Elan Microelectronics Corporation v. Apple, Inc.

Filing 320

Declaration of Jane H. Bu in Support of 319 Opposition/Response to Motion to Compel Elan Witness Depositions in the Northern District of California filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Related document(s) 319 ) (Bu, Jane) (Filed on 7/1/2011)

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1 2 3 4 5 6 7 8 9 10 11 YITAI HU (SBN 248085) yitai.hu@alston.com SEAN P. DEBRUINE (SBN 168071) sean.debruine@alston.com ELIZABETH H. RADER (SBN 184963) elizabeth.rader@alston.com JANE HAN BU (SBN 240081) jane.bu@alston.com JENNIFER LIU (SBN 268990) celine.liu@alston.com PALANI P. RATHINASAMY (SBN 269852) palani.rathinasamy@alston.com ALSTON & BIRD LLP 275 Middlefield Road, Suite 150 Menlo Park, CA 94025-4008 Telephone: 650-838-2000 Facsimile: 650-838-2001 Attorneys for Plaintiff and Counterdefendant ELAN MICROELECTRONICS CORPORATION 12 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 SAN FRANCISCO DIVISION 16 17 ELAN MICROELECTRONICS CORPORATION, 18 19 20 21 22 v. Plaintiff and Counterdefendant, APPLE, INC., Defendant and Counterplaintiff. Case No. 09-cv-01531 RS (PSG) DECLARATION OF JANE H. BU IN SUPPORT OF ELAN MICROELECTRONICS CORPORATION’S OPPOSITION TO APPLE, INC.’S MOTION TO COMPEL ELAN WITNESS DEPOSITIONS IN THE NORTHERN DISTRICT OF CALIFORNIA AND RELATED COUNTERCLAIMS 23 24 25 26 27 28 DECL. OF JANE H. BU ISO ELAN’S OPP’N TO APPLE’S MOTION TO COMPEL Case No. 09-cv-01531 RS (PSG) 1 I, Jane H. Bu, declare as follows: 2 1. I am an attorney with the law firm of Alston & Bird LLP, counsel to Plaintiff Elan 3 Microelectronics Corporation (“Elan”) in this action. I have personal knowledge of the following 4 facts and, if called to testify, I could and would testify competently to the matters stated herein. 5 6 7 8 9 2. On May 23, 2011, Apple issued nine individual deposition notices to Elan’s employees in Taiwan for the NDCA case. 3. On May 27, 2011, Apple issued its first 30(b)(6) Deposition Notice to Elan in the NDCA case. 4. On June 9, 2011, after Elan had a chance to investigate and search for the most 10 suitable 30(b)(6) designees, Elan served its responses and objections to the 30(b)(6) deposition 11 notice to Apple . Attached as Exhibit 1 is a true and correct copy of the June 9, 2011 Responses 12 and Objections to Apple’s 30(b)(6) Deposition Notice. 13 14 15 16 17 5. Attached as Exhibits 2 and 3 are true and correct copies of the First and Second Set of 30(b)(6) Deposition Notices issued by Apple in the parallel ITC Case. 6. Attached as Exhibit 4 is a true and correct copy of Elan’s Fourth Supplemental Response to Apple’s Interrogatories 5, 7, and 11 dated June 23, 2011. 7. Attached as Exhibit 5 is a true and correct copy of Apeldyn Corp. v Au Optronics 18 Corp, Civil Action No. 08-568-SLR, Dtk 380, December 13, 2010 Order Denying Motion to 19 Compel Deposition in U.S. 20 21 I swear under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed this 1st day of July, 2011 at Menlo Park, California. 22 23 /s/ Jane H. Bu Jane H Bu 24 25 LEGAL02/32716033v2 26 27 28 DECL. OF JANE H. BU ISO ELAN’S OPP’N TO APPLE’S MOTION TO COMPEL 1 Case No. 09-cv-01531 RS (PSG)

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