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

Filing 150

Declaration of Austin Tarango in Support of Reply in Support of #101 MOTION TO DISQUALIFY BRIDGES & MAVRAKAKIS, LLP filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Maroulis, Victoria) (Filed on 8/8/2011) Modified on 8/10/2011 counsel failed to link entry to related document (dhm, COURT STAFF).

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
Michael T. Zeller (Cal. Bar No. 196417)
10 [e-mail]
865 S. Figueroa St., 10th Floor
11 Los Angeles, California 90017
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
14 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC
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16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 APPLE INC., a California corporation,
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20

CASE NO. 11-cv-01846-LHK

Plaintiff,
vs.

21 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
22 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
23 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,
24
Defendants.
25

DECLARATION OF AUSTIN TARANGO
IN SUPPORT OF SAMSUNG’S REPLY IN
SUPPORT OF SAMSUNG'S MOTION TO
DISQUALIFY BRIDGES &
MAVRAKAKIS
Date: August 24, 2011
Time: 2:00 pm
Place: Courtroom 4, 5th Floor
Judge: Hon. Lucy H. Koh

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Case No. 11-cv-01846-LHK
DECLARATION OF AUSTIN TARANGO IN SUPPORT OF SAMSUNG’S REPLY IN SUPPORT OF ITS
MOTION TO DISQUALIFY BRIDGES & MAVRAKAKIS LLP

1

I, Austin Tarango, declare:

2

1.

I am an attorney 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 (collectively “Samsung”).

I have personal knowledge of the

5 facts set forth in this declaration and, if called upon as a witness, I could and would testify to such
6 facts under oath.
7

2.

Attached hereto as Exhibit A is a true and correct copy of the August 4, 2011

8 Northern District of California Order Granting Defendants’ Motion to Disqualify in Oliver v. SD9 3C, LLC et al., Case No. C 11-01260 JSW, Dkt. No. 70, as obtained through the ECF Website of
10 Northern District of California.
11

3.

Attached hereto as Exhibit B is a true and correct copy of the letter sent to Audrey

12 Hollins from the Office of The Chief Trial Counsel Enforcement of the State Bar of California
13 regarding the proposed changes to Professional Rule of Conduct 1.9 dated June 15, 2010, as
14 obtained through/published by State Bar of California on its website at the following address,
15 http://ethics.calbar.ca.gov/Committees/RulesCommission/June25262010MeetingMaterialsPropose
16 d.aspx.
17

4.

Attached hereto as Exhibit C is a true and correct copy of California Proposed

18 Rule of Professional Conduct 1.2, Scope of Representation and Allocation of Authority Between
19 Client and Lawyer, as obtained through/published by State Bar of California on its website at the
20 following address,
21 http://ethics.calbar.ca.gov/Committees/RulesCommission/June25262010MeetingMaterialsPropose
22 d.aspx.
23

5.

Attached hereto as Exhibit D is a true and correct copy of the February 5, 2010

24 draft of California Proposed Rule of Professional Conduct 1.2, including a comparison between
25 the proposed rule and the ABA Model rules, as obtained through/published by State Bar of
26 California on its website at the following address
27 http://ethics.calbar.ca.gov/Committees/RulesCommission/June25262010MeetingMaterialsPropose
28
Case No. 11-cv-01846-LHK
-1DECLARATION OF AUSTIN TARANGO IN SUPPORT OF SAMSUNG’S REPLY IN SUPPORT OF ITS
MOTION TO DISQUALIFY BRIDGES & MAVRAKAKIS LLP

1 d.aspx.

This comparison identifies modifications to the ABA Model Rules made by the Ethics

2 Committee.
3

6.

Attached hereto as Exhibit E is a true and correct copy of certain excerpts of the

4 transcripts of the hearing held on June 17, 2011 in this action.
5

7.

Attached hereto as Exhibit F is a true and correct copy of certain excerpts of the

6 transcript of the deposition of Richard J. Lutton Jr. dated July 26, 2011.
7
8

I declare under penalty of perjury that the foregoing is true and correct. Executed in

9 Redwood Shores, California on August 8, 2011.
10
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12
13

By /s/ Austin Tarango
Austin Tarango

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Case No. 11-cv-01846-LHK
-2DECLARATION OF AUSTIN TARANGO IN SUPPORT OF SAMSUNG’S REPLY IN SUPPORT OF ITS
MOTION TO DISQUALIFY BRIDGES & MAVRAKAKIS LLP