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EXHIBIT B
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE
MICRON TECHNOLOGY, INC., )

)
Plaintiff, ) C.A. No. 00-792-SLR
)
v. )
)
RAMBUS, INC., )
)
Defendant. )
Deposition Designations
Hawkins Reporting Service

715 North King Street - Wilmington, Delaware 19801
(302) 658-6697 FAX (302) 658-8418
170
1 company since September 98?
2 A. No.
3 Q. Now, from the documents, I see
4 that in the summer of '98, in the summer again,
5 in the summer of '99, 1999, burlap sacks were
6 handed out to employees for them to collect
7 their documents to be shred.
8 Is Rambus aware of any other
9 instances since Joel Karp joined until today
10 when burlap sacks were passed out to employees
11 for them to collect documents other than in the
12 summer of '98 and summer of '99?
13 THE WITNESS: If your question is
14 have there been any other times when Rambus has
15 had its employees review the documents that they
16 have and discard the ones that were no longer
17 relevant or necessary since Joel Karp started in
18 1997, my understanding is there have been
19 multiple occasions.
20 As to those occasions overlapping
21 with burlap sacks, I think there's one in '98 as
22 you mentioned. There's one time in 1999. And
23 my understanding is that there was one made in
24 collection in conjunction with an office move in

(302) 658-6697 FAX (302) 658-8418
171
1 2000.
2 Q. Now, in 2001 when exactly was that
3 that you recall?
4 THE WITNESS: The event that I was
5 referring to in 2000 is I believe the last week,
6 December 2000.
7 Q. Do you know what instructions the
8 employees were given as to what to retain and
9 what not to retain?
10 THE WITNESS: The document
11 retention policy that Joel Karp distributed
12 in or had distributed in July of 1998 was, of
13 course, still in effect, and the employees were
14 still operating it pursuant to that. I'm
15 unaware of any additional instructions one way
16 or the other.
17 Q. Now, seeing as how you started at
18 Rambus in October of 2001, it's safe to say you
19 weren't at Rambus for shred day 1998; right?
20 A. That would be correct.
21 Q. And that would be true for shred
22 1999, you weren't there at Rambus then either;
23 right?
24 A. That is correct.

(302) 658-6697 FAX (302) 658-8418

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Case 5:05-cv-00334-RMW Document 3151-3 Filed 01/26/2009 Page 1 of 63

IN THE UNITED STATES DISTRICT COURT

MICRON TECHNOLOGY, INC., )

Hawkins Reporting Service

1 company since September 98?

3 Q. Now, from the documents, I see

4 that in the summer of '98, in the summer again,

5 in the summer of '99, 1999, burlap sacks were

6 handed out to employees for them to collect

7 their documents to be shred.

8 Is Rambus aware of any other

9 instances since Joel Karp joined until today

10 when burlap sacks were passed out to employees

11 for them to collect documents other than in the

12 summer of '98 and summer of '99?

13 THE WITNESS: If your question is

14 have there been any other times when Rambus has

15 had its employees review the documents that they

16 have and discard the ones that were no longer

17 relevant or necessary since Joel Karp started in

18 1997, my understanding is there have been

20 As to those occasions overlapping

21 with burlap sacks, I think there's one in '98 as

22 you mentioned. There's one time in 1999. And

23 my understanding is that there was one made in

24 collection in conjunction with an office move in

Hawkins Reporting Service

2 Q. Now, in 2001 when exactly was that

3 that you recall?

4 THE WITNESS: The event that I was

5 referring to in 2000 is I believe the last week,

7 Q. Do you know what instructions the

8 employees were given as to what to retain and

9 what not to retain?

10 THE WITNESS: The document

11 retention policy that Joel Karp distributed

12 in or had distributed in July of 1998 was, of

13 course, still in effect, and the employees were

14 still operating it pursuant to that. I'm

15 unaware of any additional instructions one way

17 Q. Now, seeing as how you started at

18 Rambus in October of 2001, it's safe to say you

19 weren't at Rambus for shred day 1998; right?

20 A. That would be correct.

21 Q. And that would be true for shred

22 1999, you weren't there at Rambus then either;

Hawkins Reporting Service

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