Elan Microelectronics Corporation v. Apple, Inc.

Filing 155

Declaration of Sonal N. Mehta in Support of 152 Memorandum in Opposition to Elan's Motion to Exclude Documents or, in the Alternative, for Costs filed byApple, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit A-1, Part 1 of 2, # 3 Exhibit A-1, Part 2 of 2, # 4 Exhibit A-2, # 5 Exhibit A-3, # 6 Exhibit B)(Related document(s) 152 ) (Lumish, Douglas) (Filed on 8/3/2010)

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Elan Microelectronics Corporation v. Apple, Inc. Doc. 155 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MATTHEW D. POWERS (Bar No. 104795) matthew.powers@weil.com JARED BOBROW (Bar No. 133712) jared.bobrow@weil.com DOUGLAS E. LUMISH (Bar No. 183863) doug.lumish@weil.com SONAL N. MEHTA (Bar No. 222086) sonal.mehta@weil.com DEREK C. WALTER (Bar. No. 246322) derek.walter@weil.com NATHAN GREENBLATT (Bar No. 262279) nathan.greenblatt@weil.com WEIL, GOTSHAL & MANGES LLP Silicon Valley Office 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: (650) 802-3000 Facsimile: (650) 802-3100 Attorneys for Defendant and Counterclaim Plaintiff Apple Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ELAN MICROELECTRONICS CORPORATION, Plaintiff and Counterclaim Defendant, v. APPLE INC., Defendant and Counterclaim Plaintiff. Case No. C-09-01531 RS (PVT) DECLARATION OF SONAL N. MEHTA IN SUPPORT OF APPLE'S OPPOSITION TO ELAN MICROELECTRONICS CORPORATION'S MOTION TO EXCLUDE DOCUMENTS OR, IN THE ALTERNATIVE, FOR COSTS Hon. Patricia V. Trumbull Date: August 24, 2010 Time: 10:00 a.m. Courtroom 5, 4th Floor DECLARATION OF SONAL N. MEHTA ISO OPP TO MOTION TO EXCLUDE DOCUMENTS Case No. C-09-01531 RS (PVT) Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 this litigation. I, Sonal N. Mehta, declare: I am an attorney with the law firm of Weil, Gotshal & Manges LLP, counsel of record for Defendant and Counter-Claimant Apple Inc. ("Apple") in the above-captioned matter. I submit this declaration based on personal knowledge and following a reasonable investigation. If called upon as a witness, I could competently testify to the truth of each statement herein. 1. To date, Apple has produced over a million pages of documents to Elan in Apple's production and collection of documents has involved searches of numerous employees and servers, as well as extensive searches of archived hard-copy documents. To locate and produce documents relevant to the conception of the `218 patent, Apple's counsel have conducted searches of offsite document archives and interviewed a number of individuals, including the inventors of the `218 patent, Jay Hamlin, Mark Della Bona and Jonathan Dorfman. 2. On February 19, 2010, I met with Jay Hamlin. In that meeting, the topic of relevant documents in Mr. Hamlin's possession, custody or control was raised. 3. On July 2, 2010, Apple produced, subject to its objections, all of the responsive, non-privileged documents located in Mr. Hamlin's personal possession on June 14, 2010. Other documents, unreadable by current computers due to their age and outdated formats, have been sent to a vendor for processing. 4. Attached hereto as Exhibit A is a true and correct copy of Apple's Patent L.R. 3-1 and 3-2 Disclosures, dated October 22, 2009. 5. Attached hereto as Exhibit B is a true and correct copy of Elan's Second Supplemental Response to Apple's First Set of Interrogatories Nos. 1-17, dated June 24, 2010. I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on August 3, 2010, at Redwood Shores, California. /s/ Sonal N. Mehta Sonal N. Mehta DECLARATION OF SONAL N. MEHTA ISO OPP TO MOTION TO EXCLUDE DOCUMENTS 1 Case No. C-09-01531 RS (PVT)

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