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

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 

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 248 Filed 04/21/17 Page 1 of 6
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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 611 is a true and correct copy of Defendants’ “Privilege 

Log Associated with March 31, 2017 Production of Documents,” served on April 10, 2017. 

3. Attached hereto as Exhibit 62 is a true and correct copy of Defendants’ 

“Supplemental Privilege Log Associated with March 31, 2017 Production of Documents,” served 

on April 13, 2017. 

4. Attached hereto as Exhibit 63 is a true and correct copy of Defendants’ “Second 

Supplemental Privilege Log Associated with March 31, 2017 Production of Documents,” served 

on April 13, 2017. 

5. Attached hereto as Exhibit 64 is a true and correct copy of excerpts of the 

deposition transcript of Gaetan Pennecot, dated April 20, 2017. 

6. Attached hereto as Exhibit 65 is a true and correct copy of excerpts of the 

deposition transcript of Asheem Linaval, dated April 13, 2017. 

7. Attached hereto as Exhibit 66 is a true and correct copy of the deposition transcript 

of Anthony Levandowski, dated April 14, 2017. 

8. Attached hereto as Exhibit 67 is a true and correct copy of excerpts of the 

deposition transcript of Scott Boehmke, dated April 17, 2017 

9. Attached hereto as Exhibit 68 is a true and correct copy of excerpts of the 

deposition transcript of James Haslim, dated April 18, 2017. 

10. Attached hereto as Exhibit 69 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00011465. 

 

1

 For clarity, this Declaration begins with Exhibit 61 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.) 

Case 3:17-cv-00939-WHA Document 248 Filed 04/21/17 Page 2 of 6
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-3- Case No. 3:17-cv-00939-WHA 

DECLARATION OF JORDAN R. JAFFE

11. Attached hereto as Exhibit 70 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008536. 

12. Attached hereto as Exhibit 71 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008538. 

13. Attached hereto as Exhibit 72 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008543. 

14. Attached hereto as Exhibit 73 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008544. 

15. Attached hereto as Exhibit 74 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008505. 

16. Attached hereto as Exhibit 75 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008562. 

17. Attached hereto as Exhibit 76 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008495. 

18. Attached hereto as Exhibit 77 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008493. 

19. Attached hereto as Exhibit 78 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008592. 

20. Attached hereto as Exhibit 79 is a true and correct copy of an article titled “The 

Uber exec accused of downloading crucial tech files before quitting Google has a simple 

explanation,” dated March 16, 2017, downloaded from http://www.businessinsider.com/anthonylevandowski-says-he-did-not-steal-waymo-self-driving-technology-2017-3. 

21. Attached hereto as Exhibit 80 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00006444. 

22. Attached hereto as Exhibit 81 is a true and correct copy of Defendants’ Objections 

and Responses to Plaintiff Waymo LLC’s Notice of Deposition of James Haslim and Requests for 

Production of Documents and Things, dated April 18, 2017. 

Case 3:17-cv-00939-WHA Document 248 Filed 04/21/17 Page 3 of 6
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-4- Case No. 3:17-cv-00939-WHA 

DECLARATION OF JORDAN R. JAFFE

23. Attached hereto as Exhibit 82 is a true and correct copy of excerpts of the 

deposition transcript of Daniel Gruver, dated April 20, 2017. 

24. Attached hereto as Exhibit 83 is a true and correct copy of excerpts of the 

deposition transcript of Paul McManamon, dated April 19, 2017. 

25. Attached hereto as Exhibit 84 is a true and correct copy of excerpts of the 

deposition transcript of Dr. Michael Lebby, dated April 17, 2017. 

26. Attached hereto as Exhibit 85 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00011677. 

27. Attached hereto as Exhibit 86 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00006556. 

28. Attached hereto as Exhibit 87 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00011631. 

29. Attached hereto as Exhibit 88 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00011654. 

30. Attached hereto as Exhibit 89 is a true and correct copy of excerpts of the transcript 

from the parties’ April 12, 2017 hearing before this Court. 

31. Attached hereto as Exhibit 90 is a true and correct copy of excerpts of the 

deposition transcript of Pierre-Yves Droz, dated March 31, 2017. 

32. Attached hereto as Exhibit 91 is a true and correct copy of excerpts of the 

deposition transcript of Sameer Kshirsagar, dated April 14, 2017. 

33. Attached hereto as Exhibit 92 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00005076. 

34. Attached hereto as Exhibit 93 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00006245. 

35. Attached hereto as Exhibit 94 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00006246. 

36. Attached hereto as Exhibit 95 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00006248. 

Case 3:17-cv-00939-WHA Document 248 Filed 04/21/17 Page 4 of 6
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-5- Case No. 3:17-cv-00939-WHA 

DECLARATION OF JORDAN R. JAFFE

37. Attached hereto as Exhibit 96 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00006251. 

38. Attached hereto as Exhibit 97 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008494. 

39. Attached hereto as Exhibit 98 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008553. 

40. Attached hereto as Exhibit 99 is a true and correct copy of a document produced by 

Defendants in this action bearing Bates Number UBER00008557. 

41. Attached hereto as Exhibit 100 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00011242. 

42. Attached hereto as Exhibit 101 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00011676. 

43. Attached hereto as Exhibit 102 is a true and correct copy of a letter received from 

Amy Craig, counsel for Anthony Levandowski, on April 19, 2017. 

44. Attached hereto as Exhibit 103 is a true and correct copy of an excerpt of 

correspondence with Miles Ehrlich, counsel for Anthony Levandowski, on April 13-14, 2017. 

45. Attached hereto as Exhibit 104 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00011613. 

46. Attached hereto as Exhibit 105 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00011263. 

47. Attached hereto as Exhibit 106 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00011612. 

48. Attached hereto as Exhibit 107 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00011678. 

49. Attached hereto as Exhibit 108 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00011858. 

50. Attached hereto as Exhibit 109 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00006451. 

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-6- Case No. 3:17-cv-00939-WHA 

DECLARATION OF JORDAN R. JAFFE

/s/ Charles K. Verhoeven

51. Attached hereto as Exhibit 110 is a true and correct copy of a document produced 

by Defendants in this action bearing Bates Number UBER00006261. 

52. Attached hereto as Exhibit 111 true and correct copy of an article titled “The Uber 

exec accused of downloading crucial tech files before quitting Google has a simple explanation,” 

dated March 16, 2017, downloaded from https://www.recode.net/2017/3/14/14923056/ubergoogle-waymo-self-driving-anthony-levandowski-travis-kalanick. 

53. Attached hereto as Exhibit 112 true and correct copy of Defendants’ Objections and 

Responses to Plaintiff’s Notice of Deposition of Asheem Linaval and Requests for Production of 

Documents and Things, dated April 13, 2017. 

54. Attached hereto as Exhibit 113 true and correct copy of an email received from 

John Cooper, received April 20, 2017. 

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

foregoing is true and correct. 

DATED: April 21, 2017 /s Jordan R. Jaffe

Jordan R. Jaffe 

SIGNATURE ATTESTATION 

 Pursuant to Local Rule 5-1(i)(3), I attest under penalty of perjury that concurrence in the 

filing of this document has been obtained from Jordan Jaffe. 

 

 Charles K. Verhoeven 

Case 3:17-cv-00939-WHA Document 248 Filed 04/21/17 Page 6 of 6