DECLARATION MEREDITH DEARBORN ISO UBER’S ADMIN. MTN TO FILE UNDER SEAL PORTIONS 

AND EXHIBITS TO DEFENDANTS’ REPLY IN SUPPORT OF MOTION TO ENFORCE THE COURT’S JUNE 7,

2017 ORDER

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 

RUDY Y. KIM (CA SBN 199426) 

RKim@mofo.com 

MORRISON & FOERSTER LLP

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, D.C. 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

DECLARATION OF MEREDITH 

DEARBORN IN SUPPORT OF 

DEFENDANTS UBER 

TECHNOLOGIES, INC.’S AND 

OTTOMOTTO LLC’S 

ADMINISTRATIVE MOTION TO FILE 

UNDER SEAL PORTIONS AND 

EXHIBITS TO DEFENDANTS’ REPLY 

IN SUPPORT OF MOTION TO 

ENFORCE THE COURT’S JUNE 7, 

2017 ORDER 

Judge: Hon. William H. Alsup 

Trial Date: October 10, 2017

Case 3:17-cv-00939-WHA Document 1003-1 Filed 07/24/17 Page 1 of 3
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DECLARATION MEREDITH DEARBORN ISO UBER’S ADMIN. MTN TO FILE UNDER SEAL PORTIONS 

AND EXHIBITS TO DEFENDANTS’ REPLY IN SUPPORT OF MOTION TO ENFORCE THE COURT’S JUNE 7,

2017 ORDER

CASE NO. 3:17-CV-00939-WHA

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I, Meredith Dearborn, declare as follows: 

1. I am a partner at the law firm of Boies Schiller Flexner LLP representing 

Defendants Uber Technologies Inc. and Ottomotto LLC (collectively, “Uber”) in this matter. I 

am a member in good standing of the Bar of the State of California. I make this declaration based 

upon matters within my own personal knowledge and if called as a witness, I could and would 

competently testify to the matters set forth herein. I make this declaration in support of Uber’s 

Administrative Motion to File Under Seal Portions and Exhibits to Defendants’ Reply in Support 

of Motion to Enforce the Court’s June 7, 2017 Order. 

2. I have reviewed the following exhibits and confirmed only the portions identified 

below merit sealing: 

Document Portions to Be Filed Under Seal Designating Party

Defendant Uber Technologies, 

Inc. and Ottomotto, LLC’s 

Reply in Support of Motion to 

Enforce the Court’s June 7, 

2017 Order (Dkt. 563), to 

Strike Plaintiff Waymo LLC’s 

Corrected Supplemental Initial 

Disclosures, and to Preclude 

Damages Claims And Certain 

Witnesses (“Reply”) 

Highlighted Portions Plaintiff 

Exhibit 2 to Dearborn Decl. Highlighted Portions Plaintiff 

Exhibit 4 to Dearborn Decl. Entire document Plaintiff 

3. The highlighted portions of the Reply and Exhibit 2 and the entirety of Exhibit 4 

contain information that I understand has been designated by Waymo as “Confidential” or 

“Highly Confidential – Attorneys’ Eyes Only” under the Protective Order. 

4. Defendants’ request to seal is narrowly tailored to the specific exhibits that merit 

sealing. 

// 

// 

// 

Case 3:17-cv-00939-WHA Document 1003-1 Filed 07/24/17 Page 2 of 3
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DECLARATION OF MEREDITH DEARBORN ISO UBER’S ADMIN. MTN TO FILE UNDER SEAL PORTIONS 

AND EXHIBITS TO DEFENDANTS’ REPLY IN SUPPORT OF MOTION TO ENFORCE THE COURT’S JUNE 

7, 2017 ORDER

CASE NO. 3:17-CV-00939-WHA

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

24th day of July, 2017 at Oakland, California. 

Dated: July 24, 2017 BOIES SCHILLER FLEXNER LLP

By: /s/ Meredith R. Dearborn 

 Meredith Dearborn 

ATTESTATION OF E-FILED SIGNATURE

I, Karen L. Dunn, am the ECF User whose ID and password are being used to file this 

document. In compliance with General Order 45, X.B., I hereby attest that Meredith Dearborn 

has concurred in this filing. 

Dated: July 24, 2017 

/s/ Karen L Dunn 

Karen L. Dunn 

Case 3:17-cv-00939-WHA Document 1003-1 Filed 07/24/17 Page 3 of 3