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

Filing 106

Declaration of AUSTIN TARANGO in Support of #104 Administrative Motion to File Under Seal DECLARATION OF EUNHA KIM ISO MOTION FOR DISQUALIFICATION AND ATTACHED EXHIBITS filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Related document(s) #104 ) (Maroulis, Victoria) (Filed on 7/11/2011)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
2 [e-mail]
50 California Street, 22nd Floor
3 San Francisco, California 94111
Telephone: [phone]
4 Facsimile: [phone]
5 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
6 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
th
7 555 Twin Dolphin Drive 5 Floor
Redwood Shores, California 94065
8 Telephone: [phone]
Facsimile: [phone]
9
Edward DeFranco (Cal. Bar No.165596)
10 [e-mail]
51 Madison Avenue, 22nd Floor
11 New York, New York 10010
Telephone: [phone]
12 Facsimile: [phone]
13 Michael T. Zeller (Cal. Bar No. 196417)
[e-mail]
14 865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
15 Telephone: [phone]
Facsimile: [phone]
16
Attorneys for Samsung Electronics America, Inc.
17 and Samsung Telecommunications America LLC
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

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APPLE INC., a California corporation,
Plaintiff,

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DECLARATION OF AUSTIN TARANGO
IN SUPPORT OF SAMSUNG’S
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL

vs.

SAMSUNG ELECTRONICS CO., LTD., a
24 Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New
25 York corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA,
26 LLC, a Delaware limited liability company,
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CASE NO. 11-cv-01846-LHK

Date: August 18, 2011
Time: 1:30 pm
Place: Courtroom 4, 5th Floor
Judge: Hon. Lucy H. Koh

Defendants.

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02198.51855/4244221.1

Case No. 11-cv-01846-LHK
DECLARATION OF AUSTIN TARANGO IN SUPPORT OF SAMSUNG’S
ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

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I, Austin Tarango, declare:

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1.

I am an associate in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

3 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. and Samsung
4 Telecommunications America, LLC. I have personal knowledge of the facts set forth in this
5 declaration and, if called upon as a witness, I could and would testify to such facts under oath.
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2.

On July 11, 2011, I e-mailed counsel for Apple, Inc. (“Apple”) requesting that

7 Apple stipulate to the filing under seal of Eunha Kim’s Declaration in Support of Samsung’s
8 Motion to Disqualify Bridges & Mavrakakis LLP and attached Exhibits 1-3. I requested that
9 counsel for Apple let me know by 7:00 p.m. today whether Apple would so stipulate. I also
10 placed calls to Apple’s counsel at Morrison & Foerster to confirm this stipulation but was unable
11 to reach anyone in their offices.
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3.

Mr. Pieja from Bridges & Mavrakakis was the only attorney representing Apple

13 that responded to my e-mail. Mr. Pieja stated that he would not respond today to my e-mail but
14 said that he expected to provide a response tomorrow.
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I declare under penalty of perjury under the laws of the United States that the foregoing is

16 true and correct. Executed in Redwood Shores, CA on July 11, 2011.
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By /s/ Austin Tarango
Austin Tarango

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02198.51855/4244221.1

Case No. 11-cv-01846-LHK
-1DECLARATION OF AUSTIN TARANGO IN SUPPORT OF SAMSUNG’S
ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL