Exhibit 2

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

MILES EHRLICH (Bar No. 237954)

miles@ramsey-ehrlich.com

ISMAIL RAMSEY (Bar No. 189820)

izzy@ramsey-ehrlich.com

AMY CRAIG (Bar No. 269339)

amy@ramsey-ehrlich.com

RAMSEY & EHRLICH LLP

803 Hearst Avenue

Berkeley, CA 94710

(510) 548-3600 (Tel)

(510) 291-3060 (Fax

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

WAYMO LLC,

Plaintiffs,

vs.

UBER TECHNOLOGIES, INC.;

OTTOMOTTO LLC; OTTO TRUCKING 

LLC,

 Defendants.

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

NON-PARTY ANTHONY 

LEVANDOWSKI’S OBJECTIONS AND 

RESPONSES TO WAYMO’S JUNE 23, 

2017 SUBPOENA TO PRODUCE 

DOCUMENTS, INFORMATION, OR 

OBJECTS OR TO PERMIT INSPECTION 

OF PREMISES IN A CIVIL ACTION

Under Rule 45 of the Federal Rules of Civil Procedure, Anthony Levandowski, a nonparty to this lawsuit, hereby provides the following objections and responses to the Subpoena to 

Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil 

Action (the “Subpoena”) directed to Anthony Levandowski served by Plaintiff Waymo LLC

(“Waymo”), dated June 23, 2017.

I. PRELIMINARY STATEMENT AND GENERAL OBJECTIONS

Mr. Levandowski specifically incorporates each of the following general objections into 

his responses to each of Waymo’s document requests and topics for testimony, whether or not 

each such general objection is expressly referred to in Mr. Levandowski’s response to a specific 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 2 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

request or topic. An agreement to produce responsive documents in the responses below means 

only that Mr. Levandowski will produce non-privileged documents within his custody or control 

that he identifies after a reasonable search and diligent inquiry, and is not a representation that 

any such responsive documents exist.

1. Mr. Levandowski objects to the Subpoenas as overbroad and burdensome in that 

they fail to place any temporal limitation on the scope of the documents requested save requests 

Nos. 3 and 31. 

2. Mr. Levandowski objects to any request to the extent that it is vague, overbroad, 

unduly burdensome, or oppressive, or to the extent it purports to impose upon Mr. Levandowski

any duty or obligation that is inconsistent with or in excess of those obligations that are imposed 

by the Federal Rules of Civil Procedure or the Local Rules. The 2015 amendments to the Federal 

Rules of Civil Procedure impose strict new limits on discovery, and now obligate the “court and 

the parties to secure the just, speedy, and inexpensive determination of every action and 

proceeding.” Fed. R. Civ. P. 1. The Federal Rules now limit the scope of discovery to that which 

is “relevant to any party’s claim or defense and proportional to the needs of the case, considering 

the importance of the issues at stake in the action, the amount in controversy, the parties’ relative 

access to relevant information, the parties’ resources, the importance of the discovery in resolving 

the issues, and whether the burden or expense of the proposed discovery outweighs its likely 

benefit. Information within this scope of discovery need not be admissible in evidence to be 

discoverable.” Fed. R. Civ. P. 26(b)(1). Mr. Levandowski will not comply with any attempt to 

impose obligations not required by those Rules. 

3. Mr. Levandowski objects to any request to the extent it seeks information and 

documents protected from discovery under the attorney-client privilege, the work-product 

doctrine, the common-interest and joint-defense doctrine, and any other applicable privilege or 

doctrine. The inadvertent production by Mr. Levandowski of any information protected from 

disclosure by any privilege or doctrine shall not constitute a waiver by Mr. Levandowski of such 

protections. Mr. Levandowski expressly reserves the right to demand the return and/or 

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

destruction of any and all such privilege or protected documents or information inadvertently 

produced by Mr. Levandowski in this action.

4. Mr. Levandowski objects to any instruction or request to the extent that it would 

impose a duty on Mr. Levandowski to undertake a search for, or an evaluation of, information, 

documents, or things for which Waymo is equally able to search for and evaluate, including 

documents that are publicly available, in the possession of parties to this litigation, and/or are 

already in the possession of Waymo.

5. Mr. Levandowski objects to any request to the extent it seeks information and 

documents outside of Mr. Levandowski’s possession, custody, or control. Mr. Levandowski 

further objects to the Subpoenas to the extent they purport to require production of any materials 

that are within the possession, custody, or control of Mr. Levandowski’s former employer—Uber, 

or other Uber personnel. Documents possessed by another entity or person are not within the 

possession, custody, or control of Mr. Levandowski. 

6. Mr. Levandowski objects to any request that seeks confidential and/or proprietary 

information, as well as material impinging on the privacy interests of Mr. Levandowski. Mr. 

Levandowski will produce documents containing such information only subject to the terms of an 

appropriate protective order pursuant to Fed. R. Civ. P. 26(c).

7. Mr. Levandowski objects to any request that seeks material protected from 

disclosure by Mr. Levandowski’s Fifth Amendment privilege. The requests for documents here

are so broad as to constitute a fishing expedition and would require Mr. Levandowski to make 

testimonial acts of production to make a document-by-document response. See, e.g., United States 

v. Hubbell, 530 U.S. 27 (2000). 

8. Mr. Levandowski objects to any request that seeks information that is subject to 

confidentiality or non-disclosure agreements with third parties. This includes, most importantly, 

confidentiality and non-disclosure agreements between Mr. Levandowski and his former 

employer, Uber. Mr. Levandowski will produce such information (1) only to the extent that he is 

permitted to do so under his agreements, (2) only after those third parties receive appropriate 

notice and are provided with a reasonable opportunity to raise objections, and (3) only after the 

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

Court resolves any such third-party objections. Further, Mr. Levandowski will produce such 

information only subject to an appropriate protective order under Fed. R. Civ. P.26(c). 

9. Mr. Levandowski objects to each request and instruction to the extent that the 

information requested is in the possession of and/or is equally available from Plaintiff Waymo,

individually and on behalf of all others similarly situated. It is a matter of well-settled law that a 

party should first obtain discovery from its opponent before burdening a non-party with discovery 

requests. See, e.g., Haworth, Inc. v. Herman Miller, Inc., 998 F.2d 975, 978 (Fed. Cir. 1993) 

(holding that a district court can properly require a party to seek discovery from its party 

opponent before burdening a non-party with a subpoena); Medcorp, Inc. v. Pinpoint 

Technologies, Inc., No. 08-CV-00867, 2009 WL 2194036, at *4 (D. Colo. July 14, 2009) (“With 

respect to discovery issued to non-parties, a party seeking discovery must satisfy a burden of 

proof heavier than the ordinary burden imposed by Rule 26 relating to discovery on any matter 

relevant to the subject matter involved in the pending action . . . When, as here, discovery 

identified in the subpoena duces tecum is sought from non-parties, the status of a person as a nonparty is a factor of which weighs against disclosure. Given the short period of time in which 

third-parties have to respond to such subpoenas, particularly when compared to parties to 

litigation, this level of discovery is not appropriate.”).

10. Mr. Levandowski objects to any request that seeks “any” or “all” documents 

relating to the subject matter of the request as overly broad, unduly burdensome, and oppressive 

when documents sufficient to show the requested information would satisfy any reasonable 

discovery need of Defendant.

11. Mr. Levandowski objects to each request and instruction to the extent that it is 

vague, ambiguous, and unclear. 

12. Mr. Levandowski objects to each request to the extent it requires disclosure from 

which Mr. Levandowski is entitled to seek protection due to annoyance, embarrassment, 

oppression, or undue burden and expense. 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 5 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

13. Mr. Levandowski objects to each request and instruction to the extent they call for 

legal conclusions in order to provide a response and/or produce documents or information. 

14. Mr. Levandowski objects to each paragraph of the section labeled “Definitions” 

and to each and every request to the extent they purport to give meaning or legal significance to a 

document, fact, or purported fact whose meaning or significance is subject to dispute between the 

parties. Mr. Levandowski further objects to Waymo’s “Definitions” to the extent they (1) render 

any request vague, overbroad, or unduly burdensome; (2) seek information that is neither relevant 

to the subject matter of this litigation nor reasonably calculated to lead to the discovery of 

admissible evidence; or (3) impose obligations or demands on Mr. Levandowski beyond those

contemplated by the Federal Rules of Civil Procedure and the applicable Local Rules. Mr. 

Levandowski’s responses to each of Waymo’s requests shall not constitute an admission or 

concession to any of the definitions, terms, phrases, assertions, characterizations, or implications 

contained therein.

15. No agreement by Mr. Levandowski to provide information in response to a request 

shall be construed as a waiver of Mr. Levandowski’s right to object to the use of that information 

during trial or any other proceeding in this or any other action.

16. Mr. Levandowski objects to each paragraph of the section labeled “Instructions” to 

the extent the instructions (1) render any request vague, overbroad, or unduly burdensome; (2) 

seek information that is neither relevant to the subject matter of this litigation nor reasonably 

calculated to lead to the discovery of admissible evidence; or (3) impose obligations and demands 

on Mr. Levandowski beyond those contemplated by the Federal Rules of Civil Procedure and the 

applicable Local Rules. Mr. Levandowski will not comply with any attempt to impose 

obligations not required by those rules.

17. Mr. Levandowski reserves the right to assert additional objections to Waymo’s 

requests, as appropriate. 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 6 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

II. SPECIFIC OBJECTIONS TO DOCUMENT REQUESTS

REQUEST NO. 1:

All DOCUMENTS and COMMUNICATIONS REGARDING ODIN WAVE and/or

TYTO before May 5, 2016.

RESPONSE TO REQUEST NO. 1:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski further objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski objects 

to this request to the extent it seeks information and documents protected from discovery under 

Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the work-product 

doctrine, the common-interest and joint-defense doctrine, and any other applicable privilege or 

doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to the subject matter of this litigation. Mr. 

Levandowski objects to this request to the extent that it seeks confidential and/or proprietary 

information.

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged,

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 2:

All DOCUMENTS and COMMUNICATIONS REGARDING APPARATE

INTERNATIONAL.

RESPONSE TO REQUEST NO. 2:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski further objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski objects 

to this request to the extent it seeks information and documents protected from discovery under 

Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the work-product 

doctrine, the common-interest and joint-defense doctrine, and any other applicable privilege or 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 7 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski objects to this request to the extent that it seeks confidential and/or proprietary 

information.

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 3:

All DOCUMENTS and COMMUNICATIONS REGARDING UBER before August 23,

2016.

RESPONSE TO REQUEST NO. 3:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski further objects to this 

request as vague, overly broad, and unduly burdensome, in that it contains no limitations as to the 

subject matter of this litigation. Mr. Levandowski further objects to this request to the extent that 

it seeks confidential and/or proprietary information.

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, responsive 

documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 4:

All DOCUMENTS and COMMUNICATIONS REGARDING POUCH HOLDINGS.

RESPONSE TO REQUEST NO. 4:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 8 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 9 of 28
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9

NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

REQUEST NO. 5:

All DOCUMENTS and COMMUNICATIONS REGARDING DOGWOOD LEASING.

RESPONSE TO REQUEST NO. 5:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request as vague, overly broad, and unduly burdensome, in that it contains no 

limitations as to time or the subject matter of this litigation. Mr. Levandowski also objects to this 

request to the extent it seeks information and documents protected from discovery under Mr. 

Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the work-product 

doctrine, the common-interest and joint-defense doctrine, and any other applicable privilege or 

doctrine.

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 6:

All DOCUMENTS and COMMUNICATIONS REGARDING SANDSTONE.

RESPONSE TO REQUEST NO. 6:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request as vague, overly broad, and unduly burdensome, in that it contains no 

limitations as to time or the subject matter of this litigation. Mr. Levandowski also objects to this 

request to the extent it seeks information and documents protected from discovery under Mr. 

Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the work-product 

doctrine, the common-interest and joint-defense doctrine, and any other applicable privilege or 

doctrine. 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 10 of 28
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10

NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 7:

All DOCUMENTS REGARDING the formation of OTTOMOTTO, including, without

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

RESPONSE TO REQUEST NO. 7:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski further objects to this request to the extent that it seeks 

confidential and/or proprietary information. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 8:

All DOCUMENTS REGARDING the formation of OTTO TRUCKING, including,

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

capital.

RESPONSE TO REQUEST NO. 8:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 11 of 28
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11

NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski further objects to this request to the extent that it seeks 

confidential and/or proprietary information. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 9:

All COMMUNICATIONS with Brian McClendon.

RESPONSE TO REQUEST NO. 9:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent it seeks information and documents 

protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the attorneyclient privilege, the work-product doctrine, the common-interest and joint-defense doctrine, and 

any other applicable privilege or doctrine. Mr. Levandowski further objects to this request to the 

extent that it seeks confidential and/or proprietary information and/or documents that are 

protected by privacy rights under the United States Constitution or state or federal law, or other 

confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 10:

All COMMUNICATIONS with Travis Kalanick.

RESPONSE TO REQUEST NO. 10:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

response. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent it seeks information and documents 

protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the attorneyclient privilege, the work-product doctrine, the common-interest and joint-defense doctrine, and 

any other applicable privilege or doctrine. Mr. Levandowski further objects to this request to the 

extent that it seeks confidential and/or proprietary information and/or documents that are 

protected by privacy rights under the United States Constitution or state or federal law, or other 

confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 11:

All COMMUNICATIONS with John Bares.

RESPONSE TO REQUEST NO. 11:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent it seeks information and documents 

protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the attorneyclient privilege, the work-product doctrine, the common-interest and joint-defense doctrine, and 

any other applicable privilege or doctrine. Mr. Levandowski further objects to this request to the 

extent that it seeks confidential and/or proprietary information and/or documents that are 

protected by privacy rights under the United States Constitution or state or federal law, or other 

confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 12:

All COMMUNICATIONS with Cameron Poetzscher.

RESPONSE TO REQUEST NO. 12:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent it seeks information and documents 

protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the attorneyclient privilege, the work-product doctrine, the common-interest and joint-defense doctrine, and 

any other applicable privilege or doctrine. Mr. Levandowski further objects to this request to the 

extent that it seeks confidential and/or proprietary information and/or documents that are 

protected by privacy rights under the United States Constitution or state or federal law, or other 

confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 13:

All COMMUNICATIONS with Nina Qi.

RESPONSE TO REQUEST NO. 13:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent it seeks information and documents 

protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the attorneyclient privilege, the work-product doctrine, the common-interest and joint-defense doctrine, and 

any other applicable privilege or doctrine. Mr. Levandowski further objects to this request to the 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 14 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

extent that it seeks confidential and/or proprietary information and/or documents that are 

protected by privacy rights under the United States Constitution or state or federal law, or other 

confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 14:

All COMMUNICATIONS with STROZ.

RESPONSE TO REQUEST NO. 14:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 15:

All COMMUNICATIONS with any PERSON REGARDING STROZ. 

RESPONSE TO REQUEST NO. 15:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workCase 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 15 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

product doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 16:

All DOCUMENTS and COMMUNICATIONS REGARDING the MISAPPROPRIATED 

MATERIALS.

RESPONSE TO REQUEST NO. 16:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 17:

All COMMUNICATIONS with Lior Ron REGARDING WAYMO, GOOGLE, or

LiDAR.

RESPONSE TO REQUEST NO. 17:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 16 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. Mr. Levandowski further objects to this request to the extent that 

it seeks confidential and/or proprietary information and/or documents that are protected by 

privacy rights under the United States Constitution or state or federal law, or other confidentiality 

protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 18:

All COMMUNICATIONS with Lior Ron before August 18 REGARDING UBER.

RESPONSE TO REQUEST NO. 18:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request as it does not include a year to limit the scope 

of the request. Mr. Levandowski further objects to this request as vague, overly broad, and 

unduly burdensome, in that it contains no limitations as to the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent it seeks information and documents 

protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the attorneyclient privilege, the work-product doctrine, the common-interest and joint-defense doctrine, and 

any other applicable privilege or doctrine. Mr. Levandowski further objects to this request to the 

extent that it seeks confidential and/or proprietary information and/or documents that are 

protected by privacy rights under the United States Constitution or state or federal law, or other 

confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 19:

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

All COMMUNICATIONS with Colin Sebern REGARDING WAYMO, GOOGLE, or

LiDAR.

RESPONSE TO REQUEST NO. 19:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. Mr. Levandowski further objects to this request to the extent that 

it seeks confidential and/or proprietary information and/or documents that are protected by 

privacy rights under the United States Constitution or state or federal law, or other confidentiality 

protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 20:

All COMMUNICATIONS with Don Burnette REGARDING WAYMO, GOOGLE, or

LiDAR.

RESPONSE TO REQUEST NO. 20:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. Mr. Levandowski further objects to this request to the extent that 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 18 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

it seeks confidential and/or proprietary information and/or documents that are protected by 

privacy rights under the United States Constitution or state or federal law, or other confidentiality 

protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 21:

All COMMUNICATIONS with Soren Juelsgaard REGARDING WAYMO, GOOGLE,

or LiDAR.

RESPONSE TO REQUEST NO. 21:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. Mr. Levandowski further objects to this request to the extent that 

it seeks confidential and/or proprietary information and/or documents that are protected by 

privacy rights under the United States Constitution or state or federal law, or other confidentiality 

protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 22:

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 19 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

All COMMUNICATIONS with Ognen Stojanovski REGARDING WAYMO, GOOGLE,

or LiDAR.

RESPONSE TO REQUEST NO. 22:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. Mr. Levandowski further objects to this request to the extent that 

it seeks confidential and/or proprietary information and/or documents that are protected by 

privacy rights under the United States Constitution or state or federal law, or other confidentiality 

protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 23:

All agreements with any DEFENDANT.

RESPONSE TO REQUEST NO. 23:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski further objects to this 

request to the extent that it seeks confidential and/or proprietary information and/or documents 

that are protected by privacy rights under the United States Constitution or state or federal law, or 

other confidentiality protections. 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 20 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 24:

All agreements with SANDSTONE.

RESPONSE TO REQUEST NO. 24:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent that it seeks confidential and/or

proprietary information and/or documents that are protected by privacy rights under the United 

States Constitution or state or federal law, or other confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 25:

All agreements with APPARATE INTERNATIONAL.

RESPONSE TO REQUEST NO. 25:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 21 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent that it seeks confidential and/or

proprietary information and/or documents that are protected by privacy rights under the United 

States Constitution or state or federal law, or other confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 26:

All agreements with POUCH HOLDINGS.

RESPONSE TO REQUEST NO. 26:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent that it seeks confidential and/or

proprietary information and/or documents that are protected by privacy rights under the United 

States Constitution or state or federal law, or other confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 22 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

REQUEST NO. 27:

All agreements with DOGWOOD LEASING.

RESPONSE TO REQUEST NO. 27:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent that it seeks confidential and/or

proprietary information and/or documents that are protected by privacy rights under the United 

States Constitution or state or federal law, or other confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 28:

All agreements with Lior Ron.

RESPONSE TO REQUEST NO. 28:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

privilege or doctrine. Mr. Levandowski objects to this request as vague, overly broad, and unduly 

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

burdensome, in that it contains no limitations as to time or the subject matter of this litigation. 

Mr. Levandowski further objects to this request to the extent that it seeks confidential and/or

proprietary information and/or documents that are protected by privacy rights under the United 

States Constitution or state or federal law, or other confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 29:

All agreements with John Gardner.

RESPONSE TO REQUEST NO. 29:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Gardner is Mr. 

Levandowski’s personal attorney. Mr. Levandowski objects to this request to the extent it seeks 

information and documents protected from discovery under Mr. Levandowski’s attorney-client 

privilege, the work-product doctrine, the common-interest and joint-defense doctrine, and any 

other applicable privilege or doctrine.

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 30:

All agreements with Ognen Stojanovski.

RESPONSE TO REQUEST NO. 30:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Stojanovski is an 

attorney. Mr. Levandowski objects to this request to the extent it seeks information and 

Case 3:17-cv-00939-WHA Document 1086-2 Filed 08/04/17 Page 24 of 28
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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this request 

as vague, overly broad, and unduly burdensome, in that it contains no limitations as to time or the 

subject matter of this litigation. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

REQUEST NO. 31:

All DOCUMENTS or COMMUNICATIONS after January 27, 2016 REGARDING

WAYMO’s LiDAR.

RESPONSE TO REQUEST NO. 31:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski further objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine.

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

REQUEST NO. 32:

All COMMUNICATIONS with any PERSON REGARDING THIS CASE.

RESPONSE TO REQUEST NO. 32:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under the attorney-client privilege, the work-product doctrine, the common-interest and jointdefense doctrine, and any other applicable privilege or doctrine. Mr. Levandowski objects to this 

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

request as vague, overly broad, and unduly burdensome, in that it contains no limitations as to 

time or the individual(s) with whom the communications were made. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment.

REQUEST NO. 33:

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

RESPONSE TO REQUEST NO. 33:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege.

REQUEST NO. 34:

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

RESPONSE TO REQUEST NO. 34:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege. 

REQUEST NO. 35:

All DOCUMENTS and COMMUNICATIONS referring or relating to DOCUMENTS

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

RESPONSE TO REQUEST NO. 35:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine; 

 REQUEST NO. 36:

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

All DOCUMENTS and COMMUNICATIONS referring or relating to DOCUMENTS

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

RESPONSE TO REQUEST NO. 36:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine; 

REQUEST NO. 37:

All COMMUNICATIONS and DOCUMENTS REGARDING any attempt to conceal,

hide, or destroy the MISAPPROPRIATED MATERIALS.

RESPONSE TO REQUEST NO. 37:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request to the extent it seeks information and 

documents protected from discovery under Mr. Levandowski’s Fifth Amendment privilege, the 

attorney-client privilege, the work-product doctrine, the common-interest and joint-defense 

doctrine, and any other applicable privilege or doctrine; 

REQUEST NO. 38:

All COMMUNICATIONS and DOCUMENTS REGARDING your termination from

UBER.

RESPONSE TO REQUEST NO. 38:

Mr. Levandowski incorporates his General Objections above as though set forth in this 

response. Mr. Levandowski objects to this request because it is not calculated to lead to 

discoverable material, and constitutes an improper fishing expedition. Mr. Levandowski further 

objects to this request to the extent it seeks information and documents protected from discovery 

under Mr. Levandowski’s Fifth Amendment privilege, the attorney-client privilege, the workproduct doctrine, the common-interest and joint-defense doctrine, and any other applicable 

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NON-PARTY ANTHONY LEVANDOWSKI’S OBJECTIONS AND RESPONSES TO WAYMO’S JUNE 23, 2017 

SUBPOENA TO PRODUCE DOCUMENTS, Case No. 3:17-cv-00939-WHA

CONFIDENTIAL, ATTORNEY’S EYES ONLY under PROTECTIVE ORDER (DKT. NO. XXX)

privilege or doctrine. Mr. Levandowski further objects to this request to the extent that it seeks 

confidential and/or proprietary information and/or documents that are protected by privacy rights 

under the United States Constitution or state or federal law, or other confidentiality protections. 

Subject to and without waiving his objections, Mr. Levandowski responds as follows:

After a reasonable, diligent search, Mr. Levandowski will produce non-privileged, 

responsive documents, the act of production of which is not protected by the Fifth Amendment. 

Dated: July 7, 2017 Respectfully Submitted,

/s/ Miles Ehrlich

Miles Ehrlich

Ismail Ramsey

Amy Craig

Ramsey & Ehrlich LLP

803 Hearst Ave.

Berkeley, CA 94710

Tel: (510) 548-3600

Counsel to Anthony Levandowski

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