Apple Computer Inc. v., Inc.

Filing 120

Declaration of Nicholas A. Brown in Support of 119 MOTION to Strike the Declarations of Drs. Hemami and Gersho filed byApple Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Related document(s) 119 ) (Brown, Nicholas) (Filed on 7/3/2007)

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Apple Computer Inc. v., Inc. Doc. 120 Att. 3 Case 3:06-cv-00019-MHP Document 120-4 Filed 07/03/2007 Page 1 of 3 Exhibit C Case 3:06-cv-00019-MHP Document 120-4 Filed 07/03/2007 Page 2 of 3 Ian Crosby <icrosby @ susmangodfrey . c om > 06-16-07 12:54 PM History: To < > cc bcc Subject Re: Burst: Request for Expert Depositions This message has been forwarded. Nick, our position is unchanged. We will oppose. Regards, -Ian B. Crosby SUSMAN GODFREY LLP 1201 Third Avenue Suite 3800 Seattle, Washington 98101 206-516-3861 (tel)/206-516-3883 (fax) This confidential message may be subject to the attorney-client privilege or protected by the attorney work-product doctrine. If you have received this message in error, please delete it and notify me. On 6/15/07 5:26 PM, "" <> wrote: Ian We disagree with your refusal to provide your experts for brief depositions on the subject of their declarations. The Court has set a hearing date that leaves ample time to complete depositions. Accordingly, we will move to strike the declarations of both experts unless you agree to provide the depositions. Sincerely, Nick Brown Case 3:06-cv-00019-MHP Document 120-4 Filed 07/03/2007 Page 3 of 3 "Ian B. Crosby" <> 06-11-07 10:41 AM To <> cc Subject Burst: Request for Expert Depositions Nick, neither of our experts are available for deposition on such short notice , and you will need to move in any event if you would like to take them prior to expert reports as we will oppose presenting either of them more than once in this case . Not trying to be difficult , but we view the timing of your motion and the decision not to submit your own supporting expert declarations as Apple's strategic choices , and don't agree to alter the ordinary sequence of discovery to accommodate . Regards , --Ian Crosby < END > The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by email (, and destroy the original message. Thank you

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