Ex-Uber In-House Lawyer Fights Waymo's Quick-Turnaround Depo Request
Former Uber in-house lawyer Craig Clark argues he cannot be forced to testify 3,000 miles away from home on less than a week's notice.
December 19, 2017 at 02:51 PM
5 minute read
A former Uber Technologies Inc. in-house lawyer is fighting Google subsidiary Waymo's attempt to depose him this week in the $1.86 billion trade secrets litigation between the two rival companies.
Until he left Uber last month, Craig Clark was in-house counsel in the San Francisco-based company's security division. Clark was fired for his role in hiding a data breach from 57 million affected users, according to Bloomberg LP. He is not a party to Waymo's lawsuit against Uber in California federal court, which is related to automated car technology.
Clark, now living in South Florida, argues he cannot be required to fly 3,000 miles to San Francisco to testify Thursday about a whistleblower letter unsealed Dec. 15 in the civil case. The letter from former Uber employee Richard Jacobs alleges Clark trained the security team to use disappearing and encrypted messages, and to mark communications as “attorney-client privileged” to evade discovery.
“Mr. Clark, whose sterling reputation in Silicon Valley has been wrongfully damaged by an underperforming and disgruntled former Uber employee, anxiously awaits the opportunity to clear his name and to expose the sensational and patently false allegations made by Mr. Jacobs,” Clark's attorneys argued in a Monday filing in Miami federal court. “Mr. Clark, however, is entitled under the Federal Rules of Civil Procedure to do so at an appropriate time and place, not across the country in a hastily scheduled deposition without adequate notice.”
Jacobs' attorney, Clayton Halunen, who wrote the letter and sent it to Uber in-house counsel Angela Padilla in May, did not respond to a request for comment by deadline. Jacobs retracted some of the allegations in a November hearing.
Clark hired Miami attorneys Ryan Stumphauzer and Jorge Santiago of Stumphauzer & Sloman. Stumphauzer specializes in white-collar criminal defense and was appointed special master in the nationwide Takata airbag litigation.
According to the motion to quash and stay the subpoena to testify, Clark did not have time to prepare for the deposition with his counsel since he read Jacobs' letter at the same time as the general public. He was served with the subpoena at his Florida home Dec. 15.
“Mr. Clark and his counsel will have only three business days to prepare to testify on several issues, many of which are also the subject of the government's criminal investigation,” Stumphauzer wrote. “Moreover, due to the compressed time frame, Mr. Clark has not been able to meet and coordinate with counsel for Uber, his former employer, regarding the delicate and difficult attorney-client privilege issues that will undoubtedly arise during Mr. Clark's deposition.”
According to the motion, Clark's lawyers tried to negotiate with Waymo to limit the deposition to four hours, to avoid questions about the 2016 data breach, to produce relevant documents days ahead of time and to pay for travel to California. They did not reach an agreement.
Stumphauzer did not respond to a request for comment by deadline. The subpoena battle was assigned to U.S. District Judge Kathleen Williams in Miami.
Waymo and its legal team at Quinn Emanuel Urquhart & Sullivan declined to comment on the motion. But in its response filed Tuesday, Waymo said it worked quickly to comply with a Dec. 22 discovery deadline set by Alsup in November. Uber was slow to provide contact information for Clark, “stonewalling” Waymo until Dec. 8, the company said.
Waymo served the subpoena at three different addresses listed for Clark, including the Boca Raton address where he says he now resides. The notice mistakenly referred to San Francisco as the deposition location, according to Waymo.
“Waymo is willing to depose Mr. Clark either in Miami or in San Francisco, mooting this complaint,” according to the response.
The underlying California civil case is scheduled for trial Feb. 5 after two continuances, the second one coming after what the special master in the case called the “belated discovery” of Jacobs' letter, which Uber should have produced in response to May discovery requests from Waymo.
“The facts in this case suggest that Ms. Padilla knew of the Jacobs letter at the time Uber had to respond to discovery requests calling for its production—it certainly was 'reasonably accessible,'” special master John Cooper of Farella Braun + Martel in San Francisco wrote Dec. 15.
In an unusual move, the Northern District of California's U.S. Attorney's Office sent Jacobs' letter to U.S. District Judge William Alsup, who is overseeing the California case. Federal prosecutors got ahold of the letter as part of a criminal investigation into Waymo's trade secret theft claims against Uber.
“While we haven't substantiated all the claims in this letter — and, importantly, any related to Waymo—our new leadership has made clear that going forward we will compete honestly and fairly, on the strength of our ideas and technology,” Uber said in a statement after the letter was unsealed.
An Uber spokesman reached Tuesday declined to comment further.
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