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

Filing 1259

MOTION to Shorten Time re Motion to Clarify Portions of the Court's June 30, 2012 Order Denying Samsung's Motion for Summary Judgment filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Cashman Declaration, #2 Ex. 1, #3 Proposed Order)(Maroulis, Victoria) (Filed on 7/17/2012)

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 (PSG)



DECLARATION OF ADAM CASHMAN
IN 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.




02198.51855/4860101.1

Case No. 11-cv-01846-LHK (PSG)
CASHMAN DECLARATION IN SUPPORT OF SAMSUNG'S MOTION TO SHORTEN TIME

1

I, Adam Cashman, declare as follows:



1.

I am an associate 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 Clarify
 Portions of the Court’s June 30, 2012 Order Denying Samsung’s Motion for Summary Judgment
 (“Motion for Clarification”). 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 July 17, 2012, I contacted counsel for Apple via email in order to propose a

 shortened briefing schedule whereby Samsung would file its Motion for Clarification on July 17,
 Apple would file its opposition brief by July 20, Samsung would waive its right to file a reply
 brief, and hearing on the Motion for Clarification would be held on July 24.


3.

Apple responded to my message indicating that it would oppose a shortened

 briefing schedule. Attached hereto as Exhibit 1 is a true and correct copy of my email exchange
 with counsel for Apple.


4.

The relief requested in Samsung’s Motion to Shorten Time is necessary in order to

 allow the Court to decide Samsung’s Motion for Clarification prior to the commencement of trial.
 If the Court does not grant briefing and hearing on shortened time, the Motion for Clarification
 would not be briefed until August 6, and would not be heard until August 23. By that time, trial in
 this case will be concluding.


5.

The present request to shorten the briefing and hearing schedule on Samsung’s

 Motion for Clarification will not affect the schedule of the case.


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

th
 true and correct. Executed on the 17 of July, 2012, in San Francisco, California.





02198.51855/4860101.1

Adam S. Cashman
Case No. 11-cv-01846-LHK (PSG)
-1CASHMAN DECLARATION IN SUPPORT OF SAMSUNG'S MOTION TO SHORTEN TIME

1
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GENERAL ORDER ATTESTATION
I, Victoria F. Maroulis, am the ECF user whose ID and password are being used to file this

3 Declaration. In compliance with General Order 45(X)(B), I hereby attest that Adam Cashman has
4 concurred in this filing.
5

/s/ Victoria Maroulis

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02198.51855/4860101.1

Case No. 11-cv-01846-LHK (PSG)
-2CASHMAN DECLARATION IN SUPPORT OF SAMSUNG'S MOTION TO SHORTEN TIME