Data Scape Limited v. Dropbox, Inc.

Western District of Texas, txwd-6:2019-cv-00023

Affidavit of Gerald Padian

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UNITED STATES DISTRICT COURT IN THE WESTERN DISTRICT OF TEXAS WACO DIVISION DATA SCAPE LIMITED, C.A. No. 6:19-cv-00023-ADA Plaintiff, V. JURY TRIAL DEMANDED DROPBOX, INC., Defendant. DECLARATION OF GERALD PADIAN IN SUPPORT OF PLAINTIFF DATA SCAPE LIMITED'S OPPOSITION TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA 1 I, Gerald Padian, declare and state as follows: I. I have personal knowledge of the facts set forth herein, and if called upon to testify, could and would testify competently thereto. 2. I am employed by Data Scape Limited and a director of Data Scape Limited ("Data Scape"). I reside in Katonah, New York. 3. I understand that Defendant DropBox, Inc. ("DropBox") has filed a motion requesting that the above captioned action be transferred to the Northern District of California ("N.D. Cal."), where Dropbox has its San Francisco headquarters. 4. I understand that the Court will consider my convenience in connection with its decision on the pending motion to transfer. As such, I make this declaration to indicate that it would be more convenient for me for the above captioned action to proceed in Texas than in San Francisco, California. 5. If asked to testify in Waco, Texas, I would be willing to do so. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated this 8th of May 2019 at New York, New York. 2