Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 1 of 24 Waymo v. Uber Case No. 3:17-cv-00939-WHA   TRIAL EXHIBIT 8855 Uber Objections:  Fed. R. Evid. 802 – This document contains inadmissible hearsay; namely, out of court statements made by Anthony Levandowski, who participated in the Stroz diligence process in his individual capacity. See Br. § II.  Fed. R. Evid. 805 – This document contains inadmissible hearsay within hearsay; namely, Anthony Levandowski’s recitation of out of court statements made by other declarants. See Br. § II.  Fed. R. Evid. 403M – The original document contains multiple different colors of writing. The different colors are attributable to different authors and/or were composed separately at different points in time, which raises a risk of jury confusion. See Br. § II. Note: This document contains handwriting and original highlights, and therefore is not susceptible to highlighting. Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 2 of 24 EXHlBlT EXHIBIT 9/55-S:: lI 9/55-L Interview rview start startssat at 11:10 11:10 Inte Mthvllly reviewed reviewed questionnaire.questionnaire.Mthvllly ,..,-I- C~ C~ ,.., + We review review the the devices. devices. Approx. Approx. 37. 37. We ne 6s. 6s. primary primary phone. phone. Personal Personal and and work. work. Any Any communicat communication ion including including Google. Google. Got Got the the phone phone iPhone iPho ... used Dec 2015. 2015. Shouldn't Shouldn't have have google go ogle ema email.il. Used Used google google apps. apps. Didn't Didn't sync sync with with email email... used app. app. Google Google Dec use Doesn't app. Gmail device. the on is email confirmed email was disabled at departure. Ottomotto email is on the device. Gmail app. Doesn't use Ottomotto departure. at disabled was email confirmed imessage. snapchat, messages, Text 6? default mail app. What accounts do you access on the iphone 6? Text messages, snapchat, imessage. iphone the on access you do accounts What app. default mail Synce notes notes with with gmail. gmail. Sync Sync contacts contacts with with carddav. carddav. These These should should all all exist exist in in gmail. gmail. Had Had evernote evernote Synce enabled be may Backup only. safari, News, Is phone syncing icloud? News, safari, only. Backup may be enabled,, before but not on the phone . icloud? syncing phone before but not on the phone. Is What was was the the phone phone prior? prior? !phone Iphone 66 was was wiped wiped and and given given away. away. What Neltus us Ne~ as crushed crushed.. as Does not not have have any any other other phones. phones. Does Password protected itunes backup. J,pad ml l'li? Didn't bring it with him. Tablets are easy to get. Used to fly his helicopter... remote. Got in 2014 . Girlfriend has access to the ipad mini. Should not include any relevant data . p~d3UGot in 2013, used for personal use. Looking at Netflix video, games, games, personal pictures. Not p$1d3UGot syncing email. Dropbox may be installed but not connected and synced. GF has access ... doesn't use (NexuS'l'hasn' t been used ., Project airplane controls . Not google go ogle related . Never synced mail. Set up dev (NexuS'l'hasn't email, set up site project how to pick up things on the ground . Testing only,.no google IP. (side project FiiNow a funded by google, but not google related . Google exec funding it Tiramisu, now called Flye r) FilNow startup called Kittyhawk, Tiramisu, Flyer. Apple Laptop. Primary. Used for both work and personal. FileVault encrypted. Got it in 2013 . GF has Otto motto . access. Uses it fo r everyting. For work, yes used it for Google. Uses it now for Ottomotto Gbogle Google : email, presentation, no software, no code, no dev work, used it to work on docs. VM for windows, to configure tools . Work gmail, gdocs. What type of work doc, videos, presentations, via·web. Did not in-a datasheets. Anyth.ing related for chauffeur? All should be in a folder? Accessed email via"web. d 3Jd has 3J Also has laptop. Also on-his laptop. fil~s related fil google related has google sync., ~s on-his Still has drop box. Still with dropbox. synced with ar ee synced documents ar All documents sync., All google. at google. while at given while Presentations given party vendors). Presentations (google vendors). updates (google vendor updates Including vendor dociJlllen .. Including party doclJll1en internal and internal documents and Public documents What sheets. Public data sheets. and data buy and would buy they would Parts they Manuals? Parts of Manuals? sorts of What sorts through went through manually went (we manually chauffeur. (we in chauffeur. documents. contained in be contained all be Should all priviledged. Should Seems priviledged. documents. Seems in be in should be stuff should Most stuff triggered). Most some been triggered). have been may have stamps may time stamps updated time last updated some last so some files so some files chauffeu chauffeur.r. of documents of some documents are some There are data.. There proprietary data Worked has proprietary Laptop has previously. Laptop maps previously. and maps streetview and on streetview Worked on chauffer. under chauffer. docs) under related docs) other (management related confidential (management data confidential personal data employees personal other employees return.. to return needed to he needed data he some data had some he had A'fly (someone) he told (someone) He told ... He No... docs? No ffer docs? chauffer or chau google or other google A'fJ.y other was asked ifif itit was He asked data.. He the data -ofthe rid-of get rid to get said to Tal~d else said someone else it, someone keep it, said keep one-person said ·and one-person Uber·and to Uber Tal~d to OK yes. said yes. Uber said delete, Uber to delete, OKto CONFIDENTIAL CONFIDENTIAL United States District Court Northern District of California Trial Exhibit 8855 Case No. 3:17-cv-00939-WHA Date Entered._ _ _ _ _ __ By_ _~~_._~~---Deputy Clerk 23 of23 TX-8855, Page 11of TX-8855, Page 0021120 STROZ__ 0021120 STROZ vv Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 3 of 24 / Did you you save save any any google google work work email? email? Not Not that that II know know o0 Did Ottomotto: uses itit for for work, work, datasheets, datasheets, spreadsheets, spreadsheets, text text files, files, no no local local emails. emails. Uses Uses webbrowser webbrowser for for motto: uses Otto in Anything docs. google to stuff of lot a move dropbox, gmail check downloads folder. Files it online in dropbox, move a lot of stuff to go ogle docs. Anything in in online it Files gmail check downloads folder. over. anything copying not about careful super was Ottomotto that was copied from Google? NO. he was super careful about not copying anything over. he NO. Otto motto that was copied from Google? Filevault enabled. enabled. Have Have you you wiped wiped your your laptop laptop recent? recent? No. No. but but he he may may have have wiped wiped itit in in 2014. 2014. Filevault Reinstalled OS. Reinstalled OS. ~oOO Uses itit to to keep keep big big files. files. Shredded Shredded all all the the drives. drives. New New drives drives not not even even formatted. formatted. oo .. Uses ll('o On to to the the next... next... On Desktop. Used Used as as aa gaming gaming machine machine running running windows windows 10. 10. There There is is nothing nothing on on there. there. Pictures, Pictures, no no work work Desktop. email. Doesn't seem to be in scope. 0o Dell servers in storage. Lathrup, Ca. hasn't touched the, was never google property. Contains what is now google data. Vutool, 510 systems, and Anthony's Robots. VuTool turned into Streetview. 510 moble mapping Anthony's robots, wiring for robot cars. Contained log of gps, indoor mapping tool, trials of different versions of camera and GPS mapping. Made a list of what they wanted, these machines were part of what they didn't want . Google took all the info and let theft these machines behind . Lets put them in storage. Google didn't instruct them to keep or destroy any of the assets so they kept them in storage. They delivered what they wanted and left behin~ the others. 20 Homebuilt machines were part of the same agreement. Doesn't know whats on them. Never used for google related work. Part of the assets Google didn't want. Not attached to these. Doesn't know how many or whats on them. May not even know where they are. Haven't accessed anything since 2010 or 2011. Employee workstations. Bought 510 later. Bought vutool in 2007?? 10 email. ac unts. (gmail may have dual authentication). Anthony is going to disable 2 factor so we can pull down his accounts. Cant disable it on his phone so he gives us authorization to use "authenticator" on his phone to access his account. gmail account. his gmail its anymore. IfIf its items anymore. the items of the possession of have possession doesn't have Lists He doesn't past. He the past. in the em ails in access emails to access devices to r:nany devices Lists many he doesn't own it anymore. not listed, anymore. it own not listed, he doesn't 10 accounts. emaill accounts. 10 emai He many. He not many. but not Some but google? Some from google? emails from yourself emails Bulk send yourself ever send you ever Did you personal. Did are personal. accounts are of accounts Bulk of in personal in or personal tax or likely tax are likely most are but most personal, but to personal, was work to from work emails from are emails There are that. There about that. cafeful about was cafeful CONFIDENTIAL CONFIDENTIAL 0021121 STROZ_ 0021121 STROZ_ 23 of 23 TX-8855, Page 22 of TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 4 of 24 nature. A A few few files files he he needed needed to to print, print, but but not not substancial. substancial. We We should should search search from from nature. @google.com.. @google.com @mac account'is accQunt'is not not use use much, much, @mac @US, election election stuff stuff @US, UCFSRoboqprbmotional stuff) stuff) discount discount for for printed printed cuircut cuircut boards boards UCFSRoboqpromotional Others were created for dating sites, Otto is otto related . l.e..c:naJ ema il acco unts Qutside of google and otto gps on bulldozers. h l.e..c:na.l Google encourages outside projects. Work accounts Set yp 2016 oto.o March 1 2016. Should not contain anything prior to 2016 (nothing (hothing interesting) Uses them now (otto) for work Hard end date January 24ish . (January 15-Feb1). 1th Domain may have been established prior to Jan 24 h,, but email was setup after. When was the Admin created on the Otto accounts? April 9, 2007 (started at Google) . Through the Vutool acq . Sebastian Thrun, Andrew Lookingbill, Joakim / / " April9, Arfvidsson, Handrik Dahlkamp, (founders of Vutool) joined Google to start streetview. /~ Signed invention, employment, etc agreement. I-r-€ceived l-r-€ceived separate contracts. -- What do the contracts obligate you to? ot to approach employees, and to keep thei r secrets a secret. otto He shouldn't tell others about their secrets. Any special policies? Several levels of non solicit, there are people who cant solicit for a year or) encourage to leave . privacy, etc~ No training Any other obligations? Not solicit or disclose? Training courses, political, user privacy, on non solicit or confidentiality. There was training on queries and user data, but nothing on IP related . Took great care in user data. r----------------· What info did you have access to about other employees. Managed 25 people, he had access to salary etc. only bonus, etc. home address, work eva Is, performance rating scores, coach them for promotions, etc. evals, the 25 he managed . He didn't have HR access. Only has some data on Laptop. Anthony is writing down the list of 25+ employees. Exhibit 5. long the long create the (to create knew (to or knew with or work with He to work used to he used employees he what employees see what to see records to his records through his went through He went exhausted list. exhausted list. CONFIDENTIAL CONFIDENTIAL 0021122 STROZ_ 0021122 STROZ_ 23 of 23 TX-8855, Page 33 of TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 5 of 24 Side work: work: what what isisgoogles googles policy? policy? Anything Anything you you did did not not related related to to google google work, work, itit was wasyours. yours. Google Google Side doesn't care care unless unless its its directly directly related related.. doesn't ~7 ~7 Side projects projects while while at at Google? Google? Side Main work: work: started started in in 2007-2008 2007-2008 Streetview Streetview.... roll roll out out vehicles vehicles world world wide, wide, Main (GEOS) 2008-2009 airplane airplane view view aero aero imagery. imagery. (GEOS) 2008-2009 ~ 2008- started started mapping. mapping. Setting Setting up up operations operations in in Mountview Mountview and and India, India, extract extract cities cities of of stop stop signs. signs. ~ 2008\~~ pizza, deliver to streetnames (GT, (GT, Ground Ground Truth). Truth). This This isis all all confidentia confidentia .. Requested Requested to to do do aa TV TV show show to deliver pizza, \~~ streetnames started aacompanyapprove companyapprove-ttbVGoogle. nthony's Robots Robots (external (external non non google google company) company) 20 20 8-/ 8-/ LLoL{ -ttbyGoogle. S aa ee nthony's started ~ 2009. Never Never used used funds funds from from Google. Google. Prototype Prototype this this (tv (tv show). show). Discovery Discovery chann chann~. ~ ~~ ~ 2009. ~J d.{-+ + s ardware done ' Finished US US Maps, Maps, started started goo~ gOo!\..~ffer in ~ardware done by by ~ ·Finished // nthony's nthony's Robots, Robots, ftware ftware at at 510, m Google. Sold Sold 2011 2011 to to Google. Google. 510 510 systems systems also also brought brought into into Google. Google. Was Was In 510, just just used used Google. their equipment equipment (but (but he he was was an=t' an"f'nnvestor). vestor). Started Started to to invest invest in in 510 510 in in 2005. 2005. Darpa Darpa Grandchallenge Grandchallenge their competition), farming farming navigation navigation for for Tractors, Tractors, Topcon Topc6n then then used used for for motorcycles, motorcycles, then then tractor tractor (robot competition), Google was aware of all side projects. Manager was a mentor. No secrets? No pol icy really as long as its not competing . Positions at Google: years. / 2007 Software Engineer to 2011.V 2011-2012 Engineering manager / b~ as product ma~er 2012-2016 Engineering Mana¢ /utf q;J\~~M ~~M /ufci'J\ Get shit done rolls. 2007-2011, find out ~ eeds to be done, do it, move on. Wrote a bill to pass self driving car. / '""' rolls . ~ Never wrote any software code . Technical project manager rOIlS I Project names Streetview (City Block), Ground Truth, Chauffer, GEOS. Help on various projects w) . (mbo"d, (Selfdc;,;ng wi· Chooffec (Selfd,;,;ng tell,pcesence). (h"ffe, (mbo.,d, tell'p,esen,e) CONFIDENTIAL CONFIDENTIAL 0021123 STROZ_ 0021123 STROZ_ 23 of23 TX-8855, Page 44 of TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 6 of 24 Interview starts-approximately 10:10. Interview starts-appro ximat ely 10:10. of~alige Returned"iphone to Ant l'n:J'rrr.fotik possession nge n of~a Returned"iphone to Ant l'n:J'rrr,t'O'Ok possessio d. e was t from.Goog1 d. Gmai Talking about the emai kj ~it he laptop. Otto. Q.tto . Q.ttois notsynce synced. Gmaitfrom ..Goog1e wassynce synced. is not Talking abou t the ema il=-ef.M:he laptop . Otto Do you have access to Google work mail ontheir theirserve server? No,nonoway. way. r? No, Do you have access to Google work mail on The messages were synced awhile ago. The messages were synced awhile ago. nal) has ox (perso . Dropb e drives ottomotto.com, google drives. Dropbox (personal) has What is on theeloud repsoitories? Ot.o andottom otto.c om, nonogoogl What is on the cloud repsoitories? Ot.o and . docs) Google work stuffwhich whichhasn' hasn't been touched (likely Chauffer docs). ffer Chau (likely t been touched Google work stuff Do you actively use this account? Yes Do you actively use this account? Yes ately g. He Apple Laptop not synced up for email, dropbox orany anydrive drivesyncin syncing. Hedoes doesaccess accessdrive drivesepar separately ox or Apple Laptop not synced up for email , dropb in. doma gmail ered gmail domain. domain registered through chrome browser, log into email. Otto motto in regist otto doma throu gh chrome browser, log into email. Ottom OClll < possession of 3 ipads OC!Il < possession of 3 ipads n. ItItmay mber the pting to Anthony forgets his password to one of the ipads ipads and and isis attem attempting to reme remember the patter pattern. may Antho ny forgets his password to one of the disable if too many incorr incorrect attemtps are made. ect attem tps are made. disable if too many Return to where we left off yesterday. Return to where we left off yesterday. Hi"redin 2007 to work on streetview until 2008. Hi"red ln 2007 to work on stree tview until 2008. 2008 and 20'09 side project GEOS 2008 and 20b9 side project GEOS d maps ase behin 2008 started to work on mapping in Mountview and India. Make the datab database behind maps.. 2008 started to work on mapping in Moun tview r. ;project, 2009 joined· chauffe 2009 joined· chauffe r. .project, Side job 2008 2009 worked on robot cars (deliver pizza) . er pizza). Side job 2008 2009 worked on robot cars (deliv Google.. by Google and got excited. All Google saw it was possible approved by was approved th iswas of this All of Google saw it was possible and got excited. This became Anthony's robo.ts which was sold to Google. to Google. This became Anthony's robo.ts which was sold 1U systems predated G~ araison was the original name.. original name 1 U.systems predated Gongle_ araison was the ~ -~ /I old 510 systems to Google in 2011. old 510 systems to Google in 2011 . Software Engineer supervisor Sebastian Thrun. .2007-2011 2007-2011 Softwa re Engineer supervisor Sebastian Thrun week or so. -------week or so . foraa supervisorfor initiallysupervisor hisinitially asashis ~ , Sebastian still his boss t, *hris Urmson Urmson prom oted , Sebastian still his boss t' *hris ~promoted ~~~4 Salecky was then his s~vlsor. Bryan Salecky was then his s~v1sor. ~ ~~4Bryan Who else did you work Who else did you work from 510. from 510. Refe nces the typed long list he previously provided. A lot of them came -- CONFIDENTIAL CONFIDENTIAL TX-8855, 5 5ofof 2323 , Page TX-8855Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 7 of 24 employeeshe heever evercontacted contacted during duringhis histime timeat atGoogle. Google. employees Gmail contacts. contacts. """"I+rh"""""c""raea'te the list? Went through the phone contact list. Gmail Did you you rely relyon on internal internal contact contact list? list? No No Did Put an an arrow arrow next next to to those those he he worked worked with with on on aaregular regular basis. basis. Put He will will identify identify those those employees employees he he did did group group with with projects projects with. with. ,.-.. ,.-.. ~ ~ He (talking to to himself, himself, may may have have found found aamistake mistake on on the the list). list). (talking ..-' J~ ~..-' (asked for for the the handwritten handwritten list list back back to to make make some some adjustments) adjustments) (asked e aa street Of documents documents did did you you cwte cw.te whil~ whil~ at at google~ google-1l ~ pe~ational pe~ational manua manua how to 0 te street What types types of What tt iew iew car, car, how how they they systems systems fit fit together, together, lots lots of of emails, emails.....some some....pr£sentations pr£sentations., tt aining aining information information AERO AERO magery, internal internal presentation presentation how how to to evaluate evaluate aa product, product, ~ ft mafery, /U Ce-c 6C-C!U ~P; tt1 Where did did you you store store these? these? On On Qogle Qogle Dr'iVi Dr'iVi Where '/ 'I Were you you issued issued any any devices? devices? Yes, Yes, (\lesktops, Giesktops, 33 raptops, 'i'aptops, may~ may~ tops11inux topsllinux desktops) desktops) mac mac laptop, laptop, 22 Were No policy? BYOD a have they chromebooks,2 levono laptops, 11inux, 1 windows. Blackberry. D. D' 2 Ievana chromebooks, Google has has the ability to install Gmail app and they control the s Google When you you resigned, resigned, what did you have? 2 desk, 2 laps When ... ftcuL../,ff ~i­ uSt[ c~ ~i­ :A f! ~ '-"-. ~:Aft What happened happened to the others? They were returned . What Did ever plu in flash or external into google desk ps. es, everyday, they use usb 0o move stuff you ever Did you ~ onto . ose were retu~ned (tracked by Google). car. the car. onto the f/k ' " r.. I All tags asset tags had asset All had . / poss·~e. {/) (/)"U) U) f~!;..s1:;f.;iM (~ f~!;..S~w( w?. Took them ..w?' J;:f.o Ever He had tons but destroyed. tbem J;:f .o_ personal usb on Google? Yes, its us aa personal Ever us to shredder and had.them shred e ew a 'bout this . this. ·bout had-them to shredder Wifi (2012). Wifi car (2012). any..streetview car into any..streetview disks,thC!i..,went disks,th~ ;MI· ' [¢turned ~~H'l-l::fte--dtrn:rtt"lef! He has has some some other other random random parts parts he he disposed disposed of, of, ose ose late late He rein aluminum, robot parts (nonproprietary), test c~~eras . They re in the the house house in in aa box. box. He He fo fo They . c~~eras test aluminum, robot parts (nonproprietary), and ed rthem. stroyed he was looking for stuff to make sure he didn't have of anything. stroyed them . red and anything. of have didn't he he was looking for stuff to make sure ,) have to want didn't he name. their melted . He paid to have them destroyed. He doesn't know their name. he didn't want to have melted . He paid to have them destroyed. He doesn't know fJ anything left. left. IfIf he he gave gave itit back, back, he he thought thought itit would would spark spark unnecessary unnecessary back back lash. lash. anything /J!l () t, Did you know the files were on your computer before yesterday? No. ~~~~:::::,,::,~::::~:::::::::::::,~::::,,,, :::::':::::::::::::~~~~:::::';::tO~::::~:::::::::::::t~::::,;og :::::,::::::::::::: tct"-1 tLt-1V 0 Any hard copies? ]'Jo 1'Jo ~~~ ~ 01/ ( 0O? tjtfJ\j 8tf)U pta lapta Did you download copy or export? Not with the intention of leaving. Some stuff on the Apple Ia R&D stuff? Yes Technical? Yes Customer? Yes Software or hardware? Maybe Employee data? Yes Trade secrets? Yes IP? No there.. was there remember itit was didn't remember He didn't Google. He He at Google. while at this while do this to do customary to because''lts customary iS-stuff because"its th iS-stuff has th He has Upon discovery the e advice was not to ~Iete. Upon discovery th,e advice was not to ~lete. -- --- stuff).. of stuff) box of (the box destroyed (the was destroyed sensitive was Did non sensitive some.non and some. disk and the disk Yes the else)7 yes destroy_ anything else you destroy-anything Did you -------,,-----The week. de.stroyed·last week. was de.stroyed·last stuff was of stuff box of r--T'he box disk) the disk) destroy the to destroy me to told me (they told Did no (they Uber?) no (from Uber?) stuff (from hat stuff destroy tthat to destroy you to tell you anyone tell Did anyone CONFIDENTIAL CONFIDENTIAL 0021128 STROZ_ 0021128 STROZ_ 23 of 23 TX-8855, Page 99 of TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 11 of 24 Did you you check check all all your your email email and and storage storage accounts? accounts? Physical Physical stuff, stuff, not not digital digital media media.. Did Did Did check online online stuff? stuff? No No y~u check ~id ~ ~ om Om/1( /l(V vrV ccable ' ::Jming wa Your you first first hear hear about about OttoMottoC OttoMottoC';:)ming wa'· ccable.. you Your They discussed lior lior joining joining Chauffer. Chauffer. He He ran ran aa competitive competitive project, project, They spoke spoke aa couple couple of of discussed ~---~ -----~ times. Their Their first first meeting meeting was was on on campus campus (august (august or or sept sept 2015). 2015). times. (Ma~. They talked talked about about what what was was going going on on at at Chauffer, Chauffer, Anthony Anthony tried tried to to get get him him on on the the team. team. They lior was was telling telling him him about about Alphabet, Alphabet, the the clothing clothing technology. technology. Alp~_g_be-ris Alp~,9.bet-is a a holding holding co co for for Google Google.. They They lior ~ discussed possibly having Trucks an Alphabet product. ~ They talked about the opportunity for Autopilot. Tr~~ket, aftermarket kits, etc. More like the Tesla He had chats with other people regarding how to make it work at Google. The opportunity with lior was --.... ---.. a last option (?). When did you start to talk about a start start~~tside ~~tside meeting, early September. The Goo -- /' -Ef-01iVeSnear by too too.. -Ef-crrrVeSiiear _,- Second outside meeting is when things started to solidify. They discussed waiting until they leave or lets ) ,.",thing this through~f:.:_ f:.:.irs irs:t~ _---------------------------~ ----------------------------___./ :t~. - When did you talk to larry and Chris? (wrong path converstion) Jan 2015. They discussed releasing the car, the agreed but then moved back to the original course . It was clear to Anthony a week before he left that the path was not going in the direction that worked for him. Every 2 weeks he met with his employees for 30 minutes to see how things are going. How many group meetings? 3, 1 bbq, ski trip, Ipm gathering, 1 pm gathering at Anthony's house. 1pm gathering, Matt Williams, lior, others on team (Chauffer) Brian Cullha, Brian Tunellini (?) When? over, came over, people came (harmless, people 2015 (harmless, December 2015 BBQengineers December software engineers (perception) 11 software team (perception) laser team whole laser BBQ- whole very casual) very casual) Ski 2016 January 2016 trip- January Ski tripAnthony meetings. the meetings. about the board about the board on the writing on was writing Ant hony was He chats group chats and group 1s and on Is had 11 on He had 11 on date) company date) new company (forming new on 11 (forming CONFIDENTIAL CONFIDENTIAL 0021129 STROZ_ 0021129 STROZ_ 23 of 23 10 of lX-88SS, Page 10 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 12 of 24 }4lit' }4Iit' "1 ~ f,.J)Itl p,.J)Iti .· .."",., Discussion Discussion with with Anthony Anthony regarding regarding what what they they want want to to do do.. 30 30 minutes minutes every every 22 weeks. weeks. ._,., p 12) (December (December 2015-Jan 2015-Jan 26) 26) did did he he initiate initiate it? it? ItIt was was mutual mutual about about whats whats next. next. They They were were 12) cussing the the bonus bonus payout. payout. 44 year year increments. increments. IfIf you you left left the the company company within within 66 months, months, you you got got itit all. all. cussing They talked talked about about lasers lasers for for drones, drones, security. security. Electrical Electrical Engineer. Engineer. #1 #1 tech tech lead. lead. They They talked talked about about They trucks, and and sort sort of of interested, interested, he he was was not not interested interested in in the the kits. kits. He He was was more more interested interested if if Arta, Arta, Sam, Sam, trucks, Liala were were to to join join.. Liala BBQ Social Intro to Lior lntro Pierre, Gatean, Luke Washer, Drew Ulrich, Morriss, (side conversations at bbq) Laser team chat with Brian Selleski All hands Tues and Thurs After talking to Chris and Brian about Anthony's future, they address the team that Anthony is moving off the laser team . Brian leaves the room and the team chats about it. After the bbq people talked amongst themselves, Anthony didn't recruit anyone directly. There might be some text messages. One on Ones Wanted to get their thoughts on trucks vs kits, exploring ideas. - Pierre (Dec 2015) regularly" regularly.....- Gaetan (Dec 2015) regularly / p Will MCCann (Jan 15, 2016) 2 times p Drew (Dec 2015) 4 times ...,.._ ......... Bernard (not at all) ---- Liala Mathos (Dec 2015) regularly • Blia times 2016) 22 times (Jan 2016) Gassend (Jan se Gassend Blia se Anthon y Hinton(not all) at all) Hinton( not at Anthony CONFIDENTIAL CONFIDENTIAL 0021130 STROZ_ 0021130 STROZ_ 23 of 23 11 of lX-88SS, Page 11 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 13 of 24 lonut lordache lordache (same (same as as Will) Will) lonut I stepped out for a break and returned within 5 minutes (see Handley's notes for diagram of what was written on the board) Those who solicited Anthony- Bryan High priority (those who showed interest) *Pierre Gaeton Laila Others who they spoke to "low" Will Drew Blaise lonut Luke Rahin Sam Don What did you talk about regarding new co and when? All communications were verbal *Pierre: (talked about different options, he preferred trucks, he wanted to be a founder, wanted to mat cr'Lior's stake, committed to funds, had meetings at his house. Strat was to ask Chauffer, if they didn't they would try trucks at alpha, if not they would leave. He asked to help and bring on people. He wrote up and brought offer letters for people to join NewCo. (hardware engineer) Gaeto g: (much lighter than discussions with Pierre. He requested a specific number of engineers. He • wanted to invest. He want Anthony to hire his brother and others Not Google employees) they met 3 times one on ones between Dec-Jan (mechanical Engineer) ~: ~: understand to understand wanted to she wanted kit, she vs kit, trucking vs chatted, trucking (she They chatted, Pierre. They to Pierre. talking to after talking him after approach him (she approach Jan and Jan Dec and between Dec on 11 between times 11 on met 33 times They met maternity time). They the time). at the pregnant at was pregnant (she was things (she leave things maternity leave person. in person. (Manufacturing talked in they talked by, they close by, sat close she sat engineer) she (Manufacturing engineer) CONFIDENTIAL CONFIDENTIAL 0021131 STROZ_ 0021131 STROZ_ 23 of 23 12 of lX-88SS, Page 12 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 14 of 24 ny did not encourage him to leave Google. Mark initiated communication Dec. he im again in Jan. Anthony wasn't very interested in him. Mark heard about it and wanted verbal meeting at Google. Z~ meeting (1 verbal chat 1 meetin he needed a team, he knew Zach letter. Anthony initiated it ver is house) he received an offer from Anthony. Anthony said nhappy. They spoke at Zach's house and was given an offer 23,d). the ~ill MCCann: 2 discussions, 1-1 on 1 at Google. and 1 evening walking around (Jan 15 and 23'd). M 15 was himS:pproaching asking what they were up to, Anthony said he was thinking of leaving and 151k doing something in the robot car space. The evening meeting was to finalize his offer letter. Will requested the meeting. They discussed salary and offer. Will was given an offer prior to the meeting through Rhian. The offer may have come later (he did not end up joining). ~ discussed general business client. Discussed new focus project at Google. Started to talk about newco in Jan . they discussed a start up earlier but nothing specific. The idea was that the team would leave google to start something. Drew received an offer. He is a mechanical Engineer. Maybe a text about setting up an evening group discussion . Sent to Google email address. Anthony encouraged him leave Google. ~e:Anthony Anthony did not encourage him to leave google. He approached Anthony (seemed pushy) they ~e: had 3 discussions and seemed forceful. 2 were on campus, 1 off campus (on the phone). There are phone calls and text messages regarding comp, role and needs. Jan communications. lonut: 1 chat in person Jan 15, 2016. Talked about where the business would be base, he approached Anthony. -- Luke: same as lonut, 2 chats both at Google, initiated by luke first then Anthony followed up. All verbal. Second meeting was discussed location for newco. General conversation about what Luke heard from nd 2nd others. He wanted to know more. Anthony asked him to talk to the others. 2 meeting was a follow up. He received and signed offer letter. Which has since expired. 3'd time met with Anthony to Rahin: Hardware Engineer. Approached by Pierre . Follow up by Luke, 3,d nd meeting was at google (walk). 3'd meeting was discuss salary. Verbal communications at Google. 22nd likely after work. Anthony didn't initiate any meetings. Not texts or emails. Jan 2016. Received offer, not signed. Which has expired . asked . (I stepped out of the room to have Don Sam : aware Engineer. Approached by Pierre. Later asked. n the COC)o COC). Break for lunch. Sam initiated conversations. They talked about more technical things. Sensors they should .develop. Why are robots important? Talked about compensation. Didn't talk about his role. No text or emails ~ Anthony Anthony \ ched out to him in November. They talked about macro pictures, why trucks are ·important. e didn't get an offer letter. 1 in person meeting. A few text about when and where to meet. ey met downtown SF. Embarc and Market . They met in January 2016. meet. CONFIDENTIAL STROZ_ 0021132 lX-88SS, TX-8855, Page 13 of 23 Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 15 of 24 Don - 22 chats chats Joined Joined Otto OttoMotto. He was was always always frustrated frustrated with with Google. Google. 22 in in person person chats chats about about Motto. He Donnd st 2nd. initiated Don meeting, 1't ~hony hony leaving leaving and and what what he he was was going going to to do. do. Anthony Anthony initiated initiated 1 meeting, Don initiated 2 • Jan Jan 4-5 4-5 ~ nd or 6. 6. 22 meetings meetings at at google. google. They They are are friends. friends. 2nd 2 meeting meeting was was about about general general discussion discussion about about what what they they or would be be doing. doing. Software Software engineer. engineer. Offer Offer letter letter was was given given before before Anthony Anthony left left Google. Google. They They would communicated aa lot lot on on aa personal personal level. level. He He joined joined Feb Feb 25ish 25ish.. communicated Anthony was was clear clear that that he he wanted wanted to to do do this this project project at at Google Google but but itit didn't didn't seem seem to to happen happen so so he he left left to to Anthony do this this on on his his on. on. do Brian (user (user experience experience designer) designer) one one onversation. 11 planned planned in in person. person. Anthony Anthony walked walked up up to to onversation. Brian 05,2016. 2016. They talked about the direction ofthe internal " Jan 05, uw hTS'desk and said "do #)'tu project. They had anned when Anthony was out with Matt and saw him at a coffee shop . Brian rd 10.. 3 conversation was "we just got offered more ~ ilz Coffee in Palo Alto. 3'd sa 10 joined e ha: given o0 stay, can I join you guys later?". Same deal applied to the other Brian . Pierre may have mo 1m an offer letter. ;> Brian (operation -program manager) manages the human side of the car. Used to work for Matt. ~ny and Brian meet after he heard what was going on . Seemed very interested . Brian reached out , to Anthony after he spoke with Matt. Walked up to Anthony's desk. Jan 2016 . He got an offer. (likely) ng time . They used to work on Streetview together. Dates Matt Wi llians. They spoke about this f D:t 2014 or Jan 2015. 109 mg concrete, but thinking about it. Fast forward to Sept, he said as t ack to Difr soon as he is paid he i g to leave. Matt encourages Anthony to leave Google . TheY'discussed a sn t agree that it's a good idea . He is the first of Chauffer to leave. He left Jan 4. He 10 1n when he returns from a long vacation . No discussions about role or compensation .. outfits the cars. He approached Anthony, they talk about money, the e didn't get an offer letter. He was going to wait for his bonus. Met in January twice . ~ eetings at Google. Anthony walked up to him the second time. n.;"..I~~~':'"' . T he ~~~~':""" Bryan Sellesky. He was upset that he wasn't apart of th he left and came back. nthony didn't give him any information . He found out Anthony was recruiting from~ aise may have told him . Not sure how he found out from~ .. AI iies there is a elCJ lies 0119 elu 116119 pp" 0o 11 jggs I!P" someJbipss exactly. Sept 2015 Bryan said" let dinner," "I know someSh m Fffi was never approached, but expressed intere (October)....... .t"Bryan later contacts Uber (October)........ ~ Bryan seems to wan 0o n ut Anthony doesn't trts'i' him .rs was he was if said Anthony Uber. to it selling and 'He said he was talking t er to have the vehicle team and selling it to Uber. Anthony said if he team vehicle the er to have 'He said he was talking t Uber to introduced was introduced to Uber Anthony was together. Anthony Uber together. they with Uber down with sit down all sit should all they should October. business. October. new business. he about new Uber about with Uber meeting with first meeting he first with meets with he meets evening he That evening expected. That he expected. than he zes Bryan advanced than more advanced was more discussion was of discussion levell of the leve zes the Bryan rr involved not involved but not on but going on was going what was of what aware of nds then aware was then He was 10m. He for 10m. stay for to stay decided to he decided nds he CONFIDENTIAL CONFIDENTIAL 0021133 STROZ_ 0021133 STROZ_ 23 of 23 14 of lX-88SS, Page 14 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 16 of 24 Collin (user experience) Lior: They had several conversation, chats, text, meetings with Uber. Anthony had the contacts with Uber. Lior' s email address on There may be one accidental email to Google account about meeting. (search Lior's Anthony' s devices) . Maybe snapchat. Anthony's devices). How did they begin? How do we build something at Google. It will likely be too complicated to do at is when they decided to make the move. Google so we should just leave. Nov or Dec is . " you rself in the company? To build what needs to be built. How did you see yourself Group Meetings. ere were a couple of side chats Laser Team BBQ to celebrate a mile stone. Discussed work st to the group. Nov 2015. about NewCo and related conversation. Lior was introd Dec 2015. 20 people Pierre, Gaetan, Drew, Liala, Lu , ior. Bunch of non google people. About everyone is interested, organized by Anthony . sl ide , ust verbal discussion (Lior may have had a slide pptx but not sure). Additional Claire Delaunay David Wakerstoffer Brian Dowdall Brian T BrianT Early jan 2016. ~~~'I'B'/!~ __ilJ.Qwed wed ~~""'-"'~l!:'!oeoliWJJ.Q without using any IP. They cou l~~NMI!'I'I!I'I!-!'I''''~~~~~ coul~~!lwMI!'I'e'I!-!!'I'T'M~~i:si~~ up. Not an official google trip. tted about how to build from scratch CONFIDENTIAL STROZ 0021134 15 of 23 lX-88SS, TX-8855, Page 1S Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 17 of 24 Who brought brought itit up? up? Anthony Anthony asked asked ififthey they could could make make aa laser laser wit wit ut ut using using IP. IP. Pierre Pierre said said they they could could Who to was ee "world" or infringing infringing on on IP. IP. The The point point of of the the laser laser interoperate interoperate "world".. Their Their intention intention was to do do redo itit or redo from scratch. scratch. this clean clean and and build build itit from this They would would rebuy rebuy the the same same parts, parts, but but they they were were not not They was not on this trip. trip. was not on this mg mg to to remake remake what what Google Google already already made. made. Lior Lior Drew organized organized meeting meeting at at Anthony's Anthony's house house to to discuss discuss an an exit exit from from Google. Google. Confirm Confirm within within the the nn Drew of day day Anthony Anthony would would leave leave and and the the rest rest would would follow. follow. couple of couple Piere ere Pi Gateon will Liala Brian Dowdall Claire Delaunay: now work at Otto c;:laire David Wakerstoffer: now work at Otto lonut: received offer that night (he req Luke : received offer that night Lior goo google people there. Other pon ccgppts Drew may have a calendar invite to e r;..a erg "pts Qtber havess Han e ou ex a offer letters. Actively encouraging people to leave. forwa rd.. They The n t day (Tuesday), they have a chat with Brian Seleski about his role at Google going forward Then was leaving Anthony announce ss something before the 11 am weekly meeting. Brian was going to di e laser team but staying within Google. 100 % charade. 100% up opens up then opens Anthony then room. Anthony the room. leaves the Brian leaves They news, Brian the news, break the They break meeting. They actually meeting. the actually to the go to They go Google, within Google, something within find something cant find he cant leaving ifif he be leaving the may be he may mentioned he Anthony mentioned discussion. Anthony for discussion. room for the room Alphabet. Alphabet. team.. the team of the charge of in charge person in loyal person more loyal Why put aa more to put wanted to They wanted replaced? They being replaced? you being are you Why are leaving was leaving he was undecided ifif he was undecided he was and he team and the team of the Anthony proud of was proud he was that he group that the group to the announced to Anthony announced the company.. the company does he does what he likes what Brian likes him. Brian like him. doesn't like Chris doesn't Larry say. Chris much say. have much doesn't have he doesn't but he does but he does what he likes what Larry likes but leaving. be leaving. may be he may knows he he knows but he CONFIDENTIAL CONFIDENTIAL 0021135 STROZ_ 0021135 STROZ_ 23 of 23 16 of lX-88SS, Page 16 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 18 of 24 Anthony leaves leavesthe the next next day. day. Anthony He spoke spoke with with Chelsea, Chelsea, John John kraftcheck, kraftcheck, and and Sergai. Sergai. Who do do you you contact. contact. Very Very very very few few at at Google Google.. He Who didn't want want him him to to leave. leave. He He mentions mentions to to both both that that he he may may start start up up aanew new company. company. Sergei didn't Sergei John, what what happened? happened? He He asked asked what what he he was was going going to todo. He tries tries to to find find him him aaposition position back back at at do. He John, Google. Google. Chelsea and and her her boss boss and and bosses bosses boss. boss. (Stacey (Stacey Sullivan). Sullivan). Chelsea Social nice nice conversation. conversation. Social of people people reach reach out out about about joining joining Newco. Newco. He He responds responds that that he he cant cant respond respond or or he he doesn't doesn't A number number of A No Google. at anyone to talk doesn't respond. He answers social stuff but not about work. Anthony doesn't talk to anyone at Google. No Anthony work. about not but stuff social respond. He answers oral, written, or electronic. Inbound but no outbound. outbound. no but oral, written, or electronic. Inbound There are some people who left google on their own. There Claire: they used to date and had many chats about robots. She expressed interest in joining the Claire: newco. How many times did you meet about NewCo? 4 times. Started Sept2015. Software engineer. newco. Talked about the software requirement~ for a truck. She left Google 2 weeks after Anthony Talked Met David about N~wco 1 before and 1 after group meetings about Newco. He was on a visa that Met needed l't1 meeting at google, 2"d 2nd on the street by Anthony's house. Left 2 weeks needed to be transferred. 1' ago. ago. Dan Ratner used to work for Google but Anthony didn't talk to him. Dan talked to Lior after he left Dan Ratner Gooogle. Gooogle. How How many employees? 30 How How many from google? 16 (10 of them were recent). l't Sept. Uber Sept. with Uber communications with 1'1 communications Tell Disk·. the Dis with the happened with what happened us what Tell us l m"'g'.'-Anthony disclosed he went through his There th;;;ln-ncrr:rn>:-m"riti"i> how th;;;lr;ncrr-:rn>:-m'rii about how in about check in to check meeting to was aa meeting There was stuff data. Google data. sensititve Google have sensititve that have stuff that car. driving car. self driving create self to create docs to What Engineering docs value. Engineering high value. files, high design files, code, design Source code, it? Source on it? was on What was (Googles) car. the car. driving the for driving required for software required (Googles) software How process. work process. the work Through the it? Through obtain it? you obtain did you How did CONFIDENTIAL CONFIDENTIAL 0021136 STROZ_ 0021136 STROZ_ 23 of23 17of TX-8855, Page 17 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 19 of 24 How did did they they get get on on the the hard hard disck? disck? Nature Nature course course of of business. business. How out code code to to work work on on it. it. As As early early as as December. December. Checked out Checked Did you you create create the the files files on on the the disk? disk? He He got got them them off off the the personal personal mac. mac. Did be called? called? .tc .tc truecrypt truecrypt file file.. What would would itit be What can pull pull data. data. Common Common team team password. password. Anyone from from Google Google can Anyone for many many years. years. They were were likely likely there there for They as the the "box "box of of stuff" stuff".. Found them them the the same same time time as Found Who did did you you tell. tell. Attorney, Attorney, Liar. Lior. Who What happens next. Go to Uber, I have some stuff I want to get rid of. Cam Nina and Travis. Cam says: oh you should not delete that we need to see it and understand what in there. (for preservation purposes" Travis says: Don't take any advice from Cam. If you have google stuff I don't want know about it, I don't want it here, do what you need to do " Anthony says: I am going to delete it Travis: nods Cam clearly disagrees but does not object (Visibly (visibly disagrees) Nina: is amused data . Took them to a What did you do then? He left the meeting with the understanding to delete the data. shredder by the airport (Oakland). How long was the conversation . 3 minutes. Later that afternoon, Cam called and said "please don't shred them" Anthony said "too late", and then Cam said please don't delete or shred other things. Cam called back again and said "I want to make sure you don't delete more stuff". (sometime over the weekend). Lior Liar also called and said they told him the same thing, he may have spoken to Nina. Lior Liar only knew there was confidential data on there. tell should tell they should that they said that and said surprised and was surprised He was What data. He the data. had the you had out you found out he found when he say when Liar say did Lior What did it. delete it. to delete was to Uber consensus was the consensus clear the was clear meeting itit was the meeting After the it. After about it. Uber about Lior data.. the data delete the to delete suggested to never suggested Liar never Was disks? the disks? destroyed the you destroyed that you upset that Cam upset Was Cam They deleted. be deleted. would be disks would the disks understood the all understood They all CONFIDENTIAL CONFIDENTIAL 0021137 STROZ_ 0021137 STROZ_ 23 of 23 18 of lX-88SS, Page 18 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 20 of 24 Met Travis Travis in in 2012 2012 and and Garret Garret Kamp, Kamp, gave gave them them laps laps in in the the self self driving driving car. car. They They wanted wanted to to buy buy 20 20 cars cars Met right there there but but they they were were not not ready. ready. right off to to Jeff Jeff Holden Holden and and tried tried to to get get him him to to join join Uber. Uber. Late 2014, 2014, travis travis handed handed him him off Late business. 22 lunches lunches in in July July Later he saw Brian had joined Uber and followup meeting about a separate business. or August 2015. August Sept, Antony by himself, lets seek funding from you guys... started negotiating, (fund raising and purchase of future technology) . They said they didn't want to fund they wanted to be a beta customer, Talk to TK to decide what to do. Travis doesn't want to just buy stuff they wanted to be more involved, Started out them being a customer. They go to Uber twice a month since Sept, (Brian, Cam, Nina, Jeff, TK) They spoke to Travis and said they were thinking of leaving Google in Oct., Brian peels off (from Google). And their project kept moving forward . 1 meeting with Brian Sand Uber During meetings at uber, do you discuss the Newco? No specifics, just that there is a New Co When did they become aware? Second meeting. Did Uber direct the hires? Not really, no specific names. General conversation about laser technology . What happens December 2015 They progress further and further, price, tax structure, Reached agreement December (started negotioning term sheet which was signed in Feb) . There was a plan to acq Otto before he left Google. The group discussions were sparked by internal issues at Google . John Bayers (runs Uber self driving car division). Things are progressing but not as quickly as they hoped . One other person at Uber Emil who is Cams boss. Only had 3 conversations. Make sure the deal was still on. Wanted to set up a corporate database to get people who worked on robots. Would you have left Google if Uber wasn't there? Yes. lunch. get lunch. lets get hey lets said, hey Brian said, and Brian Who Brian and congratulated Brian Anthony congratulated June. Anthony in June. who in called who Who called There up follow up later follow was aa later There was CONFIDENTIAL CONFIDENTIAL 0021138 STROZ_ 0021138 STROZ_ 23 of 23 19 of lX-88SS, Page 19 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 21 of 24 June 16th 16th Brian Brian left left google google to to go go to to Uber. Uber. June doing there. there. How How its its going. going. They They leave leave itit as as they they should should What do do you you talk talk about about at at lunch? lunch? What What Brian Brian isis doing What follow up. up. Brian Brian follows follows up up in in July July or or Aug. Aug. They They meet meet alone, alone, in in person. person. They They talk talk about about ideas ideas .... follow When you you left left the the first first meeting, meeting, did did he he encourage encourage you? you? Anthony Anthony was was not not solicited. solicited. When or 33 weeks weeks later. later. He He may may have have emailed emailed about about lunch? lunch? Anthony Anthony expresses expresses unhappiness, unhappiness, they they 2nd lunch 22 or 2"d need additional robotic efforts. The don't discuss New Co. they leave the conversation by having a mutual interest. @gmail.com gmail.com it would be interesting to have an offer from Uber to buy the Google team. They wanted to know the market value for the chauffer team. They never followed up on that. They wanted to put a price tag on the team. 3rd meeting. Uber said they were not going to get a price for the team . Anthony reached out for the 3'd They got lunch in SF by Uber office. (with just Brian at Alta Cafe) they start discussing uber buying lasers from the start up for their cars. 4th meeting Bryan Cam Nina meeting at Uber (Sept or Oct). Discuss customer roll up, they don't intend 4th to invest in a start up. They talk about being a customer, th 5 Cam Nina and Lior Anthony (customer deal) 5th th 6 6th Bryan Cam Nina (verbal of what they might do) Travis comes into the picture October at Uber office (Travis calls or text) Only emails with Jeff and Bryan. Some texts with Cam. Nina 30 messages TK 200 messages Jeff 20 messages. Travis is main contact. All emails were deleted from gmail account. It was weird to have emails from Uber while still at Google. Oct there is a 1 on 1 with Travis. They meet at Uber on Sunday. They talk high level robot stuff. This is the first long discussion with him, he doesn't know much about robot cars. He wanted to buy or nothing, 8pm to 2am. Bigger deal or smaller deal. Met with someone at uber the following week . Cam and Bryan. Only Anthony no Lior. At Uber. They get on the same page. Next steps are if they want to do something like this. There are a total of about 20 meetings . They then start to negotiate specifics. (nov-Dec) meetings now every other week. John. Travis, John. Nina Travis, Cam Nina Liar. Cam include Lior. and include regular and Post been regular have been meetings have the meetings Saleski, the with Saleski, meeting with the meeting Post the Continue month. twice aa month. meetings twice Continue meetings CONFIDENTIAL CONFIDENTIAL 0021139 STROZ_ 0021139 STROZ_ 23 of 23 20 of lX-88SS, Page 20 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 22 of 24 Did they they ever ever ask ask about about confidentiality? confidentiality? Yes, Yes, Did They discussed discussed with with uber uber multiple multiple times times before before leaving leaving google google (nov (nov dec). dec). they they always always said said they they would would They rd party called called Velenime Velenime that that has has similar similar technology. technology. Anthony Anthony said said he he could could do do itit start from from scratch. scratch. 3'd 3 party start without infringing infringing on on any any patents. patents. without of research? research? deliver deliver lasers, lasers, help help deploy deploy vehicle vehicle quickly, quickly, help help build build kit. kit. He He expects expects to to have have aa What sort sort of What role to be in charge of the technology. Not relying on Google technology to do the work for Uber. Have you discussed with anyone about joining Uber? No, just Liar Lior and Anthony. Nobody that he knows of at Google know about the Uber deal. Brian may have guarded the secret but he may use it later to help him negotiate later. (all speculation). John Hankey left, Larry Page, John Kraftcheck, John Hankey started a game co from Google. Lior and Anthony talked to him about how to spin out trucks. He left within the last 6 months. Asked advice how to handle Google legal, PR, mechanics. Wanted insite on the kit solution. (sept 2015) he doenst know about Uber. Are you anticipated duties at uber similar to google. Yes Will they compete? He will help a division compete with Google, but he will help build trucks and kits which wont compete. Describe otto : design trucks to eliminate a driver. kits? Sell hardware to install and have the car drive itself. Why pursue it? Its awesome. Great profit potential. Both jobs involve making something with wheels without a driver. Otto focuses on self driving trucks which is different from picking up people. The kits are secondary. Google wasn't doing any of this. Rely on experience at Google, did not rely on information. Relying on understanding. 50 SO (individuals) skill sets, engineers Do you have alternatives, yes Source? Take referalls, recruiting spree from non google, referals non google, they have recruiter. What is your role? Meet and interview all non google employees and evaluate. Not the sole person to hire. (has the power to veto) New hires meet with individually with people, group discussion, offer Have googlers contacted you about wanting to work at Otto. Yes, there are some more specific but he doesn't respond. They are all saved on his phone. Not taking any calls from Googleres. How match. and match. w2 and at w2 Look at salary. Look determine salary. you determine do you How do CONFIDENTIAL CONFIDENTIAL 0021140 STROZ_ 0021140 STROZ_ 23 of 23 21 of lX-88SS, Page 21 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 23 of 24 Glassdoor isis used used as as aareference. reference. Glassdoor Based on on skill skill set, set, that that determines determines their their role role at at Otto. Otto. Based that different different for for Google. Google. Totally Totally separate separate process. process. IsIs that for Google Google employees employees is, is, interview interview with with non non google, google, they they decide, decide, rhian rhian decides decides salary. salary. Expects process process for Expects Have them them sign sign aa piece piece of of paper paper stating stating they they are are not not brining brining in in any any data data What safeguards safeguards are are in in place. place. Have What from last last employer. employer. Google Google employees employees confirm confirm they they were were not not solicited. solicited. from has to to be be written written and and checked checked in. in. All code code has All Any training? training? No No Any Policy? Yes, Yes, don't don't bring bring personal personal computers. computers. Don't Don't take take any any tools tools home. home. Policy? rd party venors? venors? Yes, Yes, they they contact contact same same vendors vendors to to make make machine machine parts parts (not (not the the same same parts). parts). Any 3'd 3 party Any vendors. same contact will They They also purchase equipment boards). They will contact same vendors. boards). cuircut for (tooling They Made a list from trade shows. Agreements? Yes Anything to add? Probably not Anything you want to check? Sure but nothing right now Have you provided everything? Yes True and correct? Yes Did Oid you announce your departure? No No press release? No How do you think your departure will effect google? They will get press inquiries, slow them down . google. leaving google. or leaving co or new co your new about your to about spoke to Any you spoke individuals you these individuals with these communications with other communications Any other him. Anthony provided him. mary provided list mary the list off the them off checking them Anthony isis checking Google / ' Bavor / Clay Bavor with Clay side with Google side Cardboard Cardboard // // Mega presence Tela presence orTela presence or Mega presence CONFIDENTIAL CONFIDENTIAL 0021141 STROZ_ 0021141 STROZ_ 23 of23 22 of TX-8855, Page 22 TX-8855, Page Case 3:17-cv-00939-WHA Document 2623-10 Filed 02/05/18 Page 24 of 24 Clay still has some of his equipment. A robot arm. Non google side projects with clay predictor) Future game (stock market predictor} Prototype this Anthony's robots 510 Systems Laraison raison which turned into 510 (gps bulldozers) Darpa grand challenge into La Glimmer (3 second video sharing). Non google related. Dead start up Date Knight (non google side project) Nemo (non google) modular building manufacturing company. East Bay Portfolio (real estate development) Brian Dowdall CONFIDENTIAL STROZ_ 0021142 lX-88SS, TX-8855, Page 23 of 23