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Case No. 3:17-cv-00939-WHA DECLARATION OF ADRIAN J. SAWYER

ADRIAN J. SAWYER (203712)

sawyer@kerrwagstaffe.com

KERR & WAGSTAFFE LLP

101 Mission Street, 18th Floor

San Francisco, CA 94105–1727

Telephone: (415) 371-8500

Fax: (415) 371-0500

Attorneys for Non-Parties

SANDSTONE GROUP, LLC,

TYTO LIDAR, LLC, and 

OGNEN STOJANOVSKI

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 ADRIAN J. SAWYER 

IN SUPPORT OF WAYMO LLC’S 

ADMINISTRATIVE MOTION TO FILE 

UNDER SEAL ITS CORRECTED 

SUPPLEMENTAL BRIEF IN SUPPORT 

OF ITS MOTION FOR ORDER TO SHOW 

CAUSE WHY DEFENDANTS SHOULD 

NOT BE HELD IN CONTEMPT OF THE 

PRELIMINARY INJUNCTION ORDER 

AND EXPEDITED DISCOVERY ORDER 

Case 3:17-cv-00939-WHA Document 1573 Filed 09/14/17 Page 1 of 3
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Case No. 3:17-cv-00939-WHA DECLARATION OF ADRIAN J. SAWYER

I, Adrian J. Sawyer, hereby declare as follows: 

1. I am an attorney licensed to practice before all courts of the State of California. I 

am a partner in the law firm of Kerr & Wagstaffe LLP, attorneys for non-parties Sandstone 

Group, LLC, Tyto LiDAR, LLC, and Ognen Stojanovski. I have personal knowledge of the 

matters stated herein and if called upon would testify competently thereto. 

2. I make this declaration in support of Waymo’s Administrative Motion to File 

Under Seal Its Supplemental Brief in Support of Its Motion for Order to Show Cause Why 

Defendants Should Not be Held in Contempt of the Preliminary Injunction Order and Expedited 

Discovery Order (Dkt. 1501). I have reviewed the Administrative Motion to File Under Seal 

(the “Administrative Motion”), together with Waymo’s Corrected Supplemental Brief in Support 

of Its Motion for Order to Show Cause Why Defendants Should Not be Held in Contempt of the 

Preliminary Injunction Order and Expedited Discovery Order (the “Supplemental Brief”) (Dkt. 

1501-3), and those exhibits to the Supplemental Brief sought to be filed under seal.

3. Tyto LiDAR and Sandstone Group are non-parties and are existing limited 

liability companies. All information designated by Tyto LiDAR or Sandstone Group and 

included in the Supplemental Brief was designated confidential; none was designated highly 

confidential/AEO by Tyto LiDAR or Sandstone Group.

4. Exhibit 4 to the Supplemental Brief consists of portions of the deposition of 

Anthony Levandowski, taken in this action. The yellow1 highlighted portions of Exhibit 4 reflect 

confidential information regarding the ownership and structure of non-party Sandstone Group, 

financing of Sandstone Group, the ownership of Tyto LiDAR, and the financing of Tyto LiDAR. 

Because Sandstone Group and Tyto LiDAR are non-parties and existing private companies, they 

request that their confidentiality interests in this ownership and financing information be 

respected in this proceeding.

5. Exhibit 7 to the Supplemental Brief consists of two separate documents 

combined. The first document, labeled SANDSTONE 000001-000002, Sandstone Group’s 

Articles of Organization, has been publicly filed with the Secretary of State. Sandstone does not 

 1 Waymo erroneously refers to “orange” highlighting in the Administrative Motion. 

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Case No. 3:17-cv-00939-WHA DECLARATION OF ADRIAN J. SAWYER

contend that it is confidential, and will remove the confidentiality designation in the footer. The 

second document, SANDSTONE 000003-000007, is the Operating Agreement of Sandstone 

Group, LLC. It has not been filed with the Secretary of State and remains confidential. The 

Operating Agreement contains confidential information regarding Sandstone Group’s ownership, 

operations, and finances. Sandstone Group is a non-party and existing private company and as 

such is entitled to confidentiality in its ownership, operations, and finances.

6. Exhibits 10 and 11 to the Supplemental Brief reflect confidential operational 

information of Tyto LiDAR, namely equipment purchases.

7. Exhibit 12 to the Supplemental Brief reflects confidential proprietary and 

operational information of Tyto LiDAR, namely information related to product development, 

product and prototype design, equipment purchases, and software purchases.

8. Waymo’s request to seal is narrowly tailored to those exhibits to Waymo’s 

Supplemental Brief that merit sealing.

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

foregoing is true and correct. Executed this 14th day of September, 2017 at San Francisco, 

California. 

 /s/ Adrian J. Sawyer 

ADRIAN J. SAWYER

Case 3:17-cv-00939-WHA Document 1573 Filed 09/14/17 Page 3 of 3