Elan Microelectronics Corporation v. Apple, Inc.

Filing 358

Declaration of Jane H. Bu in Support of 357 MOTION to Compel Discovery on Various Issues filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Related document(s) 357 ) (Bu, Jane) (Filed on 7/26/2011)

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YITAI HU (SBN 248085)
[e-mail]
SEAN P. DEBRUINE (SBN 168071)
[e-mail]
ELIZABETH H. RADER (SBN 184963)
[e-mail]
JANE HAN BU (SBN 240081)
[e-mail]
JENNIFER LIU (SBN 268990)
[e-mail]
PALANI P. RATHINASAMY (SBN 269852)
[e-mail]
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

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ELAN MICROELECTRONICS
CORPORATION,
Plaintiff and Counterdefendant,

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v.
APPLE, INC.,

Case No. 5:09-cv-01531 RS (PSG)
DECLARATION OF JANE H. BU IN
SUPPORT OF ELAN
MICROELECTRONICS
CORPORATION’S MOTION TO
COMPEL DISCOVERY ON VARIOUS
ISSUES

Defendant and Counterplaintiff.
AND RELATED COUNTERCLAIMS

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DECL. OF JANE H. BU ISO ELAN’S MOT. TO COMPEL
DISCOVERY ON VARIOUS ISSUES

Case No. 5:09-cv-01531 RS (PSG)

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I, Jane H. Bu, declare as follows:

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I am an associate with the law firm of Alston & Bird LLP, counsel to Plaintiff Elan

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Microelectronics Corporation (“Elan”) in this action. I have personal knowledge of the following

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facts and, if called to testify, I could and would testify competently to the matters stated herein.

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1.

Attached as Exhibit A is a true and correct copy of relevant excerpts of Apple

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Inc.’s (“Apple’s”) Objections and Responses to Elan Microelectronics Corporation’s Third Set of

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Requests for Production of Documents and Things to Defendant Apple, Inc. [Nos. 73-99], dated

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May 12, 2011.

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2.

Attached as Exhibit B is a true and correct copy of correspondences between

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Apple’s counsel, Mr. Derek Walter and me, between June 17, 2011 and July 25, 2011 concerning

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Apple’s discovery deficiencies.

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3.

Attached as Exhibit C is a true and correct copy of an email from me to Apple’s

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counsel, dated July 12, 2011 requesting Apple to produce all third party subpoenas and

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communications with Elan’s customers.

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4.

Attached as Exhibit D is a true and correct copy of relevant excerpts of Apple

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Inc.’s First Supplemental Responses and Objections to Elan Microelectronics Corporation’s First

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Request for Documents and Things to Apple, Inc., dated January 26, 2010.

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5.

Attached as Exhibit E is a true and correct copy of correspondences between my

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colleague Mr. Sean DeBruine and Apple counsel requesting the production of Apple’s

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communications with Elan customers and potential customers.

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6.

Attached as Exhibit F is a true and correct copy of email correspondences between

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my colleague Mr. Palani Rathinasamy and Apple’s counsel Mr. Walter regarding Apple’s

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objections to Elan RFPs 101-104 (filed partially under seal).

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7.

Attached as Exhibit G is a true and correct copy of Apple’s Objections and

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Responses to Elan’s Fourth Set of Request for Documents dated July 14, 2011 (filed partially

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under seal).

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I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.
DECL. OF JANE H. BU ISO ELAN’S MOT. TO COMPEL
DISCOVERY ON VARIOUS ISSUES

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Case No. 5:09-cv-01531 RS (PSG)

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Executed this 26th day of July, 2011 at Menlo Park, California.

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By:

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/s/ Jane H. Bu
Jane H Bu

LEGAL02/32761613v1

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DECL. OF JANE H. BU ISO ELAN’S MOT. TO COMPEL
DISCOVERY ON VARIOUS ISSUES

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Case No. 5:09-cv-01531 RS (PSG)