Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-00148-GIVIS Document 34 Filed 04/25/2005 Page 1 of 2
UNITED STATES DISTRICT CO`UR.'I`
DISTRICT OF DELAWARE U I
EQACOM CORP., on behel1;`ot` ell affiliated X Case N0. 04—CV—579
debtors, S
Tleintiff, {
vs. l
TECH DATA CORPORATION, ·
U Defendant.
TECH DATA CORPORATION,
‘ I Thixd-Petty ?lsintif;l§
vs.
COMPAQ COMP U”I`E`R CORP., ITY
CORP., end CUSTOM EDGE, INC.,
'1`hird-Party Defendants. ‘
DECLARATION OF GAH. S. G-REENVVOOD IN SUP?ORT OF HEWLETT-
PACKARD COMPANWS OPPOSITION TO TECH DATNS MOTION FOR LEAVE
I ‘ TO FILE AMENDED THIRD PARTY C()lV{PLA.INT
. 1, Gail S. Greenwood, declare:
1. I am an attorney with the tlrm ofF1·iedn1en Dumas & Springwater LLP
-("FD&S"), attorneys for Defendant I~Iewlett—Psckexd Company ("HP?’). I am licensed to
pmcti ce in courts ofthe State of California end have been admitted pro imc vice to practice
in this Court. I have fxsthand knowledge of the facts stated herein and if celled as s witness
could end would competently testify as foliows.
2. Attached hereto es Exhibit A is e. true and correct copy ofthe Scheduling ` 1
Order entered by this Court on October 4, 2004. l
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Case 1 :04-cv—00148-GIVIS Document 34 Filed 04/25/2005 Page 2 of 2
3. Attached hereto as Exhibit B is a true and correct copy ofthe Amended
Scheduling Order entered by this Court on February i 1, 2005.
4. On Ianuary 24, 2005, HP served responses to 'I`hird¥P2uty Plaintiff Tech Cate
Co1poration("Tech Data")’s First Set of interrogatories. Interrogstory responses numbers 20
and 23 identity the Accounts Payable Aging Report dated February ii, 2000 ("AP Aging
Roper?) that was simuitaneously produced, reflecting all accounts payable that were
assumed by Compaq pursuant to the Asset Purchase Agreement between Compaq and
Inacorn Corporation. HP produced an electronic version ofthe AP Aging Report, which is
over 2000 pages. Attached hereto as Exhibit C and Exhibit D are true and correct copies of
_ excerpts from 5P*s Interrogatoty Responses and the AP Aging Report, respectively.
5. Attached hereto as Exhibit E are true and correct copies of excerpts from the-
Deposition of Michael Zava taken on January 26, 2005. Tech Data’s Proof of Claim dated
Jane 27, 2000 is identified as Exhibit 1 to the deposition.
6. Attached hereto as Exhibit F are true and correct copies of excerpts from the
Deposition of Mike Ward taken on March 4, 2004. Tech Data’s ARNotes are identified as
Exhibit l to the deposition.
7. Attached hereto as Exhibit G is a one and correct copy of an emaii dated
March 7, 2000 from Mike Ward to Michael Zava, Bates Number 3187. The document was
produced by Tech Data to HP.
I declare under penalty ofperj ery under the laws of the State of California and the
United States that the foregoing is true and correct, and that this declaration was executed at
San Francisco, Caiifornia, on April 22, 2005.
_ April 22, 2005 if
Gail S. Greenwood
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Case 1:04-cv-00148-GMS

Document 34

Filed 04/25/2005

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Case 1:04-cv-00148-GMS

Document 34

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