Case 6:12-cv-00855-RWS Document 984 Filed 11/02/20 Page 1 of 134 PageID #: 63176
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`113
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`VIRNETX INC., ET AL,
`
`PLAINTIFFS,
`
`VS.
`
`APPLE INC.,
`
`DEFENDANTS.
`
`
`
`CIVIL ACTION NO.
`6:12-CV-855-RWS
`
`
`)(
`)(
`)(
`)(
`)(
`TYLER, TEXAS
`)(
`)( OCTOBER 26, 2020
`)(
`2:20 P.M.
`)(
`
`TRANSCRIPT OF JURY TRIAL
`AFTERNOON SESSION
`BEFORE THE HONORABLE JUDGE ROBERT W. SCHROEDER, III
`UNITED STATES DISTRICT JUDGE
`
`APPEARANCES:
`
`FOR THE PLAINTIFFS:
`BRADLEY W. CALDWELL
`JASON D. CASSADY
`JOHN AUSTIN CURRY
`CALDWELL CASSADY & CURRY
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`T. JOHN WARD, JR.
`WARD, SMITH & HILL PLLC
`1507 Bill Owens Parkway
`Longview, Texas 75604
`R. CHRISTOPHER BUNT
`PARKER BUNT & AINSWORTH
`100 East Ferguson, Suite 418
`Tyler, Texas 75702
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`113
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`VIRNETX INC., ET AL,
`
`PLAINTIFFS,
`
`VS.
`
`APPLE INC.,
`
`DEFENDANTS.
`
`
`
`CIVIL ACTION NO.
`6:12-CV-855-RWS
`
`
`)(
`)(
`)(
`)(
`)(
`TYLER, TEXAS
`)(
`)( OCTOBER 26, 2020
`)(
`2:20 P.M.
`)(
`
`TRANSCRIPT OF JURY TRIAL
`AFTERNOON SESSION
`BEFORE THE HONORABLE JUDGE ROBERT W. SCHROEDER, III
`UNITED STATES DISTRICT JUDGE
`
`APPEARANCES:
`
`FOR THE PLAINTIFFS:
`BRADLEY W. CALDWELL
`JASON D. CASSADY
`JOHN AUSTIN CURRY
`CALDWELL CASSADY & CURRY
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`T. JOHN WARD, JR.
`WARD, SMITH & HILL PLLC
`1507 Bill Owens Parkway
`Longview, Texas 75604
`R. CHRISTOPHER BUNT
`PARKER BUNT & AINSWORTH
`100 East Ferguson, Suite 418
`Tyler, Texas 75702
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`FOR THE PLAINTIFFS:
`
`ANDY TINDEL
`MT2 LAW GROUP
`MANN TINDEL THOMPSON
`112 E. Line Street
`Suite 304
`Tyler, Texas 75702
`
`FOR THE DEFENDANT:
`GREGORY S. AROVAS
`ROBERT A. APPLEBY
`JEANNE M. HEFFERNAN
`JOSEPH A. LOY
`LESLIE M. SCHMIDT
`AARON D. RESETARITS
`KIRKLAND & ELLIS LLP
`601 Lexington Avenue
`New York, New York 10022
`AKSHAY S. DEORAS
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, California 94104
`MICHAEL E. JONES
`POTTER MINTON
`110 North College Avenue, Suite 500
`Tyler, Texas 75702
`
`COURT REPORTER:
`
`Ms. Shelly Holmes, CSR, TCRR
`Official Court Reporter
`United States District Court
`Eastern District of Texas
`Marshall Division
`100 E. Houston
`Marshall, Texas 75670
` (903) 923-7464
`
`(Proceedings recorded by mechanical stenography, transcript
`produced on a CAT system.)
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`P R O C E E D I N G S
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`(Jury in.)
`COURT SECURITY OFFICER: All rise.
`THE COURT: Please be seated.
`Ms. Schroeder, if you would, call the case for us.
`COURTROOM DEPUTY: Cause No. 6:12-CV-855, VirnetX
`Inc., et al., versus Apple Inc.
`THE COURT: Announcements for the record?
`MR. WARD: Johnny Ward for VirnetX, and we're
`
`ready.
`
`THE COURT: Good afternoon, Mr. Ward.
`MR. WARD: Good afternoon.
`MR. JONES: Your Honor, Mike Jones for Apple, and
`we're ready to proceed. Thank you, Your Honor.
`THE COURT: Good afternoon, Mr. Jones.
`Good afternoon, ladies and gentlemen of the jury
`panel. I want to thank you for being here and to welcome
`you to jury service in the Eastern District of Texas.
`I'm Judge Trey Schroeder. You've already met some
`of our court personnel this afternoon but I want to
`introduce to you the members of my courtroom staff. My
`courtroom deputy is Ms. Betty Schroeder. Our court
`reporter this week is Ms. Shelly Holmes. The law clerks
`assisting me on the case are Jacob Vannette, Jonathan
`Powers, and Susan Stradley. Our Court Security Officers
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`during the course of this trial are going to be Mr. Stephen
`Richardson in the morning and Mr. James Millers in the
`afternoon. Mr. Kirk Haddix is joining us this afternoon as
`well.
`
`I want to start off by thanking you for serving
`your country during these trying times. In every way,
`COVID-19 adds a weight to the significance of your
`service -- service. In this new normal that we're all
`living in, your life responsibilities are more serious, and
`our intrusion into them more jarring. I do understand
`that. And as I wrote to you regarding your jury service,
`we've taken a number of important precautions to enhance
`your health and safety during jury selection and the trial,
`if you are chosen as a juror, and I want to briefly mention
`those now.
`Your temperature should have been taken before you
`entered the courthouse. You should have been escorted to
`the courtroom by a member of the Court staff or one of our
`Court Security Officers. We provide masks if you don't
`have one, and we ask that you wear them during the
`afternoon. We've got gloves available for anyone who wants
`them, plenty of hand sanitizer throughout the courtroom and
`courthouse, and we will have breaks not only this afternoon
`but during the course of the trial for those who are
`selected to serve as jurors.
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`We will have a slightly shortened trial day once
`trial begins, and we'll provide lunch for you each day of
`the trial, limiting your need to go in and out of the
`building.
`We've also reconfigured the courtroom to
`accommodate the needs for social distancing. The jury will
`be seated where you are seated now in the gallery. We'll
`use another courtroom down the hall for our jury room
`instead of the regular jury room at the back of this
`courtroom. The witness will be seated in the jury box
`where Mr. Millers is now instead of on the normal witness
`stand. We also have air purifiers spread throughout the
`courtroom and in the jury room, as well.
`We have also split jury selection into two
`sessions. We had a session this morning, just like the one
`we will have this afternoon. And that helps us follow the
`CDC guidelines on social distancing.
`So those are some preliminary comments about the
`efforts we are taking to enhance your health and safety,
`not only this afternoon but if you're chosen as a juror
`throughout the course of the week.
`As I said, I'm Judge Schroeder. I'm a United
`States District Judge for the Eastern District of Texas. I
`live in Texarkana, where I was born and grew up. I have
`been a lawyer for 25 years now almost. I was in private
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`practice for about 15 years before coming on the bench five
`years ago. And before I was in private practice, I worked
`as a federal appellate clerk for a couple of years and as a
`lawyer for the government in Washington.
`I went to college in Missouri and then in
`Arkansas. I graduated from law school in Washington D.C.
`I'm married. I have two daughters who are juniors in
`college this fall. My wife is a lawyer, too, but she
`doesn't practice anymore. I call her a recovering lawyer.
`And I'm telling you all these things about myself because
`in a few minutes, I'm going to ask you to tell us the same
`kind of things about yourself so that we will know more
`about you -- each of you. And I think you're entitled to
`know as much about me as we're all about to learn about
`you.
`
`We are going to begin tomorrow the trial of a
`civil case that involves damages for patent -- for patent
`infringement. I want to thank you for your service here
`today. You're playing a pivotal role in our system of
`justice, and I hope you will consider it a -- a -- an honor
`to serve your country in this important role because that's
`what it is. By asking you to be here and by asking you to
`potentially serve as a juror in this matter, we're asking
`you to be away from your jobs and your families and your
`other responsibilities.
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`For those of you who have children at home, I know
`how hectic your lives are. And the same goes for those of
`you who may be a caregiver for a family member or a friend.
`By asking you to be here and by potentially serving as a
`juror, we are creating a somewhat significant intrusion in
`your lives. But the reason that we do that is that we have
`important work for you to do. We have important work to do
`this week that will not get done without a jury.
`I've tried nearly 40 cases as a judge, and I
`believe that your experience as a juror will depend in
`large part on what your initial frame of mind is. And I
`recently read about a judge in Houston who said, well, you
`can look upon a jury service as a -- as a form of a tax,
`just like the income tax we -- we pay to the federal
`government or the property or the sales tax we pay to the
`county or state or school district where we live, and it's
`a tax that you pay not with money but with your time and
`your effort.
`And this judge said there might be a better way to
`look at it, a better perspective, because the truth is that
`you're doing something that is more important than merely
`discharging a duty. You're performing the most sacred duty
`asked of Americans in peacetime society. You're being
`asked to resolve a dispute between two litigants that's
`been going on for a long time, to occupy the attention and
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`time and effort and expense of a lot of people, the
`parties, the lawyers, and the Court.
`You're going to see some fine lawyers in the
`courtroom this afternoon and, for those of you who are
`selected to serve as jurors, throughout the course of the
`week. Many of them have years of experience trying cases
`in courtrooms just like this one throughout the country.
`But at the end of the day, this case will be decided not by
`the parties and not by the lawyers and not by me but by
`you.
`
`Juries have been around for a long time throughout
`history in the world. Those of you who know your Old
`Testament know that juries were used to decide issues of
`property value and ownership. The Greeks began using the
`jury system in about 1500 BC. And the Romans who adopted
`the jury system from the Greeks brought jury trials to
`England in the 4th Century AD so that, by the 12th century,
`jury trials had been part of the judicial system in England
`for over 800 years.
`King John tried to do away with the right to trial
`by jury, and by the 13th century, the Magna Carta was
`signed, and that guaranteed the right to jury trials for
`the English people. 28 of our united states have adopted
`verbatim the exact language of the Magna Carta and placed
`it in their state constitution.
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`So the concept of jury trials was really ingrained
`in our founding fathers as British colonists in the
`settling of America. When George, III came along, he, too,
`tried to deny the right to jury trials to his citizen
`colonists in America. And Thomas Jefferson, in penning the
`complaints against the British Crown in our own Declaration
`of Independence, set out the denial of the right to jury
`trials as one of the specific grounds mandating our
`separation from England.
`The men who met in Philadelphia in 1776, they had
`no doubt about the importance of the jury trial. They had
`a whole range of grievances against the crown. And one of
`the most important of those grievances was the denial of
`the right to a jury trial to the colonists.
`Our constitution was drafted in 1787, and it
`created the framework, the fundamental framework of our
`democracy. And the men who were there in Philadelphia and
`signed that document, they, too, knew about the importance
`of the jury trial. It is the only constitutional right
`that is mentioned in both the body of the Constitution
`itself and the Bill of Rights.
`No doubt many of your parents served on juries and
`some of your grandparents probably did, as well. So jury
`service stretches back many generations from today, all the
`way back to 1787, all the way back to 1776.
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`So while I certainly understand it may be an
`inconvenience for you at some level, I hope you will
`understand that it is more than that. It is a chance,
`perhaps, not to repay the debt that we owe to our country
`but at least to acknowledge it, to recognize it, and in
`some way to honor it.
`I firmly believe that jury service is one of the
`highest forms of public service that you as a citizen can
`render to your country. Of course, the highest form of
`public service centers around those young men and women who
`serve in the armed forces and put their lives on the line
`every day to guarantee for all of us the rights and
`freedoms that we all enjoy as Americans. And those young
`men and women who serve in the armed forces don't get to
`decide where it is that they are going. They go where our
`country asks them to go when it asks them to go.
`And so in a way, by being here today and by
`participating as you are, you're doing what your country is
`asking you to do, too. And I hope you will think about it
`in that way and hope that you will think about your time
`here today -- this afternoon, serving on this panel and on
`the jury, if you're selected, to help resolve this dispute
`perhaps in a little different light, perhaps as an
`opportunity for you to serve your country by seeking to do
`justice between these two parties.
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`Now, this is a patent infringement damages case
`where the Plaintiff, VirnetX, claims that Apple owes it
`certain damages for infringing its patents. Apple agrees
`that VirnetX is entitled to compensation but disputes the
`amount.
`
`I and the parties will have much more to say about
`what this case involves but, for now, I just wanted you to
`have some basic knowledge of what the case is about.
`I anticipate that the presentation of evidence
`will take about five days. We will begin the trial
`tomorrow morning, and so we will conclude no later than
`Monday, November 2nd, a week from today.
`Those of you, of course, who are selected to serve
`as our jury will need to be available at that time. If any
`of you have any prepaid vacations that are planned that
`you've already bought non-refundable tickets for or you
`have a surgery that's scheduled for later this week or
`anything else that's really serious enough to make it very
`difficult for you to serve, then I need for you to identify
`yourselves for me now.
`If there's anybody on the panel this afternoon who
`has those type of reasons that you could not serve, if you
`would please raise your hand for me now.
`Anybody on the left side? Let's see, one person
`in the back. Ms. McFadden; is that right? Ms. McFadden,
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`we'll -- we'll visit about it at the very end. I just want
`you to identify yourself for me now.
`Anybody else on the left side of the courtroom?
`Mr. Swann?
`Mr. Swann and Ms. McFadden.
`All right. And on the right side of the
`courtroom, anybody have any of those reasons that would
`make it very difficult for you to serve? No one on the
`right. Okay. Very well.
`I want to give you an overview of what is going to
`be happening over the next few days. Right now we're
`beginning the first stage of the trial, what we call the
`voir dire examination of the jury panel. This is where I
`and the attorneys will be asking you some questions to help
`us evaluate you as a potential juror.
`As the parties address you this afternoon, they're
`going to be asking you various questions. And I want you
`to understand at the outset that they're not seeking to
`inquire into your private affairs unduly. They are
`entitled to ask questions in order to secure a fair and
`impartial jury.
`Now, I don't know if it will happen this
`afternoon, but sometimes it does, when panel members are
`asked a question that they don't really -- really want to
`talk about in front of the whole panel. So if you have any
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`hesitancy at all about giving a complete answer to
`something that you consider private, then I just need you
`to say you want to talk about it to the judge at the end,
`and I'll give you an opportunity to answer that question
`outside the presence of all the other panel members.
`The important thing -- the most important thing
`this afternoon is for you to give full, complete, and
`truthful answers to the questions that are asked. There
`really are no wrong answers, as long as your answer is
`full, complete, and truthful.
`We did this same process this morning, and once we
`finish this afternoon, each side will be allowed to strike
`a certain number of jurors. After that has occurred, the
`first eight panel members will become our eight jurors.
`Some time at the end of the day today, you will
`get a telephone call letting you know whether or not you
`have been selected to serve on the jury. Everybody will
`get a call, not just those selected to serve.
`So when you leave here this afternoon, you won't
`know yet whether you've been selected or not. We'll call
`you and let you know in the -- in the early evening whether
`you've been selected or not.
`Tomorrow morning when the jury returns, each side
`will make opening statements. And following that, evidence
`will be presented to you -- or to the jury through the form
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`of witness testimony and documents that are admitted into
`evidence.
`Following the presentation of all of the evidence,
`I will instruct the jury on the law that it is required to
`follow during its deliberations, and then the parties will
`present their closing arguments to you.
`Finally, the jury will retire to the jury room to
`begin its deliberations.
`Now, the purpose of voir dire is to enable the
`Court to determine whether or not any prospective juror
`should be excused from jury service either by the -- the
`Court for what we call cause or by counsel for the parties
`by way of what we call peremptory challenges, which are
`challenges for which no reason need be given.
`Voir dire is an old French phrase, and it means to
`speak the truth. And I know that you will speak the truth
`as you answer the questions that I and the parties ask you
`this afternoon. Please listen carefully to the questions
`and don't be timid about speaking up if they apply to you.
`Now, we're going to start over with Ms. Willis.
`And I'm going to ask you to come to the microphone in the
`middle, Ms. Willis, and I'm going to ask you to tell us
`several things about yourself. Tell us your name; your
`city of residence; if you're employed, what your occupation
`is; a favorite thing to do in your spare time; and if
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`you're married, what your spouse's name and occupation is.
`So we'll start with you, Ms. Willis. And if you
`forget those things, I'll remind you as you go along.
`PROSPECTIVE JUROR: Okay. I'm Jenny Willis. I'm
`from Canton. Can you hear me okay?
`THE COURT: You're welcome to take your -- your
`mask off if you want. You're welcome to leave it on as
`well, if you prefer. It's up to you.
`PROSPECTIVE JUROR: Okay. Jenny Willis. I live
`in Canton. I work for First State Bank of Ben Wheeler and
`have been in banking for about 30 years. I'm a vice
`president there. I enjoy running. That's my hobby of
`choice.
`
`THE COURT: Could you come a little closer to the
`mic for me?
`PROSPECTIVE JUROR: Okay. Is that better?
`THE COURT: That's better, yes.
`PROSPECTIVE JUROR: People usually don't tell me I
`need to speak up. I usually do okay without --
`THE COURT: Thank you.
`PROSPECTIVE JUROR: But do you need me to repeat
`anything?
`THE COURT: Just maybe what your employment is.
`PROSPECTIVE JUROR: I work for First State Bank of
`Ben Wheeler. I'm in banking. I'm vice president there. I
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`enjoy running. I'm married. My husband's name is Scott,
`and he works for Benjamin Moore Paint.
`THE COURT: All right. Thank you, Ms. Willis.
`Ms. Richardson?
`PROSPECTIVE JUROR: Yes, sir. My name is LaKisha
`Richardson.
`THE COURT: Can you get a little closer for me?
`PROSPECTIVE JUROR: Yes, sir. Is that good?
`THE COURT: That's better.
`PROSPECTIVE JUROR: My name is LaKisha Richardson.
`I work for Austin Bank. I've been there for four years. I
`am married. I live in Longview. And my husband is an
`electrician. And in my spare time we enjoy outdoor
`activities with our two children.
`THE COURT: Okay. Thank you, Ms. Richardson.
`Mr. McLeod?
`PROSPECTIVE JUROR: Yes. My name is Jeremy
`McLeod. I work here in Tyler. Live in Bullard. I work as
`a petroleum engineer for Tanos Exploration, oil and gas.
`We have -- me and my wife, Chelsea, we have three kids,
`a -- I forget, seven -- seven, four, and six months.
`That's why I forget. And we -- we are very busy, baseball
`and soccer.
`THE COURT: All right. Thank you, Mr. McLeod.
`Mr. Swain [sic]?
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`PROSPECTIVE JUROR: Darien Swann.
`THE COURT: Swann.
`PROSPECTIVE JUROR: I live in Lindale. I work
`at -- work in the retail industry as a regional manager.
`My hobby is fishing and tournament fishing.
`THE COURT: All right. Thank you, Mr. Swann.
`Ms. Lambert?
`PROSPECTIVE JUROR: Hi. I'm Judy Lambert. And
`I'm in -- from Mineola, Texas. I'm married, and I have
`three children. They're all grown. My crafts are quilting
`and sewing. And I work for Comfort Keepers. I've worked
`as a caregiver for 17 years.
`THE COURT: All right. And your husband, what's
`
`he do?
`
`PROSPECTIVE JUROR: He's retired now, but he did
`work for TXDOT.
`THE COURT: Okay. Thank you.
`Mr. -- is it McCunn?
`PROSPECTIVE JUROR: Scott McCunn. I work at --
`or -- sorry -- I live here in Tyler. I work at 3D
`Resources.
`THE COURT: Can you raise your voice for me? I'm
`having a little trouble hearing you.
`PROSPECTIVE JUROR: All right. I live here in
`
`Tyler.
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`THE COURT: Okay.
`PROSPECTIVE JUROR: I work at 3D Resources.
`THE COURT: All right.
`PROSPECTIVE JUROR: I was just married Friday.
`THE COURT: Congratulations.
`PROSPECTIVE JUROR: Thank you.
`THE COURT: Is your wife employed?
`PROSPECTIVE JUROR: Yes, sir.
`THE COURT: Okay.
`PROSPECTIVE JUROR: She's a nurse.
`THE COURT: All right. And something that you
`enjoy to do -- doing in your spare time?
`PROSPECTIVE JUROR: I enjoy woodworking.
`THE COURT: Okay. All right. Thank you.
`Ms. Littlejohn?
`PROSPECTIVE JUROR: My name is Kaylee Littlejohn
`and I am from Longview, Texas. I work for my father doing
`pest control. One of my things I enjoy doing is painting
`and building things. And I'm neither married or have
`children.
`THE COURT: Okay. Thank you, Ms. Littlejohn.
`Mr. Martin?
`Can you -- can you raise it at all? Is that as
`high as it will go?
`PROSPECTIVE JUROR: I can squat.
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`THE COURT: You can either -- you can touch it if
`you want to to raise it up there.
`PROSPECTIVE JUROR: No, that's fine.
`My name is Sam Martin. I live in Jacksonville,
`Texas. I work at -- for UT Health East Texas as an
`exercise specialist. My wife is Katie. She works in
`Nacogdoches for SFA as a teacher certification officer. My
`down time, really, honestly is just work.
`THE COURT: Okay. All right. Thank you, sir.
`Ms. Ricketts?
`PROSPECTIVE JUROR: I am Sabrina Ricketts. I work
`for Lindale Independent School District as a teacher
`assistant for special needs children. I have a -- a senior
`and a sophomore. Sorry. It's hard for me to speak in
`public.
`
`THE COURT: Okay.
`PROSPECTIVE JUROR: I live in Tyler. I'm married
`to William. He works for himself --
`THE COURT: Okay.
`PROSPECTIVE JUROR: -- as a contract laborer. And
`I like to do arts and crafts with my kids, my students.
`Thank you.
`THE COURT: Thank you very much.
`Ms. McFadden?
`PROSPECTIVE JUROR: My name is Kathy McFadden. I
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`live in Garrison, Texas. I work at BancorpSouth. I've
`been there 38 years. I'm a personal banker. My husband's
`name is Mark. He's -- we are -- he is self-employed. We
`have our own business. I enjoy watching my grandchildren
`play ball and sports activities. Anything else?
`THE COURT: No. Thank you --
`PROSPECTIVE JUROR: Thank you.
`THE COURT: -- Ms. McFadden. Thank you very much.
`Is it Ms. LaPeyre?
`PROSPECTIVE JUROR: LaPeyre.
`THE COURT: LaPeyre. Ms. LaPeyre.
`PROSPECTIVE JUROR: My name is Casey LaPeyre. I
`work in Tyler. I live in Troup. I have two boys and a
`husband. And he works for CREST Process Systems. I work
`for American Renal Associates. And in my spare time I'm a
`baseball mom.
`THE COURT: Thank you.
`Ms. Phillips?
`PROSPECTIVE JUROR: Hi, my name is Debra Phillips.
`I'm from Mineola, Texas. I am a registered nurse, retired,
`45 years -- 45 years. I am not married. I have -- my
`hobbies are quilting.
`THE COURT: Thank you, ma'am.
`Ms. Ross?
`PROSPECTIVE JUROR: Hi, my name is Pamela Ross.
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`I'm from Frankston. And my husband's name is Frank. I'm
`medically -- I'm retired from the medical field. And my
`husband -- he drives a forklift for Frankston Packaging.
`And in my spare time, I enjoy spending time with my two
`grandkids, and it's basically whatever they want to do,
`that's what I enjoy doing.
`THE COURT: Good for you.
`PROSPECTIVE JUROR: And also watching the Dallas
`Mavericks.
`THE COURT: All right. Thank you, ma'am.
`Mr. Mogle?
`PROSPECTIVE JUROR: My name is John Mogle. I work
`for KETK. My responsibility is producing content that
`appears on the digital platforms. My wife's name is
`Melanie. She works for the Cowan Center. That's a large
`performance hall at the University of Texas at Tyler, and
`she deals with client relations. I'm currently in the
`process of writing a book about my maternal ancestry.
`THE COURT: Thank you.
`Mr. Parker?
`PROSPECTIVE JUROR: My name is Gerald Parker. I
`live here in Tyler. I'm semiretired. I have a business.
`I DJ weddings on the weekends. And when I'm not doing
`that, I hunt and fish.
`THE COURT: All right. Thank you, Mr. Parker.
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`Case 6:12-cv-00855-RWS Document 984 Filed 11/02/20 Page 22
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