Free Declaration - District Court of Arizona - Arizona

1 Lawrence G. Scarborough (No 6965)
George C. Chen (N0. 19704)
2 BRYAN CAVE, LLP
Two North Central Avenue, Suite 2200
3 Phoenix, AZ 85004-4406
Telephone: (602) 364-7000
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Michael D. Rounds (admitted pro hac vice)
5 WATSON ROUNDS
5371 Kietzke Lane
6 Reno, NV 89511
Telephone: (775) 324-4100
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Henry C. Bunsow (admitted pro hac vice)
8 Michelle A. Madriaga (admitted pro hac vice)
HOWREY LLP
9 525 Market Street, Suite 3600
San Francisco, Califomia 94105
10 Telephone: (415) 848-4900
Facsimile: (415) 848-4999
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Attorneys for Defendant/Counterplaintiff
12 RENO A & E
UNITED STATES DISTRICT COURT
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DISTRICT OF ARIZONA
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15 EBERLE DESIGN, INC., and Case Nos. CIV 02 2575 PHX DGC (Lead)
ELECTRONIC DEVICES, INC., CIV 03 883 PHX DGC
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Plaintiffs/Counterdefendants, ) (Consolidated)
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vs. DECLARATION OF GEORGE C. CHEN IN
18 SUPPORT OF RENO A & E'S OPPOSITION
RENO A & E, TO EBERLE’S MOTION FOR NEW TRIAL
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Defendant/Counterplaintiff. §
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Case 2:02-cv-02575-DGC Document 251 Filed 12/05/2005 Page 1 of 4

1 I, George C. Chen, declare as follows:
2 l. I am an attomey associated with the law firm of Bryan Cave LLP, counsel of record for
3 Reno A & E. I have personal knowledge of the facts set forth in this Declaration and, if called as a
4 witness, could and would testify competently to such facts under oath.
5 2. Attached hereto as Exhibit A is a true and correct copy of excerpts from the Reporter’s
6 Transcript of Proceedings, Day 2 Trial Transcript, dated August 3l, 2005.
7 3. Attached hereto as Exhibit B is a true and correct copy of excerpts from the Reporter’s
8 Transcript of Proceedings, Day 3 Trial Transcript, dated September 1, 2005.
9 4. Attached hereto as Exhibit C is a true and correct copy of excerpts from the Reporter’s
10 Transcript of Proceedings, Day 4 Trial Transcript, dated September 2, 2005.
11 5. Attached hereto as Exhibit D is a true and correct copy of excerpts from the Reporter’s
12 Transcript of Proceedings, Day 5 Trial Transcript, dated September 6, 2005.
13 6. Attached hereto as Exhibit E is a true and correct copy of excerpts from the Reporter’s
14 Transcript of Proceedings, Day 6 Trial Transcript, dated September 8, 2005.
15 7. Attached hereto as Exhibit F is a true and correct copy of Jury Instruction No. 28 from
16 the September 12, 2005 Final Jury Instructions.
17 8. Attached hereto as Exhibit 34 is a true and correct copy of a letter dated May 20, 1996
18 from Tom Potter to Alain Lamoureux and Gisele Lecourtois.
19 9. Attached hereto as Exhibit 35 is a true and correct copy of a letter dated April 22, 1996
20 from Tom Potter to Alain Lamoureux and Gisele Lecourtois.
21 10. Attached hereto as Exhibit 38 is a true and correct copy of a letter dated February 21,
22 1996 from Tom Potter to Alain Lamoureux.
23 11. Attached hereto as Exhibit 39 is a true and correct copy of a letter dated February 21,
24 1996 from Alain Lamoureux to Tom Potter.
ig 12. Attached hereto as Exhibit 40 is a true and correct copy of a letter dated February 20,
27 1996, from Alain Lamoureux/Gisele Lecourtois to Tom Potter.
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Case 2:02-cv-02575-DGC Document 251 Filed 12/05/2005 Page 2 of 4

1 13. Attached hereto as Exhibit 62 is a true and correct copy of a letter dated June 22, 1996
2 from Tom Potter to Alain Lamoureux and Gisele Lecourtois.
3 14. Attached hereto as Exhibit 109 is a true and correct copy of an invoice dated October
4 17, 1996 from Reno A & E to Electromega.
5 15. Attached hereto as Exhibit 225 is a true and correct copy of the Declaration and Power
6 of Attorney executed by Thomas Potter and Robert Allen.
7 16. Attached hereto as Exhibit 226 is a true and correct copy of the Declaration executed by
8 Thomas Seabury.
9 17. Attached hereto as Exhibit 258 is a true and correct copy of the August 12, 1996 letter
10 from Alain Lamoureux and Gisele Lecourtois to Tom Potter.
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Case 2:02-cv-02575-DGC Document 251 Filed 12/05/2005 Page 3 of 4

I
2 Executed thislifllday of December, 2005, at Phoenix, Arizona.
3 I declare under penalty of perjury under the laws ofthe United States of America that the
4 foregoing is true and correct.
5 i /\,\ \_______________________
6 George C. Chen
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