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`Exhibit 4
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`
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`Case 1:19-cv-07529-DLC Document 30-1 Filed 10/17/19 Page 2 of 3
`Case 1:19-cv-07529—DLC Document 30-1 Filed 10/17/19 Page 2 of 3
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF NEW YORK
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`Bot M8 LLC,
`
`
`1 Plaintiff,
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`
`
`E:
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`SONY CORPORATION OF AMERICA, SONY
`CORPORATION, and SONY INTERACTIVE
`ENTERTAINMENT AMERICA LLC,
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`[Defendants
`
`
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`Civil Action No.1:19—cv-07529-DLC
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`DECLARATION OF JESSE CLEMENS
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`1, Jesse Clemens, declare as follows:
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`1.
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`I work at Sony Interactive Entertainment LLC (“SIE”). My job title is
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`Technical Supervisor, Software Engineering.
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`I have been employed by SIE or its predecessors-
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`in-interest since 2011.
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`I am familiar with the facts set forth herein and could testify competently
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`thereto.
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`2.
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`I submit this Declaration in support of SIE’s motion to transfer this case due to
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`improper venue.
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`3.
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`The facts set forth in this Declaration were true as of August 12, 2019 and
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`remain true at present.
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`\
`
`10/ M m )(C
`
`
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`Case 1:19-cv-07529-DLC Document 30-1 Filed 10/17/19 Page 3 of 3
`Case 1:19-cv-07529—DLC Document 30-1 Filed 10/17/19 Page 3 of 3
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`4.
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`I have been informed that the plaintiff in this case has made the following
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`allegation in a brief filed in this case:
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`SIE employs personnel in this District and requires or strongly encourages them
`to reside within the District. For example, one of SIE’s senior software engineers
`resides in New York. Ex. H (Jesse_Clemens_LinkedIn. Pdf.).
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`5.
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`I live in New York solely for personal and familial reasons, not because SIE
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`requires or encourages me to do so.
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`I grew up in New Jersey and have always loved New York
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`City. In addition, I have two aging parents residing in New Jersey and I prefer living close to
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`them. SIE sought to hire me multiple times between 2006 and 2010, with the condition that I had
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`to move to California, but I refused each time. SIE was only successful in hiring me in 2011
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`after allowing me to work remotely. To perform my job, I telecommute into SIE’s offices in
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`California and routinely fly to California to be in the office.
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`I am a senior engineer on the Visual
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`Arts Service Group (VASG) engineering team at SIE in California, and I mentor and lead less
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`experienced engineers on my team.
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`I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
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`Executed on October i, 2019
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`J
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`se Cle ens
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`
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