EXHIBIT 8

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 1 of 13
          	 
      
      	 
      
    
  
     

1 UNITED STATES DISTRICT COURT

2 NORTHERN DISTRICT OF CALIFORNIA

3 SAN FRANCISCO DIVISION

4 __________________________________

5 WAYMO LLC, )

 )

6 Plaintiff, )

 vs. ) Case No.

7 ) 17-cv-00939-WHA

UBER TECHNOLOGIES, INC.; )

8 OTTOMOTTO, LLC; OTTO TRUCKING LLC, )

 )

9 Defendants. )

 )

10 )

___________________________________)

11

12

13 HIGHLY CONFIDENTIAL--OUTSIDE COUNSEL'S EYES ONLY

14 VIDEOTAPED DEPOSITION OF

15 OGNEN STOJANOVSKI, ESQ.

16 San Francisco, California

17 Thursday, July 20, 2017

18 Volume I

19

20

21

22 Reported by:

MARY J. GOFF

23 CSR No. 13427

24 Job No. 2663397

25 PAGES 1-321

Page 1

                     

   ! !


 " #

 $

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 2 of 13
          	 
      
      	 
      
    
  
     

1 Q And what else have you -- well, let me ask 09:22:15

2 it this way: What else have you communicated with 09:22:18

3 Steve Nunnemaker about with respect to accounting 09:22:23

4 services? 09:22:26

5 A I have referred clients of mine to his 09:22:26

6 accounting firm for their own accounting needs. 09:22:30

7 Q Have you ever, on behalf of any other 09:22:33

8 clients, communicated with Mr. Nunnemaker about 09:22:38

9 accounting services? 09:22:41

10 A No, I wouldn't say on behalf of. I have 09:22:45

11 had clients who have asked, Do you know any 09:22:48

12 accountants, and I have referred them to Steve to 09:22:50

13 see if he could meet their needs. 09:22:53

14 Q How did you -- well, let me -- let me ask 09:22:57

15 it a better way. 09:23:00

16 How did Mr. Nunnemaker be -- end up 09:23:02

17 becoming the accountant for Sandstone? 09:23:06

18 MR. SAWYER: Objection, form. 09:23:11

19 MS. RAY: Join. 09:23:13

20 A He was the accountant for -- my 09:23:13

21 understanding is he was the accountant for 09:23:18

22 Sandstone's parent. And Sandstone being a 09:23:20

23 pass-through entity for accounting purposes. 09:23:24

24 He's -- its accountant as well. That's the most 09:23:27

25 straightforward way to do it. 09:23:32

Page 21

                     

   ! !


 " #

 $

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 3 of 13
          	 
      
      	 
      
    
  
     

1 09:34:03

2 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 09:34:03

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 4 of 13
          	 
      
      	 
      
    
  
     

1 MS. RAY: Objection, form. 09:35:21

2 MR. SAWYER: Join. 09:35:22

3 A I don't know for sure why he asked me to 09:35:24

4 be the manager of Sandstone Group. 09:35:26

5 Q (BY MR. JUDAH) Do you have any 09:35:28

6 understanding why you were selected to be the 09:35:30

7 manager of Sandstone Group? 09:35:32

8 MR. SAWYER: Objection, form. 09:35:33

9 MS. RAY: Join. 09:35:34

10 A Can you repeat that? Can you rephrase 09:35:36

11 that? 09:35:37

12 Q Well, you answered earlier that you don't 09:35:39

13 know for sure why John Gardner asked you to be the 09:35:43

14 manager of Sandstone Group. 09:35:47

15 And so now I'm asking: Well, do you have 09:35:49

16 any understanding as to why you were selected to be 09:35:51

17 manager of Sandstone Group? 09:35:53

18 A Yeah, I -- my understanding is John knew 09:35:57

19 that I was -- that I was in the business of 09:36:06

20 representing start-up companies and also angel 09:36:09

21 investors in line with the solo practice I had at 09:36:15

22 the time. 09:36:20

23 Q Had you ever worked for John Gardner 09:36:22

24 before he asked you to be the manager of Sandstone 09:36:24

25 Group? 09:36:27

Page 31

                     

   ! !


 " #

 $

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 5 of 13
          	 
      
      	 
      
    
  
     

1 A I had not worked with John Gardner before 09:36:28

2 he asked me to be the manager of Sandstone Group. 09:36:32

3 Q Had you ever met John Gardner before 09:36:36

4 that -- that time he asked you to be the manager of 09:36:38

5 the Sandstone Group? 09:36:42

6 MR. SAWYER: Objection, form. 09:36:43

7 A I had not met John Gardner before he asked 09:36:43

8 me to be the manager of Sandstone Group. 09:36:46

9 Q So what were the circumstances under which 09:36:51

10 he reached out to you to -- to tell you that he 09:36:54

11 wanted you to be the manager of Sandstone Group? 09:36:56

12 MR. SAWYER: Objection, form. 09:36:59

13 A He called me to describe an opportunity 09:37:00

14 for me to represent a client. 09:37:12

15 Q How did he -- well, let me ask you this: 09:37:23

16 Did he say that he was referred to you by someone? 09:37:25

17 A Can you rephrase? Can you say that -- he 09:37:30

18 was -- referred to me? So somebody referred him to 09:37:32

19 me? Is that the -- 09:37:38

20 Q I -- 09:37:38

21 A -- question? 09:37:38

22 Q -- well, I'm asking -- well, let me take a 09:37:39

23 step back. 09:37:42

24 So you had never met John Gardner before 09:37:43

25 he called you about this opportunity with the 09:37:45

Page 32

                     

   ! !


 " #

 $

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 6 of 13
          	 
      
      	 
      
    
  
     

1 Sandstone Group, right? 09:37:48

2 A I had not met John Gardner before he 09:37:48

3 called me. 09:37:50

4 Q So -- so my question is: Why -- why did 09:37:51

5 he think to call you? 09:37:54

6 MR. SAWYER: Objection, form. 09:37:56

7 MS. RAY: Join. 09:37:58

8 A He told me that he had gotten my name from 09:38:02

9 Anthony Levandowski. 09:38:06

10 Q And what else do you remember about that 09:38:11

11 conversation when he called you? 09:38:14

12 A He called me to tell me that he was in the 09:38:15

13 process of forming an investment company and asked 09:38:20

14 if I would be interested in being his manager. That 09:38:26

15 was the gist of the first conversation. 09:38:30

16 

 

 

 

 

 

 

 

 

 

Page 33

                     

   ! !


 " #

 $

 

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 7 of 13
          	 
      
      	 
      
    
  
     

1 THE VIDEOGRAPHER: -- I'm sorry. I have 01:19:31

2 to check and see if my recording overwrote 01:19:32

3 something. I'm sorry. 01:19:36

4 MR. JUDAH: Sure. Take a quick break. 01:19:37

5 THE VIDEOGRAPHER: Take a quick break. We 01:19:40

6 are going off the record. This is the end of Media 01:19:45

7 unit No. 6. We are off the record. 01:19:47

8 (A break was taken from 1:20 p.m. to 01:19:51

9 1:20 p.m.) 01:20:09

10 THE VIDEOGRAPHER: Okay. We are back on 01:20:11

11 the record. This is beginning of Media Unit No. 7. 01:20:25

12 The time is approximately 1:20 p.m. We are on the 01:20:30

13 record. 01:20:33

14 Q (BY MR. JUDAH) All right. So let me just 01:20:37

15 ask that again because we had technical issues. 01:20:38

16 A Sure. 01:20:42

17 

 

 

 

 

 

 

 

 

Page 128

                     

   ! !


 " #

 $

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 8 of 13
1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 9 of 13
1 

 

 

 

5 Q (BY MR. JUDAH) Were those communications 01:22:37

6 with Mr. Levandowski e-mails or -- or oral? 01:22:39

7 A Oral, I believe. 01:22:45

8 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Page 130

                     

   ! !


 " #

 $

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 10 of 13
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Page 131

                     

   ! !


 " #

 $

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 11 of 13
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Page 132

                     

   ! !


 " #

 $

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 12 of 13
 

 

 

 

 

 

 

 

9 MR. SAWYER: Objection, form. 05:04:17

 

 

 

 

 

 

 

 

 

 

20 Q And -- and you were introduced to 05:04:59

21 Mr. Nunnemaker by Mr. Gardner? 05:05:02

22 A I think so. Although, I don't recall that 05:05:09

23 introduction. 05:05:11

 

 

Page 261

                     

   ! !


 " #

 $

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:17-cv-00939-WHA Document 1086-8 Filed 08/04/17 Page 13 of 13