EXHIBIT 1 

Case 3:17-cv-00939-WHA Document 397-6 Filed 05/08/17 Page 1 of 3
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From: David Perlson 

Sent: Monday, May 08, 2017 4:00 PM 

To: 'Gonzalez, Arturo J.' <AGonzalez@mofo.com>; John Cooper <JCooper@fbm.com> 

Subject: RE: Potential resolution involving Special Master 

John, we appreciate your efforts to reach agreement on discovery issues. Unfortunately, we cannot agree to your 

proposal. We think the request for the acquisition documents fits squarely within our document requests and what the 

Court has already asked for. On the other hand, Defendants’ most recent ask regarding the first dates that QE was 

contacted is entirely without merit based on what we have already said, including there no document request to which 

it relates, it seeks irrelevant information, and goes beyond what the Court already ordered. 

David 

From: Gonzalez, Arturo J. [mailto:AGonzalez@mofo.com] 

Sent: Monday, May 08, 2017 2:45 PM 

To: John Cooper <JCooper@fbm.com>; David Perlson <davidperlson@quinnemanuel.com> 

Subject: Potential resolution involving Special Master 

John,

I know this is probably obvious, but we need the first date that Quinn spoke to Google about Uber. We don’t 

want a repeat where they give us the information about Waymo instead, since that entity was not formed until 

this past December. We want the first communication. 

Arturo J. González

Chair, Commercial Litigation and Trial Practice Group

Morrison & Foerster LLP

425 Market St. | San Francisco, CA 94105

P: 415.268.7020 | F: 415.276.7020 | C: 415.425.9548

AGonzalez@mofo.com | www.mofo.com

From: John Cooper [mailto:JCooper@fbm.com] 

Sent: Monday, May 08, 2017 2:39 PM 

To: 'David Perlson'; Gonzalez, Arturo J. 

Subject: [EXT] Potential resolution involving Special Master

 

David and Arturo 

 

Case 3:17-cv-00939-WHA Document 397-6 Filed 05/08/17 Page 2 of 3
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A discussion was held with the Special Master today at 2:00 pm. The Special Master raised the possibility of a 

compromise whereby the parties will make a mutual exchange of information as follows: 

 

Uber shall provide to Waymo the acquisition agreement whereby Uber acquired Otto Motto and Otto Trucking, 

which acquisition agreement shall include the exhibits, appendices and any document incorporated into that 

agreement. 

 

Waymo will provide Uber the date or dates on which Google and or Waymo first communicated with Quinn Emanuel 

about a potential violation of the law or potential legal action against Anthony Levandowski. Waymo and or Google will 

provide the same information as to their first communication with Quinn Emanuel about a potential violation of the law 

or potential legal action against Uber. This may require identification of more than one date. 

 

Please consult with your clients and let me and the other party know as soon as you can if this exchange is agreeable. It 

would be ideal if this exchange of this information could occur prior to 4:00 this afternoon. 

 

John 

 

John L Cooper

Partner

jcooper@fbm.com

415.954.4410

 

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Case 3:17-cv-00939-WHA Document 397-6 Filed 05/08/17 Page 3 of 3