Elan Microelectronics Corporation v. Apple, Inc.

Filing 408

Declaration of Jane H. Bu in Support of 406 Objection filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Related document(s) 406 ) (Bu, Jane) (Filed on 8/22/2011)

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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,

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Plaintiff and Counterdefendant,
v.
APPLE, INC.,
Defendant and Counterplaintiff.
AND RELATED COUNTERCLAIMS

Case No. 09-cv-01531 RS (PSG)
DECLARATION OF JANE H. BU IN
SUPPORT OF ELAN
MICROELECTRONICS
CORPORATION’S OBJECTIONS TO
MAGISTRATE JUDGE GREWAL’S
NONDISPOSITIVE PRETRIAL ORDER
COMPELLING THE PRODUCTION OF
PRIVILEGED DOCUMENTS (DKT 382)
PURSUANT TO FED. R. CIV. P 72(A)
AND 28 U.S.C. § 636(b)(1)(A)

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DECL. OF JANE H. BU ISO ELAN’S OBJECT IONS T O ORDER
DKT 382

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

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I, Jane H. Bu, declare as follows:

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1.

I am an attorney 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.
2.

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Attached as Exhibit A is a true and correct copy of the Declaration of Mr. Wayne

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Chang submitted in support of Elan’s Opposition to Apple’s Motion to Compel, dated June 14,

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2011.

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3.

Attached as Exhibits B through D are true and correct copies of the updated

Privilege Logs Elan served dated July, September and October 2010.
4.

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

counsel regarding Elan’s privilege logs.
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Attached as Exhibit F through H are true and correct copies of the revised Privilege

Logs Elan served on July 1, 2011.

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I swear under penalty of perjury under the laws of the United States that the foregoing is
true and correct. Executed this 22nd day of August, 2011 at Menlo Park, California.

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/s/ Jane H. Bu
Jane H Bu

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LEGAL02/32826373v1

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DECL. OF JANE H. BU ISO ELAN’S OBJECT IONS T O ORDER
DKT 382

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