`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 13-919-JLH
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`))))))))))
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`ARENDI S.A.R.L.,
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`Plaintiff,
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`
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`v.
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`GOOGLE LLC,
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`
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`Defendant.
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`
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`DECLARATION OF GARRETT SAKIMAE IN SUPPORT OF
`NON-PARTY APPLE INC.’S MOTION FOR SANCTIONS
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`I, Garrett Sakimae, declare as follows:
`
`1.
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`I am over the age of 18, a member in good standing of the bar of the State of
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`California, and am Legal Counsel at Apple Inc. I make this declaration in support of the Motion
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`of Non-Party Apple Inc. for Sanctions. My knowledge of these matters stated within this
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`declaration is either personal or has been developed and confirmed through discussions with
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`other Apple employees. If compelled to testify as a witness, I would testify competently to the
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`facts set forth herein.
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`2.
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`On September 15, 2021, I received an email from Kalpana Srinivasan that
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`requested Apple’s consent to produce the Apple Agreement in all of Plaintiff’s litigations in this
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`District, including Plaintiff’s litigation with Google.
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`3.
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`That same day, I consented to that production on behalf of Apple provided that
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`the document was marked as CONFIDENTIAL OUTSIDE COUNSEL ONLY and that Plaintiff
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`agreed to the following supplemental protections:
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`
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`Case 1:13-cv-00919-JLH Document 540 Filed 05/03/23 Page 2 of 2 PageID #: 55563
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`• That Arendi would provide Apple with notice and the opportunity to object before it
`disclosed the Apple Agreement to any experts disclosed under the operative Protective
`Order;
`• That Arendi would provide Apple with notice at the time exhibit lists are first exchanged
`if the Apple Agreement appeared on a party’s exhibit list; and
`• That, if the Apple Agreement is used at a hearing or trial, Arendi agreed to use reasonable
`efforts to seal the courtroom and redact any related transcript portions.
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`4.
`
`Ms. Srinivasan agreed to these supplemental protections on that same day, and
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`Plaintiff thereafter produced the Apple Agreement subject to Apple’s supplemental protections
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`and designated it as CONFIDENTIAL OUTSIDE COUNSEL ONLY pursuant to the Agreed
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`Protective Order. (Dkt. No. 16-1).
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`I declare under penalty of perjury under the laws of the United States of America and the
`State of California that the foregoing is true and correct.
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`Executed this 3rd of May, 2023 in San Diego, California.
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`_____________________________________________
`Garrett Sakimae
`Apple Inc.
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`2
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