CORRECTED DECLARATION OF W. RAY ISO UBER’S ADMINISTRATIVE MOTION RE: KSHIRSAGAR

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

sf-3751227 

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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 

RUDY Y. KIM (CA SBN 199426) 

RudyKim@mofo.com 

MORRISON & FOERSTER LLP

755 Page Mill Road 

Palo Alto, California 94304-1018 

Telephone: 650.813.5600 

Facsimile: 650.494.0792 

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

CORRECTED DECLARATION OF 

WENDY J. RAY IN SUPPORT OF 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC, AND OTTO 

TRUCKING LLC’S 

ADMINISTRATIVE MOTION TO 

ALLOW SAMEER KSHIRSAGAR 

ACCESS TO CERTAIN MATERIAL 

Complaint Filed: February 23, 2017 

First Am. Compl. Filed: March 10, 2017 

Trial Date: October 2, 2017

Case 3:17-cv-00939-WHA Document 69 Filed 03/23/17 Page 1 of 3
CORRECTED DECLARATION OF W. RAY ISO UBER’S ADMINISTRATIVE MOTION RE: KSHIRSAGAR

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

sf-3751227 

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I, Wendy J. Ray, 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 Technologies, Inc., Ottomotto LLC, and 

Otto Trucking LLC’s (collectively “Uber”) Administrative Motion to Allow Sameer Kshirsagar 

Access to Certain Material. 

2. Attached hereto as Exhibit 1 is a true and correct copy of an email chain between 

Arturo González and counsel for Waymo LLC (“Waymo”) at Quinn Emanuel dated March 20, 

2017, at 11:26 a.m. requesting that counsel for Waymo agree to allow counsel for Uber to show 

Mr. Kshirsagar the five files Waymo alleges he downloaded. 

3. On March 20, 2017, at 2:00 p.m., I met and conferred telephonically with counsel 

for Waymo. I requested that counsel for Waymo agree to allow counsel for Uber to show 

Mr. Kshirsagar the file names of the files at issue. Counsel for Waymo agreed in writing to this 

request on March 21, 2017, at 8:11 p.m., but did not agree that counsel for Uber could show 

Mr. Kshirsagar the files themselves. 

4. Attached hereto as Exhibit 2 is a true and correct copy of an email chain between 

Arturo González and counsel for Waymo. On March 21, 2017, at 10:24 p.m., Arturo González 

again asked counsel for Waymo if they would agree to allow counsel for Uber to show Mr. 

Kshirsagar the five files, not just file names, that Waymo alleges he downloaded. On March 22, 

2017, at 2:55 p.m., Arturo González requested that counsel for Waymo agree to allow counsel for 

Uber to show Mr. Kshirsagar the transition memorandum he prepared when he departed from 

Waymo. Waymo has not responded. 

5. Attached hereto as Exhibit 3 is a true and correct copy of Exhibit A to Patent Local 

Rule 2-2 Interim Model Protective Order that currently applies in this case, executed by Sameer 

Kshirsagar. 

Case 3:17-cv-00939-WHA Document 69 Filed 03/23/17 Page 2 of 3
CORRECTED DECLARATION OF W. RAY ISO UBER’S ADMINISTRATIVE MOTION RE: KSHIRSAGAR

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

sf-3751227 

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

foregoing is true and correct. Executed this 23rd day of March, 2017, in Los Angeles, California 

 /s/ Wendy J. Ray 

 Wendy J. Ray 

ATTESTATION 

I, Arturo J. González, am the ECF User whose ID and Password are being used to file this 

document. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that Wendy J. Ray concurs in 

this filing. 

Dated: March 23, 2017 MORRISON & FOERSTER LLP

By: /s/ Arturo J. González

ARTURO J. GONZÁLEZ 

Case 3:17-cv-00939-WHA Document 69 Filed 03/23/17 Page 3 of 3