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

Filing 1221

STIPULATION WITH PROPOSED ORDER re Stipulated and Disputed Jury Instructions Filing Deadline 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 Jon Steiger in Support of Joint Stipulation)(Maroulis, Victoria) (Filed on 7/12/2012)

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]
th
 555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
 Telephone: [phone]
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 (PSG)



DECLARATION OF JON STEIGER IN
SUPPORT OF JOINT STIPULATION
REGARDING STIPULATED AND
DISPUTED JURY INSTRUCTION
FILING DEADLINE



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.


02198.51855/4854541.1

Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF JON STEIGER

1

I, Jon Steiger, declare as follows:

2

1.

I am a member of the State Bar of California and a partner with Quinn

3 Emanuel Urquhart & Sullivan LLP, attorneys for Samsung Electronics Co., Ltd., Samsung
4 Electronics America, Inc. and Samsung Telecommunications America, LLC (collectively,
5 “Samsung”). I make this declaration of personal, firsthand knowledge, and if called and sworn as
6 a witness, I could and would testify competently thereto.
7

2.

On May 3, 2012, the Court held a case management conference with

8 counsel for Samsung and Apple Inc. (“Apple”).
9

3.

The Court issued an Order, dated May 2, adopting the parties’ pretrial

10 deadlines for various filings, including the parties’ stipulated and disputed proposed jury
11 instructions. (Dkt. No. 901.) The Court ordered that the parties file proposed jury instructions by
12 July 11, 2012. (Id.)
13

4.

On June 29, 2012, the Court held an additional case management

14 conference with counsel for the parties.
15

5.

The Court issued an Order, dated July 9, 2012, confirming the deadline for

16 filing proposed jury instructions and ordering the parties to provide the Court with four binders
17 containing the parties’ stipulated and disputed proposed jury instructions. (Dkt. No. 1197.)
18

6.

The parties first exchanged proposed jury instructions on July 6, 2012 and

19 have worked diligently since then to try and resolved disputes regarding the proposed jury
20 instructions.
21

7.

Given the numerous other pre-trial deadlines and the complexities of the

22 parties’ claims and defenses, despite their best efforts, the parties were not able to file the joint
23 proposed jury instructions by July 11, 2012.
24

8.

After meeting and conferring, the parties agree that a short, 36-hour

25 extension is required to file the joint proposed jury instructions.
26

9.

The parties propose that the joint proposed jury instructions be filed by

27 12:00 p.m. on July 13, 2012, and that the binders with the stipulated and disputed proposed jury
28 instructions be lodged with the Court by 3:00 p.m. on July 13, 2012.
02198.51855/4854541.1

-2-

Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF JON STEIGER

1

10.

The Court has granted several motions filed by both parties to shorten time

2 on discovery motions. For example, Apple filed a motion to compel on December 8, 2011 and
3 Samsung filed a motion to compel on December 12, 2011. In both cases, the moving party sought
4 and was granted the requested Order shortening time.
5

11.

The requested time modification will not affect the overall schedule for the

6 case.
7

I declare under penalty of perjury under the laws of the United States of America

8 that the foregoing is true and correct.
9

Executed July 12, 2012, at Los Angeles, California.

10
11

/s/ Jon Steiger
Jon Steiger

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
02198.51855/4854541.1

-3-

Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF JON STEIGER

1

GENERAL ORDER ATTESTATION

2
I, Victoria Maroulis, am the ECF user whose ID and password are being used to file the
3
foregoing document. I hereby attest pursuant to General Order 45.X.B. that concurrence in the
4
electronic filing of this document has been obtained from Jon Steiger.
5
6
/s/ Victoria Maroulis
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
02198.51855/4854541.1

-4-

Case No. 11-cv-01846-LHK (PSG)
DECLARATION OF JON STEIGER