KELLEY DRYE &

WARREN LLP
333 WEST W
 Case 5:03-cv-05340-JF Document 68 Filed 12/23/2005 Page 2 of 3

1 I, Caroline C. Plater declare as follows:

2 1. I am an attorney at Kelley Drye & Warren LLP, counsel of record for

3 Defendant/Counter-Plaintiff American Blind & Wallpaper Factory, Inc. (“American Blind”) in

4 the above-captioned action. I am a member in good standing of the State Bar of Illinois. I have

5 personal knowledge of the facts set forth in this declaration and, if called as a witness, could and

6 would testify competently to such facts under oath.

7 2. Attached hereto as Exhibit A is a true and correct copy of American Blind

8 & Wallpaper Factory, Inc.’s First Set of Requests for Production of Documents and Things to

9 Google, Inc., dated April 20, 2005.

10 3. Attached hereto as Exhibit B is a true and correct copy of Plaintiff and

11 Counter-Defendant Google Inc.’s Responses and Objections to American Blind & Wallpaper

12 Factory, Inc.’s First Set of Requests for Production of Documents and Things to Google, Inc.,

13 dated June 21, 2005.

14 4. Attached hereto as Exhibit C is a true and correct copy of an e-mail from

15 David A. Rammelt to Klaus Hamm, dated November 29, 2005.

16 5. Attached hereto as Exhibit D is a true and correct copy of correspondence

17 from Klaus Hamm to David A. Rammelt, dated November 29, 2005.

18 6. Attached hereto as Exhibit E is a true and correct copy of Google Inc.’s

19 Responses and Objections to Defendant and Counter-Plaintiff American Blind & Wallpaper

20 Factory, Inc.’s First Set of Interrogatories, dated June 21, 2005.

21 7. Attached hereto as Exhibit F is a true and correct copy of correspondence

22 from Klaus Hamm to David A. Rammelt, dated December 5, 2005.

23 Executed on December 22, 2005, at Chicago, Illinois.

24 I declare under penalty of perjury under the laws of the State of California that the

25 foregoing is true and correct.

26
/s/ Caroline C. Plater
27 Caroline C. Plater
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KELLEY DRYE & Case No. C03-5340 JF
WARREN LLP
333 WEST WACKER DRIVE
SUITE 2600
Declaration of Caroline C. Plater ISO -2-
CHICAGO, IL 60606 Motion to Enforce Stipulated Protective Order
DM_US\8294178.v1
 Case 5:03-cv-05340-JF Document 68 Filed 12/23/2005 Page 3 of 3

2 ATTESTATION OF CONCURRENCE OF FILING

3 I, Ethan B. Andelman, under penalty of perjury of the laws of the United States of
4 America, attest that concurrence in the filing of this document has been obtained from each of the
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other signatories to this document.
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/s/ Ethan B. Andelman
8 Ethan B. Andelman
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KELLEY DRYE & Case No. C03-5340 JF
WARREN LLP
333 WEST WACKER DRIVE
SUITE 2600
Declaration of Caroline C. Plater ISO -3-
CHICAGO, IL 60606 Motion to Enforce Stipulated Protective Order
DM_US\8294178.v1