On May 12, 2023 a
Party Statement
was filed
involving a dispute between
Trace3, Llc,
and
Devin Tomcik,
Geoffrey Peterson,
John Barnes,
Lilian Elias,
Sycomp A Technology Company, Inc.,
Timothy Cordell,
for Business Tort/Unfair Bus Prac Unlimited (07)
in the District Court of Santa Clara County.
Preview
RAJIV DHARNIDHARKA (Cal. Bar No. 234756)
rajiv.dharnidharka@dlapiper.com
JEANETTE BARZELAY (Cal. Bar No. 261780)
jeanette.barzelay@us.dlapiper.com
MICAH A. CHAVIN (Cal. Bar No. 313634)
micah.chavin@dlapiper.com
DLA PIPER LLP (US)
2000 University Avenue
East Palo Alto, CA 94303-2214
Tel: 650.833.2000
Fax: 650.833.2001
Attorneys for Defendant,
Sycomp A Technology Company, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
TRACE3, LLC a California limited liability CASE NO. 23CV415833
company,
DECLARATION OF NEAL CALLAHAN
Plaintiff, Date: July 28, 2023
Time: 9:00 a.m.
Dept: 1
SYCOMP A TECHNOLOGY COMPANY, Action Filed: May 12, 2023
INC., a California corporation; TIMOTHY
CORDELL, an individual; LILIAN ELIAS, an
individual; GEOFF PETERSON, an individual;
DEVIN TOMCIK, an individual; and DOES 1-
10, inclusive;
Defendants.
DLA P I PER LLP (US)
ALO L TO
-1- CASE NO. 23CV415833
DECLARATION OF NEAL CALLAHAN
ACTIVE\1601167056.1
I, Neal Callahan, declare as follows:
I am the Chief Operating Officer of Sycomp A Technology Company, Inc.
(“Sycomp”) and I have held this position for several years. I have personal knowledge of the facts
set forth in this Declaration, and if called as a witness, could and would testify competently to such
facts under oath.
On April 17, 2023, I received the following message via LinkedIn from Trace3,
LLC’s Chief Executive Officer, Rich Fennessy, which has a timestamp of 3:48 p.m.:
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed this 14th day of July 2023, at San Jose, California.
NEAL CALLAHAN
DLA P I PER LLP (US)
ALO L TO
-2- CASE NO. 23CV415833
DECLARATION OF NEAL CALLAHAN
ACTIVE\1601167056.1
Document Filed Date
July 17, 2023
Case Filing Date
May 12, 2023
Category
Business Tort/Unfair Bus Prac Unlimited (07)
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