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

Filing 1146

MOTION to Shorten Time for Briefing and Hearing On Samsung's Motion to Stay June 26, 2012 Preliminary Injunction Pending Appeal filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Declaration of Victoria F. Maroulis, #2 Exhibit 1, #3 Exhibit 2, #4 Proposed Order Granting Samsung's Motion to Shorten Time)(Maroulis, Victoria) (Filed on 6/27/2012)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]


Kevin P.B. Johnson (Bar No. 177129
[e-mail]
 Victoria F. Maroulis (Bar No. 202603)
[e-mail]
555 Twin Dolphin Drive, 5th Floor

Redwood Shores, California 94065-2139
[phone]
 Telephone:
Facsimile:
[phone]

Michael T. Zeller (Bar No. 196417)
 [e-mail]
865 S. Figueroa St., 10th Floor
 Los Angeles, California 90017
Telephone: [phone]
 Facsimile: [phone]
 Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
 INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK



DECLARATION OF VICTORIA F.
MAROULIS SUPPORT OF SAMSUNG'S
MOTION TO SHORTEN TIME



Plaintiff,
vs.

 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

Defendant.




02198.51855/4833115.1

Case No. 11-cv-01846-LHK
MAROULIS DECLARATION IN SUPPORT OF SAMSUNG'S MOTION TO SHORTEN TIME

1

I, Victoria F. Maroulis, declare as follows:



1.

I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

 counsel for Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
 Telecommunications America, LLC (collectively, “Samsung”). I submit this declaration in
 support of Samsung's Motion to Shorten Time For Briefing and Hearing on its Motion to SDtay
 June 26, 2012 Preliminary Injunction Pending Appeal Or, Alternatively, Pending Decision By
 Federal Circuit On Stay Pending Appeal. I have personal knowledge of the facts set forth in this
 declaration and, if called upon as a witness, I could and would testify to such facts under oath.


2.

On June 27, 2012, I contacted counsel for Apple via email in order to propose a

 shortened briefing schedule whereby Samsung would file a motion to stay the preliminary
 injunction pending appeal on Wednesday, June 27, 2012, Apple would file its opposition brief by
 12:00 p.m. on Friday, June 29, 2012, Samsung would waive its right to file a reply brief, and the
 Court decide Samsung's Motion to Stay with any oral argument that the Court deems appropriate.
 Attached hereto as Exhibit 1 is a true and correct copy of my email to Apple's counsel.


3.

After initially refusing to agree to any shortened briefing schedule, counsel for

 Apple replied that Apple would agree to a shortened briefing schedule, provided that its opposition
 was due no later than Monday, July 2, 2012. Attached hereto as Exhibit 2 is a true and correct
 copy of Apple's response to my email.



I declare under penalty of perjury under the laws of the United States that the foregoing is

th
 true and correct. Executed on the 27 of June, 2012, in Palo Alto, California.





___/s/ Victoria F. Maroulis____
Victoria F. Maroulis





02198.51855/4833115.1

Case No. 11-cv-01846-LHK
-1MAROULIS DECLARATION IN SUPPORT OF SAMSUNG'S MOTION TO SHORTEN TIME