Case 3:18-cv-00296-LRH-VPC Document 8-10 Filed 06/22/18 Page 1 of 2 1 JACKSON LEWIS P.C. Joshua A. Sliker, Nevada Bar No. 12493 2 Joshua.Sliker@jacksonlewis.com 3800 Howard Hughes Parkway, Suite 600 3 Las Vegas, NV 89169 Telephone: (702) 921-2460 (702) 921-2461 4 Facsimile: 5 Attorneys for Plaintiff Tesla, Inc. 6 7 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 TESLA, INC., a Delaware corporation, Plaintiff, 13 14 vs. 15 MARTIN TRIPP, an individual, 16 Defendant. Case No. 3:18-cv-296 DECLARATION OF ANDREW LINDEMULDER IN SUPPORT OF PLAINTIFF TESLA, INC.’S EMERGENCY MOTION FOR AUTHORIZATION TO ISSUE DOCUMENT PRESERVATION SUBPOENAS 17 18 19 20 21 22 23 24 25 26 27 28 -1- Case Document 8-10 Filed 06/22/18 Page 2 of 2 DECLARATION OF ANDREW LINDEMULDER 1, Andrew Lindemulder, declare as follows: 1. I am an employee of Tesla, Inc., Plaintiff in this action. I have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could and would testify competently to such facts under oath. 2. Earlier this month, Tesla opened an investigation into one of its employees, Defendant Martin Tripp, who was suspected of extracting con?dential and trade secret information from Tesla?s systems and sharing it with one or more third parties. 3. During an interview with me on June 14, 2018, Tripp admitted to transferring Tesla?s con?dential and trade secret data outside of the company, including Via his personal email and cloud storage accounts with Apple (iCloud) and Microsoft (OneDrive and SharePoint). Tripp also admitted that he had been deleting such materials to ?cover [his] tracks.? I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on this 32nd day of jun 30K at Sparks, Nevada. Andrew Lindemulder