IN THE UNITED STATES DISTRICT COURT
FOR TI-IE DISTRICT OF DELAWARE
PAPST LICENSING GMBH & CO. KG, )
)
Plaintiff] )
)
v. ) C.A. No. 07-415~***
)
OLWPUS CORPORATION; OLYMPUS )
IMAGING AMERICA, INC., )
I )
Defendants. )
DECLARATION OF JOSEPHINE N. CACACE IN SUPPORT OF DEFENDANTS’
MOTION TO TRANSFER THIS ACTION TO THE DISTRICT OF COLUMBIA
Case 1:07-cv-00415-***-MPT Document 13 Filed 08/O1/2007 Page 2 of 3
I, Josephine N. Cacace declare and state as follows:
1. I am the Tax Director for Olympus America inc. ("Olympus America"). In that
position, i have responsibility for overseeing tax matters relating to Olympus U.S.A. Inc.
("Olympus U.S.A.") and its subsidiaries, the parent company of Olympus imaging America Inc.
("Olympus l1nagingâ€), one of the defendants in this action. The foilowing is of my personal
knowledge, and if called as a witness, I could and would competently testify thereto.
2. Olympus Corporation is a Japanese company with its principal place of business
in Tokyo, Japan. lt does not have any offices in Delaware or in the United States. Further, it
does not have any agent for service of process in the United States.
3. Olympus Imaging is a subsidiary of Olympus U.S.A, which is a subsidiary of
Olympus Corporation.
4. Olympus Imaging is a Delaware corporation. Olympus Imaging maintains no
offices or other facilities in the State of Delaware.
I declare under the penalty of perjury under the laws of the United States of America that
the foregoing is true and correct.
Executed this lst day of August, 2007, in Pennsylvania, United States.
/s/ Josephine N Ccxcctce
Josephine N. Cacace
2
Case 1:07-cv-00415-***-MPT Document 13 Filed 08/O1/2007 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR TI-IE DISTRICT OF DELAWARE
· CERTIFICATE OF SERVICE
1, Kenneth L. Dorsney, hereby certify that on August 1, 2007, the attached document was
electronically tiled with the Clerk ofthe Court using CM/ECF which will send notification to the
registered attorney(s) of record that the document has been tiled and is available for viewing and
downloading.
I hereby certify that on August 1, 2007, I have Electronically Mailed the document to the
following pers0n(s):
Steven J. Balick Jerold B. Schnayer
Qfohn G. Day John L. Ambrogi
Lauren E. Maguire Welsh & Katz, Ltd.
Ashby & Geddes 120 South Riverside Plaza, 22nd Floor
500 Delaware Avenue, 8** Floor Chicago, Illinois 60606
P.O. Box 1 150 ;'bschnayer@welsl1l
s‘oalick@ashby—geddeacom
jday@,ashby-geddes.com
lmagg,1ire@ashby-geddescom
/.s*/ Kenneth L. Dorsney
Richard L. Horwitz
Kenneth L. Dorsney
Potter Anderson & Corroorr LLP
Hercules Plaza — Sixth Floor
1313 North Market Street
Wilmington, DE 19899-0951
(302) 984-6000
[email protected]
dmoore@,pottera11derson.com
810412 .·' 32031 _