EXHIBIT B

Case 3:17-cv-00939-WHA Document 217-2 Filed 04/11/17 Page 1 of 4
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Case No.3:17-cv-00939-WHA 

DECLARATION OF PAUL FRENCH

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 PAUL T. FRENCH

IN SUPPORT OF WAYMO’S RESPONSE 

TO DEFENDANTS’ LETTER BRIEF

Case 3:17-cv-00939-WHA Document 217-2 Filed 04/11/17 Page 2 of 4
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-2- Case No. 3:17-cv-00939-WHA 

DECLARATION OF PAUL FRENCH

I, Paul T. French, hereby declare as follows.

1. I am a Data Forensics Expert at Discovia. I have consulted in private sector 

electronic forensic matters since 1999 following a thirteen year career in the U. S. Air Force. I 

have vast experience with e-discovery practice, and have spearheaded large-scale electronic 

discovery engagements for law firms, Fortune 1000 corporations, and government entities across 

the globe. I have managed high visibility e-discovery engagements and authored custom software 

for a wide array of intricate discovery issues. I have experience planning and executing largescale, complex electronic collections and investigations in the fields of intellectual property, SEC 

violations, document recovery/validation, and employee/employer misconduct. I have authored 

over 75 custom software utilities to convert, search, analyze and present data from a variety of 

platforms.

2. In sum, defendants have provided scant detail into their claimed inability to meet 

the Court’s deadlines. They have described the amount of data, devices, and custodians 

potentially at issue, and have stated that searching the material has been time-consuming, but have 

provided little to no insight into the techniques they are using to search and prioritize the data.

3. Defendants claim to be unable to collect, process and review 106.5 terabytes of 

data by Friday’s deadline. Defendants have provided insufficient information to back up this 

claim. For instance, they do not specify whether they have taken steps to prioritize their review of 

that data. Large datasets need to be organized into smaller groups using various filtering criteria 

so that the information most likely to have value is examined first. Date ranges, file types, file 

locations, the number of relevant custodians tied to a set of files, the subject material of the data –

all can be used to facilitate a rolling examination of materials that begins with items most likely to 

be relevant.

4. Similarly, defendants have provided insufficient information to back up their claim 

to be unable to search the data of the 45 remaining custodians by Friday’s deadline. It seems 

unlikely that defendants can definitively claim the number of resulting documents to be “in the 

millions” before the work is actually done. On many occasions I have had a small group of 

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