McKellar

I. BACKGROUND

23 Mithril Capital is a venture capital firm that manages two venture capital funds. FAC 24 (dkt. 40) ¶ 20.1 Royan is Mithril Capital’s owner and Managing General Partner. Id. ¶¶ 16, 20. 25 26 1 Mithril objects to McKellar’s reliance on her First Amended Complaint as evidence for her 27 motion for a preliminary injunction. See Objection to Reply Evidence (dkt. 53). Because the 1 Mithril Feeder exists to distribute to certain employees of Mithril Capital carried interest generated 2 by Mithril’s venture capital funds. Id. ¶ 31. Mithril Feeder is a Delaware limited liability 3 company. Id. ¶ 16. 4 In happier times, McKellar was General Counsel and a Managing Director of Mithril 5 Capital, a member of Mithril Feeder entitled to awards of carried interest, and long-time friend of 6 Royan’s. Id. ¶¶ 21, 23, 31. She was well-qualified for these roles. McKellar is a Harvard Law 7 School graduate, member of the California Bar, and has worked for Judge Marilyn L. Huff, Davis 8 Polk & Wardwell LLP, and Morrison & Foerster LLP. Shipley Decl. Ex. A (dkt. 23-2) & Ex. B 9 (dkt. 23-3). 10 As a member of Mithril Feeder, McKellar agreed to…