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

Filing 1540

OBJECTIONS to Apples Responses To Samsungs Objections To Forstall, Bressler, Kare, Denison And Schiller Direct Examination Materials Apples Objections To Samsungs Proposed Direct Examination Materials For Jdenison And Supplemental Objections To Samsungs Proposed Cross Examination Materials For Schiller by Apple Inc.. (Attachments: # 1 Declaration Of Richard Hung In Support Of Apples Objections And Responses Re Samsungs Responses, # 2 Exhibit A, # 3 Exhibit B)(Jacobs, Michael) (Filed on 8/2/2012)

1
2
3
4
5
6
7
8
9
10
11

HAROLD J. MCELHINNY (CA SBN 66781)
[e-mail]
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
RACHEL KREVANS (CA SBN 116421)
[e-mail]
JENNIFER LEE TAYLOR (CA SBN 161368)
[e-mail]
ALISON M. TUCHER (CA SBN 171363)
[e-mail]
RICHARD S.J. HUNG (CA SBN 197425)
[e-mail]
JASON R. BARTLETT (CA SBN 214530)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

WILLIAM F. LEE
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
60 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile: [phone]
MARK D. SELWYN (SBN 244180)
[e-mail]
WILMER CUTLER PICKERING
HALE AND DORR LLP
950 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff and
Counterclaim-Defendant APPLE INC

12
13

UNITED STATES DISTRICT COURT

14

NORTHERN DISTRICT OF CALIFORNIA

15

SAN JOSE DIVISION

16
17

APPLE INC., a California corporation,
Plaintiff,

18
19
20
21
22

v.

Case No.

11-cv-01846-LHK

DECLARATION OF RICHARD
HUNG IN SUPPORT OF APPLE’S
OBJECTIONS AND RESPONSES
RE SAMSUNG’S RESPONSES

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,

23

Defendants.

24
25
26
27
28
HUNG DECL ISO OF APPLE’S OBJS AND RESPONSES RE SAMSUNG’S RESPONSES
CASE NO. 11-CV-01846-LHK

sf-3178058

1

I, RICHARD HUNG, declare as follows:

2

1.

I am a partner in the law firm of Morrison & Foerster LLP, counsel for Apple Inc.

3

(“Apple”). I am licensed to practice law in the State of California and admitted to practice

4

before this Court. I have personal knowledge of the matters stated herein or understand them to

5

be true from members of my litigation team. I make this declaration in support of Apple’s

6

Objections and Responses to Samsung’s Responses and Objections to the Day 3 Disclosures.

7

2.

Apple served its amended disclosures for Peter Bressler, Susan Kare, Phil Schiller,

8

and Justin Denison and its disclosure for Scott Forstall for Day 3 of trial at 7:15 p.m. on August

9

1, 2012. A true and correct copy of this disclosure is attached as Exhibit A.

10
11
12

3.

Samsung did not provide its list of objections to the materials Apple disclosed at

7:15 p.m. until 12:26 a.m. on August 2.
4.

Samsung’s list of objections alone consisted of six pages of objections, which

13

exceeds the Court’s five-page limit. Apple promptly inquired as to whether Samsung genuinely

14

intended to fully brief its six pages of objections, but received no response.

15
16
17
18
19
20

5.

Samsung’s list of objections included no fewer than 18 exhibits and

demonstratives that the Court already ruled on, with new objections to those exhibits.
6.

Attached as Exhibit B is a true and correct copy of this email correspondence

between Apple and Samsung.
I declare under penalty of perjury that the foregoing is true and correct. Executed this
2nd day of August, 2012 at San Jose, California.

21
/s/ Richard Hung
Richard Hung

22
23
24
25
26
27
28

HUNG DECL ISO OF APPLE’S OBJS AND RESPONSES RE SAMSUNG’S RESPONSES
CASE NO. 11-CV-01846-LHK

sf-3178058

1

1
2

ATTESTATION
I, Michael A. Jacobs, 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 Richard Hung has

4

concurred in this filing.

5

Dated: August 2, 2012

/s/ Michael A. Jacobs
Michael A. Jacobs

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
HUNG DECL ISO OF APPLE’S OBJS AND RESPONSES RE SAMSUNG’S RESPONSES
CASE NO. 11-CV-01846-LHK

sf-3178058

2