Preview
David C. Lee (SBN 193743)
FILED
SAN M ATEO COUNTY
dlee mrllp.com
Ilse . Scott (SBN 233433)
iscott@mrllp.com
Taylor C. Foss (SBN 253486)
tfoss rllp.com
MIC LMAN & ROBINSON, LLP
One Post Street, Suite 2500
San Francisco, CA 94104
Telephone: 415 882-7770
Fac31mile: 415 882—1570
Attorneys for Specially Appearing Defendant JOSEPH GALL UZZO
\
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
GUIDEWIRE SOFTWARE, INC., Case No.: 16CIV01769
Plaintiff, DEFENDANT GALLUZZO’S
V. EVIDENTIARY OBJECTIONS TO
DECLARATION OF MAX B. TWINE
JAY GALLUZZO, and DOES 1 through 20, IN SUPPORT OF PLAINTIFF
inclusive, GUIDEWIRE SOFTWARE, INC.’S
OPPOSITION TO DEFENDANT
Defendants. GALLUZZO’S MOTION TO QUASH
SERVICE OF SUMMONS
Hearing Date: March 14, 2017
Time: 9:00 am
Dept: Law & Motion
Complaint Filed: October 7, 2016
15—0111—01769
OBJECT
obiecfion
lllll\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\
‘
4
DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION
Defendant Joseph “Jay” Galluzzo hereby submits the following evidentiary objections to
the Declaration of Max B. Twine in Support of Guidewire’s Supplemental Brief in Further
Opposition to Defendant Galluizo’s Motion to Quash Service of Summons.
OBJECTION NO. 1
\OOO\IO\Ul-J>UJI\Jy—-
EVIDENCE OBJECTED TO:
Exhibit 2 purporting to be “a true and correct copy of the October 17, 2012 email
between Defendant and Guidewire Senior Recruiter of Worldwide Sales and Services Evan
Pellett.”
GROUND FOR OBJECTIONS:
- Lacks Authentication (Cal. Evid. Code § 1401(a) and (b)). Plaintiff’s counsel is
neither an author nor recipient of Exhibit 2 and cannot appropriately authenticate the
evidence.
; My '
(Cal. Evid. Code §§ 1200, 1201).
OBJECTION N0. 2
EVIDENCE OBJECTED TO:
Exhibit 3 purporting to be “a true and correct copy a (sic) Salesforce.com File Content
NNNNNNNNNHHi—np—ay—AHr—tr—Ai—tr—A
and Download Report generated on January 13, 2016..."
GROUND FOR OBJECTIONS:
- Lacks Authentication (Cal.
WQQMAWNF—‘OOOOQQM-PWNHO
Evid. Code § 1401(a) and (b)). Plaintiffs counsel is not
the author of Exhibit 3 and has provided no evidence establishing that exhibits origins
and therefore cannot appropriately authenticate the evidence.
- Hwy (Cal. Evid. Code §§ 1200, 1201).
OBJECTION NO. 3
EVIDENCE OBJECTED TO:
Paragraph 4: “Exhibit 3 Salesforce.com File Content and Download Report
is. . .a (sic)
generated on January 13, 2016 showing that Galluzzo downloaded 30 highly sensitive Guidewire
sales documents shortly before his departure from the company.”
///
1
DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION
GROUND FOR OBJECTIONS:
- Secondary Evidence Rule (Cal. Evid. Code 1521). Plaintiff‘s counsel’s summary of
§
the contents of the unauthenticated Exhibit 3 constitutes inadmissible secondary
evidence.
-
\OOO\]O\UIAUJNr—‘
Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200
Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port
Dist. (2003) 106 Cal.App.4th 1219, 1240 (finding conclusions of fact or law are not
evidence, nor are conclusory restatements of allegations sufficient as evidence)).
Plaintis counsel’s characterizations and conclusions of the content of Exhibit 3
(i.e., the improper conclusion that Exhibit 3 identifies “30 highly sensitive Guidewire
sales documents”) are unsubstantiated and unsupported conclusory statements.
- Lacks Foundation (Cal. Evid. Code 400, 403(a)).
§
- Heisav (Cal. Evid. Code §§ 1200, 1201).
OBJECTION NO. 4
EVIDENCE OBJECTED TO:
Exhibit 4 purporting to be “a true and correct copy a (sic) letter Guidewire’s legal counsel
(sic) Gregory S. Lemmer of the Gunderson Dettmer law firm sent to Galluzzo
NNNNNNNNNv—Ay—tv—Iv—ai—ar—Iv—ar—tt—tp—a
on January 29,
2016...”
GROUND FOR OBJECTIONS:
- Lacks Authentication
ooucxmawwwoooouoxmap—‘o
(Cal. Evid. Code 1401(a) and (b)). Plaintiffs counsel is
§
neither an author nor recipient of Exhibit 4 and cannot appropriately authenticate the
evidence.
-
My (Cal. Evid. Code §§ 1200, 1201).
OBJECTION NO. 5
EVIDENCE OBJECTED TO:
Paragraph 5: “Exhibit 4 is.. .a true and correct copy a (sic) letter Guidewire’s legal
counsel (sic) Gregory S. Lemmer of the Gunderson Dettmer law firm sent to Galluzzo on
January 29, 2016. . .demanding that, among other things, he confirm in writing that he had
2
DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION
returned all company data or documents or describe how he intended to. do so.”
GROUND FOR OBJECTIONS:
- Secondary Evidence Rule (Cal. Evid. Code § 1521). Plaintiff’s counsel’s summary of
the contents of the unauthenticated Exhibit 4 constitutes inadmissible secondary
©00\lO\UI-S>UJN»—A
evidence.
- Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200
Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port
Dist. (2003) 106 Cal.App.4th 1219, 1240 (finding conclusions of fact or law are not
‘
evidence, nor are conclusory restatements of allegations sufficient as evidence)).
Plaintiff’s counsel’s characterizations and conclusions of the content of Exhibit 4
(i.e., the improper conclusion that Exhibit 4 makes certain demands) are
unsubstantiated and unsupported conclusory statements.
- Lacks Foundation (Cal. Evid. Code § 400, 403(a)).
- My (Cal. Evid. Code §§ 1200, 1201).
OBJECTION NO. 6
EVIDENCE OBJECTED T0:
“Galluzzo produced a total of 2,089 pages of “Company Documents,” as
NNNNNNNNNp—nb—di—Ir—Ay—ni—np—ar—Ir—Ai—r
Paragraph 6:
defined in the PIIA, including several documents that are clearly marked as “Confidential” and
“Proprietary” and/or for “Internal Use Only.”
OONONMAWNF—‘OKOOOVONM-D-WNHO
GROUND FOR OBJECTIONS:
- Lacks Authentication (Cal. Evid. Code § 1401(a) and (b)). Plaintiff’s counsel’s
statement seeks to characterize and summarize unattached and unidentified
“Company Documents” without authentication.
- Secondary Evidence Rule (Cal. Evid. Code § 1521). Plaintiff’s counsel’s summary of
the contents of purported “Company Documents” constitutes inadmissible secondary
evidence.
- Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200
Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port
3
DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION
Dist. (2003) 106 Cal.App.4th 1219, 1240 (finding conclusions of fact or law are not
evidence, nor are conclusory restatements of allegations sufficient as evidence)).
Plaintiff’s counsel’s characterizations and conclusions of the content of unattached
and undefined “Company Documents” are unsubstantiated and unsuppmted
\OOOQCBU‘I-P-UJNI—t
conclusory statements. .
- Lacks Foundation (Cal. Evid. Code § 400, 403(a)).
- gear—say (Cal. Evid. Code §§ 1200, 1201).
OBJECTION NO. 7
EVIDENCE OBJECTED TO:
Paragraph 8: “I have personally reviewed and analyzed the Microsoft Outlook .pst file
that Guidewire has maintained for the email address igalluzzo@guidewire.com. I have
determined that Galluzzo sent no fewer than 1,077 emails to Guidewire employees identified by
Melody Fan as having worked in California during Galluzzo’s tenure with the company. I have
counted 215 emails from those Guidewire employees identified by Ms. Fan, a number that only
reflects emails that remained in Galluzzo’s Outlook inbox at the time he left the company. In
other words, this number is almost certainly lower than the actual number of emails Galluzzo
received from California-based colleagues during his nearly three years as a Guidewire
NMNNNNNNNP—‘HP—‘HHHHy—lp—tp—A
employee. In total,
MQOMAWNU—‘OOOOQONLAAUJNt—‘O
I counted 1,292 emails Galluzzo either sent to or received from his
colleagues based in California. I also counted 71 separate conference calls that Galluzzo
participated in with colleagues based in California, a number that only includes formal
conference calls for which Microsoft Outlook calendar invites were created and maintained. In
total, current Guidewire records show at least 1,363 separate contacts between Galluzzo and
company personnel in CA.”
GROUND FOR OBJECTIONS:
- mar—say (Cal. Evid. Code §§ 1200, 1201). Plaintiff’s counsel’s purported summary
of out-of-court “company records” and his purported “analysis” of such records
constitutes inadmissible hearsay.
4
DEFENDANT GALLUZZO’S OBJECTIONS TO TWTNE DECLARATION
y—a
Lacks Authentication (Cal. Evid. Code § 1401(a) and (b)). Plaintiff‘s counsel’s
statement seeks to characterize and summarize unattached and unidentified
“Guidewire records” purportedly including “the Microsoft Outlook .pst file that
Guidewire has maintained” without authentication.
Secondary Evidence Rule (Cal. Evid. Code § 1521). Plaintiffs counsel’s summary of
DOOQQM-RWN
the numbers of purported emails sent to and from Galluzzo and other Guidewire
employees and “calendar invites” and “conference calls” as reviewed in the purported
“Microsoft Outlook .pst file that Guidewire has maintained” constitutes inadmissible
secondary evidence.
Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200
Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port
Dist. (2003) 106 Ca1.App.4th 1219, 1240 (finding conclusions of fact or law are not
evidence, nor are conclusory restatements of allegations sufficient as evidence)).
Plaintiff’s counsel’s characterizations and conclusions concerning the so-called
numbers of purported emails sent to and from Galluzzo and other Guidewire
employees and “calendar invites” and “conference calls” as reviewed in the purported
“Microsoft Outlook .pst file that Guidewire has maintained” are unsubstantiated and
NNNNNNNNNh—r—ay—ap—ny—Ai—tp—r—ti—di—t
unsupported conclusory statements.
Lacks Foundation (Cal. Evid. Code § 400, 403(a)).
OO\]O\Lh4>UJl\Ji—‘O\OOO\]O\UI-{hWN)—io
Dated: March 10, 2017 MICHELMAN & ROBINSON LLP
JOSEPH GALLUZZO
5
DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION
PROOF OF SERVICE
Guidewire Software, Inc. v.Jay Galluzzo
San Mateo County Superior Court Case No. 16CI‘V01769
I am employed in the County of San Francisco, State of California. I am over the age of
18 and not a party to the within action. My business address is One Post Street, Suite 2500, San
Francisco, California 94104.
\OOO\IO\U‘I-I>-LA)N)-‘
On March 10, 2017, I served the foregoing document(s) described as follows:
DEFENDANT GALLUZZO’S EVIDENTIARY OBJECTIONS TO DECLARATION
OF MAX B. TWINE IN SUPPORT OF PLAINTIFF GUIDEWIRE SOFTWARE,
INC.’S OPPOSITION TO DEFENDANT GALLUZZO’S MOTION TO QUASH
SERVICE OF SUMMONS
on the interested parties in this action, by placing a true copy thereof enclosed in a sealed
envelope(s) addressed to the following addressee(s):
Attorneys for Plaintiffs
Jonathan A. Patchen
Cheryl A. Galvin
Max B. Twine
TAYLOR & PATCHEN, LLP, LLP
One Ferry Building, Suite 355
San Francisco, CA 94111
Tel: 415—788-8200
Fax: 415—788—8208
Email: jpatchen@tcolaw.com
Email: mtwine@tcolaw.eom
NNNNNNNNNi—‘H—‘I—‘v—‘t—Ii—It—i—Ir—t
[Xl(BY FEDERAL EXPRESS/STANDARD OVERNIGHT MAIL): I caused the above-
described document to be served on the interested parties noted above by Federal
mumm-PWNHOOOONQMAWNHO
Express/Standard Overnight Mail.
Ki (STATE) Ideclare under penalty of perjury u- : —
th laws of the State of California,
that the above 15 true and correct.
94A:il'/ ' ‘
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DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION
Preview
David C. Lee (SBN 193743) FILED SAN M ATEO COUNTY dlee mrllp.com Ilse . Scott (SBN 233433) iscott@mrllp.com Taylor C. Foss (SBN 253486) tfoss rllp.com MIC LMAN & ROBINSON, LLP One Post Street, Suite 2500 San Francisco, CA 94104 Telephone: 415 882-7770 Fac31mile: 415 882—1570 Attorneys for Specially Appearing Defendant JOSEPH GALL UZZO \ SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO GUIDEWIRE SOFTWARE, INC., Case No.: 16CIV01769 Plaintiff, DEFENDANT GALLUZZO’S V. EVIDENTIARY OBJECTIONS TO DECLARATION OF MAX B. TWINE JAY GALLUZZO, and DOES 1 through 20, IN SUPPORT OF PLAINTIFF inclusive, GUIDEWIRE SOFTWARE, INC.’S OPPOSITION TO DEFENDANT Defendants. GALLUZZO’S MOTION TO QUASH SERVICE OF SUMMONS Hearing Date: March 14, 2017 Time: 9:00 am Dept: Law & Motion Complaint Filed: October 7, 2016 15—0111—01769 OBJECT obiecfion lllll\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\ ‘ 4 DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION Defendant Joseph “Jay” Galluzzo hereby submits the following evidentiary objections to the Declaration of Max B. Twine in Support of Guidewire’s Supplemental Brief in Further Opposition to Defendant Galluizo’s Motion to Quash Service of Summons. OBJECTION NO. 1 \OOO\IO\Ul-J>UJI\Jy—- EVIDENCE OBJECTED TO: Exhibit 2 purporting to be “a true and correct copy of the October 17, 2012 email between Defendant and Guidewire Senior Recruiter of Worldwide Sales and Services Evan Pellett.” GROUND FOR OBJECTIONS: - Lacks Authentication (Cal. Evid. Code § 1401(a) and (b)). Plaintiff’s counsel is neither an author nor recipient of Exhibit 2 and cannot appropriately authenticate the evidence. ; My ' (Cal. Evid. Code §§ 1200, 1201). OBJECTION N0. 2 EVIDENCE OBJECTED TO: Exhibit 3 purporting to be “a true and correct copy a (sic) Salesforce.com File Content NNNNNNNNNHHi—np—ay—AHr—tr—Ai—tr—A and Download Report generated on January 13, 2016..." GROUND FOR OBJECTIONS: - Lacks Authentication (Cal. WQQMAWNF—‘OOOOQQM-PWNHO Evid. Code § 1401(a) and (b)). Plaintiffs counsel is not the author of Exhibit 3 and has provided no evidence establishing that exhibits origins and therefore cannot appropriately authenticate the evidence. - Hwy (Cal. Evid. Code §§ 1200, 1201). OBJECTION NO. 3 EVIDENCE OBJECTED TO: Paragraph 4: “Exhibit 3 Salesforce.com File Content and Download Report is. . .a (sic) generated on January 13, 2016 showing that Galluzzo downloaded 30 highly sensitive Guidewire sales documents shortly before his departure from the company.” /// 1 DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION GROUND FOR OBJECTIONS: - Secondary Evidence Rule (Cal. Evid. Code 1521). Plaintiff‘s counsel’s summary of § the contents of the unauthenticated Exhibit 3 constitutes inadmissible secondary evidence. - \OOO\]O\UIAUJNr—‘ Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200 Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port Dist. (2003) 106 Cal.App.4th 1219, 1240 (finding conclusions of fact or law are not evidence, nor are conclusory restatements of allegations sufficient as evidence)). Plaintis counsel’s characterizations and conclusions of the content of Exhibit 3 (i.e., the improper conclusion that Exhibit 3 identifies “30 highly sensitive Guidewire sales documents”) are unsubstantiated and unsupported conclusory statements. - Lacks Foundation (Cal. Evid. Code 400, 403(a)). § - Heisav (Cal. Evid. Code §§ 1200, 1201). OBJECTION NO. 4 EVIDENCE OBJECTED TO: Exhibit 4 purporting to be “a true and correct copy a (sic) letter Guidewire’s legal counsel (sic) Gregory S. Lemmer of the Gunderson Dettmer law firm sent to Galluzzo NNNNNNNNNv—Ay—tv—Iv—ai—ar—Iv—ar—tt—tp—a on January 29, 2016...” GROUND FOR OBJECTIONS: - Lacks Authentication ooucxmawwwoooouoxmap—‘o (Cal. Evid. Code 1401(a) and (b)). Plaintiffs counsel is § neither an author nor recipient of Exhibit 4 and cannot appropriately authenticate the evidence. - My (Cal. Evid. Code §§ 1200, 1201). OBJECTION NO. 5 EVIDENCE OBJECTED TO: Paragraph 5: “Exhibit 4 is.. .a true and correct copy a (sic) letter Guidewire’s legal counsel (sic) Gregory S. Lemmer of the Gunderson Dettmer law firm sent to Galluzzo on January 29, 2016. . .demanding that, among other things, he confirm in writing that he had 2 DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION returned all company data or documents or describe how he intended to. do so.” GROUND FOR OBJECTIONS: - Secondary Evidence Rule (Cal. Evid. Code § 1521). Plaintiff’s counsel’s summary of the contents of the unauthenticated Exhibit 4 constitutes inadmissible secondary ©00\lO\UI-S>UJN»—A evidence. - Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200 Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port Dist. (2003) 106 Cal.App.4th 1219, 1240 (finding conclusions of fact or law are not ‘ evidence, nor are conclusory restatements of allegations sufficient as evidence)). Plaintiff’s counsel’s characterizations and conclusions of the content of Exhibit 4 (i.e., the improper conclusion that Exhibit 4 makes certain demands) are unsubstantiated and unsupported conclusory statements. - Lacks Foundation (Cal. Evid. Code § 400, 403(a)). - My (Cal. Evid. Code §§ 1200, 1201). OBJECTION NO. 6 EVIDENCE OBJECTED T0: “Galluzzo produced a total of 2,089 pages of “Company Documents,” as NNNNNNNNNp—nb—di—Ir—Ay—ni—np—ar—Ir—Ai—r Paragraph 6: defined in the PIIA, including several documents that are clearly marked as “Confidential” and “Proprietary” and/or for “Internal Use Only.” OONONMAWNF—‘OKOOOVONM-D-WNHO GROUND FOR OBJECTIONS: - Lacks Authentication (Cal. Evid. Code § 1401(a) and (b)). Plaintiff’s counsel’s statement seeks to characterize and summarize unattached and unidentified “Company Documents” without authentication. - Secondary Evidence Rule (Cal. Evid. Code § 1521). Plaintiff’s counsel’s summary of the contents of purported “Company Documents” constitutes inadmissible secondary evidence. - Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200 Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port 3 DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION Dist. (2003) 106 Cal.App.4th 1219, 1240 (finding conclusions of fact or law are not evidence, nor are conclusory restatements of allegations sufficient as evidence)). Plaintiff’s counsel’s characterizations and conclusions of the content of unattached and undefined “Company Documents” are unsubstantiated and unsuppmted \OOOQCBU‘I-P-UJNI—t conclusory statements. . - Lacks Foundation (Cal. Evid. Code § 400, 403(a)). - gear—say (Cal. Evid. Code §§ 1200, 1201). OBJECTION NO. 7 EVIDENCE OBJECTED TO: Paragraph 8: “I have personally reviewed and analyzed the Microsoft Outlook .pst file that Guidewire has maintained for the email address igalluzzo@guidewire.com. I have determined that Galluzzo sent no fewer than 1,077 emails to Guidewire employees identified by Melody Fan as having worked in California during Galluzzo’s tenure with the company. I have counted 215 emails from those Guidewire employees identified by Ms. Fan, a number that only reflects emails that remained in Galluzzo’s Outlook inbox at the time he left the company. In other words, this number is almost certainly lower than the actual number of emails Galluzzo received from California-based colleagues during his nearly three years as a Guidewire NMNNNNNNNP—‘HP—‘HHHHy—lp—tp—A employee. In total, MQOMAWNU—‘OOOOQONLAAUJNt—‘O I counted 1,292 emails Galluzzo either sent to or received from his colleagues based in California. I also counted 71 separate conference calls that Galluzzo participated in with colleagues based in California, a number that only includes formal conference calls for which Microsoft Outlook calendar invites were created and maintained. In total, current Guidewire records show at least 1,363 separate contacts between Galluzzo and company personnel in CA.” GROUND FOR OBJECTIONS: - mar—say (Cal. Evid. Code §§ 1200, 1201). Plaintiff’s counsel’s purported summary of out-of-court “company records” and his purported “analysis” of such records constitutes inadmissible hearsay. 4 DEFENDANT GALLUZZO’S OBJECTIONS TO TWTNE DECLARATION y—a Lacks Authentication (Cal. Evid. Code § 1401(a) and (b)). Plaintiff‘s counsel’s statement seeks to characterize and summarize unattached and unidentified “Guidewire records” purportedly including “the Microsoft Outlook .pst file that Guidewire has maintained” without authentication. Secondary Evidence Rule (Cal. Evid. Code § 1521). Plaintiffs counsel’s summary of DOOQQM-RWN the numbers of purported emails sent to and from Galluzzo and other Guidewire employees and “calendar invites” and “conference calls” as reviewed in the purported “Microsoft Outlook .pst file that Guidewire has maintained” constitutes inadmissible secondary evidence. Improper Conclusion Without Evidentiarv Facts (Snider v. Snider (1962) 200 Cal.App.2d 741, 751; Tuchscher Develop. Enterprises, Inc. v.San Diego Unified Port Dist. (2003) 106 Ca1.App.4th 1219, 1240 (finding conclusions of fact or law are not evidence, nor are conclusory restatements of allegations sufficient as evidence)). Plaintiff’s counsel’s characterizations and conclusions concerning the so-called numbers of purported emails sent to and from Galluzzo and other Guidewire employees and “calendar invites” and “conference calls” as reviewed in the purported “Microsoft Outlook .pst file that Guidewire has maintained” are unsubstantiated and NNNNNNNNNh—r—ay—ap—ny—Ai—tp—r—ti—di—t unsupported conclusory statements. Lacks Foundation (Cal. Evid. Code § 400, 403(a)). OO\]O\Lh4>UJl\Ji—‘O\OOO\]O\UI-{hWN)—io Dated: March 10, 2017 MICHELMAN & ROBINSON LLP JOSEPH GALLUZZO 5 DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION PROOF OF SERVICE Guidewire Software, Inc. v.Jay Galluzzo San Mateo County Superior Court Case No. 16CI‘V01769 I am employed in the County of San Francisco, State of California. I am over the age of 18 and not a party to the within action. My business address is One Post Street, Suite 2500, San Francisco, California 94104. \OOO\IO\U‘I-I>-LA)N)-‘ On March 10, 2017, I served the foregoing document(s) described as follows: DEFENDANT GALLUZZO’S EVIDENTIARY OBJECTIONS TO DECLARATION OF MAX B. TWINE IN SUPPORT OF PLAINTIFF GUIDEWIRE SOFTWARE, INC.’S OPPOSITION TO DEFENDANT GALLUZZO’S MOTION TO QUASH SERVICE OF SUMMONS on the interested parties in this action, by placing a true copy thereof enclosed in a sealed envelope(s) addressed to the following addressee(s): Attorneys for Plaintiffs Jonathan A. Patchen Cheryl A. Galvin Max B. Twine TAYLOR & PATCHEN, LLP, LLP One Ferry Building, Suite 355 San Francisco, CA 94111 Tel: 415—788-8200 Fax: 415—788—8208 Email: jpatchen@tcolaw.com Email: mtwine@tcolaw.eom NNNNNNNNNi—‘H—‘I—‘v—‘t—Ii—It—i—Ir—t [Xl(BY FEDERAL EXPRESS/STANDARD OVERNIGHT MAIL): I caused the above- described document to be served on the interested parties noted above by Federal mumm-PWNHOOOONQMAWNHO Express/Standard Overnight Mail. Ki (STATE) Ideclare under penalty of perjury u- : — th laws of the State of California, that the above 15 true and correct. 94A:il'/ ' ‘ 6 DEFENDANT GALLUZZO’S OBJECTIONS TO TWINE DECLARATION