DECLARATION OF A. GONZÁLEZ ISO UBER’S ADMINISTRATIVE MOTION TO SHORTEN TIME

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

sf- 3752346

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MICHAEL A. JACOBS (CA SBN 111664)

MJacobs@mofo.com

ARTURO J. GONZÁLEZ (CA SBN 121490) 

AGonzalez@mofo.com

ERIC A. TATE (CA SBN 178719) 

ETate@mofo.com

MORRISON & FOERSTER LLP

425 Market Street 

San Francisco, California 94105-2482 

Telephone: 415.268.7000 

Facsimile: 415.268.7522 

KAREN L. DUNN (Pro Hac Vice app. pending) 

kdunn@bsfllp.com

HAMISH P.M. HUME (Pro Hac Vice app. pending) 

hhume@bsfllp.com

BOIES SCHILLER FLEXNER LLP 

1401 New York Avenue, N.W. 

Washington DC 20005 

Telephone: 202.237.2727 

Facsimile: 202.237.6131 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC, and OTTO TRUCKING LLC

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

v. 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC; OTTO TRUCKING LLC, 

Defendants. 

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

DECLARATION OF ARTURO J. 

GONZÁLEZ IN SUPPORT OF UBER 

TECHNOLOGIES, INC., 

OTTOMOTTO LLC, AND OTTO 

TRUCKING LLC’S 

ADMINISTRATIVE MOTION TO 

SHORTEN TIME FOR HEARING ON 

UBER’S MOTION TO COMPEL 

ARBITRATION 

Complaint Filed: February 23, 2017 

First Am. Compl. Filed: March 10, 2017 

Trial Date: October 2, 2017

Case 3:17-cv-00939-WHA Document 95-1 Filed 03/27/17 Page 1 of 3
DECLARATION OF A. GONZÁLEZ ISO UBER’S ADMINISTRATIVE MOTION TO SHORTEN TIME

Case No. 3:17-cv-00939-WHA 1

sf- 3752346

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I, Arturo J. González, declare as follows: 

1. I am a partner with the law firm of Morrison & Foerster LLP. I am a member in 

good standing of the Bar of the State of California. I make this declaration based on personal 

knowledge and, if called as a witness, I could and would testify competently to the matters set 

forth herein. I make this declaration in support of Uber’s Administrative Motion to Shorten Time 

for Hearing on Uber’s Motion to Compel Arbitration. 

2. Uber moves to shorten time on the hearing for its Motion to Compel Arbitration so 

that the hearing may take place prior to the hearing on Waymo LLC (“Waymo”)’s Motion for 

Preliminary Injunction. At the Case Management Conference in this case, this Court asked us to 

raise the arbitration issue so that it is considered before that hearing, set for May 4. (Attached 

hereto as Exhibit A is a true and correct excerpt of the transcript of that conference.) 

3. On March 27, 2017, I spoke with counsel for Waymo, and explained why we 

needed to have this matter heard on shortened time. I reminded him that the Court asked us to 

raise this issue before too much time is spent by the Court on the pending motion for preliminary 

injunction, and noted that the Court is dark on April 20. Counsel for Waymo responded later in 

the day advising me in writing that Plaintiff opposes this request and asked that I attach his 

written response to this motion. (Attached hereto as Exhibit B is a true and correct copy of our 

email exchange on this topic.) 

4. The underlying Motion to Compel Arbitration seeks an order that Waymo arbitrate 

their trade secret misappropriation and UCL claims against Uber, and that those claims be stayed 

pending the outcome of the arbitration. 

5. The deadline for Uber to oppose Waymo’s Motion for Preliminary Injunction has 

been continued from March 24 to April 7. (Tentative Order at 2, ECF No. 54). The deadline for 

Waymo to file its Reply has been continued from March 31 to April 21. (Id.) The hearing on the 

Motion for Preliminary Injunction has been continued from April 27 to May 4. (Id.) 

Case 3:17-cv-00939-WHA Document 95-1 Filed 03/27/17 Page 2 of 3
DECLARATION OF A. GONZÁLEZ ISO UBER’S ADMINISTRATIVE MOTION TO SHORTEN TIME

Case No. 3:17-cv-00939-WHA 2

sf- 3752346

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6. The requested relief would have no effect on any other deadlines in the case. 

I declare under the penalty of perjury under the laws of the United States that the 

foregoing is true and correct. Executed this 27th day of March, 2017, in San Francisco, 

California. 

 /s/ Arturo J. González 

 ARTURO J. GONZÁLEZ 

Case 3:17-cv-00939-WHA Document 95-1 Filed 03/27/17 Page 3 of 3