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SCHMIDT DECLARATION IN SUPPORT OF WAYMO’S MOTION FOR ORDER TO SHOW CAUSE

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

DECLARATION OF PATRICK 

SCHMIDT IN SUPPORT OF PLAINTIFF 

WAYMO LLC’S NOTICE OF MOTION 

AND MOTION FOR ORDER TO SHOW 

CAUSE WHY DEFENDANTS SHOULD 

NOT BE HELD IN CONTEMPT OF THE 

PRELIMINARY INJUNCTION ORDER 

(Dkt. 426) AND EXPEDITED 

DISCOVERY ORDER (Dkt. 61)

Date: July 27, 2017

Time: 8:00 a.m.

Ctrm: 8, 19th Floor

Judge: Honorable William H. Alsup

Trial Date: October 10, 2017 

Case 3:17-cv-00939-WHA Document 677-1 Filed 06/21/17 Page 1 of 3
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SCHMIDT DECLARATION IN SUPPORT OF WAYMO’S MOTION FOR ORDER TO SHOW CAUSE

I, Patrick Schmidt, hereby declare as follows.

1. I am a member of the bar of the State of California and an associate 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 1 is a true and correct copy of an excerpt from 

Defendants’ Responses to Waymo’s First Set of Expedited Interrogatories Pursuant to Paragraph 

Six of the May 11, 2017 Preliminary Injunction Order (Nos. 1-9).

3. Attached hereto as Exhibit 2 is a true and correct copy of email correspondence 

between my office and counsel for Defendants spanning May 31, 2017 to June 1, 2017.

4. Attached hereto as Exhibit 3 is a true and correct copy of email correspondence 

between my office and counsel for Defendants spanning June 7, 2017 to June 14, 2017.

5. Attached hereto as Exhibit 4 is a true and correct copy of two letters sent by 

Defendants and forwarded to my office on June 12, 2017.

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

transcript of the June 19, 2017 deposition of Lior Ron in this matter (cover page incorrectly reads 

“April 19”). 

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

transcript of the June 19, 2017 deposition of Cameron Poetzscher in this matter. 

8. Attached hereto as Exhibit 7 is a true and correct copy of email correspondence 

between my office and counsel for Defendants spanning May 31, 2017 to June 12, 2017.

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SCHMIDT DECLARATION IN SUPPORT OF WAYMO’S MOTION FOR ORDER TO SHOW CAUSE

/s/ Charles K. Verhoeven

I declare under penalty of perjury under the laws of the State of California and the United 

States of America that the foregoing is true and correct, and that this declaration was executed in 

Los Angeles, California, on June 21, 2017. 

DATED: June 21, 2017 /s/ Patrick Schmidt

Patrick Schmidt

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 Patrick Schmidt. 

 

 Charles K. Verhoeven

Case 3:17-cv-00939-WHA Document 677-1 Filed 06/21/17 Page 3 of 3