Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 102

Declaration of AUSTIN TARANGO in Support of #101 MOTION to Disqualify Counsel BRIDGES & MAVRAKAKIS LLP filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11)(Related document(s) #101 ) (Maroulis, Victoria) (Filed on 7/11/2011)

EXHIBIT 2

!Mtn emanuel trial lawyers 1 silicon valley
555 Twin Dolphin Drive, 5th Floor, Redwood Shores, California 94065-21391 TEL: [phone] FAX: [phone]

WRITER'S DIRECT DIAL No.

[phone]
WRITER'S INTERNET ADDRESS

[e-mail]

Jason R. Bartlett, Esq.
Partner
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105

Apple, Inc. v. Samsung Electronics Co. Ltd., Samsung Electronics America, Inc.,
Samsung Telecommunications America, LLC, Case No. 11-cv-1846-LHK (N.D. Cal.)

• Re:

Dear Jason:
I write to request information regarding Morrison & Foerster's association with its co-counsel,
Bridges & Mavrakakis, in this case. Mr. Bridges entered an appearance on behalf of Apple on
June 16, 2011. It has come to our attention that Mr. Bridges, and other attorneys at Bridges &
Mavrakakis, previously represented Samsung in one or more matters that are substantially
related to the current litigation. Given Mr. Bridges' apparent conflict, Samsung is very
'concerned that you and other attorneys at Morrison & Foerster have received confidential
Samsung information.
In light of these serious issues, we request a meet and confer, no later than June 29th to discuss
the following issues:
•

Any receipt by Morrison & Foerster of confidential Samsung information from
any attorney at Bridges & Mavrakakis.

•

A description of the relationship between Morrison & Foerster and Bridges &
Mavrakakis in the present litigation, including (a) the name of the Morrison &

Quinn emenuel urquhart a sullivan, Hp
LOS ANGELES 1865 South Figueroa Street, 10th Floor, Los Angeles, California 90017-2543 1 TEL [phone] FAX [phone]
NEW YORK 151 Madison Avenue, 22nd Floor, New York, New York 10010-1601 I TEL [phone] FAX [phone]
SAN FRANCISCO 150 California Street, 22nd Floor, San Francisco, California 94111-4788 I TEL [phone] FAX [phone]
CHICAG01500 W. Madison Street, Suite 2450, Chicago, Illinois 60661-2510 I TEL [phone] FAX [phone]
LONDON116 Old Bailey, London EC4M 7EG, United Kingdom I TEL [phone] FAX [phone]
TOKYOINBF Hibiya Bldg., 25F, 1-1-7, Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan I TEL [phone] FAX [phone]
MANNHEIMIErzbergerstral3e 5, 68165 Mannheim, Germany I TEL [phone] FAX [phone]

Foerster attorneys that have had contact with attorneys from Bridges &
Mavrakakis, and (b) the content of these communications.
•

Whether any Morrison & Foerster attorneys conveyed confidential information
received from any attorneys working for Bridges & Mavrakakis to Apple.

We appreciate your prompt cooperation on this matter. While we would prefer to resolve this
matter without the need for judicial intervention, Samsung expressly reserves all of its rights
therein.

Very truly yours,

/Ayr

Victoria F. Maroulis
VFM
cc: Mr. Kenneth Bridges, Bridges & Mavrakakis

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