Elan Microelectronics Corporation v. Apple, Inc.

Filing 52

Declaration of Sonal N. Mehta in Support of Opposition to Motion to Shorten Time for Hearing on Elan's Motion to Compel Production of Source Code Pursuant to Patent L.R. 3-4(A re 51 filed by Apple, Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E) (Mehta, Sonal) (Filed on 1/19/2010) Modified on 1/20/2010 (bw, COURT STAFF).

Elan Microelectronics Corporation v. Apple, Inc.

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MATTHEW D. POWERS (Bar No. 104795) [e-mail] EDWARD R. REINES (Bar No. 135960) [e-mail] SONAL N. MEHTA (Bar No. 222086) [e-mail] WEIL, GOTSHAL & MANGES LLP Silicon Valley Office 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff and Counterclaim Defendant, 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 DECLARATION OF SONAL N. MEHTA IN SUPPORT OF APPLE INC.'S OPPOSITION TO ELAN MICROELECTRONICS CORPORATION'S MOTION TO SHORTEN TIME FOR HEARING ON ELAN'S MOTION TO COMPEL PRODUCTION OF SOURCE CODE PURSUANT TO PATENT L.R. 3-4(A) Hon. Richard Seeborg Demand for Jury Trial

MEHTA DEC. ISO APPLE'S OPPOSITION TO ELAN'S MOTION TO SHORTEN TIME

Case No. C-09-01531 RS

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I, Sonal N. Mehta, declare: 1. 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. 2. Attached as Exhibit A is a true and correct copy of an email I sent to Sean

DeBruine, counsel for Elan, on December 16, 2009, at 12:13 a.m. 3. Attached as Exhibit B is a true and correct copy of an email I sent to Augie

Rakow and Sean Debruine, both counsel for Elan, on January 8, 2010, at 12:55 p.m. 4. Attached as Exhibit C is a true and correct copy of an email I sent to

Augie Rakow on January 14, 2010, at 2:34 p.m. 5. Attached as Exhibit D is a true and correct copy of an email I sent to

Augie Rakow and Sean Debruine on January 19, 2010, at 4:29 p.m. 6. Attached as Exhibit E is a true and correct copy of an email sent to me by

Sean DeBruine on January 19, 2010, at 5:06 p.m.

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 January 19, 2010 at Redwood Shores, California. /s/ Sonal N. Mehta Sonal N. Mehta

MEHTA DEC. ISO APPLE'S OPPOSITION TO ELAN'S MOTION TO SHORTEN TIME

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Case No. C-09-01531 RS