SAN DIEGO-#650333-v2-PSi Yardi 4A Resp to Yardi Rogs 1 2 3 ... · PSI’s 4A Resp. to Yardi’s Int. No. 1, 2, 3, 6, 11 Case No. 2:13-cv-07764 sd-650333 of any documents (or the subject

EXHIBIT 59

Case 2:13-cv-07764-FMO-CW Document 106-63 Filed 04/15/15 Page 1 of 83 Page ID #:2289

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PSI’s 4A Resp. to Yardi’s Int. No. 1, 2, 3, 6, 11 Case No. 2:13-cv-07764

sd-650333

MICHAEL A. JACOBS (CA SBN 111664)[email protected] Morrison & Foerster LLP 425 Market Street San Francisco, California 94105-2482 Telephone: 415.268.7000 Facsimile: 415.268.7522

ERIC M. ACKER (CA SBN 135805)[email protected] CHRISTIAN G. ANDREU-VON EUW (CA SBN 265360) [email protected] MARY PRENDERGAST (CA SBN 272737) [email protected] Morrison & Foerster LLP 12531 High Bluff Drive San Diego, California 92130-2040 Telephone: 858.720.5100 Facsimile: 858.720.5125 Attorneys for Defendant/Counterclaimant PROPERTY SOLUTIONS INTERNATIONAL, INC.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

YARDI SYSTEMS, INC.,

Plaintiff,

v.

PROPERTY SOLUTIONS INTERNATIONAL, INC.,

Defendant.

Case No. 2:13-CV-07764-FMO-CW

PROPERTY SOLUTIONS INTERNATIONAL, INC.’S SECOND AMENDED RESPONSE TO YARDI SYSTEMS, INC.’S INTERROGATORY NO. 3, THIRD AMENDED RESPONSETO INTERROGATORY NO. 11 AND FOURTH AMENDED RESPONSE TO INTERROGATORIES NO. 1, 2, AND 6.

PROPERTY SOLUTIONS INTERNATIONAL, INC.,

Counterclaimant,

v.

YARDI SYSTEMS, INC.,

Counterdefendant.

PORTIONS HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY

DEMAND FOR JURY TRIAL

Hon. Fernando M. Olguin

EXHIBIT 59

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1 PSI’s 4A Resp. to Yardi’s Int. No. 1, 2, 3, 6, 11 Case No. 2:13-cv-07764

sd-650333

PROPOUNDING PARTY: Plaintiff YARDI SYSTEMS, INC.

RESPONDING PARTY: Defendant PROPERTY SOLUTIONS

INTERNATIONAL, INC.

SET NO.: One

PRELIMINARY STATEMENT Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, and

Rule 33 of the Local Rules of Civil Procedure for the United States District Court

for the Central District of California, Defendant Property Solutions International,

Inc. (“Property Solutions” or “Defendant”) hereby serves its second amended

response and objections to Plaintiff Yardi Systems, Inc.’s (“Yardi” or “Plaintiff”)

interrogatory No. 3 to Property Solutions, its third amended response and

objections to Yardi’s interrogatory No. 11, and its fourth amended response and

objections to Yardi’s interrogatories No. 1, 2, and 6.

Property Solutions’ Responses to Interrogatories No. 1 and 2 are hereby

marked “Confidential” under the protective order in this action. Property

Solutions’ Responses to Interrogatories No. 3, 6 and 11 are hereby marked “Highly

Confidential – Attorney’s Eyes Only.”

GENERAL OBJECTIONS The responses and objections set forth in this section apply to each of the

interrogatories as if each were set forth in full in response to each interrogatory.

The assertion of the same, similar or additional objections in Property Solutions’

specific objections to individual interrogatories, or the failure to assert any

additional objection to an interrogatory, does not waive any of Property Solutions’

objections set forth in this section or the following sections.

These responses and objections are made without waiving or intending to

waive: (a) all objections to competency, relevancy, materiality, privilege and

admissibility as evidence for any purpose in the trial of this or any other action or

any subsequent proceedings; (b) the right to object to the use of these responses or EXHIBIT 59

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sd-650333

of any documents (or the subject matter thereof) that may be produced in the trial of

this or any other action or any subsequent proceedings on any grounds; (c) the right

to preserve, prior to production and as a condition of production, the confidentiality

or the proprietary nature of any documents or information that may be produced or

the subject matter thereof; (d) the right to object on any ground at any time to a

demand for further production or other discovery involving or relating to the

subject matter of the interrogatories; and (e) the right at any time to revise,

supplement, clarify or amend the responses and objections to the interrogatories, if

further factual developments or analysis warrants a modification, or if additional

information is obtained or documents are located that are properly called for by the

interrogatories.

Property Solutions objects to the interrogatories to the extent they seek

information or documents protected from discovery by the attorney-client privilege,

the work product doctrine, or any other applicable privilege or doctrine. Nothing

contained in these general responses and objections or the responses and objections

to individual interrogatories is intended as, or shall in any way be deemed as, a

waiver of any attorney-client privilege, any work product doctrine, or any other

applicable privilege or protection. Inadvertent production of any such protected

information shall not constitute a waiver of any privilege or any other ground for

objection to discovery with respect to such information or document or any other

information or document, or with respect to the subject matter thereof, or with

respect to the information contained therein nor shall such inadvertent production

waive Property Solutions’ right to object to the use of any such document or the

information contained therein during any subsequent proceeding. Upon notification

that such disclosure was inadvertent, the information or document(s) and any copies

thereof shall be returned immediately.

Property Solutions objects to the interrogatories, including the “Definitions”

section therein, to the extent that they seek to impose obligations beyond that which EXHIBIT 59

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sd-650333

is permitted by the Federal Rules of Civil Procedure or the Local Rules of Civil

Procedure for the United States District Court for the Central District of California

and any applicable Chambers Rules or Standing Orders.

Property Solutions objects to the interrogatories to the extent that they are

vague, ambiguous, overly broad or unduly burdensome and/or to the extent that

they request information neither relevant nor reasonably calculated to lead to the

discovery of admissible evidence.

Property Solutions has interpreted the interrogatories utilizing the ordinary

meaning of any undefined words. To the extent that any request purports to seek

information other than so interpreted, Property Solutions objects on the ground that

any such request is vague, ambiguous, and overbroad.

Property Solutions objects to each interrogatory that is not limited to a

particular time frame on the ground that any such request is vague, ambiguous, and

overbroad.

Property Solutions objects to the interrogatories to the extent that they

impose or attempt to impose a discovery obligation on any person who is not a

party to this litigation and/or to the extent that they request information that is not

within Property Solutions’ possession, custody and control.

Property Solutions objects to the interrogatories to the extent that they seek

confidential and/or proprietary business information of Property Solutions and/or

third parties prior to the entry of an appropriate protective order.

Property Solutions objects to the interrogatories to the extent that they seek to

impose an obligation on Property Solutions to search for information or documents

beyond where such information or documents would be kept in the ordinary course

of business. These responses are limited to information from sources reasonably

likely to have responsive information or documents.

Property Solutions objects to the interrogatories to the extent that they seek

information or documents that are a matter of public record and/or equally available EXHIBIT 59

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CONFIDENTIAL 4 PSI’s 4A Resp. to Yardi’s Int. No. 1, 2, 3, 6, 11 Case No. 2:13-cv-07764sd-650333

to Plaintiff.

Property Solutions’ investigation is ongoing and these responses have been

prepared after a reasonable and diligent investigation and search for the information

requested. Property Solutions reserves the right to supplement and/or modify its

responses and objections should any additional information become available

through discovery or otherwise.

Property Solutions objects to Yardi’s definition of the term “PROPERTY

SOLUTIONS” and “YOU” as vague, overbroad and unduly burdensome.

Property Solutions objects to Yardi’s definition of the term “ENTRATA” as

vague and ambiguous.

Property Solutions objects to Yardi’s definitions of the terms “STATE WITH

SPECIFICITY,” “STATE ALL BASES,” and “STATE THE BASIS” as vague and

ambiguous.

Property Solutions objects to Yardi’s definition of the term “YARDI

SOFTWARE” as vague, ambiguous, and overbroad.

RESPONSES TO INTERROGATORIES INTERROGATORY NO. 1:

Describe in detail the circumstances under which YOU possessed a copy of

the VOYAGER SOFTWARE as admitted in paragraph 24 of YOUR ANSWER

AND COUNTERCLAIMS, including, but not limited to, the dates YOU had the

software in YOUR possession, the PERSON or PERSONS from whom YOU

obtained the software, the manner in which you obtained the software, the reasons

for your possession of the software, the version(s) of the VOYAGER SOFTWARE

YOU had in YOUR possession, the locations and hardware on which YOU had the

software installed, and when (if at all) YOU ceased to possess the software.

RESPONSE TO INTERROGATORY NO. 1:

Property Solutions objects to this interrogatory on the grounds that it is

overly broad and unduly burdensome. EXHIBIT 59

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Property Solutions objects to this interrogatory as a compound question that

includes at least two subparts in violation of FRCP 33(a).

Property Solutions objects to the phrases “in YOUR possession”, “obtained

the software,” “your possession of the software,” and “possess the software” as

vague and ambiguous.

Property Solutions’ investigation is ongoing and this response has been



response and objections should any additional information become available


Subject to the General Objections and the specific objections to this

interrogatory, Property Solutions responds that it has not yet determined the exact

circumstances under which it received the copy of the Voyager software referenced

in paragraph 24 of its answer. Property Solutions believes it obtained a copy of

Voyager in 2006, and the first login to a copy of the Voyager software in Property

Solutions’ possession that Property Solutions has been able to confirm occurred on

July 21, 2006. After a diligent and reasonable search, Property Solutions has been

unable to pinpoint a more specific date upon which it received the Voyager

software, nor has Property Solutions been able to confirm from whom it received

the Voyager software. The version of Voyager Property Solutions originally

obtained was Voyager 5.0. Sometime before August 2009, Property Solutions

obtained a copy of Voyager 6.0. Despite a diligent and reasonable search, Property

Solutions has been unable to confirm from whom it received the Voyager 6.0

software. Property Solutions states that although it has not used the copy of the

Voyager software in its possession since May 24, 2012, it previously used the

software at the request of its joint customers to facilitate Property Solutions’

development and maintenance of an integration tool that allowed Property

Solutions’ products to connect to Yardi’s products, and to demonstrate that EXHIBIT 59

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connection to joint customers. Property Solutions believes the Voyager software

may have been installed or stored on computers known as “tweedledee,”

“tweedledum” (sometimes spelled “tweetledee” and “tweetledum”), “sputnik,”

“vesuvius,” “ramman,” and “recoil” at various points in time. More specifically,

Property Solutions believes the copy of Voyager was located on Property Solutions

server 192.168.111.207, also called “tweedledee,” until approximately March 2009.

Tweedledee has since been retired and is no longer in Property Solutions’

possession. The copy of the Voyager software in Property Solutions’ possession

has been located on Property Solutions server 192.168.111.208, also called

“tweedledum,” from approximately March of 2009 to the present. The IP address

for “tweedledum” was changed from 192.168.111.208 to 192.168.115.208 in

approximately May of 2012. Property Solutions has also been able to locate, and

has produced, install files for the Voyager software found on its servers, for

example, at PSI-0566474, PSI-0576236-94, PSI-0591594, PSI-0591596, PSI-

0591597, PSI-0599714, PSI-0599717, PSI-0599719, and PSI-0600196-202.

Property Solutions continues to possess a copy of the Voyager software

because its document preservation obligations prohibit it from destroying or

otherwise disposing of the software.

INTERROGATORY NO. 2:

STATE WITH SPECIFICITY all instances in which YOU copied the

VOYAGER SOFTWARE to any computer or other device.



overly broad and unduly burdensome.




response and objections should any additional information become available EXHIBIT 59

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Property Solutions objects to the term “copied” as vague, ambiguous and,

overbroad.

Property Solutions objects to the phrase “computer or other device” as vague,

ambiguous, and overbroad.


interrogatory, Property Solutions incorporates its response to Interrogatory No. 1.

Property Solutions further responds that it believes that as computing devices were

retired, re-purposed, or reassigned, the files located on a given device were

transferred from one device to another. As a result, installation files, client

databases and other files may have been transferred as well. To date, Property

Solutions has identified six computing devices: “tweedledee,” “tweedledum”

(sometimes spelled “tweetledee” and “tweetledum”), “sputnik,” “vesuvius,”

“ramman,” and “recoil,” that may contain install files or other files related to the

Voyager software. Property Solutions did not keep records of each time the

Voyager Software or other files related to the Voyager Software were moved from

one device to another. Property Solutions has produced the install files for the

Voyager software it has been able to locate on these servers, including directory

path information where available, for example, at PSI-0566474, PSI-0576236-94,

PSI-0591594, PSI-0591596, PSI-0591597, PSI-0599714, PSI-0599717, PSI-

0599719, and PSI-0600196-202.

Property Solutions only has one functional copy of the software in its

possession, which is installed on the server called “tweedledum,” but Property

Solutions does not have an active license key for the software. Property Solutions

continues to possess that copy because its document preservation obligations

prohibit it from destroying or otherwise disposing of the software or other related

files.

EXHIBIT 59

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HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY 8 PSI’s 4A Resp. to Yardi’s Int. No. 1, 2, 3, 6, 11 Case No. 2:13-cv-07764sd-650333


IDENTIFY all of YOUR or YOUR subsidiaries’ or affiliates’ officers,

employees, contractors, agents, or representatives who ever had access to a copy or

copies of the VOYAGER SOFTWARE.


Property Solutions objects to this interrogatory on the grounds that it seeks

discovery regarding Yardi’s trade secret claims, and/or claims that are factually

dependent on those claims, before Yardi has complied with Section 2019.210 of the

California Code of Civil Procedure. Property Solutions reserves the right to

supplement and/or modify its response after Yardi complies with Section 2019.210.

Property Solutions objects to this interrogatory on the grounds that it seeks

information about the conduct of third parties and is overbroad, unduly

burdensome, and not reasonably calculated to lead to discoverable information.

Property Solutions objects to the phrase “access to a copy or copies” as

vague, ambiguous, and overbroad.







interrogatory, Property Solutions states that it was repeatedly provided access to the

Voyager software by people who included Yardi employees and Yardi customers.

Property Solutions does not have records of the circumstances surrounding every

time it was given access to Voyager software or a record of every person who was

given access to Voyager software. Property Solutions incorporates its response

(and any amendments) to Interrogatory No. 6. Property Solutions further

incorporates its response (and any amendments) to Interrogatory No. 25, which lists EXHIBIT 59

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all persons that Property Solutions has been able to confirm had access to, or the

ability to access, a copy of Voyager software in Property Solutions’ possession.

Property Solutions further responds that the following people may have seen a

Voyager screenshot or may have been provided some other information related to

the Voyager software, during the course of Property Solutions’ relationship with

Yardi:

Aaron Gibbons, Aaron Reimschiissel, Alicia Sly, Abby Stevens, Abraham

Richards, Adam Gundersen, Adam Macleod, Adam Moore, Adam Stevens, Adam

Tolman, Adrian Maco, Adrian Nef, Aj Dexter, Alec Zuber, Ali Garbero, Allen

Williams, Alvan Ormsby, Amy Cardon, Andrea Treu, Andrew Buhler, Andrew

Dabell, Andrew Packer, Andrew Tillack, Andrew Wilding, Anna Doty, Anthony

Gibson, Anthony Nielsen, Anthony Ranallo, Arthur Saraiva, Ashlee Cowley,

Ashley Reid, , Baxter Gillespie, Ben Martin, Ben Reeves, Benjamin Zimmer,

Benjamin Angbejar, Benjamin Blaker, Benjamin Boster, Benjamin Smith, Benson

Jaten, Blake Baird, Blake Leszczynski, Blake Moore, Brad Humphrey, Braeden

Brown, Brandon Breivik, Brandon Mccloskey, Brandon Riggs, Brandon Schank,

Braxton Carey, Breann Lehr, Breezy Daley, Brenton Hoyos, Brett Allen, Brett

Gardiner, Brett Stewart, Brett Weber, Brian Corbett, Brian Grob, Brianne Cass,

Brindie Mccleary, Britt Wilkinson, Britten Roe, Bruce Stanford, Bryan Castle,

Bryan Wade, Bryce Beach, Bryce Nelson, Byron Putnam, Cameron Cloward,

Cameron Conover, Cameron Long, Cameron Wilbur, Candace Matagi, Carla Hurst,

Casey Keele, Casey Moon, Cassidy Kennedy, Celeste Boyce, Chant Duplantier,

Chante King, Charles Mitchell, Charles Noble, Charles Webster, Chase Brimhall,

Chase Donohue, Chase Harrington, Chase Thomason, Chelsea Dixon, Cheryl

Boden, Cheryl Gali, Chris Sandberg, Chrisie Allen, Christian Allred, Christian Nye,

Christin Chalfant, Christine Ricks, Christopher Brasher, Christopher Martin,

Christopher Murdock, Clark Hatch, Clint Meeks, Colby Collier, Colby Critchfield,

Colby Hargis, Connie Walker, Cordell Washburn, Cory Nemelka, Cory Peterson, EXHIBIT 59

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Craig Zimet, Dallas Jensen, Dan Ludlow, Dan Manion, Dane Bendixen, Daniel

Ainsworth, Daniel Clay, Daniel Lloyd, Daniel Simpson, Daniel Wood, Daniele

Tucker, Dannielle Stout, Daron Barnes, Darrin Perry, Dave Carter, Dave Rush,

David Bateman, David Coles, David Davies, David Grant, David Hatch, David

Hendricks, David Hurtado, David Merriman, David Mickelson, David Romero,

David Schneider, David Smith, David Staal, David Witt, Deepak Tilekar, Dena

Morgan, Dennison Harris, Derek Hornberger, Derek Lefler, Derik Epperson,

Desiree Syme, Devin Mccabe, Dharmesh Shroff, Diane Samudio, Don

Zimmerman, Doug Bell, Douglas Phillips, Duane Michaelis, Dustin Maxfield,

Edward Galbraith, Elise Barrus, Emma Naftzger, Eric Barbour, Eric Bjornn, Erica

York, Erik Cornelsen, Erik Kolste, Garrett Bybee, Gary Hanks, Gena Haynes,

Gerson Torres, Gilbert Thomas, Giovanni Gomez, Glenn Thomas, Guruprasad

Bhase, Harrison Harding, Hitekshu Paliwal, Jackson Snyder, Jacob Balanzategui,

Jacob Beck, Jacob Bingham, Jacob Chappell, Jacob Cusworth, Jacob Harries, Jacob

Jones, Jacob Rich, Jad Startin, Jaime Conde, Jaimi Shoemaker, Jake Bertelsen, Jake

Johnson, James Ashworth, James Brausch, James Davis, James Draper, James

Heninger, Jamie Spraberry, Janel Ganim, Jared Bolding, Jared Crouch, Jared

Mashburn, Jared Snow, Jaren Larsen, Jason Cherry, Jason Dunn, Jason Hahn, Jason

Timpson, Jason Wilson, Jeff Kettle, Jeffrey Duke, Jeffrey Nicholson, Jeffrey

Schwartz, Jenee Smith, Jennifer Hatch, Jennifer Lambert, Jennifer Owen, Jeremy

Bell, Jeremy Peterson, Jerry Brooks, Jesse Bulpitt, Jessica Largent, Jessica Morris,

Jessica Myer, Jim Gifford, Joel White, John Caravela, John Gardner, John Hanna,

John Williams, Jolie Giles, Jon Soldan, Jon Wyant, Jonathan Bechtold, Jonathan

Jesperson, Jonathan Rojas, Jonathon Ames, Jonathon Winmill, Jordan Colton,

Jordan Dolinar, Jordan King, Jordan Lewis, Jordan Torbit, Jordan Wade, Jorge

Menendez, Joseph Biscoff, Joseph Swetel, Joseph Woodruff, Josh Bolding, Josh

Cann, Joshua Albrechtsen, Joshua Heck, Joshua Mendenhall, Julia Manookin,

Justin Stokes, Kaci Cardon, Kaiden Redd, Kaitlyn Michaelis, Kaleb Klingler, Katie EXHIBIT 59

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Forbes, Kellie Rich, Kelsie Bowles, Kennedee Ward, Kevin Anderson, Kevin

Clarke, Kevin Gwynn, Kevin Lambert, Kim Adams, Kim Senn, Kimberly Brooks,

Kimberly Fletcher, Kinnith Holloway, Kirk Dunn, Kirk Eisele, Amy Cardon, Klark

Brinkerhoff, Kory Kehl, Kristopher Edwards, Kurt Radmall, Kyle Brogdon, Kyle

Harris, Kyle Jepson, Kylie Carter, Lani Grant, Laura Kearney, Laura Parker, Layne

Bingham, Lea Pherribo, Leianne Phillips, Leslie Eldredge, Lindsay Francis,

Lindsey Tsuya, Linsey Loader, Lizzy King, Logan Clark, Luke Estes, Lynn

Shepherd, Mackay Breivik, Makafui Danhounsrou, Manish Awasthi, Maralee

Carlin, Marci Harman, Marcus Varner, Marcus Wyckoff, Margaret Swetel, Maria

Crockett, Mark Freeman, Mark Hill, Mark Mathews, Martha Dawson, Mary Olsen,

Matt Hurley, Matt Webb, Matthew Bos, Matthew Carlin, Matthew Haynie,

Matthew Mildenstein, Matthew Neilsen, Mckay Stevens, Meagan Saltmarsh,

Megan Hall, Melissa Rask, Michael Byrd, Michael Hanley, Michael Huff, Michael

Lewis, Michael Mccorristin, Michael Nielsen, Michael Peterson, Michael Sly,

Michelle Dahle, Michelle Flake, Michelle White, Mika Mcintosh, Mike Haroldsen,

Mike Wright, Mitchell Moody, Monda Watson, Nai Kakalia, Nate Babbel, Nathan

Bangerter, Nathan Ewert, Nathan Hodell, Nathan Parkin, Nathan Singleton, Nathan

Slater, Neal Taylor, Netaji Wakade, Nick Masina, Nick Nelson, Nicole Fischer,

Nilesh Matkari, Nils Kolste, Jamie Spraberry, Noelle Halasima, P Chandrasekar,

Parker Redding, Patricia Bradford, Patrick Conkling, Patrick Lynch, Paul Allen,

Paul Dunford, Paul Gwilliam, Paul Johnston, Peter Brown, Peter Fazio, Peter

Stevenson, Phil Broadbent, Prashant Shinde, Priti Chaudhari, Pravin Chaudhari,

Preetam Yadav, Rachel Perry, Rahul Sinha, Rajesh Gupta, Randon Morford,

Ravindra Sonar, Rebecca Campbell, Rebecca Robinson, Rebecca Vaughn, Rebekah

Allred, Richard Gordon, Richard Hackett, Rob Martin, Robert Felt, Robert

Milligan, Robert Myers, Robert Weathers, Robison Wells, Roe Lall, Ron Merrell,

Russell Jensen, Ryan French, Ryan Hadlock, Ryan Hornberger, Ryan Lee, Ryan

Mclaughlin, Ryan Mortimer, Ryan Tyson, Ryan Ward, Sam Denning, Kevin EXHIBIT 59

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Lambert, Sandeep Chavhan, Sandra Geary, Sandra Smith, Santosh Harnekar, Sara

Lencheck, Sara Sharpe, Sarah Burroughs, Sarah Butler, Sarah Gifford, Sarah

Jespersen, Sarah Taffe, Scott Bradford, Scott Romney, Sean Taylor, Shahjad Ali,

Shahnawaj Alam, Nick Nelson, Sheldon Sadler, Sherrie Stone, Sierra Jacox,

Spencer Harman, Spencer Mccain, Stefan Jimenez, Stefanie Lukowski, Stephanie

Roy, Stephanie Sigler, Stephen Maquinalez, Stephen Porter, Steve Nguyen, Tammy

Stailey, Tashina Wortham, Tauni Senn, Thomas Birch, Thomas Holston, Thomas

Owens, Thomas Tenney, Thomas Toomey, Tiffany Mcneil, Tiffany Morgan, Tim

Enger, Timothy Avery, Tj Golson, Todd Katler, Todd Parker, Tom Akagi, Tracy

Quispe, Travis Baker, Trena King, Trennon Judd, Trevor Bruce, Trevor Hill,

Trevor Reed, Trevor Riley, Trevor Smith, Tulao Moeai, Tyson England, Tyler

Carter, Tyler Christiansen, Tyler Frazier, Tyler Huskinson, Tyler Mundy, Tyler

Tucker, Tyler Urrutia, Tyson England, Venkataramana Gubbala, Virginia Tory,

Vrena Ranallo, Vrushali Sundkar, Wade Mcgown, Wayne Warnock, Westley

Stoddard, Will Mcbride, William Clinton, William Klinetop, William Prendergast,

Yogesh Patil, Zachary Stewart, Zachary Summers, Zak Corbridge, Zak Salisbury,

and Zont’l Mcaffee.


STATE WITH SPECIFICITY all instances in which YOU have viewed,

analyzed, installed, used, or otherwise had access to YARDI SOFTWARE.



overly broad and unduly burdensome.





through discovery or otherwise. EXHIBIT 59

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Property Solutions objects to the phrase “viewed, analyzed, installed, used, or

otherwise had access to YARDI SOFTWARE” as vague, ambiguous, and

overbroad.


interrogatory, Property Solutions responds as follows:

Property Solutions has not kept records of each and every time a copy of

Yardi software or a Yardi database in its possession was logged into or otherwise

interacted with. Through a reasonable search, however, Property Solutions has

been able to identify some specific dates on which the Yardi software or a Yardi

database may have been accessed. Attached hereto as Appendix A is a listing of

each of the instances of access Property Solutions has been able to confirm.

Property Solutions has also confirmed that the most recent access to the Voyager

software in its possession took place on or about May 24, 2012. At the time the

Voyager software was last accessed, it was located at Xento’s offices in Pune,

India. Property Solutions has also confirmed that the most recent access to the

Genesis software took place on June 9, 2010. At the time the Genesis software was

last accessed, it was located in Provo, Utah.

In addition to these specific instances, certain individuals in the following

departments at Property Solutions may have accessed Yardi software or databases

for the following reasons:

Individuals in Property Solutions’ sales department from

approximately 2007-2012 accessed the Yardi software and

demonstrated the functionality of the real-time integration between

Property Solutions’ products and the Yardi software. Property

Solutions does not keep records of every demonstration given by its

sales team, and also cannot confirm that Property Solutions accessed

Yardi software at every such demonstration.

Individuals in Property Solutions’ customer support department EXHIBIT 59

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(implementation, client executives, tier 1 and tier 2 technical support

representatives, merchant services, accounting, migrations, training,

etc.) had access to screen shots and other technical information

regarding the software to help troubleshoot client issues, which include

but are not limited to integrations support, implementation support,

training, and other client related problems. In most cases, the

individuals in these departments saw nothing more than screenshots,

database table and field names, or other technical information sent to

the employee from a Yardi representative and/or mutual customer.

Certain individuals in Property Solutions’ development department

accessed the Yardi software and/or Yardi databases to effect a stable

integration for mutual customers of Property Solutions and Yardi.

Yardi software and databases were used during the construction,

troubleshooting, and QA processes for each version of Property

Solutions’ integration utility, oftentimes in cooperation with Yardi

representatives and/or mutual customers. As part of this process,

Property Solutions completed certain actions in its software and

referenced the Yardi software to determine what occurred in the

software, including which tables and fields in the databases were

affected by the transaction. Also as part of this process, Property

Solutions completed certain actions in the Yardi software and

referenced its own software to determine what occurred in the

software.

As Yardi is aware, Property Solutions accesses the databases of mutual

Yardi/Property Solutions’ clients each day through Property Solutions’

integration utility, both on Yardi servers and client servers. Property

Solutions continues to maintain certain Yardi databases on its servers

for the purposes of testing and maintaining the integration only. From EXHIBIT 59

PAGE 399


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time to time, Property Solutions’ integrations and QA teams access

those databases in an effort to assist mutual customers.


IDENTIFY all PERSONS and companies who were or have ever been

involved in the design, development, modification, testing, or validation of

ENTRATA and describe the role of each PERSON.


Property Solutions objects to this interrogatory on the grounds that it is,

vague, ambiguous, overbroad, and unduly burdensome.

Property Solutions objects to this interrogatory as a compound question that

includes at least two subparts in violation of FRCP 33(a).

Property Solutions objects to the terms “involved in” and “ENTRATA” as

vague, ambiguous, and overbroad.







interrogatory, Property Solutions responds that each and every developer at

Property Solutions and Xento may have had a hand in the development of some

aspect of VantageXP, ResidentWorks, or Entrata at some point in time. Because

several of Property Solutions’ products are interrelated and built on the same

platform, many lines of code affect more than one product. The following people

were or are specifically assigned to the Entrata Core Development Team for some

period of time:

EXHIBIT 59

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Name Job Title/Role Contact Information Aarti Kumari Development and/or QA- Assist

with development, testing and implementation of portions of Entrata

C/O Morrison & Foerster LLP

Aasif Rasul Team Lead - Manage development teams and tasks related to the development of Entrata; implement and debug portions of ResidentWorks

C 106, Eisha Bella Vista, Near Sai Service Station, Kondhwa, Budruk, Pune IN 7385280101

Abhijeet Singh Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Abhijit Raval

Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Abhilash Mishra Associate Engineer – AR; implement, test and debug portions of Entrata


Abhilasha Gupta Senior Engineer –Reports / BI; implement, test and debug portions of Entrata

CC-12 SAI SAHEB, PIMPLE SAUDAGAR, Pune, MH 8552919925

Abhishek Badnore Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Abhishek Bose Software Engineer – Reports; implement, test and debug portions of Entrata


Abhishek Soni QA – ResidentWorks; Manage development teams and tasks related to the development of Entrata; implement and debug portions of ResidentWorks and


EXHIBIT 59

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Name Job Title/Role Contact Information Entrata

Abin Thomas Technical Product Manager – Entrata AP; gather requirements, develop and debug portions of Entrata. Oversee the technical implementation of the development of Entrata.


Aditi Chaudhari Associate Engineer – Entrata AR; implement, test and debug portions of Entrata


Afsha Sayyad Associate Engineer – Entrata AR; implement, test and debug portions of Entrata


Ahasan Shaikh


64/65 Ganesh Peth, Next to Dilliwala Sweet Dairy,4th floor, pune, MH, 8421378751

AJ Dexter Director of Network & Security Operations – Manage IT requirements; develop, implement, test and debug portions of VantageXP

195 E 800 S Orem UT 801-372-9378

Ajay Khedkar Associate Team Lead – Entrata AR; Manage development teams and tasks related to the development of Entrata; implement and debug portions of Entrata


Ajay Yadav Associate Engineer– Entrata AR Affordable; implement, test and debug portions of Entrata


Ajit Pawar



EXHIBIT 59

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Name Job Title/Role Contact Information Ajit Yadav Trainee Engineer – QA, Entrata

AR student; implement, test and debug portions of Entrata

5/6,AJINKYATARA HOU SOC SEC NO 27A,NIGDI PRADHIKARAN, PUNE 44, PUNE, MH, 9762809150

Akash Bedi Senior Engineer – Reports Entrata AP/GL; implement, test and debug portions of Entrata


Akshata Kamat


Sweekar Galli Nal stop pune 0, Pune, MH, 9823142381

Amar Jaiswal Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Ameya Gaikwad Associate QA Manager – Entrata AR; implement, test and debug portions of ResidentWorks and Entrata


Amit Dahiya Software Engineer – Reports; implement, test and debug portions of Entrata


Amit Ingulkar



Amit Kadam



Amit Padmawar Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Amit Paliwal Development and/or QA- Assist 39, Junior Bajrang

EXHIBIT 59

PAGE 403


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Name Job Title/Role Contact Information with development, testing and

implementation of portions of Entrata

Nagar, Near Bhamori Bridge, Indore (MP) 0, Indore, MP, 9673465152

Amit Prasad



Amit Sawant Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Amita Dutta Team Lead – Entrata AR Student; Manage development teams and tasks related to the development of Resident Works and Entrata; implement and debug portions of Entrata


Amiteshwar Prasad



Amol Bhalerao



Amol Deshpande Technical Product Manager – Reports; gather requirements, develop and debug portions of Entrata. Oversees the technical implementation of the development of Entrata.


Amol Savat


Bunglow No .5, Trimbekswar Hsg. Soc. Wadgaonsheri, Pune, MH, 7385290299

EXHIBIT 59

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Name Job Title/Role Contact Information

Amrut Sabnis


Anand nagar, malwadi, Hadapsar, Pune, MH, 9975586485

Amruta Langade Senior Engineer – Reports / BI; implement, test and debug portions of Entrata


Anand Joshi Sr. Team Lead – AR Student; Manage development teams and tasks related to the development of Entrata; implement, test and debug portions of Entrata


Anand Lahoti



Anant Haral Principal Engineer – Implement and debug portions of ResidentWorks and Entrata


Anil Bidve



Anil Chauhan Software Engineer – Entrata AR Reports; implement, test and debug portions of Entrata

Sant tukaram nagar, Nea water tank, Alandi Road, Gujarati chawl, Bhosari, Pune, MH, 9970357865

Animesh Joshi Software Engineer – Entrata AR Reports; implement, test and debug portions of Entrata


Aniruddha Malvi Team Lead - Manage development teams and tasks related to the development of Entrata; implement and debug


EXHIBIT 59

PAGE 405


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Name Job Title/Role Contact Information portions of ResidentWorks and Entrata

Ankush Kasture Associate Engineer – Entrata AR Affordable; implement, test and debug portions of Entrata


Annapurna Thadani Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Anshul Saxena Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Anthony Gibson


Former Employee – C/O Morrison Foerster

Anuja Divalkar Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Anupama Netke Associate Engineer – Reporting - AP/GL; debugged portions of Entrata


Apeksha Jain


Flat No.804,Block- D, Jasmenium, Magarpatta City,Hadapsar ,Pune- 0, Pune, MH, 8149017048

Aqueel Peerzade Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Archana Divekar Development and/or QA- Assist with development, testing and implementation of portions of


EXHIBIT 59

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Arti Parandwal Associate Engineer – AR Student; implement, test and debug portions of Entrata


Ashish Alulkar Associate Engineer – AR; implement, test and debug portions of Entrata

Bilwa-Kunja Soc. B- Wing, Flat no 18, Near Chinchechi talim Chowk, Survey no 264,265. Shukrawar peth, Pune, MH 9762264263

Ashish Singh Associate Engineer – AR Student; implement, test and debug portions of Entrata


Ashish Tiwari Development and/or QA- Assist with development, testing and implementation of portions of Entrata

Gat No. 2343 Kawade Wasti Sai Satyam Near Bharat Gas Agency Wagholi, Pune, MH, 9579372743

Ashutosh Padhye


Flat no 502 vishwa vilas resi. NDA rd Shivne Pune-23, Pune, MH, 7709908489

Ashutosh Shidid



Ashwini Chitnis Associate Engineer – AR Reports; implement, test and debug portions of Entrata


Ashwini Gadakh Associate Engineer – AR Affordable; implement, test and debug portions of Entrata


Ashwini Khairnar Development and/or QA- Assist C/O Morrison &

EXHIBIT 59

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Name Job Title/Role Contact Information with development, testing and implementation of portions of Entrata

Foerster LLP

Ashwini Naidu Development and/or QA- Assist with development, testing and implementation of portions of Entrata

Shree Apartment, F-3, Rajshree Colony, Anand Park, Vadgaon Sheri, Pune, MH, 9028449726

Avinashkumar Pujari Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Ben Zimmer President – Help define product requirements; implement and execute sales, marketing and strategic product decisions


Benjamin Taylor Director of Information Technology

Former Employee C/O Morrison & Foerster LLP

Bhargavi Ashish Associate QA Engineer - implement, test and debug portions of Entrata


Bhargavi Rao Team Lead – QA – AP; Manage development teams and tasks related to the development of Entrata; implement and debug portions of Entrata


Bhawna Thadhani



Bhupendra Khade Associate Engineer – AP; implement, test and debug portions of Entrata


Bhupendra Yadav Software Engineer – AR; implement, test and debug portions of Entrata

Adeeth Acting Academy, 153-A, Magarpatta, Near

EXHIBIT 59

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Name Job Title/Role Contact Information State Bank Of India, Mundhwa Road, Hadapsar, Pune – 411028, 9165561788

Bhushan Ahirrao Associate Team Lead – AR; Manage development teams and tasks related to the development of Entrata; implement and debug portions of Entrata


Bimal Satpathy Associate QA Engineer – Tests and reports implementation problems, writes automated tests AR Student; implement, test and debug portions of Entrata


Brad Humphrey Senior Software Engineer - implement, test and debug portions of ResidentWorks

Former Employee C/O Morrison & Foerster LLP

Brandon Mccloskey Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Bruce Stanford Development and/or QA- Assist with development, testing and implementation of portions of Entrata

13750 South 1300 West 0, Riverton, UT, 801-920-0103

Bushra Rashid Associate QA Engineer – AR Student; implement, test and debug portions of Entrata


Chaitali Kolte Trainee Engineer – QA Reports; implement, test and debug portions of Entrata


Chase Harrington Executive Vice President – Help define property management software requirements, assist in and


EXHIBIT 59

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Name Job Title/Role Contact Information oversee sales, point of contact for Entrata sales

Chase Thomason Software Development Manager I - Assist with development and implementation of portions of ResidentWorks

99 North Cambria Way #0202 Pleasant Grove UT 208-403-4028

Chetan Bhalerao Associate QA Engineer - implement, test and debug portions of ResidentWorks and Entrata


Chetan Kulkarni Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Chinmayi Sahu Technical Product Manager gather requirements, develop and debug portions of ResidentWorks and Entrata. Oversee the technical implementation of the development of ResidentWorks and Entrata.


Chirayu Tailor



Chitranjan Bharti Development and/or QA- Assist with development, testing and implementation of portions of Entrata

At+p.o.:Khagra P.S:Naugauchia Dist:Bhagalpur Pin:853204 0, Bhagalpur, MH, 9665120547

Christian Nye Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Christopher Martin Director of Engineering – C/O Morrison &

EXHIBIT 59

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Name Job Title/Role Contact Information Entrata – Define product requirements oversee administrative and technical development of Entrata

Foerster LLP

Clark Hatch Jr. Software Engineer - Assist with development and implementation of portions of ResidentWorks

121 South 200 East Apt. 51 Provo UT 208-206-7357

Clint Meeks Director of Product Development – Help define product requirements

2885 E Lookout Drive Eagle Mountain UT 801-735-1917

Collin Monteiro



Cory Nemelka Senior Engineer - Assist with development and implementation of portions of ResidentWorks

9149 Glenn Abbey Way Sandy UT 801-520-1959

Danashree Khule Associate Engineer QA - implement, test and debug


Dane Bendixen



Daniel Lloyd Executive Vice President of Technology

9640 North Charleston Drive Cedar Hills UT 801-753-0832

Darshana Tatkar



Darshankumar Khendake

Development and/or QA- Assist with development, testing and implementation of portions of


EXHIBIT 59

PAGE 411


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Dattatray Phadatare



Dave Carter Software Development Manager I - Assist with development and implementation of portions of ResidentWorks

Former Employee – C/O Morrison Foerster

Dave Carter Development and/or QA- Assist with development, testing and implementation of portions of Entrata

607 N 1550 W 0, Pleasant Grove, UT, 801.946.5515

Dave Rush Integrations Development Manager - Assist with development and implementation of portions of ResidentWorks

883 W 400 N Orem UT 801-613-2652

David Bateman Chief Executive Officer - Software Developer – Oversee product requirements and direction, develop, implement, test and debug portions of VantageXP, ResidentWorks and Entrata


David Merriman Senior Engineer / Architect - Help define architectural needs and serve as the lead technical resource for the development team.


David Schneider Independent Contractor, develop accounting portions of Entrata


David Smith Business Analyst – Entrata AP - Analyze and implement business reporting needs


EXHIBIT 59

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Name Job Title/Role Contact Information Deepa Johri



Deepak Mahajan Software Engineer – Reports; implement, test and debug portions of Entrata

Flat No. 09, Shreepad Apt, Lane 423, Right Bhusari Colony, Kothrud, Pune, MH, 8976177370

Deepak Mishra UX Designer – Design user interface for ResidentWorks and Entrata


Deepali Gujarathi Associate Team Lead – AR Reports; Manage development teams and tasks related to the development of Entrata; implement and debug portions of Entrata


Deepesh Vijayvargiya Development and/or QA- Assist with development, testing and implementation of portions of Entrata

B 12.4, kalpataru Splendour Wakad, Pune., Pune, MH, 7709868148

Delizia dsilva



Devendra Chaudhari Associate Engineer – BI Reports; implement and debug portions of Entrata


Devendra Janhale Associate QA Engineer – Reports; implement, test and debug portions of Entrata


Devin Merril VP – Revenue Management – Defines needs of Revenue Management Product in conjunction with Entrata.


EXHIBIT 59

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Name Job Title/Role Contact Information Dhanashree Khule Associate Engineer – Reports;

implement, test and debug portions of Entrata

304 A2 Building B Wing Katepuram, Navi sagvi, Pune, MH, 9271362712

Dhanlaxmi Soma



Dhannya Nair Trainee Engineer– AP; implement, test and debug portions of Entrata

A/6 Vikram Vihar, Near Deodhar Hospital, Pimpri, Pune, MH 9960053020

Dharmesh Shroff Lead Software Development Manager – Act as a scrummaster, communicates product requirements to development teams and ensure proper implementation of requirements; Migrations


Dharmi Patel Trainee Engineer

Room No-91, Kaveri Hostel, STES Campus, Kusgaon. Lonavala MH

Dinesh Vadhri Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Dipak Mane



Douglas Phillips Lead Software Development Manager – Helped design and develop portions of ResidentWorks

2158 Whisper Wood Drive Lehi UT 8013613081

Duane Michaelis

Senior Engineer - Helped design and develop portions of

6533 S. Nod Hill Rd Cottonwood Heights

EXHIBIT 59

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Name Job Title/Role Contact Information ResidentWorks UT 8014200957

Edward Galbraith Development and/or QA- Assist

with development, testing and implementation of portions of Entrata


Erik Cornelsen Software Development Manager II – Entrata AR - Act as a scrummaster, communicates product requirements to development teams and ensure proper implementation of requirements


Faisal Khan QA Manager – ResidentWorks; implement, test and debug portions of ResidentWorks and Entrata

10 Gautam Buddha Marg, Lucknow, IN, +91-9975609186

Gagan Upadhyay Software Engineer – Reports; implement, test and debug portions of Entrata


Gary Hanks Chief Architect – Help define architectural needs and serve as the lead technical resource for the development team for portions of VantageXP

427 S. 700 W. Lehi UT 801-776-8679

Gaurav Bhargava Senior Engineer – AR Student; Implements new features and debugs portions of Entrata

A1-202 Pawan Co-op Society, Sus Road, SaiChowk, Pashan, Pune, MH 8975628980

George Lukose QA Manager – ResidentWorks; implement, test and debug portions of ResidentWorks and Entrata

Earathu George Bhavan , Koduvila P.O, East Kallada , Kollam, Kerala IN

EXHIBIT 59

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Name Job Title/Role Contact Information 0474-2585419

Ghanshyam Agarwal

Software Engineer – AR; implement, test and debug portions of Entrata

Ganeshpur, Bahramghat, Barabanki, Uttar Pradesh, Barabanki, MH, 8446550578

Gilbert Thomas



Girish Shinde QA Engineer – AR Student; implement, test and debug portions of Entrata


Glenn Thomas Lead Software Development Manager – BI - Assist with development and implementation of portions of ResidentWorks

2049 Sleepy Hollow Trail Frisco TX 972-814-5736

Goutami Mishra Associate Team Lead – AR Student; Manage development teams and tasks related to the development of Entrata; implement and debug portions of Entrata


Harish Chawria Associate QA Engineer – AR; implement, test and debug portions of Entrata


Harish Pandey Sr. QA Engineer – AR; implement, test and debug portions of Entrata


Harshada Vaze Associate QA Engineer – ResidentWorks; Manage development teams and tasks related to the development of Entrata; implement and debug portions of ResidentWorks and Entrata

Flat no.27, B- wing, Nachiket Apartment, opposite Gharkul Lawns, DP Road, Pune, MH, 9689941095

EXHIBIT 59

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Name Job Title/Role Contact Information Harshada Vaze Associate QA Engineer – AR;

implement, test and debug portions of Entrata

Flat no.27, B- wing, Nachiket Appartment, opposite Gharkul Lawns, DP Road, Pune MH, 9689941095

Harshawardhan Pathak Associate Engineer – AP Student; implement, test and debug portions of Entrata

"Athang", Plot No:33, Swedganga Society, Warje, Pune Maharashtra MH 8149138710

Harshit Gokhe Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Hitekshu Paliwal Technical Product Manager – AR; gather requirements, develop and debug portions of Entrata. Oversees the technical implementation of the development of ResidentWorks and Entrata.


Hui Zheng UX Developer – Design user interface for ResidentWorks

105 E. 950 S. Orem UT 801.636.4490

Ian Morris Product Development Manager –Assist in development and implementation of portions of ResidentWorks

11251 South State Street #E208 Sandy UT 8015983293

Jacob Bingham VP of Product Management – Business Intelligence

9526 Canyon Heights Drive Cedar Hills UT 801-473-1894

Jacob Jones

Development and/or QA- Assist with development, testing and


EXHIBIT 59

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Name Job Title/Role Contact Information implementation of portions of Entrata

Jad Startin Software Architect – Help define architectural needs and serve as the lead technical resource for the development team.


Jagdish Jagdale UX Designer – Design user interface for ResidentWorks and Entrata


Jaime Conde Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Jalindar Avhale Software Engineer – AR Student; implement, test and debug portions of Entrata


James Ashworth Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Janel Ganim VP of Product – AR – Define AR requirements for property management software


Jared Mashburn Product Development Manager – Assist with development and implementation of portions of ResidentWorks

855 N. 1760 W. Provo UT 8012280216

Jeff Nicholsen Sr. UX Designer – Design user interface


Jeramy Morril Creative Director – UX designer – design user interface of Vantage XP

Unknown

Jesse Bulpitt Senior Engineer - Assist with development and implementation of portions of ResidentWorks

4521 Butterfly Way Keller TX 817-320-1473

EXHIBIT 59

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Name Job Title/Role Contact Information Jignesh Bharada Associate Engineer – AP;

implement new features, test and debug portions of Entrata


Jignesh Patel Senior Engineer – Reports; implement new features, test and debug portions of Entrata


Jiwan Jagtap Development and/or QA- Assist with development, testing and implementation of portions of Entrata


John Hanna President – Define requirements for property management software; facilitates user feedback and development coordination


Jonathan Jesperson Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Jonathon Winmill Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Jordan Jones Senior Software Engineer – develop, implement, test and debug portions of VantageXP

Unknown

Jordan King Business Analyst – Reports – Analyze and implement business reporting needs


Joseph Woodruff Development - Assist with development and implementation of portions of ResidentWorks

155 S. PG Blvd #29 Pleasant Grove UT 8016025811

Joshua Albrechtsen Development and/or QA- Assist with development, testing and implementation of portions of Entrata

4776 West Vermillion Drive 0, South Jordan, UT, 8013105343

Kaiden Redd Sr. UX Designer – Design user C/O Morrison &

EXHIBIT 59

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Name Job Title/Role Contact Information interface Foerster LLP

Kalpana Devi Associate Engineer – AR Affordable; implement new features, test and debug portions of Entrata


Kalyani Pawar Associate Engineer – Reports AR; implement new features, test and debug portions of Entrata


Kapil Kapoor Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Kartik Surkulta Associate QA Engineer – AR Student; implement new features, test and debug portions of Entrata


Kartik Surkutla Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Kaustubh Deolwadkar


E-104,Sundar Sankul,Near Magarpatta city Hadapsar, Pune, MH, 8888556400

Kedar Langade Technical Product Manager gather requirements, develop and debug portions of ResidentWorks and Entrata. Oversee the technical implementation of the development of ResidentWorks and Entrata.


Ketaki Yeolekar

Development and/or QA- Assist with development, testing and implementation of portions of


EXHIBIT 59

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Kevin Gwynn Database Administrator / Software Engineer – develop, implement, test and debug portions of VantageXP

1576 W 4300 S Taylorsville UT 801-375-5522

Kewal Sarode Associate Engineer – AR Student; implement new features, test and debug portions of Entrata


Khushbu Fuletra Development and/or QA- Assist with development, testing and implementation of portions of Entrata

Iris, K - 903, Magarpatta city, Hadapsar, Pune, IN, 9960330459

Kim Senn VP of Entrata – Define requirements for Property Management Software

2313 Cedarwood Dr., Garland, TX, 972-494-2229

Kiran Sarode Associate Engineer – Reports BI; implement new features, test and debug portions of Entrata


Kirk Dunn Lead Software Development Manager – Entrata AP - Act as a scrummaster, communicates product requirements to development teams and ensure proper implementation of requirements


Kirk Eisele Software Development Manager I - implement new features, test and debug portions of ResidentWorks

11965 South Calif. Way #16-402 Herriman UT 567-259-6753

Kishor Kadam QA Engineer – AR; implement, test and debug portions of Entrata


Komal Jadhav Development and/or QA- Assist with development, testing and

29/A, Saraswati Complex, Near Sane

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Name Job Title/Role Contact Information implementation of portions of Entrata

Guruji Hospital, Malwadi Hadapsar, Pune, Pune, MH, 7709240889

Krishna Mokadam Associate QA Engineer – Reports; test and debug portions of Entrata


Kumar Saurabh Associate Team Lead – AP; Manage development teams and tasks related to the development of Entrata; implement and debug portions of Entrata


Kunal Kurhade Development and/or QA- Assist with development, testing and implementation of portions of Entrata

N-16, Mourya Vihar, Sahajanand Society Kothrud, Pune, MH, 8308350700

Kyle Brogdon Product Development Manager – Software Development Manager - Entrata AR - Act as a scrummaster, communicate product requirements to development teams and ensure proper implementation of requirements


Lani Grant Implementation Consultant – Assist customer with implementing software requirements.


Laura Kearney Implementation Consultant – Assist customer with implementing software requirements.


Laxman Lamani Development and/or QA- Assist with development, testing and implementation of portions of Entrata


Laxman Waghmare Associate Team Lead – QA Reports; Manage development


EXHIBIT 59

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Name Job Title/Role Contact Information teams and tasks related to the development of Entrata; implement and debug portions of Entrata

Leslie Eldredge



Lokesh Kalluholemath Development and/or QA- Assist with development, testing and implementation of portions of Entrata

A-202, Madhav Baug, Near Amonora City, Hadapsar, Pune, MH, 9960754749

Lubna Shaikh



Lynn Shepherd Development - Assist with development and implementation of portions of ResidentWorks

961 E. 70 S. Lindon UT 801-319-5882

Maaz Shaikh Associate Engineer – AR; implement new features, test and debug portions of Entrata


Madhurani Chavan Associate Engineer – AR Affordable; implement new features, test and debug portions of Entrata


Madhuri Shinde Associate Engineer – AP; implement new features, test and debug portions of Entrata


Madhuvanti Athawale Development - Assist with development and im

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SAN DIEGO-#650333-v2-PSi Yardi 4A Resp to Yardi Rogs 1 2 3 ... · PSI’s 4A Resp. to Yardi’s Int. No. 1, 2, 3, 6, 11 Case No. 2:13-cv-07764 sd-650333 of any documents (or the subject