Exhibit 1

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 1 of 17
, who issues or requests this subpoena, are:

Place: Date and Time:

AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

Civil Action No.

UNITED STATES DISTRICT COURT

for the

)

)

)

)

Plaintiff

v.

Defendant

)

)

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

To:

Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following

documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the

material:

Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or

other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party

may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;

Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to

respond to this subpoena and the potential consequences of not doing so.

Date:

CLERK OF COURT

OR

Signature of Clerk or Deputy Clerk Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)

AO-88B

District of

(Name of person to whom this subpoena is directed)

Notice to the person who issues or requests this subpoena

If this subpoena commands the production of documents, electronically stored information, or tangible things or the

inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before

it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION

Place: Date and Time:

 Northern California

WAYMO LLC

UBER TECHNOLOGIES, INC.; OTTOMOTTO 

LLC; OTTO TRUCKING LLC

3:17-cv-00939-WHA

X

See Attachment A. 

 

Charles K. Verhoeven

Waymo LLC

Charles K. Verhoeven, 50 California Street, 22nd Floor, San Francisco, 

California 94111; qewaymo@quinnemanuel.com; Tel: (415) 875-6600 

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 2 of 17
AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)

I received this subpoena for (name of individual and title, if any)

on (date) .

I returned the subpoena unexecuted because:

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:

Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc.:

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also

tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of

$ .

I served the subpoena by delivering a copy to the named person as follows:

on (date) ; or

.

0.00

 0.00 0.00 0.00

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 3 of 17
AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)

Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)

(c) Place of Compliance.

person to attend a trial, hearing, or deposition only as follows:

(1) For a Trial, Hearing, or Deposition. A subpoena may command a

(A) within 100 miles of where the person resides, is employed, or

regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly

transacts business in person, if the person

(i) is a party or a party’s officer; or

(ii) is commanded to attend a trial and would not incur substantial

expense.

(2) For Other Discovery. A subpoena may command:

(A) production of documents, electronically stored information, or

tangible things at a place within 100 miles of where the person resides, is

employed, or regularly transacts business in person; and

(B) inspection of premises at the premises to be inspected.

(d) Protecting a Person Subject to a Subpoena; Enforcement.

(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney

responsible for issuing and serving a subpoena must take reasonable steps

to avoid imposing undue burden or expense on a person subject to the

subpoena. The court for the district where compliance is required must

enforce this duty and impose an appropriate sanction—which may include

lost earnings and reasonable attorney’s fees—on a party or attorney who

fails to comply.

(2) Command to Produce Materials or Permit Inspection.

(A) Appearance Not Required. A person commanded to produce

documents, electronically stored information, or tangible things, or to

permit the inspection of premises, need not appear in person at the place of

production or inspection unless also commanded to appear for a deposition,

hearing, or trial.

(B) Objections. A person commanded to produce documents or tangible

things or to permit inspection may serve on the party or attorney designated

in the subpoena a written objection to inspecting, copying, testing, or

sampling any or all of the materials or to inspecting the premises — or to

producing electronically stored information in the form or forms requested.

The objection must be served before the earlier of the time specified for

compliance or 14 days after the subpoena is served. If an objection is made,

the following rules apply:

(i) At any time, on notice to the commanded person, the serving party

may move the court for the district where compliance is required for an

order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the

order must protect a person who is neither a party nor a party's officer from

significant expense resulting from compliance.

(3) Quashing or Modifying a Subpoena.

(A) When Required. On timely motion, the court for the district where

compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits

specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no

exception or waiver applies; or

(iv) subjects a person to undue burden.

(B) When Permitted. To protect a person subject to or affected by a

subpoena, the court for the district where compliance is required may, on

motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research,

development, or commercial information; or

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).

(ii) disclosing an unretained expert’s opinion or information that does

not describe specific occurrences in dispute and results from the expert’s

study that was not requested by a party.

(C) Specifying Conditions as an Alternative. In the circumstances

described in Rule 45(d)(3)(B), the court may, instead of quashing or

modifying a subpoena, order appearance or production under specified

conditions if the serving party:

(i) shows a substantial need for the testimony or material that cannot be

otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

(1) Producing Documents or Electronically Stored Information. These

procedures apply to producing documents or electronically stored

information:

(A) Documents. A person responding to a subpoena to produce documents

must produce them as they are kept in the ordinary course of business or

must organize and label them to correspond to the categories in the demand.

(B) Form for Producing Electronically Stored Information Not Specified.

(e) Duties in Responding to a Subpoena.

If a subpoena does not specify a form for producing electronically stored

information, the person responding must produce it in a form or forms in

which it is ordinarily maintained or in a reasonably usable form or forms.

(C) Electronically Stored Information Produced in Only One Form. The

person responding need not produce the same electronically stored

information in more than one form.

(D) Inaccessible Electronically Stored Information. The person

responding need not provide discovery of electronically stored information

from sources that the person identifies as not reasonably accessible because

of undue burden or cost. On motion to compel discovery or for a protective

order, the person responding must show that the information is not

reasonably accessible because of undue burden or cost. If that showing is

made, the court may nonetheless order discovery from such sources if the

requesting party shows good cause, considering the limitations of Rule

26(b)(2)(C). The court may specify conditions for the discovery.

(2) Claiming Privilege or Protection.

(A) Information Withheld. A person withholding subpoenaed information

material must:

under a claim that it is privileged or subject to protection as trial-preparation

(i) expressly make the claim; and

(ii) describe the nature of the withheld documents, communications, or

tangible things in a manner that, without revealing information itself

privileged or protected, will enable the parties to assess the claim.

(B) Information Produced. If information produced in response to a

subpoena is subject to a claim of privilege or of protection as

trial-preparation material, the person making the claim may notify any party

that received the information of the claim and the basis for it. After being

notified, a party must promptly return, sequester, or destroy the specified

until the claim is resolved; must take reasonable steps to retrieve the

information and any copies it has; must not use or disclose the information

present the information under seal to the court for the district where

compliance is required for a determination of the claim. The person who

produced the information must preserve the information until the claim is

resolved.

information if the party disclosed it before being notified; and may promptly

(g) Contempt.

The court for the district where compliance is required—and also, after a

motion is transferred, the issuing court—may hold in contempt a person

who, having been served, fails without adequate excuse to obey the

subpoena or an order related to it.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 4 of 17
ATTACHMENT A 1

ATTACHMENT A

DEFINITIONS

1. “YOU” or “LEVANDOWSKI” means Anthony Levandowski.

2. “WAYMO” means Waymo LLC and its officers, directors, current and former

employees, counsel, agents, consultants, representatives, and any other persons acting on behalf

of any of the foregoing, and WAYMO’s affiliates, parents, divisions, joint ventures, licensees,

franchisees, assigns, predecessors and successors in interest, and any other legal entities, whether

foreign or domestic, that are owned or controlled by WAYMO, and all predecessors and

successors in interest to such entities, and any entity owned in whole or in part by, affiliated

with, or controlled in whole or in part by WAYMO.

3. “GOOGLE” means Google Inc. and its officers, directors, current and former

employees, counsel, agents, consultants, representatives, and any other persons acting on behalf

of any of the foregoing, and GOOGLE’s affiliates, parents, divisions, joint ventures, licensees,

franchisees, assigns, predecessors and successors in interest, and any other legal entities, whether

foreign or domestic, that are owned or controlled by GOOGLE, and all predecessors and

successors in interest to such entities, and any entity owned in whole or in part by, affiliated

with, or controlled in whole or in part by GOOGLE.

4. “UBER” means Uber Technologies, Inc. and its officers, directors, current and

former employees, counsel, agents, consultants, representatives, and any other persons acting on

behalf of any of the foregoing, and UBER’s affiliates, parents, divisions, joint ventures,

licensees, franchisees, assigns, predecessors and successors in interest, and any other legal

entities, whether foreign or domestic, that are owned or controlled by UBER, and all

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 5 of 17
ATTACHMENT A 2

predecessors and successors in interest to such entities, and any entity owned in whole or in part

by, affiliated with, or controlled in whole or in part by UBER.

5. “OTTOMOTTO” means Ottomotto LLC and its officers, directors, current and

former employees, counsel, agents, consultants, representatives, and any other persons acting on

behalf of any of the foregoing, and OTTOMOTTO’s affiliates, parents, divisions, joint ventures,

licensees, franchisees, assigns, predecessors and successors in interest, and any other legal

entities, whether foreign or domestic, that are owned or controlled by OTTOMOTTO, and all

predecessors and successors in interest to such entities, and any entity owned in whole or in part

by, affiliated with, or controlled in whole or in part by OTTOMOTTO. For the avoidance of

doubt, OTTOMOTTO includes all former names under which OTTOMOTTO operated,

including without limitation 280 Systems, Inc., 280 Systems, LLC, and Ottomotto, Inc.

6. “OTTO TRUCKING” means Otto Trucking LLC and its officers, directors,

current and former employees, counsel, agents, consultants, representatives, and any other

persons acting on behalf of any of the foregoing, and OTTO TRUCKING’s affiliates, parents,

divisions, joint ventures, licensees, franchisees, assigns, predecessors and successors in interest,

and any other legal entities, whether foreign or domestic, that are owned or controlled by OTTO

TRUCKING, and all predecessors and successors in interest to such entities, and any entity

owned in whole or in part by, affiliated with, or controlled in whole or in part by OTTO

TRUCKING.

7. “DEFENDANTS” means UBER and OTTOMOTTO AND OTTO TRUCKING.

8. “LiDAR” means Light Detection and Ranging.

9. “ODIN WAVE” means Odin Wave, LLC and its officers, directors, current and

former employees, counsel, agents, consultants, representatives, and any other persons acting on

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 6 of 17
ATTACHMENT A 3

behalf of any of the foregoing, and ODIN WAVE’s affiliates, parents, divisions, joint ventures,

licensees, franchisees, assigns, predecessors and successors in interest, and any other legal

entities, whether foreign or domestic, that are owned or controlled by ODIN WAVE, and all

predecessors and successors in interest, and any entity owned in whole or in part by, affiliated

with, or controlled in whole or in part by ODIN WAVE.

10. “TYTO” means Tyto Lidar LLC, and its officers, directors, current and former

employees, counsel, agents, consultants, representatives, and any other persons acting on behalf

of any of the foregoing, and TYTO’s affiliates, parents, divisions, joint ventures, licensees,

franchisees, assigns, predecessors and successors in interest, and any other legal entities, whether

foreign or domestic, that are owned or controlled by TYTO, and all predecessors and successors

in interest, and any entity owned in whole or in part by, affiliated with, or controlled in whole or

in part by TYTO.

11. “POUCH HOLDINGS” means Pouch Holdings LLC, and its officers, directors,

current and former employees, counsel, agents, consultants, representatives, and any other

persons acting on behalf of any of the foregoing, and POUCH HOLDINGS’ affiliates, parents,

divisions, joint ventures, licensees, franchisees, assigns, predecessors and successors in interest,

and any other legal entities, whether foreign or domestic, that are owned or controlled by

POUCH HOLDINGS, and all predecessors and successors in interest, and any entity owned in

whole or in part by, affiliated with, or controlled in whole or in part by POUCH HOLDINGS.

12. “DOGWOOD LEASING” means Dogwood Leasing, LLC, and its officers,

directors, current and former employees, counsel, agents, consultants, representatives, and any

other persons acting on behalf of any of the foregoing, and DOGWOOD LEASING’s affiliates,

parents, divisions, joint ventures, licensees, franchisees, assigns, predecessors and successors in

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 7 of 17
ATTACHMENT A 4

interest, and any other legal entities, whether foreign or domestic, that are owned or controlled

by DOGWOOD LEASING, and all predecessors and successors in interest, and any entity

owned in whole or in part by, affiliated with, or controlled in whole or in part by DOGWOOD

LEASING.

13. “APPARATE INTERNATIONAL” means Apparate International C.V., and its

officers, directors, current and former employees, counsel, agents, consultants, representatives,

and any other persons acting on behalf of any of the foregoing, and APPARATE

INTERNATIONAL’s affiliates, parents, divisions, joint ventures, licensees, franchisees, assigns,

predecessors and successors in interest, and any other legal entities, whether foreign or domestic,

that are owned or controlled by APPARATE INTERNATIONAL, and all predecessors and

successors in interest, and any entity owned in whole or in part by, affiliated with, or controlled

in whole or in part by APPARATE INTERNATIONAL.

14. “SANDSTONE” means Sandstone Group, LLC, and its officers, directors, current

and former employees, counsel, agents, consultants, representatives, and any other persons acting

on behalf of any of the foregoing, and SANDSTONE’s affiliates, parents, divisions, joint

ventures, licensees, franchisees, assigns, predecessors and successors in interest, and any other

legal entities, whether foreign or domestic, that are owned or controlled by SANDSTONE, and

all predecessors and successors in interest, and any entity owned in whole or in part by, affiliated

with, or controlled in whole or in part by SANDSTONE.

15. “STROZ” means Stroz Friedberg, LLC, and its officers, directors, current and

former employees, counsel, agents, consultants, representatives, and any other persons acting on

behalf of any of the foregoing, and STROZ’s affiliates, parents, divisions, joint ventures,

licensees, franchisees, assigns, predecessors and successors in interest, and any other legal

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 8 of 17
ATTACHMENT A 5

entities, whether foreign or domestic, that are owned or controlled by STROZ, and all

predecessors and successors in interest, and any entity owned in whole or in part by, affiliated

with, or controlled in whole or in part by STROZ.

16. “MISAPPROPRIATED MATERIALS” refers to all GOOGLE and WAYMO

DOCUMENTS and materials, whether digital or physical, and regardless of the manner stored,

for which LEVANDOWSKI retained possession, without authorization of either GOOGLE or

WAYMO, after LEVANDOWSKI’s employment with GOOGLE/WAYMO ended. Without

limitation, MISAPPROPRIATED MATERIALS includes at least: (i) each of the more than

14,000 digital files downloaded by LEVANDOWSKI on or about December 11, 2015 from the

SVN repository; (ii) each file copied by LEVANDOWSKI from his GOOGLE laptop to an

RDF5 USB 3.0 card reader on or about December 14, 2015; (iii) each of the five documents that

were exported by LEVANDOWSKI from Google Drive to a personal device on or about January

4, 2016; and (iv) the file exported by LEVANDOWSKI from Google Drive to a personal device

on or about January 11, 2016.

17. “THIS CASE” means Waymo LLC v. Uber Technologies, Inc., Ottomotto, LLC,

and Otto Trucking LLC, No. 3:17-cv-00939-JCS, filed in the Northern District of California.

18. “DOCUMENTS” shall INCLUDE, without limitation, all written, graphic or

otherwise recorded material, INCLUDING without limitation, electronically stored information

regardless of the form of storage medium, microfilms or other film records or impressions, tape

recordings or computer cards, floppy disks or printouts, any and all papers, photographs, films,

recordings, memoranda, books, records, accounts, communications, letters, telegrams,

correspondence, notes of meetings, notes of conversations, notes of telephone calls, inter-office

memoranda or written communications of any nature, recordings of conversations either in

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 9 of 17
ATTACHMENT A 6

writings or upon any mechanical or electrical recording devices, INCLUDING e-mail, notes,

papers, reports, analyses, invoices, canceled checks or check stubs, receipts, minutes of

meetings, time sheets, diaries, desk calendars, ledgers, schedules, licenses, financial statements,

telephone bills, logs, and any differing versions of any of the foregoing, whether so denominated,

formal, informal or otherwise, as well as copies of the foregoing which differ in any way,

INCLUDING by the addition of handwritten notations or other written or printed matter of any

nature, from the original. The foregoing specifically INCLUDES information stored in a

computer database and capable of being generated in documentary form, such as electronic mail,

text messages (i.e., SMS messages), other electronic messages including messages sent or

received via Slack, WhatsApp, Google Hangouts, Facebook Messenger, and the like.

19. “COMMUNICATIONS” shall mean, without limitation, any transmission,

conveyance or exchange of a word, statement, fact, thing, idea, DOCUMENT, instruction,

information, demand or question by any medium, whether by written, oral or other means,

including but not limited to, electronic communications and electronic mail (“e-mail”).

20. “REGARDING,” shall mean relating to, referring to, mentioning, reflecting,

pertaining to, evidencing, involving, describing, discussing, commenting on, embodying,

responding to, supporting, contradicting, or constituting (in whole or in part), as the context

makes appropriate.

21. “INCLUDE” and “INCLUDING” shall mean including without limitation.

22. Use of the singular also INCLUDES the plural and vice-versa.

23. The words “or” and “and” shall be read in the conjunctive and in the disjunctive

wherever they appear, and neither of these words shall be interpreted to limit the scope of these

Requests for Production.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 10 of 17
ATTACHMENT A 7

24. The use of a verb in any tense shall be construed as the use of the verb in all other

tenses.

INSTRUCTIONS

The following instructions shall apply to each of the Document Requests herein:

1. In answering the following Document Requests, furnish all available information,

INCLUDING information in the possession, custody, or control of YOU or any of YOUR

attorneys, directors, officers, agents, employees, representatives, associates, investigators or

division affiliates, partnerships, parents or subsidiaries, and persons under YOUR control, who

have the best knowledge, not merely information known to YOU based on YOUR own personal

knowledge. If you cannot fully respond to the following Document Requests after exercising

due diligence to secure the information requested thereby, so state, and specify the portion of

each Document Request that cannot be responded to fully and completely. In the latter event,

state what efforts were made to obtain the requested information and the facts relied upon that

support the contention that the Document Request cannot be answered fully and completely; and

state what knowledge, information or belief YOU has concerning the unanswered portion of any

such Document Requests.

2. Electronic records and computerized information must be produced in an

intelligible format.

3. Selection of documents from the files and other sources and the numbering of

such documents shall be performed in such a manner as to ensure that the source of each

document may be determined, if necessary.

4. File folders with tabs or labels or directories of files identifying documents must

be produced intact with such documents.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 11 of 17
ATTACHMENT A 8

5. Documents attached to each other shall not be separated.

6. If YOUR response to a particular Document Request is a statement that YOU lack

the ability to comply with that Document Request, YOU must specify whether the inability to

comply is because the particular item or category of information never existed, has been

destroyed, has been lost, misplaced, or stolen, or has never been, or is no longer, in YOUR

possession, custody, or control, in which case the name and address of any person or entity

known or believed by you to have possession, custody, or control of that information or category

of information must be identified.

7. If YOUR response to a particular Document Request is a statement that the

requested documents have been deleted, YOU must state the extent of such deletion and produce

all documents bearing on said deletion, destruction, or modification.

8. If any DOCUMENT(S) or COMMUNICATION(S) are considered “confidential”

by YOU, such DOCUMENT(S) or COMMUNICATION(S) should be produced subject to the

terms and provisions of the Northern District of California’s Patent Local Rule 2-2 Interim

Model Protective Order, available at http://www.cand.uscourts.gov/model-protective-orders.

9. YOUR obligation to respond to these Document Requests is continuing and its

responses are to be supplemented to INCLUDE subsequently acquired information in accordance

with the requirements of Rule 26(e) of the Federal Rules of Civil Procedure.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 12 of 17
ATTACHMENT A 9

DOCUMENTS TO BE PRODUCED AND INSPECTED

REQUEST FOR PRODUCTION NO. 1:

All DOCUMENTS and COMMUNICATIONS REGARDING ODIN WAVE and/or

TYTO before May 5, 2016.

REQUEST FOR PRODUCTION NO. 2:

All DOCUMENTS and COMMUNICATIONS REGARDING APPARATE

INTERNATIONAL.

REQUEST FOR PRODUCTION NO. 3:

All DOCUMENTS and COMMUNICATIONS REGARDING UBER before August 23,

2016.

REQUEST FOR PRODUCTION NO. 4:

All DOCUMENTS and COMMUNICATIONS REGARDING POUCH HOLDINGS.

REQUEST FOR PRODUCTION NO. 5:

All DOCUMENTS and COMMUNICATIONS REGARDING DOGWOOD LEASING.

REQUEST FOR PRODUCTION NO. 6:

All DOCUMENTS and COMMUNICATIONS REGARDING SANDSTONE.

REQUEST FOR PRODUCTION NO. 7:

All DOCUMENTS REGARDING the formation of OTTOMOTTO, including, without

limitation, business formation documents, business plans, and solicitations of investment capital.

REQUEST FOR PRODUCTION NO. 8:

All DOCUMENTS REGARDING the formation of OTTO TRUCKING, including,

without limitation, business formation documents, business plans, and solicitations of investment

capital.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 13 of 17
ATTACHMENT A 10

REQUEST FOR PRODUCTION NO. 9:

All COMMUNICATIONS with Brian McClendon.

REQUEST FOR PRODUCTION NO. 10:

All COMMUNICATIONS with Travis Kalanick.

REQUEST FOR PRODUCTION NO. 11:

All COMMUNICATIONS with John Bares.

REQUEST FOR PRODUCTION NO. 12:

All COMMUNICATIONS with Cameron Poetzscher.

REQUEST FOR PRODUCTION NO. 13:

All COMMUNICATIONS with Nina Qi.

REQUEST FOR PRODUCTION NO. 14:

All COMMUNICATIONS with STROZ.

REQUEST FOR PRODUCTION NO. 15:

All COMMUNICATIONS with any PERSON REGARDING STROZ.

REQUEST FOR PRODUCTION NO. 16:

All DOCUMENTS and COMMUNICATIONS REGARDING the

MISAPPROPRIATED MATERIALS.

REQUEST FOR PRODUCTION NO. 17:

All COMMUNICATIONS with Lior Ron REGARDING WAYMO, GOOGLE, or

LiDAR.

REQUEST FOR PRODUCTION NO. 18:

All COMMUNICATIONS with Lior Ron before August 18 REGARDING UBER.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 14 of 17
ATTACHMENT A 11

REQUEST FOR PRODUCTION NO. 19:

All COMMUNICATIONS with Colin Sebern REGARDING WAYMO, GOOGLE, or

LiDAR.

REQUEST FOR PRODUCTION NO. 20:

All COMMUNICATIONS with Don Burnette REGARDING WAYMO, GOOGLE, or

LiDAR.

REQUEST FOR PRODUCTION NO. 21:

All COMMUNICATIONS with Soren Juelsgaard REGARDING WAYMO, GOOGLE,

or LiDAR.

REQUEST FOR PRODUCTION NO. 22:

All COMMUNICATIONS with Ognen Stojanovski REGARDING WAYMO, GOOGLE,

or LiDAR.

REQUEST FOR PRODUCTION NO. 23:

All agreements with any DEFENDANT.

REQUEST FOR PRODUCTION NO. 24:

All agreements with SANDSTONE.

REQUEST FOR PRODUCTION NO. 25:

All agreements with APPARATE INTERNATIONAL.

REQUEST FOR PRODUCTION NO. 26:

All agreements with POUCH HOLDINGS.

REQUEST FOR PRODUCTION NO. 27:

All agreements with DOGWOOD LEASING.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 15 of 17
ATTACHMENT A 12

REQUEST FOR PRODUCTION NO. 28:

All agreements with Lior Ron.

REQUEST FOR PRODUCTION NO. 29:

All agreements with John Gardner.

REQUEST FOR PRODUCTION NO. 30:

All agreements with Ognen Stojanovski.

REQUEST FOR PRODUCTION NO. 31:

All DOCUMENTS or COMMUNICATIONS after January 27, 2016 REGARDING

WAYMO’s LiDAR

REQUEST FOR PRODUCTION NO. 32:

All COMMUNICATIONS with any PERSON REGARDING THIS CASE.

REQUEST FOR PRODUCTION NO. 33:

All DOCUMENTS belonging to WAYMO in YOUR possession, custody, or control.

REQUEST FOR PRODUCTION NO. 34:

All DOCUMENTS belonging to GOOGLE in YOUR possession, custody, or control.

REQUEST FOR PRODUCTION NO. 35:

All DOCUMENTS and COMMUNICATIONS referring or relating to DOCUMENTS

belonging to WAYMO in YOUR possession, custody, or control.

REQUEST FOR PRODUCTION NO. 36:

All DOCUMENTS and COMMUNICATIONS referring or relating to DOCUMENTS

belonging to GOOGLE in YOUR possession, custody, or control.

Case 3:17-cv-00939-WHA Document 1086-1 Filed 08/04/17 Page 16 of 17
ATTACHMENT A 13

REQUEST FOR PRODUCTION NO. 37:

All COMMUNICATIONS and DOCUMENTS REGARDING any attempt to conceal,

hide, or destroy the MISAPPROPRIATED MATERIALS.

REQUEST FOR PRODUCTION NO. 38:

All COMMUNICATIONS and DOCUMENTS REGARDING your termination from

UBER.

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