Conference: Daniel Ocampo vs Dominic Williams

• 
• 
• 
• 

						
                                
Preview
                                QUINN EMANUEL URQUHART & SULLIVAN, LLP
     Michael E. Liftik (CA Bar No. 232430)
     Sarah Heaton Concannon (pro hac vice)
     1300 I Street, Suite 900
     Washington, D.C. 20005
     Telephone: (202) 538-8000
     michaelliftik@quinnemanuel.com
     sarahconcannon@quinnemanuel.com

     Emily C. Kapur (CA Bar No. 306724)
     555 Twin Dolphin Dr., Sth Fl.
     Redwood Shores, California 94065
     Telephone: (650) 801-5000
     emilykapur@quinnemanuel.com

     [Additional Counsel on Signature Page]
10
     Attorneys for Specially Appearing Defendant Dominic   Williams    and Defendants Dfinity   USA
11
     Research, LLC and Dfinity Stiftung
12
                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
                                           COUNTY OF SAN MATEO
14
     DANIEL      OCAMPO,      Individually and    on       Case No. 21-CIV-03843
15   Behalf of All Others Similarly Situated,
                                                           DECLARATION OF MICHAEL E
16
                              Plaintiff,                   LIFTIK ESTABLISHING MEET
17                                                         AND CONFER CONFERENCE
                                                           CONCERNING DEFENDANT
18              v                                          DFINITY USA’S DEMURRER TO
                                                           PLAINTIFF’S THIRD AMENDED
19   DFINITY USA RESEARCH LLC, DFINITY                     COMPLAINT AND SPECIALLY
     STIFTUNG, AH CAPITAL MANAGEMENT,
                                                           APPEARING DEFENDANT
20   L.L.C., POLYCHAIN CAPITAL, DOMINIC                    DOMINIC WILLIAMS’ MOTION
     WILLIAMS, and JOHN DOES 1-20,                         TO QUASH FOR DEFECTIVE
21
                                                           SERVICE OF PROCESS
                              Defendants.
22

23                                                         Hon. Susan L. Greenberg
                                                           Dept. 22 — Ctrm. I
24                                                         Date Action Filed: July 15, 2021
                                                           Date:   January 11, 2024
25
                                                           Time:   9:00 a.m. PST
26

27

28
                                                                        Case No. 21-CIV-03843}
     DECLARATION OF MICHAEL E. LIFTIK ESTABLISHING MEET AND CONFER CONCERNING DEMURRER
                                  TO TAC AND MOTION TO QUASH
I, Michael E. Liftik, declare:

                1        I am an attorney at law licensed to practice before this Court and all of the courts of

     the state of California.      I am an attorney with the law firm Quinn Emanuel Urquhart & Sullivan,

     LLP, counsel of record for Defendants Dfinity USA Research, LLC and Dfinity Stiftung.                  Iam one

     of the attorneys responsible for the representation of Defendants Dfinity USA Research, LLC and

     Dfinity Stiftung in this matter and, as such, I have personal knowledge of the facts set forth in this

     declaration.      I am also counsel of record and one of the attorneys responsible for representation of

     Dfinity USA        Research, LLC,    Dfinity Foundation and Specially Appearing Defendant Dominic

     Williams in the action captioned        Valenti v. DFINITY     USA Research LLC,       et al., No. 21-cv-6118

10   (N.D. Cal.), currently pending in the Northern District of California. If called as a witness for this

11   purpose, I could and would testify competently under oath to the facts stated herein.

12           2.          Pursuant to Case Management Order #1, on January 8, 2024, the parties conducted a

13   telephonic meet and confer conference concerning (a) Defendant Dfinity USA                  Research, LLC’s

14   pending Demurrer to the Third           Amended    Complaint;     and (b) Specially Appearing      Defendant

15   Dominic        Williams’   pending   Motion   to Quash     for Defective   Service   of Process.   (See Case

16   Management Order #1 (July 21, 2021), 426.)               Counsel did not reach agreement on the pending

17   motions.

18

19   Executed on this 8th day of January, 2024, in Washington, DC.

20

21                                                      /s/ Michael E. Liftik
                                                        Michael E. Liftik (CA Bar No. 232430)
22

23

24

25

26

27

28
                                                              -2-                                Case No. 21-cv-03843
     DECLARATION OF MICHAEL E. LIFTIK ESTABLISHING MEET AND CONFER CONCERNING DEMURRER
                                  TO TAC AND MOTION TO QUASH