Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1541
OBJECTIONS to Samsung's (1) Objections Regarding Forstall Exhibits, and Amended Exhibit Disclosures for Bresller, Kare, Schiller and Denison, and (2) Responses Regarding Exhibits for Denison Direct Exam and Schiller Cross Exam by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: # 1 Declaration of Ketan V. Patel, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I)(Maroulis, Victoria) (Filed on 8/2/2012)
1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Bar No. 170151)
charlesverhoeven@quinnemanuel.com
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Kevin P.B. Johnson (Bar No. 177129)
kevinjohnson@quinnemanuel.com
Victoria F. Maroulis (Bar No. 202603)
victoriamaroulis@quinnemanuel.com
th
555 Twin Dolphin Drive, 5 Floor
Redwood Shores, California 94065-2139
Telephone: (650) 801-5000
Facsimile: (650) 801-5100
Michael T. Zeller (Bar No. 196417)
michaelzeller@quinnemanuel.com
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
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 KETAN V. PATEL
IN SUPPORT OF SAMSUNG’S (1)
OBJECTIONS REGARDING FORSTALL
EXHIBITS, AND AMENDED EXHIBIT
DISCLOSURES FOR BRESSLER, KARE,
SCHILLER AND DENISON, AND (2)
RESPONSES REGARDING EXHIBITS
FOR DENISON DIRECT EXAM AND
SCHILLER CROSS EXAM
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,
Defendants.
02198.51845/4887926.1
Case No. 11-cv-01846-LHK
DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES
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DECLARATION OF KETAN V. PATEL
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I, KETAN V. PATEL, do hereby declare as follows:
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1.
I am an associate with Quinn Emanuel Urquhart & Sullivan, LLP, counsel for
4 Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung
5 Telecommunications America, LLC (collectively, “Samsung”). I submit this declaration in
6 support of Samsung’s Objections to Apple’s Proposed Examination Exhibits and Materials for
7 Third Day of Trial. I have personal knowledge of the facts set forth in this declaration and, if
8 called as a witness, could and would competently testify to them under oath.
9
2.
Attached as Exhibit A is a true and correct copy of Apple Inc.’s Initial Disclosures
10 Pursuant to Rule 26(A)(1) served on August 26, 2011.
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3.
Attached as Exhibit B is a true and correct copy of Apple Inc.’s First Amended and
12 Supplemental Initial Disclosures Pursuant to Rule 26(A)(1) served on March 4, 2012.
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4.
Attached as Exhibit C is a true and correct copy of Apple’s Revised Deposition
14 Designation List (Exhibit 3 to Joint Pretrial Conference Statement) served on July 23, 2012.
15
5.
Attached as Exhibit D is a true and correct excerpt from the Oct. 27, 2011
16 deposition of Scott Forstall.
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6.
Attached as Exhibit E is a true and correct excerpt from the Feb. 9, 2012
18 Deposition of Scott Forstall.
19
7.
Attached as Exhibit F are true and correct excerpts from Apple Inc.’s Objections
20 and Responses to Samsung Electronics Co. Ltd.’s First Set of Interrogatories to Apple Inc., Apple
21 Inc.’s Second Amended Objections and Response to Samsung’s Interrogatory No. 1 to Apple,
22 Apple Inc.’s Third Amended Objections and Response to Samsung’s Interrogatory No. to Apple,
23 Apple Inc.’s Fourth Amended Objections and Response to Samsung’s Interrogatory No. 1 to
24 Apple, Apple Inc.’s Fifth Amended Objections and Response to Samsung’s Interrogatory No. 1 to
25 Apple and Apple Inc.’s Amended Objections and Response to Samsung’s Interrogatory No. 1 to
26 Apple.
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02198.51845/4887926.1
Case No. 11-cv-01846-LHK
-2DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES
1
8.
Attached as Exhibit G are true and correct copies of pages 20 and 21 from
2 Samsung’s Objections to Apple’s Notice of Rule 30(B)(6) Deposition of Samsung Electronics
3 Co., Ltd Relating to Apple’s Motion for a Preliminary Injunction.
4
9.
Attached as Exhibit H are true and correct copies of pages 6 through 9 of Apple
5 Inc.'s Corrected Amended Objections and Responses to Samsung Electronics Co. Ltd.’s
6 Interrogatory Nos. 4, 6, 7, 16, 17, 18 to Apple, Inc. The relevant passages are at 6:5-10 and 9:117 26.
8
10.
Attached as Exhibit I are true and correct copies of two email exchanges between
9 Victoria Maroulis and Taryn Rawson dated August 1, 2012 in which Samsung requested that
10 Apple identify what the alleged “related theories” were that Samsung failed to disclose, but Apple
11 refused to do so.
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I declare under penalty of perjury that the forgoing is true and correct to the best of my
14 knowledge.
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Executed this 2nd day of August, 2012, in San Jose, CA.
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/s/ Ketan V. Patel
KETAN V. PATEL
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02198.51845/4887926.1
Case No. 11-cv-01846-LHK
-3DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES
1 General Order 45 Attestation
2
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 KETAN V. PATEL
4 has concurred in this filing.
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DATE: August 2, 2012
/s/ Victoria Maroulis
Victoria Maroulis
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02198.51845/4887926.1
Case No. 11-cv-01846-LHK
-4DECLARATION OF KETAN V. PATEL IN SUPPORT OF SAMSUNG’S OBJECTIONS AND RESPONSES
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