Exhibit A

Case 3:17-cv-00939-WHA Document 315-1 Filed 04/28/17 Page 1 of 4
NOTICE OF DEPOSITION OF LARRY PAGE AND REQUESTS FOR PRODUCTION

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

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MICHAEL A. JACOBS (CA SBN 111664)

MJacobs@mofo.com 

ARTURO J. GONZÁLEZ (CA SBN 121490) 

AGonzalez@mofo.com 

ERIC A. TATE (CA SBN 178719) 

ETate@mofo.com 

MORRISON & FOERSTER LLP

425 Market Street 

San Francisco, California 94105-2482 

Telephone: 415.268.7000 

Facsimile: 415.268.7522 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC, and OTTO TRUCKING LLC 

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 

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, 

Defendants. 

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

NOTICE OF DEPOSITION OF 

LARRY PAGE AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS 

AND THINGS 

Honorable William Alsup 

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NOTICE OF DEPOSITION OF LARRY PAGE AND REQUESTS FOR PRODUCTION

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 

PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 30, 

Defendants Uber Technologies, Inc., Ottomotto LLC, and Otto Trucking LLC, by and through 

their attorneys, will take the deposition upon oral examination of Larry Page. The deposition will 

commence at 10:00 a.m. on April 27, 2017, at the offices of Morrison & Foerster LLP, 

425 Market Street, San Francisco, California. The deposition will be taken by a notary public or 

other authorized officer and will continue from day to day until concluded, or may be continued 

until completed at a future date or dates. 

PLEASE TAKE FURTHER NOTICE that, pursuant to Federal Rule of Civil 

Procedure 30(b)(3), the deposition will be videotaped and recorded stenographically. 

PLEASE TAKE FURTHER NOTICE that pursuant to Rule 34 of the Federal Rules of 

Civil Procedure, the deponent is requested to produce at the time and place set forth above for his 

deposition the documents and things identified in the attached Exhibit A to Notice, which is 

incorporated herein by reference. 

Dated: April 20, 2017 MORRISON & FOERSTER LLP

By: /s/ Arturo J. González 

ARTURO J. GONZÁLEZ 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC, and OTTO TRUCKING LLC

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NOTICE OF DEPOSITION OF LARRY PAGE AND REQUESTS FOR PRODUCTION

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EXHIBIT A 

DEFINITIONS 

1. “Waymo” means Waymo LLC, Google Inc., and Alphabet Inc. 

2. “Defendants” mean Uber Technologies, Inc. (“Uber”) and Ottomotto LLC and 

Otto Trucking LLC (together “Otto”). 

REQUESTS 

1. Documents regarding any policy or written guideline regarding the ability of 

Waymo employees to participate in a personal side business while employed by Waymo. 

2. Documents sufficient to identify the Waymo employees who have had side 

businesses, including the names of all such employees and the nature of the side businesses in 

which such employees engaged in the past three years. 

3. Documents sufficient to show any joint interest or joint defense agreement that 

Waymo has entered into during the past three years. 

4. Communications about the possibility of pursuing a legal action against Anthony 

Levandowski or Defendants. 

5. Any brief or declaration provided to any court in support of a joint interest or joint 

defense privilege asserted by Waymo. 

6. Documents sufficient to show when Waymo began investigating the possibility of 

Anthony Levandowski taking Waymo files with him upon his departure. 

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