Free Redacted Document - District Court of Delaware - Delaware

Case 1 :04-cv-01452-JJF Document 1 14 Filed 08/O9/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
E.1. DUPONT DE NEMOURS AND )
COMPANY, )
}
Plaintiff, ) Civil Action No.: 04-1452 (JIF)
)
v»— )
‘ l.
GREAT LAKES CHEMICAL CORPORATION, )
7 ) REDACTED PUBLIC VERSION
Defendant. )
. DECLARATION Ol? MAYA WINEBRI£NNER1`N SUPPORT OF
GREAT LAKES’ MOTION FOR SUMMARY JUDGM ENT ON CONTRACT ISSUES
1. My name is Maya Winebrenner. lam a United States citizen, currently residing
in Fishers, indiana. Each statement contained in this declaration is based upon my own personal
lcnowledgc, and is true and correct to the best of my personal knowledge, information and belief
2. I am currently employed by Cherntuna Corporation ("Chemtura"), the corporate
parent of`Grcat Lakes Chemical Corporation ("Great lealces"), as Finance Manager, Fluorine
Chemicals & Fumigants. I have been employed by Chemtura, and previously by Great Lakes,
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Case 1 :04-cv-01452-JJF Document 1 14 Filed 08/O9/2007 Page 2 of 3
since [year], and have served in my current position From 2000 to the present. 1 am currently
responsible for managing, the linancial and accounting, records for Chcmtnra’s Fluorine
Chemicals & Fumigants business unit, which includes the product HFC-227.
3. l prepared a summary of Great l-akes’ royalty payments to DuPont under the
l994 and 2002 Cr0ss»l.,icensc Agreements from numerous financial statements prepared and
maintained by Great Lakes in the ordinary course of' running its business. ' 1

all The business/financial records reflecting royalty payments paid by Great Lakes
to DuPont under the terms ofthe 1994 and 2002 Cross·l...icense Agreements cover the period r
from 1992 until the Fourth quarter of 2006. 1 could not locate records for two quarters in 1995,
namely the third and tburth quarters of 1995, but am not aware of any in Rurmation to indicate that
Great Lakes did not sell l·ll°C—227 during this period or that royalty payments were not made
during those two quarters Accordingly, the sumtuary l prepared includes estimated royalty
payments for these two quarters,. True and correct copies of`Great Lakes business and financial
records retlecting, royalty payments to DuPont under the 1994 and 2002 Cross—Liccnse
Agreements, from which I prepared the royalty summary in Exhibit 1, are attached as Exhibit 2.,
1 declare under penalty of perjury under the laws of thc United States that the foregoing
information is true and correct to the best of “ my knowledge, information and beliefl
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Maya Winebrérmer
RITA S. P/HEL
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Case 1:O4—cv-01452-JJF Document 114 Filed 08/O9/2007 Page 3 of 3
UNITED STATES l)IS'I`RiC"l` COURT
DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
I hereby certify that 0r1 August 9, 2007, I caused t0 be served by electronic mail the
foregoing document(s) and electronically tiled the same with the Clerk of Court using CM/ECP
which will send notification of such liling(s) to the following:
Richard Lt Horwitz
David E,. Moore
Po1:terAnclerson & Corroon LLP
Hercules Plaza, 6th Floor
I3 I 3 N. l\/Iarket Street
P. O. Box 951
Wilmington, DE l9899~095i
I hereby certify that on August 9, 2007, I have caused to be served by electronic mail the
foregoing document(s) to the following, who will also receive notification ofsucli tiling(s) from
CM/ECP:
Richard C. Komson
John I`. Gallagher
Morgan & Finnegan, LLP
3 World Financial Center
New York, NY l0.28l-2l Ol
{QL/» { .. ceew -+1-
Fredericlc L. Cottrell, lil (#2555)
cot£reli@rlfZcom
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