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Declaration of Amy Sorenson - as text
Friday, May 28 2004 @ 07:27 PM EDT

We are buried under an avalanche of documents filed as exhibits by the parties in the SCO v. IBM case, which we are busy scanning in from the paper format. Here, just to start, is the Declaration of Amy Sorenson, listing IBM's exhibits. This declaration is in support of IBM's Memorandum in Opposition to SCO's Motion to Dismiss or Stay Count Ten of IBM's Second Amended Counterclaims.

A great deal more will follow. Some of the exhibits are documents we have already, so we won't redo those, but as you will see, there are some new goodies. Thanks go to Henrik Grouleff for transcribing for us.

********************************

SNELL & WILMER LLP
Alan L. Sullivan (3152)
Todd M. Shaughnessy (6651)
Amy F. Sorenson (8947)
[address, phone, fax]

CRAVATH, SWAINE & MOORE LLP
Evan R. Chesler (admitted pro hac vice)
David R. Marriott (7572)
[address, phone, fax]

Attorneys for Defendant/Counterclaim-Plaintiff
International Business Machines Corporation

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH

THE SCO GROUP, INC.,

Plaintiff/Counterclaim-Defendant,

v.

INTERNATIONAL BUSINESS
MACHINES CORPORATION,

Defendant/Counterclaim-Plaintiff.

DECLARATION OF AMY F. SORENSON

Civil No. 2:03CV-0294 DAK

Honorable Dale A. Kimball

Magistrate Judge Brooke C. Wells

---------------------------------------

I, Amy F. Sorenson, declare as follows:

1. I represent IBM in the lawsuit brought by SCO against IBM, titled The SCO Group, Inc. v. International Business Machines Corporation, Civil No. 2:03CV-0294 DAK (D. Utah 2003). This declaration is submitted in support of Defendant/Counterclaim-Plaintiff IBM's Memorandum in Opposition to SCO's Motion to Dismiss or Stay Count Ten of IBM's Second Amended Counterclaims.

2. Attached hereto are true and correct copies of the following documents:

(a) Exhibit 1 is SCO's Opening Brief in Support of its Motion to Dismiss in Red Hat, Inc. v. The SCO Group, Inc., Civ. No. 03-772, (D. Del.), dated September 15, 2003.

(b) Exhibit 2 is the Memorandum Order issued by Judge Sue L. Robinson in the Red Hat case on April 6, 2004.

(c) Exhibit 3 is SCO's Opposition to Red Hat's Motion for Reconsideration in Red Hat, dated May 4, 2003.

(d) Exhibit 4 is a letter from D. McBride to L. Noto, dated May 12, 2003.

(e) Exhibit 5 is "Event Transcript: SCO Group (SCOX) Conference Call", dated July 21, 2003.

(f) Exhibit 6 is a transcript of the December 5, 2003 hearing before Magistrate Judge Wells.

(g) Exhibit 7 is a form letter from R. Tibbitts to "Linux User", dated December 19, 2003.

(h) Exhibit 8 is AutoZone, Inc.'s Motion to Stay or, in the Alternative, For a More Definite Statement, filed April 23, 2004 in The SCO Group, Inc. v. AutoZone, Inc., Case No. CV-S-04-0237 (D. Nev.).

3. I declare under penalty of perjury that the foregoing is true and correct.

Executed: May 18th, 2004

Salt Lake City, Utah

______[signature]_______

Amy F. Sorenson

CERTIFICATE OF SERVICE

I hereby certify that on the 18th day of May, 2004, a true and correct copy of the foregoing was sent by U.S. Mail, postage prepaid, to the following:

Brent O. Hatch
Mark F. James
HATCH, JAMES & DODGE, P.C.
[address]

Stephen N. Zack
Mark J. Heise
BOIES, SCHILLER & FLEXNER LLP [address]

Kevin P. McBride
[address]

______[signature]_________


  


Declaration of Amy Sorenson - as text | 48 comments | Create New Account
Comments belong to whoever posts them. Please notify us of inappropriate comments.
Corrections
Authored by: Anonymous on Friday, May 28 2004 @ 10:05 PM EDT
SDo PJ can find them

[ Reply to This | # ]

Links
Authored by: overshoot on Friday, May 28 2004 @ 10:06 PM EDT
Because they're nice to have

[ Reply to This | # ]

Goody, Goody, but
Authored by: tangomike on Friday, May 28 2004 @ 10:21 PM EDT
we've got at least an extra week to examine and savour these, so take your time
gang. I couldn't think of a way to help with the scanning, unless Kinko's or
Staples can scan and email, in which case, how about some donations to help with
the cost?

---
To The SCO Group - please come back when you pass a Turing test.

[ Reply to This | # ]

Declaration of Amy Sorenson - as text
Authored by: ujay on Friday, May 28 2004 @ 11:56 PM EDT
PJ,

I don't mean to be a nag, but I would really like to see exhibits 4, 5 and 7.
Are there links to these, or do we wait for transcription.


---
Programmer: A biological system designed to convert coffee and cheesies into
code

[ Reply to This | # ]

Declaration of Amy Sorenson - as text
Authored by: inode_buddha on Saturday, May 29 2004 @ 12:14 AM EDT
/me is a willing transcriber for the time being.

---
"When we speak of free software, we are referring to freedom, not price." --
Richard M. Stallman

[ Reply to This | # ]

URLs and other topics here please
Authored by: Anonymous on Saturday, May 29 2004 @ 12:19 AM EDT

[ Reply to This | # ]

..on tools to drink up the avalanche... ;-)
Authored by: Anonymous on Saturday, May 29 2004 @ 12:30 AM EDT
...what _do_ you guys use?

..do we have a guideline idea for a preferrable tool set?

..I see 7 basic jobs in the tool chain:
0. Scan the papers,
1. OCR the scans for text and figures|tables|graphics etc,
2. proofread the texts, clean up figures|tables|graphics,
3. set up and maintain the database mill,
4. feed them into the Groklaw database mill,
5. htmlisation,
6. customizable presentation of the enjoyable evolutionary
pleadings. ;-)

..I'm onto 2 similar things, documenting my wee stunts in
thermochemical gasification ;-), and recycling the 130?
different language texts of the 4 Geneva Conventions,
to make a multi-language machine translator application.

..the 2 languages I've got native speaker level skills in,
are Norwegian and English, English is one of the 5 base
text languages of the 4 Geneva Conventions, so _I_ just
picked it. ;-)

[ Reply to This | # ]

OT: Robert Silver
Authored by: Anonymous on Saturday, May 29 2004 @ 01:49 AM EDT
New attorney for SCO

You can find him in Google. He was involved in the Napster case trying to
prevent the injunction.

He is also mentioned in 2002 press release in connection with BSF and Wide
Orbit, Inc.

[ Reply to This | # ]

Letter from Heise to Mariott dated 2-4-04
Authored by: Lev on Saturday, May 29 2004 @ 02:12 AM EDT
FWIW, tuxrocks shows [157] Exhibit 29 as "coming soon," but I think we
already have it as [103] Exhibit 3.

[ Reply to This | # ]

Declaration of Amy Sorenson - as text
Authored by: Khym Chanur on Saturday, May 29 2004 @ 03:11 AM EDT
Why is refered to as "Declaration of Amy Sorenson" rather than
something like "Declaration of List of Exhibits" or something? If
you're busy wading through a pile of documents, seems like remembering which
lawyer name went with which document would be a pain.

---
Give a man a match, and he'll be warm for a minute, but set him on fire, and
he'll be warm for the rest of his life. (Paraphrased from Terry Pratchett)

[ Reply to This | # ]

TYPO - Declaration of Amy Sorenson - as text
Authored by: Anonymous on Saturday, May 29 2004 @ 04:36 AM EDT
"Red Hat's successes, while making now mention of SCO's lawsuits . .
."

(should be "no mention . . ." ?)


bkm
(i think my groklogin is fotoguzzi)

sorry if this is wrong place for errata.

[ Reply to This | # ]

Declaration of Amy Sorenson - as text
Authored by: Anthem on Saturday, May 29 2004 @ 11:35 AM EDT
Interesting that they include a transcript of the conference call.

Anybody think they used ours?

[ Reply to This | # ]

Exhibit 3 Anxiously Awaited
Authored by: jldill22 on Saturday, May 29 2004 @ 09:30 PM EDT
Could we, please, please, have a copy of Exhibit 3, in pdf or text form asap.

It is SCO's response to Red Hat's motion lift the current judicially imposed
stay in the Red Hat lawsuit. The document appears as being availabe on
tuxrocks, both as an exhibit to the Sorenson declaration and as a document in
the Red Hat proceedings, but both links are broken and have been broken for at
least 24 hours, if they ever worked.

[ Reply to This | # ]

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