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

SUPPLEMENTAL DECLARATION OF JORDAN R. JAFFE

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

 Charles K. Verhoeven (Bar No. 170151) 

 charlesverhoeven@quinnemanuel.com 

 David A. Perlson (Bar No. 209502) 

 davidperlson@quinnemanuel.com 

 Melissa Baily (Bar No. 237649) 

 melissabaily@quinnemanuel.com 

 John Neukom (Bar No. 275887) 

 johnneukom@quinnemanuel.com 

 Jordan Jaffe (Bar No. 254886) 

 jordanjaffe@quinnemanuel.com 

50 California Street, 22nd Floor 

San Francisco, California 94111-4788 

Telephone: (415) 875-6600 

Facsimile: (415) 875-6700 

Attorneys for WAYMO LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

vs. 

UBER TECHNOLOGIES, INC.; 

OTTOMOTTO LLC; OTTO TRUCKING 

LLC, 

Defendants. 

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

SUPPLEMENTAL DECLARATION OF 

JORDAN R. JAFFE 

Hearing: 

Date: May 3, 2017 

Time: 8:00 a.m. 

Place: 8, 19th Floor 

Judge: The Honorable William H. Alsup 

 

Case 3:17-cv-00939-WHA Document 373 Filed 05/08/17 Page 1 of 4
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-2- Case No. 3:17-cv-00939-WHA 

DECLARATION OF JORDAN R. JAFFE

I, Jordan R. Jaffe, hereby declare as follows. 

1. I am a member of the bar of the State of California and a partner with Quinn 

Emanuel Urquhart & Sullivan, LLP, counsel for Plaintiff Waymo LLC (“Waymo”). I make this 

declaration of personal, firsthand knowledge, and if called and sworn as a witness, I could and 

would testify competently as follows. 

2. Attached hereto as Exhibit 1141 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00012755. 

3. Attached hereto as Exhibit 115 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00012750. 

4. Attached hereto as Exhibit 116 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016410. 

5. Attached hereto as Exhibit 117 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016400. 

6. Attached hereto as Exhibit 118 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016401. 

7. Attached hereto as Exhibit 119 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016402. 

8. Attached hereto as Exhibit 120 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016403. 

9. Attached hereto as Exhibit 121 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016404. 

10. Attached hereto as Exhibit 122 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016405. 

 

1

 For clarity, this Declaration begins with Exhibit 114 because Waymo submitted Exhibits 1-

60 with the Declaration of Jordan R. Jaffe that it submitted in support of its opening brief on 

March 10, 2017 (Dkt. 25-6) and Exhibits 61-113 with the Declaration of Jordan R. Jaffe that it 

submitted in support of its reply brief on April 21, 2017 (Dkt. 248). 

Case 3:17-cv-00939-WHA Document 373 Filed 05/08/17 Page 2 of 4
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-3- Case No. 3:17-cv-00939-WHA 

DECLARATION OF JORDAN R. JAFFE

11. Attached hereto as Exhibit 123 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016406. 

12. Attached hereto as Exhibit 124 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016407. 

13. Attached hereto as Exhibit 125 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00016408. 

14. Attached hereto as Exhibit 126 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00012740. 

15. Attached hereto as Exhibit 127 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00012741. 

16. Attached hereto as Exhibit 128 is a true and correct copy of a letter from counsel 

for Defendants to counsel for Waymo, dated April 25, 2017. 

17. Attached hereto as Exhibit 129 is a true and correct copy of an article titled “Uber's 

self-driving car boss, Anthony Levandowski, is stepping aside amid legal fight with Waymo,” 

dated April 27, 2017, downloaded from http://www.businessinsider.com/anthony-levandowski-nolonger-leads-uber-self-driving-cars-2017-4. 

18. Attached hereto as Exhibit 130 is a true and correct copy of excerpts of the 

deposition transcript of William Grossman, dated March 24, 2017. 

19. Attached hereto as Exhibit 131 is a true and correct copy of Defendants’ Objections 

and Responses to Plaintiff Waymo LLC’s Notice of Deposition of Kevin Faulkner and Requests 

for Production of Documents and Things, dated April 17, 2017. 

 

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-4- Case No. 3:17-cv-00939-WHA 

DECLARATION OF JORDAN R. JAFFE

I declare under penalty of perjury under the laws of the State of California that the 

foregoing is true and correct. 

DATED: May 8, 2017 /s/ Jordan R. Jaffe 

Jordan R. Jaffe 

Case 3:17-cv-00939-WHA Document 373 Filed 05/08/17 Page 4 of 4