM S. HOFFMAN
`ADAM S. HOFFMAN
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
