DECL: DECLARATION OF MARY BETH BROWN ISO DEFS' SPECIAL MOTION TO STRIKE PORTIONS OF COMPLAINT FILED BY ELON MUSK, TESLA MOTORS, INC
This document contains a second letter from Stanford University confirming that Elon Musk was accepted to its graduate program in Material Science Engineering in 1995. This is the same letter quoted by Ashlee Vance in the appendix to his biography of Elon Musk.
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FILED
. SAN MATEO COUNTY
FRED W. ALVAREZ, State Bar No. 068115 i
GARY M. GANSLE, State Bar No. 200755 JUL 2 & 2009
STEPHEN L, TAEUSCH, State Bar No. 247708
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road f—
Palo Alto, CA 94304-1050
Telephone: (650) 493-9300
Facsimile: (650) 565-5100 . —
Attomeys for Defendant
ELON MUSK AND TESLA MOTORS, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
MARTIN EBERHARD; ) CASENO.: CIV-484400
)
Plaintiff, | ) DECLARATION OF MARY BETH
) BROWN IN SUPPORT OF
v. }) DEFENDANTS’ SPECIAL MOTION
) TOSTRIKE PORTIONS OF
-ELON MUSK, an individual, TESLA MOTORS, } PLAINTIFF’S COMPLAINT AS A
INC., a Delaware Corporation, and DOES 1 ) STRATEGIC LAWSUIT AGAINST
‘through 20, inclusive; ) PUBLIC PARTICIPATION (C.C.P.
» § 425.16)
Defendants. )
)
)
)
)
)
I, Mary Beth Brown, hereby declare and state as follows:
1. Tam employed by Space Exploration Technologies Corp., a space transportation
company founded by Elon Musk in 2002, as Elon Musk’s Executive Assistant. Ihandle Mr.
Musk’s correspondence. I have personal knowledge of the facts set forth herein, and if called as
a witness, I could and would testify competently thereto. .
2. InJune 2009, a reporter from a national magazine contacted me to request
confirmation of Mr. Musk’s degrees because the reporter was preparing a profile of Mr. Musk. I.
already had copies of Mr. Musk’s diplomas from the University of Pennsylvania in my
possession, and I forwarded copies of them to the reporter.
- 1 ~CADocuments and Settings\marybeth\Lacal Settings\Temporary Internet Files
BROWN DECLARATION iso DEFENDANTS’ SPECIAL MOTION TO STRIKE PORTIONS OF PLAINTIFF'S
COMPLAINT AS A STRATEGIC LAWSUIT AGAINST PUBLIC PARTICIPATION (C.C.P. § 425.16)
ConterPage 2 . Jul'20 2009 12:50PM s@=« 31@63-s001 p.3
1 3. As I was aware of the allegations made in Martin Eberhard’s complaint regarding Mr.
2 || Musk’s educational background, I requested confirmation from Stanford Univers ity (“Stanford”)
3 || that the allegations were inaccurate. Stanford’s Office of the University Registrar readily
4 | confirmed to me that Mr. Musk had indeed been admitted to Stanford’s graduate program in
5 || Material Science Engineering in 1995. A true and correct copy of the confirmation letter
6 || Stanford University sent to Mr. Musk, which I opened, is attached hereto as Exhibit 1.
7 I declare under penalty of perjury under the laws of the State of California that the
& foregoin g is true and correct and that this Declaration was executed on JulyZo , 2009 in
9 |) Hore , Califomia.
10
Mary Beth Brown
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-2-C\Documents and Settings\marybeth\Local Settings\Temporary Intemet Files\Conter
BROWN DECLARATION ISO DEFENDANTS’ SPECIAL MOTION TO STRIKE PORTIONS OF PLAINTIFF'S
COMPLAINT AS A STRATEGIC LAWSUIT AGAINST PUBLIC PARTICIPATION (C.C.P. § 425.16)Page 3 EXHIBIT 1Page 4 EXHIBIT 1
MOd %0€ @Page 5 STANFORD
UNIVERSITY
June 22, 2009
Elon Musk
Spacex
1 Rocket Road
Hawthorne, CA 90250
Dear Elon,
As per special request from my colleagues in the School of Engineering, I have searched
Stanford’s admission data base and acknowledge that you applied and were admitted to
the graduate program in Material Science Engineering in 1995. Since you did not enroll,
Stanford is not able to issue you an official certification document.
Sincerely,
Judith Haccou, Director
Graduate Admissions
Office of the University Registrar
Office of the University Registrar
630 Serra Street, Stanford, CA 94305-6032
. Jul'20 2009 12:50PM s@=« 31@63-s001 p.3
1 3. As I was aware of the allegations made in Martin Eberhard’s complaint regarding Mr.
2 || Musk’s educational background, I requested confirmation from Stanford Univers ity (“Stanford”)
3 || that the allegations were inaccurate. Stanford’s Office of the University Registrar readily
4 | confirmed to me that Mr. Musk had indeed been admitted to Stanford’s graduate program in
5 || Material Science Engineering in 1995. A true and correct copy of the confirmation letter
6 || Stanford University sent to Mr. Musk, which I opened, is attached hereto as Exhibit 1.
7 I declare under penalty of perjury under the laws of the State of California that the
& foregoin g is true and correct and that this Declaration was executed on JulyZo , 2009 in
9 |) Hore , Califomia.
10
Mary Beth Brown
jl
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14
15
16
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18
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-2-C\Documents and Settings\marybeth\Local Settings\Temporary Intemet Files\Conter
BROWN DECLARATION ISO DEFENDANTS’ SPECIAL MOTION TO STRIKE PORTIONS OF PLAINTIFF'S
COMPLAINT AS A STRATEGIC LAWSUIT AGAINST PUBLIC PARTICIPATION (C.C.P. § 425.16)
PDF Page 4
EXHIBIT 1
PDF Page 5
EXHIBIT 1
MOd %0€ @
PDF Page 6
STANFORD
UNIVERSITY
June 22, 2009
Elon Musk
Spacex
1 Rocket Road
Hawthorne, CA 90250
Dear Elon,
As per special request from my colleagues in the School of Engineering, I have searched
Stanford’s admission data base and acknowledge that you applied and were admitted to
the graduate program in Material Science Engineering in 1995. Since you did not enroll,
Stanford is not able to issue you an official certification document.
Sincerely,
Judith Haccou, Director
Graduate Admissions
Office of the University Registrar
Office of the University Registrar
630 Serra Street, Stanford, CA 94305-6032
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