GONZALEZ DECL. ISO DEFS. OPPOSITION TO WAYMO’S MOTION FOR CONTINUANCE OF TRIAL DATE

Case No. 3:17-cv-00939-WHA 

pa-1802525 

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MICHAEL A. JACOBS (CA SBN 111664)

MJacobs@mofo.com 

ARTURO J. GONZÁLEZ (CA SBN 121490) 

AGonzalez@mofo.com 

425 Market Street 

San Francisco, California 94105-2482 

Telephone: 415.268.7000 

Facsimile: 415.268.7522 

KAREN L. DUNN (Pro Hac Vice) 

kdunn@bsfllp.com 

HAMISH P.M. HUME (Pro Hac Vice) 

hhume@bsfllp.com 

BOIES SCHILLER FLEXNER LLP 

1401 New York Avenue, N.W. 

Washington DC 20005 

Telephone: 202.237.2727 

Facsimile: 202.237.6131 

WILLIAM CARMODY (Pro Hac Vice) 

bcarmody@susmangodfrey.com 

SHAWN RABIN (Pro Hac Vice) 

srabin@SusmanGodfrey.com 

SUSMAN GODFREY LLP 

1301 Avenue of the Americas, 32nd Floor 

New York, NY 10019-6023 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC. 

and OTTOMOTTO LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

v. 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC; OTTO TRUCKING LLC, 

Defendant. 

Case No. 3:17-cv-00939-WHA

DECLARATION OF 

ARTURO J. GONZALEZ IN 

SUPPORT OF DEFENDANTS UBER 

TECHNOLOGIES, INC. AND 

OTTOMOTTO LLC’S OPPOSITION 

TO WAYMO’S MOTION FOR 

CONTINUANCE OF TRIAL DATE 

Judge: The Honorable William Alsup 

Trial Date: October 10, 2017 

REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED

Case 3:17-cv-00939-WHA Document 1625 Filed 09/18/17 Page 1 of 3
GONZALEZ DECL. ISO DEFS. OPPOSITION TO WAYMO’S MOTION FOR CONTINUANCE OF TRIAL DATE

Case No. 3:17-cv-00939-WHA 1

pa-1802525 

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I, Arturo J. González, declare as follows: 

1. I am an attorney with the law firm of Morrison & Foerster LLP. I am a member in

good standing of the Bar of the State of California. I make this declaration based on personal 

knowledge and, if called as a witness, I could and would testify competently to the matters set 

forth herein. I make this declaration in support of Defendants Uber Technologies, Inc. and 

Ottomotto LLC’s Opposition to Waymo’s Motion for Continuance of Trial Date. 

2. Since the Federal Circuit’s decision, Uber has provided deposition dates for

5 deponents. Waymo has rejected these dates.

3. Once the Federal Circuit issued its decision, Uber produced the Stroz Report and

its exhibits within hours. 

4. Uber produced its Stroz-related documents the day after the Federal Circuit’s

decision. 

5. MoFo made the from the Stroz database that are in its files available for 

review on September 17, 2017. MoFo received these on behalf of Mr. Levandowski after

Google filed its arbitrations against him. 

6. Attached as Exhibit 1 is a true and correct copy of a deposition exhibit number

743, marked at the deposition of Adam Bentley, taken on August 22, 2017. 

7. Attached as Exhibit 2 is a true and correct copy of a document produced in this

litigation bearing Bates number UBER00319640-UBER00319669. 

8. Attached as Exhibit 3 is a true and correct copy of a document produced in this

litigation bearing Bates number UBER00319664. 

9. Attached as Exhibit 4 is a true and correct copy of a document produced in this

litigation bearing Bates number UBER00319665. 

10. Attached as Exhibit 5 is a true and correct copy of a document produced in this

litigation bearing Bates number UBER00319666. 

11. Attached as Exhibit 6 is a true and correct copy of a document produced in this

litigation bearing Bates number UBER00319667. 

Case 3:17-cv-00939-WHA Document 1625 Filed 09/18/17 Page 2 of 3
GONZALEZ DECL. ISO DEFS. OPPOSITION TO WAYMO’S MOTION FOR CONTINUANCE OF TRIAL DATE

Case No. 3:17-cv-00939-WHA 2

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12. Attached as Exhibit 7 is a true and correct copy of a document produced in this 

litigation bearing Bates number UBER00319668. 

13. Attached as Exhibit 8 is a true and correct copy of excerpts from the deposition of 

Rhian Morgan, dated April 14, 2017. 

14. Attached as Exhibit 9 is a true and correct copy of excerpts from the deposition of 

Rhian Morgan, dated August 28, 2017. 

15. Attached as Exhibit 10 is a true and correct copy of a document produced in this 

litigation bearing Bates number WAYMO-UBER-00086796-WAYMO-UBER-00087999. 

16. Attached as Exhibit 11 is a true and correct copy of excerpts from the Expert 

Report of Michael J. Wagner, dated August 24, 2017. 

17. Attached as Exhibit 12 is a true and correct copy of a document produced in this 

litigation bearing Bates number UBER0022196-UBER00022199. 

18. Attached as Exhibit 13 is a true and correct copy of a document produced in this 

litigation bearing Bates number UBER0022246. 

19. Attached as Exhibit 14 is a true and correct copy of a document produced in this 

litigation bearing Bates number WAYMO-UBER-00022288-WAYMO-UBER-00022289. 

20. Attached as Exhibit 15 is a true and correct copy of an email from Maxwell Pritt, 

counsel for Uber to Andrea Roberts, counsel for Waymo, dated September 15, 2017. 

21. Attached as Exhibit 16 is a true and correct copy of excerpts from the Reply 

Expert Report of Lambertus Hesselink, Ph.D., dated September 14, 2017. 

I declare under penalty of perjury that the foregoing is true and correct. Executed this 18th

day of September, 2017 at San Francisco, California. 

 /s/ Arturo J. Gonzàlez 

 ARTURO J. GONZÀLEZ 

Case 3:17-cv-00939-WHA Document 1625 Filed 09/18/17 Page 3 of 3