Preview
19CV346663
Santa Clara — Civil
B. Roman-Antunez
Vincent Galvin (#104448)
Joel Smith (Pro Hac Vice)
Lauren O. Miller (#279448) Electronically Filed
BOWMAN AND BROOKE LLP. by Superior Court of CA,
1741 Technology Drive, Suite 200 County of Santa Clara,
San Jose, California 95110-1364 on 4/20/2023 1:20 PM
Telephone: (408) 279-5393 Reviewed By: B. Roman-Antunez
Facsimile: (408) 279-5845 Case #19CV346663
vincent.galvin@bowmanandbrooke.com Envelope: 11764336
joel.smith@bowmanandbrooke.com
lauren.miller@bowmanandbrooke.com
Thomas Branigan #P41774 (Pro Hac Vice)
BOWMAN AND BROOKE LLP.
41000 Woodward Avenue, Suite 200 East
Bloomfield Hills, MI 48303
Telephone: (248) 205.3300
Facsimile: (248) 205.3399
10 thomas.branigan@bowmanandbrooke.com
11 Attorneys for Defendant
Tesla, Inc.
12
13 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 COUNTY OF SANTA CLARA
15 SZ HUA HUANG, Individually and as successor Case No. 19CV346663
in interest to WEI LUN HUANG, deceased;
16 TRINITY HUANG, a minor; TRISTAN HUANG, Assigned for all purposes to Hon. Evette
a minor; HSI KENG HUANG; and CHING FEN Pennypacker; Dept. 6
17 HUANG,
DECLARATION OF LAUREN O. MILLER IN
18 Plaintiff, SUPPORT OF TESLA, INC.’S OPPOSITION TO
MOTION TO COMPEL THE DEPOSITION OF
19 vs. DEFENDANT TESLA’S PERSON MOST
QUALIFIED
20 TESLA, INC. dba TESLA MOTORS INC. THE
STATE OF CALIFORNIA, and DOES 1 through DATE: April 27, 2023
21 100, TIME: 9:00 a.m.
DEPT.: 6
22 Defendants.
23
24 I, Lauren O. Miller, declare:
1
25 | am an attorney at law duly licensed to practice before the Courts in the State of
26 California and am an attorney with the law firm of Bowman and Brooke LLP, attorneys for defendant
27 Tesla, Inc. (“Tesla”) in this matter.
28
278752541 1
DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO
COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED
2. | have personal knowledge of each of the matters stated herein and if called upon to
testify to any of these matters, | can do so in a truthful and competent manner.
3. On December 24, 2019, Tesla served its responses to plaintiffs’ Form Interrogatories,
Special Interrogatories Nos. 1-45, and Request for Production of Documents, Nos. 1-175. Thereafter,
Tesla supplemented its responses to Request for Production three times and produced additional
documents. In Tesla’s responses to these initial sets of discovery, Plaintiffs received information about
driver monitoring (for example: SPROG 8, 35, RFP 27, 102-103, 170, 174-175), vehicle data (for
example: SPROG 11-14, RFP 1-7, 19-22), software update 2018.10.4 (for example: SPROG 17, RFP
24, 122), the design and testing process for Autopilot (for example: SPROG 23, RFP 52-74, 147-162),
10 lane labeling and lateral control (for example: SPROG 26-29, 32, RFP 78), obstacle labeling and
11 longitudinal control (for example: RFP 30, 76, 106), NTSB investigation (for example: RFP 8, 46-50),
12 other incidents (for example: RFP 33-41), machine learning and neural networks (for example: RFP
13 107-108, 123-131, 134.)
14 4 On August 18, 2020, Tesla responded to Request for Production Nos. 175-192 and
15 Plaintiff obtained information about customer complaints regarding faded lane markings, neural network
16 training, and further information on driver monitoring. On December 9, 2020, Tesla responded to
17 Request for Production Nos. 193-196 regarding certain Tesla software. On March 12, 2021, Tesla
18 responded to Request for Production Nos. 197-210 and Plaintiffs obtained information about video clips
19 and images of Tesla vehicles near the crash scene and certain clips and images related to gores. On
20 July 6, 2022, Tesla responded to Request for Admission Nos. 1-15, Request for Genuineness No 1,
21 Form Interrogatories, and Request for Production Set 5, No. 211-213 related to statements that
22 Plaintiffs attribute to Elon Musk. On September 30, 2022, Tesla responded to Request for Admission
23 Nos. 16-53, Request for Genuineness, Form Interrogatories, Special Interrogatories, Set 3, Nos. 46-48,
24 and Request for Production, Set 6, No. 214 about further statements that Plaintiffs attributed to Elon
25 Musk. Tesla also served supplemental responses to this set of discovery on March 31, 2023.
26 5 On March 31, 2023, Tesla responded to Request for Admission Nos. 54-70, Request for
27 Genuineness, Form Interrogatories, Special Interrogatories, Set 4, No 49-72, Special Interrogatories,
28 Set 5, Nos. 72-105, Request for Production, Set 7, Nos. 215-229, as well as Supplemental Request for
278752541 2
DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO
COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED
Production and Supplemental Interrogatory. These sets of discovery related to Elon Musk statements
as well as information about radar only braking, driver monitoring, and Autopilot safety. Notably,
Plaintiffs’ Request for Production, Set 7, Nos. 216-229 are similar to the Request for Production
attached to Plaintiffs PMQ deposition notice.
6 In addition to the above sets of discovery, on October 28, 2020, the parties entered into
a stipulation regarding hyperlink production and ES|/email searches as a means to avoid further
discovery disputes, notwithstanding Tesla’s representation it had made reasonable searches for
documents responsive to plaintiffs’ discovery requests. The parties agreed that Plaintiffs could make
informal requests for hyperlinks appearing within certain produced documents and Tesla would attempt
10 to produce them within 15 days of receipt of the request. Pursuant to the stipulation regarding
11 hyperlinks, over the past two years, Tesla has responded to 12 sets of hyperlink requests. This
12 amounts to an additional 275 documents Plaintiffs hand-picked and directed Tesla to produce pursuant
13 to this agreement, whether relevant to this vehicle, Autopilot hardware or crash or not. Plaintiffs
14 obtained items like Confluence pages, video clips, JIRA tickets, annotated images, validation tickets,
15 comparisons between software versions related to a variety of topics including Autopilot design,
16 development, testing, validation, driver monitoring, performance near gores, and Automatic Emergency
17 Braking.
18 7 In the same stipulation the parties agreed to an ESI/email protocol for collection of 19
19 custodians’ emails wherein Tesla proposed the initial terms, but Plaintiffs were then permitted to edit
20 and add terms. Tesla then accepted those terms as edited by Plaintiffs and performed a review and
21 production of the 19 custodians’ emails. These custodians included current and former Autopilot
22 directors, i.e., the decision-makers relative to Autopilot development and deployment.
23 8 On November 5, 2019, Tesla produced non-confidential case specific materials before
24 even responding to the first set of discovery. Following entry of the Stipulated Protected Order, which
25 involved lengthy meet and confer and negotiations, Tesla has produced Autopilot design, development,
26 and testing documents, employee emails, software tickets, video clips, machine learning images; the
27 most recent document produced by Tesla bears a Bates Number of 183,681 with an additional 28,000
28 pages of case specific documents produced.
278752541 3
DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO
COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED
9. With respect to depositions, Plaintiffs deposed two service center technicians, one
corporate representative (PMQ), and eleven employee depositions in their individual capacity who work
or worked on Autopilot, including four directors of Autopilot. Tesla witness Mohammad Azam Javed
was produced in response to a PMQ deposition notice regarding consumer complaints and testified for
6 hours and 48 minutes. Next, Plaintiffs began the procession of noticing and taking individual Tesla
employees to testify about Autopilot: Dhaval Shroff, Chris Payne, Kate Park, Pete Schuetzow, Nicklas
Gustafsson (not completed), Andrej Karpathy, Milan Kovac, Ashok Elluswamy, and former employees
Sameer Qureshi, Andreas Koehler, Florian Rohde, and C.J. Moore and each of their depositions have
been between four and six hours long. It is important to note that many of these witnesses - already
10 deposed by Plaintiffs - are the most knowledgeable people in the world on issues related to Autopilot.
11 Indeed, people like Andrej Karpathy, Milan Kovac, Ashok Elluswamy, and former employees Sameer
12 Qureshi and C.J. Moore invented Autopilot. Thus, Plaintiffs have already deposed people are “most
13 qualified” to answer questions about Autopilot.
14 10. A true and correct copy of excerpts from the deposition of C.J. Moore are attached as
15 Exhibit A.
16 11. A true and correct copy of excerpts from the deposition of Kate Park are attached as
17 Exhibit B.
18 12. A true and correct copy of excerpts from the deposition of Chris Payne are attached as
19 Exhibit C.
20 13. A true and correct copy of excerpts from the deposition of Sameer Qureshi are attached
21 as Exhibit D.
22 14. A true and correct copy of excerpts from the deposition of Florian Rhode are attached as
23 Exhibit E.
24 15. A true and correct copy of excerpts from the deposition of Pete Scheutzow are attached
25 as Exhibit F.
26 16. A true and correct copy of excerpts from the deposition of Ashok Elluswamy are
27 attached as Exhibit G.
28
278752541 4
DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO
COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED
17. A true and correct copy of excerpts from the deposition of Andrej Karpathy are attached
as Exhibit H.
18. A true and correct copy of excerpts from the deposition of Andreas Koehler are attached
as Exhibit |.
19. A true and correct copy of excerpts from the deposition of Person Most Qualified at
Tesla, Inc. taken on January 27, 2021 (Azam Javed) are attached as Exhibit O.
20. In May 2022, Tesla indicated its concern with Plaintiffs’ tactic of constantly noticing
individual depositions of Tesla employees and its concern that Plaintiffs would harass Tesla with a
PMQ deposition notice that would require the individuals be produced again because they would be
10 identified as persons “most knowledgeable” on various topics. A true and correct copy of
11 correspondence is attached as Exhibit J.
12 21. Plaintiffs’ Motion fails to accurately describe the procedural background preceding the
13 parties’ impasse. Plaintiffs’ original Notice unilaterally set the deposition for February 14, 2023. A true
14 and correct copy of the Notice is attached as Exhibit K. On February 7, 2023, prior to Tesla’s deadline
15 for objecting to Plaintiffs’ Notice, counsel for Tesla communicated with counsel for Plaintiffs about the
16 unilateral notice and the parties’ agreed that Tesla would provide objections/meet and confer on the
17 PMQ Notice by February 24, 2023. A true and correct copy of correspondence is attached as Exhibit L.
18 Tesla provided a meet and confer and objections on February 24, 2023. A true and correct copy of the
19 correspondence is attached as Exhibit M.
20 22. The parties had a telephonic meet and confer discussing the topics on March 8, 2023,
21 including discussion of narrowing certain topics given testimony that had already occurred. Ultimately,
22 after considering Plaintiffs’ positions, Tesla agreed to produce a witness in response to two categories.
23 That PMQ deposition is set to occur by agreement on April 26, 2023. A true and correct copy of the
24 Amended Notice is attached as Exhibit N. Beyond those topics, Tesla objected to producing a witness
25 on the grounds that the topics had been covered at length in discovery and during the depositions of
26 the persons who would have been “most knowledgeable” on the topics which already occurred.
27 HII
28 HII
278752541 5
DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO
COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED
| declare under penalty of perjury that the foregoing is true and correct. Executed on April 20,
2023, at San Jose, California.
pt /
/
Tauren 0. Miller
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278752541 6
DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO
COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
CERTIFIED
TRANSCRIPT
SZ HUA HUANG, Individually and as [
successor in interest to WEI LUN
HUANG, deceased; TRINITY HUANG, a
minor; TRISTAN HUANG, a minor; HSI
KENG HUANG; and CHING FEN HUANG, CASE NO. 19CV346663
Plaintiffs,
-vs-
TESLA INC. dba TESLA MOTORS, INC.,
THE STATE OF CALIFORNIA, and DOES
1 through 100,
Defendants.
VIDEOTAPED
DEPOSITION OF CHRISTOPHER COLEMAN MOORE
Taken before KAREN A. CRANGLE
Certified Shorthand Reporter
State of California
C.S.R. License No. 3816
February 22, 2023
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STATE OF CALIFORNIA
ss
COUNTY OF ALAMEDA
I, Karon Ae erangie,, hereby certify that the
witness in the foregoing deposition named
CHRISTOPHER COLEMAN MOORE
Was Dye Me duly Sworn to testity FO rhe euch, the whole
10 truth, and nothing but the truth in the within-entitled
11 cause; that said deposition was taken at the time and
12 place herein named; that the testimony of said witness was
13 reported by me, a certified shorthand reporter anda
14 disinterested person, and thereafter transcribed into
15 typewriting.
16
17 And I further certify that I am not of counsel or
18 attorney for either or any of the parties to said
19 deposition, nor in any way interested in the outcome of
20 the cause named in said caption.
21
22 Date: Massehi 2 2023
23
24 Kum.
Karen A. Crangle,
Chan WS.R.
25
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CRANGLE
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
CERTIFIED
TRANSCRIPT
SZ HUA HUANG, Individually and as
successor in interest to WEI LUN
HUANG, deceased; TRINITY HUANG, a
minor; TRISTAN HUANG, a minor; HSI
KENG HUANG; and CHING FEN HUANG, CASE NO. 19CV346663
Plaintiffs,
-vs-
TESLA INC. dba TESLA MOTORS, INC.,
THE STATE OF CALIFORNIA, and DOES
1 through 100,
Defendants.
VIDEOTAPED
DEPOSITION OF KATE JIHAM PARK
Taken before KAREN A. CRANGLE
Certified Shorthand Reporter
State of California
C.S.R. License No. 3816
September 15, 2021
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Preview
19CV346663 Santa Clara — Civil B. Roman-Antunez Vincent Galvin (#104448) Joel Smith (Pro Hac Vice) Lauren O. Miller (#279448) Electronically Filed BOWMAN AND BROOKE LLP. by Superior Court of CA, 1741 Technology Drive, Suite 200 County of Santa Clara, San Jose, California 95110-1364 on 4/20/2023 1:20 PM Telephone: (408) 279-5393 Reviewed By: B. Roman-Antunez Facsimile: (408) 279-5845 Case #19CV346663 vincent.galvin@bowmanandbrooke.com Envelope: 11764336 joel.smith@bowmanandbrooke.com lauren.miller@bowmanandbrooke.com Thomas Branigan #P41774 (Pro Hac Vice) BOWMAN AND BROOKE LLP. 41000 Woodward Avenue, Suite 200 East Bloomfield Hills, MI 48303 Telephone: (248) 205.3300 Facsimile: (248) 205.3399 10 thomas.branigan@bowmanandbrooke.com 11 Attorneys for Defendant Tesla, Inc. 12 13 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF SANTA CLARA 15 SZ HUA HUANG, Individually and as successor Case No. 19CV346663 in interest to WEI LUN HUANG, deceased; 16 TRINITY HUANG, a minor; TRISTAN HUANG, Assigned for all purposes to Hon. Evette a minor; HSI KENG HUANG; and CHING FEN Pennypacker; Dept. 6 17 HUANG, DECLARATION OF LAUREN O. MILLER IN 18 Plaintiff, SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO COMPEL THE DEPOSITION OF 19 vs. DEFENDANT TESLA’S PERSON MOST QUALIFIED 20 TESLA, INC. dba TESLA MOTORS INC. THE STATE OF CALIFORNIA, and DOES 1 through DATE: April 27, 2023 21 100, TIME: 9:00 a.m. DEPT.: 6 22 Defendants. 23 24 I, Lauren O. Miller, declare: 1 25 | am an attorney at law duly licensed to practice before the Courts in the State of 26 California and am an attorney with the law firm of Bowman and Brooke LLP, attorneys for defendant 27 Tesla, Inc. (“Tesla”) in this matter. 28 278752541 1 DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED 2. | have personal knowledge of each of the matters stated herein and if called upon to testify to any of these matters, | can do so in a truthful and competent manner. 3. On December 24, 2019, Tesla served its responses to plaintiffs’ Form Interrogatories, Special Interrogatories Nos. 1-45, and Request for Production of Documents, Nos. 1-175. Thereafter, Tesla supplemented its responses to Request for Production three times and produced additional documents. In Tesla’s responses to these initial sets of discovery, Plaintiffs received information about driver monitoring (for example: SPROG 8, 35, RFP 27, 102-103, 170, 174-175), vehicle data (for example: SPROG 11-14, RFP 1-7, 19-22), software update 2018.10.4 (for example: SPROG 17, RFP 24, 122), the design and testing process for Autopilot (for example: SPROG 23, RFP 52-74, 147-162), 10 lane labeling and lateral control (for example: SPROG 26-29, 32, RFP 78), obstacle labeling and 11 longitudinal control (for example: RFP 30, 76, 106), NTSB investigation (for example: RFP 8, 46-50), 12 other incidents (for example: RFP 33-41), machine learning and neural networks (for example: RFP 13 107-108, 123-131, 134.) 14 4 On August 18, 2020, Tesla responded to Request for Production Nos. 175-192 and 15 Plaintiff obtained information about customer complaints regarding faded lane markings, neural network 16 training, and further information on driver monitoring. On December 9, 2020, Tesla responded to 17 Request for Production Nos. 193-196 regarding certain Tesla software. On March 12, 2021, Tesla 18 responded to Request for Production Nos. 197-210 and Plaintiffs obtained information about video clips 19 and images of Tesla vehicles near the crash scene and certain clips and images related to gores. On 20 July 6, 2022, Tesla responded to Request for Admission Nos. 1-15, Request for Genuineness No 1, 21 Form Interrogatories, and Request for Production Set 5, No. 211-213 related to statements that 22 Plaintiffs attribute to Elon Musk. On September 30, 2022, Tesla responded to Request for Admission 23 Nos. 16-53, Request for Genuineness, Form Interrogatories, Special Interrogatories, Set 3, Nos. 46-48, 24 and Request for Production, Set 6, No. 214 about further statements that Plaintiffs attributed to Elon 25 Musk. Tesla also served supplemental responses to this set of discovery on March 31, 2023. 26 5 On March 31, 2023, Tesla responded to Request for Admission Nos. 54-70, Request for 27 Genuineness, Form Interrogatories, Special Interrogatories, Set 4, No 49-72, Special Interrogatories, 28 Set 5, Nos. 72-105, Request for Production, Set 7, Nos. 215-229, as well as Supplemental Request for 278752541 2 DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED Production and Supplemental Interrogatory. These sets of discovery related to Elon Musk statements as well as information about radar only braking, driver monitoring, and Autopilot safety. Notably, Plaintiffs’ Request for Production, Set 7, Nos. 216-229 are similar to the Request for Production attached to Plaintiffs PMQ deposition notice. 6 In addition to the above sets of discovery, on October 28, 2020, the parties entered into a stipulation regarding hyperlink production and ES|/email searches as a means to avoid further discovery disputes, notwithstanding Tesla’s representation it had made reasonable searches for documents responsive to plaintiffs’ discovery requests. The parties agreed that Plaintiffs could make informal requests for hyperlinks appearing within certain produced documents and Tesla would attempt 10 to produce them within 15 days of receipt of the request. Pursuant to the stipulation regarding 11 hyperlinks, over the past two years, Tesla has responded to 12 sets of hyperlink requests. This 12 amounts to an additional 275 documents Plaintiffs hand-picked and directed Tesla to produce pursuant 13 to this agreement, whether relevant to this vehicle, Autopilot hardware or crash or not. Plaintiffs 14 obtained items like Confluence pages, video clips, JIRA tickets, annotated images, validation tickets, 15 comparisons between software versions related to a variety of topics including Autopilot design, 16 development, testing, validation, driver monitoring, performance near gores, and Automatic Emergency 17 Braking. 18 7 In the same stipulation the parties agreed to an ESI/email protocol for collection of 19 19 custodians’ emails wherein Tesla proposed the initial terms, but Plaintiffs were then permitted to edit 20 and add terms. Tesla then accepted those terms as edited by Plaintiffs and performed a review and 21 production of the 19 custodians’ emails. These custodians included current and former Autopilot 22 directors, i.e., the decision-makers relative to Autopilot development and deployment. 23 8 On November 5, 2019, Tesla produced non-confidential case specific materials before 24 even responding to the first set of discovery. Following entry of the Stipulated Protected Order, which 25 involved lengthy meet and confer and negotiations, Tesla has produced Autopilot design, development, 26 and testing documents, employee emails, software tickets, video clips, machine learning images; the 27 most recent document produced by Tesla bears a Bates Number of 183,681 with an additional 28,000 28 pages of case specific documents produced. 278752541 3 DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED 9. With respect to depositions, Plaintiffs deposed two service center technicians, one corporate representative (PMQ), and eleven employee depositions in their individual capacity who work or worked on Autopilot, including four directors of Autopilot. Tesla witness Mohammad Azam Javed was produced in response to a PMQ deposition notice regarding consumer complaints and testified for 6 hours and 48 minutes. Next, Plaintiffs began the procession of noticing and taking individual Tesla employees to testify about Autopilot: Dhaval Shroff, Chris Payne, Kate Park, Pete Schuetzow, Nicklas Gustafsson (not completed), Andrej Karpathy, Milan Kovac, Ashok Elluswamy, and former employees Sameer Qureshi, Andreas Koehler, Florian Rohde, and C.J. Moore and each of their depositions have been between four and six hours long. It is important to note that many of these witnesses - already 10 deposed by Plaintiffs - are the most knowledgeable people in the world on issues related to Autopilot. 11 Indeed, people like Andrej Karpathy, Milan Kovac, Ashok Elluswamy, and former employees Sameer 12 Qureshi and C.J. Moore invented Autopilot. Thus, Plaintiffs have already deposed people are “most 13 qualified” to answer questions about Autopilot. 14 10. A true and correct copy of excerpts from the deposition of C.J. Moore are attached as 15 Exhibit A. 16 11. A true and correct copy of excerpts from the deposition of Kate Park are attached as 17 Exhibit B. 18 12. A true and correct copy of excerpts from the deposition of Chris Payne are attached as 19 Exhibit C. 20 13. A true and correct copy of excerpts from the deposition of Sameer Qureshi are attached 21 as Exhibit D. 22 14. A true and correct copy of excerpts from the deposition of Florian Rhode are attached as 23 Exhibit E. 24 15. A true and correct copy of excerpts from the deposition of Pete Scheutzow are attached 25 as Exhibit F. 26 16. A true and correct copy of excerpts from the deposition of Ashok Elluswamy are 27 attached as Exhibit G. 28 278752541 4 DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED 17. A true and correct copy of excerpts from the deposition of Andrej Karpathy are attached as Exhibit H. 18. A true and correct copy of excerpts from the deposition of Andreas Koehler are attached as Exhibit |. 19. A true and correct copy of excerpts from the deposition of Person Most Qualified at Tesla, Inc. taken on January 27, 2021 (Azam Javed) are attached as Exhibit O. 20. In May 2022, Tesla indicated its concern with Plaintiffs’ tactic of constantly noticing individual depositions of Tesla employees and its concern that Plaintiffs would harass Tesla with a PMQ deposition notice that would require the individuals be produced again because they would be 10 identified as persons “most knowledgeable” on various topics. A true and correct copy of 11 correspondence is attached as Exhibit J. 12 21. Plaintiffs’ Motion fails to accurately describe the procedural background preceding the 13 parties’ impasse. Plaintiffs’ original Notice unilaterally set the deposition for February 14, 2023. A true 14 and correct copy of the Notice is attached as Exhibit K. On February 7, 2023, prior to Tesla’s deadline 15 for objecting to Plaintiffs’ Notice, counsel for Tesla communicated with counsel for Plaintiffs about the 16 unilateral notice and the parties’ agreed that Tesla would provide objections/meet and confer on the 17 PMQ Notice by February 24, 2023. A true and correct copy of correspondence is attached as Exhibit L. 18 Tesla provided a meet and confer and objections on February 24, 2023. A true and correct copy of the 19 correspondence is attached as Exhibit M. 20 22. The parties had a telephonic meet and confer discussing the topics on March 8, 2023, 21 including discussion of narrowing certain topics given testimony that had already occurred. Ultimately, 22 after considering Plaintiffs’ positions, Tesla agreed to produce a witness in response to two categories. 23 That PMQ deposition is set to occur by agreement on April 26, 2023. A true and correct copy of the 24 Amended Notice is attached as Exhibit N. Beyond those topics, Tesla objected to producing a witness 25 on the grounds that the topics had been covered at length in discovery and during the depositions of 26 the persons who would have been “most knowledgeable” on the topics which already occurred. 27 HII 28 HII 278752541 5 DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED | declare under penalty of perjury that the foregoing is true and correct. Executed on April 20, 2023, at San Jose, California. pt / / Tauren 0. Miller 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 278752541 6 DECLARATION OF LAUREN O. MILLER IN SUPPORT OF TESLA, INC.’S OPPOSITION TO MOTION TO COMPEL THE DEPOSITION OF DEFENDANT TESLA’S PERSON MOST QUALIFIED SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA CERTIFIED TRANSCRIPT SZ HUA HUANG, Individually and as [ successor in interest to WEI LUN HUANG, deceased; TRINITY HUANG, a minor; TRISTAN HUANG, a minor; HSI KENG HUANG; and CHING FEN HUANG, CASE NO. 19CV346663 Plaintiffs, -vs- TESLA INC. dba TESLA MOTORS, INC., THE STATE OF CALIFORNIA, and DOES 1 through 100, Defendants. VIDEOTAPED DEPOSITION OF CHRISTOPHER COLEMAN MOORE Taken before KAREN A. CRANGLE Certified Shorthand Reporter State of California C.S.R. 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653-1312 '= REPORTING SERVICES VIDEOTAPED DEPOSITION OF CHRISTOPHER COLEMAN MOORE rr 196 » CRANGLE www.cranglereporting.com | (510) 653-1312 REPORTING SERVICES VIDEOTAPED DEPOSITION OF CHRISTOPHER COLEMAN MOORE 212 » CRANGLE www.cranglereporting.com | (510) 653-1312 REPORTING SERVICES VIDEOTAPED DEPOSITION OF CHRISTOPHER COLEMAN MOORE STATE OF CALIFORNIA ss COUNTY OF ALAMEDA I, Karon Ae erangie,, hereby certify that the witness in the foregoing deposition named CHRISTOPHER COLEMAN MOORE Was Dye Me duly Sworn to testity FO rhe euch, the whole 10 truth, and nothing but the truth in the within-entitled 11 cause; that said deposition was taken at the time and 12 place herein named; that the testimony of said witness was 13 reported by me, a certified shorthand reporter anda 14 disinterested person, and thereafter transcribed into 15 typewriting. 16 17 And I further certify that I am not of counsel or 18 attorney for either or any of the parties to said 19 deposition, nor in any way interested in the outcome of 20 the cause named in said caption. 21 22 Date: Massehi 2 2023 23 24 Kum. Karen A. Crangle, Chan WS.R. 25 228 CRANGLE www.cranglereporting.com | (510) 653-1312 REPORTING SERVICES SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA CERTIFIED TRANSCRIPT SZ HUA HUANG, Individually and as successor in interest to WEI LUN HUANG, deceased; TRINITY HUANG, a minor; TRISTAN HUANG, a minor; HSI KENG HUANG; and CHING FEN HUANG, CASE NO. 19CV346663 Plaintiffs, -vs- TESLA INC. dba TESLA MOTORS, INC., THE STATE OF CALIFORNIA, and DOES 1 through 100, Defendants. VIDEOTAPED DEPOSITION OF KATE JIHAM PARK Taken before KAREN A. CRANGLE Certified Shorthand Reporter State of California C.S.R. 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