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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Case No. 6:21-cv-00984-ADA
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`JURY TRIAL DEMANDED
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`DECLARATION OF PETER LAMBRIANAKOS IN SUPPORT OF MOTION FOR
`ENTRY OF DISPUTED ROTECTIVE ORDER
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`I, Peter Lambrianakos, hereby declare as follows:
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`v.
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`APPLE INC.,
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`JAWBONE INNOVATIONS, LLC,
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`Plaintiff,
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`Defendant.
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`1.
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`I have personal knowledge of the facts set forth in this declaration. I am competent
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`to testify as to all matters stated, and I am not under any legal disability what would in any way
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`preclude me from testifying.
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`2.
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`I am a Partner at the law firm of Fabricant LLP and counsel of record for Plaintiff
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`RFCyber Corp., in this matter.
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`3.
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`The exhibits attached to this declaration ma contain annotations and/or excerpts of
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`the originals.
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`4.
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`Attached hereto as Exhibit A is a true and correct copy of Jawbone’s Proposed
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`Protective Order.
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`5.
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`Attached hereto as Exhibit B is a true and correct copy of Apple’s Proposed
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`Protective Order.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on May 3, 2022 in Short Hills, New Jersey.
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`Case 6:21-cv-00984-ADA Document 40-1 Filed 05/03/22 Page 2 of 2
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`/s/ Peter Lambrianakos
` Peter Lambrianakos
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`2
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